Section 271(1)(c) penalty not leviable if Specific Charge not mentioned in Notice

Shri Atul Kumar Bansal Vs DCIT (ITAT Delhi) Hon’ble Bombay High Court (Full Bench at Goa) in the case of Mr. Mohd. Farhan A. Shaikh ACIT [(2021) 434 ITR 1 (Bom)] while dealing with the issue of non-strike off of the irrelevant part in the notice issued u/s.271(l)(c) of the Act, held that assessee must be informed of the grounds of the penalty proceedings only through statutory notice and an omnibus notice suffers from the vice of vagueness. ITAT held that as in this case notice u/s. 274 r.w.s. 271(1)(c) of the Act was issued without striking off the irrelevant portion of the limb and fai...