Sec. 271(1)(c)-Penalty without specific charges is not maintainable

Brief of the Case ITAT Mumbai held In the case of Mangalam Drugs & Organics Ltd. vs. DCIT that it is clear that the penalty has been levied, on all the additions/disallowances, in a ‘whole sole’ manner. The AO has not given his findings, for levying the penalty, for each issue separately, with respect to the satisfaction of the AO for each of the issue respectively, nor has he given a finding for each issue separately as to whether there was a concealment of income or furnishing of inaccurate particulars of income. Further, the penalty is not automatic and also the Assessee cannot be f...