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

Advertisement 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 expression i.e. penalty is imposed by reason of concealment of income or furnishing inaccurate particulars of such ...