Section 271(1)(c) penalty order not sustainable if AO not mentioned specific charge

Pradeep Sugamchand Kawadiya Vs ITO (ITAT Ahmedabad)

The short point involved in this case as to whether the penalty is sustainable when the same has been initiated and levied without specifying the alleged guilt committed by the assessee either for concealment of income or furnishing of inaccurate particulars of income.

Brief facts leading to this case is this that the Assessment Order was finalized u/s.143(3) r.w.s 147 of the Act on 31.12.2015 by the Ld.A

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