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2020 (11) TMI 134 - AT - Income TaxPenalty u/s. 271(1)(c) - Validity of notice - TP adjustment - Non specification of charge - As contended that the addition was made on account of MAP resolution and that there was no wilful concealment - whether the charge against the Assessee is “concealing particulars of income or furnishing of inaccurate particulars of income”? - HELD THAT:- As the show cause notice issued in the present case u/s 274 of the Act does not specify the charge against the assessee as to whether it is for concealing particulars of income or furnishing inaccurate particulars of income. The show cause notice u/s 274 of the Act does not strike out the inappropriate words. In these circumstances, we are of the view that imposition of penalty cannot be sustained. See MANJUNATHA COTTON AND GINNING FACTORY & OTHS., M/S. V.S. LAD & SONS, [2013 (7) TMI 620 - KARNATAKA HIGH COURT] - Decided in favour of assessee.
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