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2022 (5) TMI 1571 - ITAT RAIPURPenalty u/s 271(1)(c) - non specification of clear charge - HELD THAT:- AO is under obligation to specify the appropriate limb of clause c of section 271(1)(c) of the Act at the time of initiation as well as at the time of levy of penalty notice. In this case it has been drawn our attention that while recording the satisfaction in the assessment order as well as while issuing the notice at two occasion failed to specify the charge under which the assessee is liable for penalty and therefore we set aside the order of CIT(A) and direct the Assessing Officer to delete the levy of penalty imposed upon the assessee, relying on the various decision cited by the co-ordinate bench while rendering the decision in the case of Shri Swapnil Kumar Jain [2022 (4) TMI 178 - ITAT RAIPUR] - In the result the appeal of the assessee is allowed on legal issue.
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