Penalty U/s. 271(1)(c) cannot be levied if AO did not specify grounds on which penalty was imposed

Associated Trading Vs. ITO ( ITAT Kolkata)

show cause notices issued under section 274 of the Act read with section 271 of the Act dated 30-10-2012 before imposing penalty does not contain the specific charge against the assessee namely as to whether the assessee was guilty of having concealed particulars of income or having furnished inaccurate particulars of income. A copy of the show cause notice under section 274 of the Act was filed before us and perusal of the same reveals that assessing officer has not struck out the irrelevant portion in the sho

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