Section 271(1)(c) Penalty deleted due to AO’s Failure to Specify Applicable limb

PCIT Vs Modi Rubber Ltd (Delhi High Court)

Conclusion: Penalty under section 271(1)(c) was not leviable as there was failure on the part of AO as to which limb of Section 271(1)(c) got attracted for imposition of penalty.

Held: The question which arose for consideration was whether failure on the part of AO to put to assessee a specific charge was fatal to the penalty proceedings, having regard to the provision of Section 271(1)(c). It was held that there was obviou

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