Penalty U/s. 271(1)(c) cannot be imposed unless same been particularized

CIT Vs M/s. L & T Finance Ltd (Bombay High Court)

In none of these orders there is any whisper of the alleged particulars of income which has been concealed or what particulars of  income which have been filed is inaccurate. Mere using the words that there has concealment of income and / or furnishing inaccurate particulars of income would not in the absence of same being particularized, lead to imposition of penalty. It is only when the specified officer of the Revenue is satisfied that there has been concealment of particulars of income or furni

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