Penalty u/s. 271(1)(c) not sustained as notice failed to specify particular limb: ITAT Mumbai

Priority Jewels Private Limited Vs CIT Appeals (ITAT Mumbai) ITAT Mumbai held that notice issued u/s. 274 r.w.s. 271(1)(c) of the Income Tax Act without specifying the particular limb is unsustainable in law. Accordingly, the penalty imposed u/s. 271(1)(c) is not sustainable. Facts- The assessment was completed u/s. 143(3) of the Act and the total income sought to be evadedamount to Rs 33,10,243/- related to the disputed purchases. The penalty proceedings was initiated u/s. 271(1)(c) of the Act and the notice u/s. 274 r.w.s. 271(1)(c) was duly issued and served. After hearing the same, the pen...