Section 271(1)(c) Penalty not sustainable if notice is vague & ambiguous 

Jyoti Samer Garg & Co. Vs ITO (ITAT Delhi)

ITAT held that when the notices issued by the AO are bad in law being vague and ambiguous having not specified under which limb of section 271(1)(c) of the Act, the penalty proceedings initiated u/s 271(1)(c) are not sustainable.

When the very initiation of the penalty by way of issuance of vague and ambiguous notices u/s 271(1)(c) read with section 274 of the Act without specifically charging the assessee if he has concealed the particulars o

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