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2021 (1) TMI 834 - AT - Income TaxPenalty u/s 271(1)(c) - Assessee failed to substantiate the details of all the assets held by him with the explainable sources and adopted "Net Wealth Accretion Method" to arrive at his undisclosed income - whether the charge against the assessee is concealing of particulars of income or furnishing of inaccurate particulars of income? - defective notice u/s 274 - income so declared by the assessee was accepted by the AO and assessment was completed for the aforesaid Assessment Year under section 153A - HELD THAT:- 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. The plea of the ld. Counsel for the assessee, which is based on the decisions referred to in the earlier part of this order, has to be accepted. We therefore hold that imposition of penalty in the present cases cannot be sustained - Decided in favour of assessee.
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