S. 271(1)(c) Penalty cannot be invoked without Specifying Exact Charge

Jumbo Electronics Corp. Pvt. Ltd. Vs. DCIT (ITAT Mumbai) The impugned penalty order certainly gives an impression that the Assessing Officer himself was not sure which limb of section 271(1)(c) is applicable to the assessee. In any case of the matter, non mentioning of particular limb for which the Assessing Officer has imposed penalty under section 271(1)(c) in the impugned penalty order coupled with the fact that in the show cause notice issued under section 274 in the standard printed form the Assessing Officer has not struck off the irrelevant clauses, thereby, not specifying exact charge ...