Penalty proceedings without specification of reason is bad in law

Aimil Pharmaceuticals (I) Ltd. Vs ITO (ITAT Delhi) Held that notice issued u/s. 274 r.w.s. 271(1)(c) needs to specify the limb under which penalty proceedings are initiated. Penalty not leviable, in absence of the specification of the limb. Facts- The assessee filed its return of income declaring income at Nil. AO completed the scrutiny assessment u/s. 143(3) at the net book profit of Rs.2,16,10,800/- after allowing set off of brought forward book loss of Rs. 89,26,065/- u/s. 115JB of the Act. AO imposed the penalty of Rs.36,72,755/- against the assessee u/s. 271(1)(c) of the Act for furnishin...