Non-specification of limb of notice render section 271(1)(c) penalty proceedings invalid

Pioneer Town Planners Pvt. Ltd Vs ACIT (ITAT Delhi) It has been clearly stated that notice issued u/s 271(1)(c) is omnibus notice without specifying the specific charge upon the assessee as to whether it is for concealment of income or furnishing of inaccurate particulars of income. In this regard, we may gainfully refer to the order of the jurisdictional High Court in the case of Pr. CIT vs Sahara India Life Insurance Company Ltd. in CM Appeal No.19863/2019 vide order darted 02.08.2019 and others, the Hon’ble High Court has laid down the following exposition:- “21. The Respondent had chal...