Section 271(1)(c) Penalty imposed without specifying the limb is invalid

Glory Lifesciences Pvt. Ltd. Vs ACIT (ITAT Delhi)

It is an admitted fact that before levy of the penalty A.O. has issued show cause notice Dated 20.06.2014 in all the years in which A.O. has mentioned both the limbs of Section 271(1)(c) of the I.T. Act that assessee have concealed the particulars of your income or furnished inaccurate particulars of such income. Thus the A.O. has not mentioned as to for which limb of Section 271(1)(c) of the I.T. Act penalty shall have to be levied against the assessee. According to Section 274 of the I.T. Act, 1961 no

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