Ambiguity in Notice u/s 274 Voids Penalty for Concealed Income u/s 271(1)(c) of Income Tax Act.

Penalty u/s 271(1)(c) - As a matter of fact the notice issued u/s 274 read with section 271 of the Act itself was ambiguous as it did not make it clear as to under which limb section of 271(1)(c) of the Act the notice was issued. On the other hand in the penalty order the ld AO has coined her own term “concealed income by furnishing inaccurate particulars.” - Thus ambiguity in issue of notice and findings make the impugned order of levying penalty void ab initio - AT .....

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