No section 271(1)(c) penalty if notice was vague & ambiguous

Addl. CIT Vs Airports Authority of India (ITAT Delhi) Perusal of the order passed by the ld. CIT (A) shows that the ld. CIT(A) deleted the penalty on two grounds : (i) that no valid notice u/s 274 of the Act has been issued to the assessee so as to inform the assessee as to under which limb of section 271(1)(c) penalty proceedings have been initiated; and (ii) that disallowances of claim made by the assessee for incurring expenditure on account of R&D does not come under the purview of section 271(1)(c) of the Act and relied upon the decisions rendered by Hon’ble Supreme Court in the cas...