Section 271(1)(c) Penalty not sustainable if specific charge not specified

Deepak Kumar Patel Vs ITO (ITAT Raipur)

Facts- The assessee has e-filed the ROI on 31-08-2010 declaring total income of Rs. 12,85,579/-. The assessee is doing business of MFG of HDP Pipes & Assembly of Sprinkler System. The scrutiny assessment completed u/s. 143(3) on 01-03-2013 determining total income of Rs. 67,14,940/-.

During the course of assessment proceedings it was noticed that the assessee has made payment of commission of Rs. 11,92,062/- on sales to 6 persons

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