Vague Penalty Notice Invalidates Proceedings under section 271(1)(c)

Thakur Dass (since deceased) Through legal heir Karan Harjani Vs ITO (ITAT Delhi) It can be observed from penalty notice that the AO had failed to distinguish and inform the Assessee as to if the notice was issued for concealment of income or for furnishing inaccurate particulars and a proforma in a mechanical manner the notice was issued. The judgment relied by the ld counsel for the Assessee in the case of Ganga Iron & Steel Trading Co. Vs. CIT (supra) reiterates the settled provision of law that if notice is vague then the penalty proceedings initiated on that basis were vitiate and for...