Not striking off irrelevant matter vitiate penalty proceedings

Sh. Prem Pal Gandhi Vs ACIT (ITAT Amritsar) The appellant objected to the levy of penalty as bad in law. He challenged that the AO has not mentioned under which limbs of section 27 1(1)(c) of the Act, whether for concealment of income or furnishing of inaccurate particulars, the penalty was initiated. Thus, He has not recorded required satisfaction as per law. Similarly, he further challenged that notice issued under section 274 read with section 271 of the Act, dated 17/08/2012 (page 7 of paper book) does not mention about the limb for which it is initiated. A.O. forms opinion that it is fit ...