No Section 271(1)(c) Notice without mentioning particular limb

Mohd. Farhan A. Shaikh Vs DCIT (Bombay High Court) Conclusion: In present facts of the case, the Larger Bench of the Hon’ble High Court was referred an issue ‘mere failure to tick mark the applicable grounds’ in the notice issued under Section 271 of the Income Tax Act, 1961 (IT Act) vitiate the entire penalty proceedings. To this, it was held that a penal provision even with civil consequences, must be construed strictly. And ambiguity, if any, must be resolved in the affected assessee’s favour. Held: In present facts of the case, there was direct conflict between The Princip...