Notice u/s 274 without specifying limb under which penalty proceeding is initiated u/s 271(1)(c) is unsustainable

Virtual Software & Training Vs ITO (Delhi High Court)

Delhi High Court has held that issuance of notice under section 274 r.w.s. 271(1)(c) of the Act without specifying the limb under which the penalty proceeding has been initiated is bad in law.

Facts-

In the instant case the Assessee by filing its return of income on 31.10.2001 declared an income of Rs. 13,32,019/- which was selected for scrutiny and during the assessment proceedin

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