2019 (5) TMI 296

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..... 6 before levy of the penalty against the assessee which is bad in law as it did not specify in which limb of Section 271(1)(c) of the Act, the penalty proceedings had been initiated i.e., whether for concealment of particulars of income or furnishing inaccurate particulars of income. The entire penalty proceedings are, therefore, vitiated and no penalty is leviable. As relying on SSA S EMERALD MEA .....

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..... r furnished inaccurate particulars of such income in terms of explanation 1, 2, 3, 4 and 5." 2.1. The Learned Counsel for the Assessee further submitted that in the show cause notice the A.O. failed to specify in which limb of Section 271(1)(c) of the Act, the penalty proceedings had been initiated. He contended that similar issue has been decided by the Hon'ble Supreme Court in the case of CIT & .....

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