Section 271(1)(c) Penalty Invalid as Notice Lacked Specific Charge: ITAT Mumbai

Moraj Group Hospitalities INC Vs Central Circle 5(2) (ITAT Mumbai) This appeal concerns the assessee’s challenge to a penalty of ₹24,72,000 levied under section 271(1)(c) of the Income-tax Act for Assessment Year 2015-16. The CIT(A) upheld the penalty, following which the assessee appealed to the ITAT Mumbai. The assessee raised multiple grounds, primarily asserting that the penalty was unlawful because the Assessing Officer (AO) failed to clearly specify whether the penalty was imposed for concealment of income or furnishing inaccurate particulars of income. According to the assessee, the...