Section 271(1)(c) Penalty not imposable if notice not Specify the Limb

Manjriben Pravinchandra Raninga Vs ITO (ITAT Ahmedabad)

It is pertinent to note that the entire basis of imposing penalty was concealment of income on the part of the assessee as to non-filing of return of income by the assessee. But from the perusal of the records we can see that the assessee has filed return of income which was very much submitted before the Assessing Officer as well as before the CIT(A) and quoted in the written submissions in both the orders. The Assessing Officer as well as the CIT(A) has not at all ver

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