Section 271(1)(c) Penalty cannot be levied without issuing proper SCN

Zile Singh Kashyap Vs ITO (ITAT Delhi)

The perusal of the assessment order dated 28.11.2018 reveals that in the assessment order addition has been made of Rs.15,00,000/- but no satisfaction has been recorded by AO as to whether it is the case of the concealment of income or the case of furnishing of inaccurate particulars of income. AO has only stated in the assessment order that initiate penalty proceedings u/s 271(1)(b) and 271(1)(c) of the Act. In the penalty order passed on 28.05.2019 AO has levied the penalty for concealment of income. It is a sett

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