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 obviously an internal inconsistency in the penalty order. AO opined that assessee had furnished inaccurate particulars of his income in ...