Section 271(1)(c) Penalty proceedings not sustainable if not specifies Limb

Balaji Telefilms Limited Vs. DCIT (ITAT Mumbai) The issue under consideration is whether the penalty proceedings u/s 271(1)(c) without specifying the limb will be sustain under law? ITAT states that, it has been held by Hon’ble Court that the notice would have to specifically state the ground mentioned in Section 271(1)(c) of the Act namely as to whether the penalty was for concealment of income or furnishing of incorrect particulars of the income. Further, issuing printed form would not satisfy the requirement of law since the assessee should know the ground which he has to meet specificall...