Section 271(1)(c) Penalty notice without any Specific allegation is unjustified

Dr. Subash Chandra Jena Vs ACIT (ITAT Cuttack)

The issue under consideration is whether the penalty notice u/s 271(1)(c) without any specific allegation is justified in law?

ITAT stated that the AO has simply initiated penalty proceedings stating therein that penalty proceedings u/s.271(1)(c) of the Act has been initiated on the differential amount disclosed in the return of income filed u/s.153A of the Act, however, in the penalty order, the AO has used both the expressio

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