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2021 (3) TMI 1065 - AT - Income TaxPenalty u/s 271(1)(c) - Defective notice - HELD THAT:- As relying on M/S. SAHARA INDIA LIFE INSURANCE COMPANY, LTD. [2019 (8) TMI 409 - DELHI HIGH COURT] and M/S. BHARAT IMMUNOLOGICAL AND BIOLOGICAL CORPORATION LTD. [2019 (5) TMI 28 - ITAT DELHI] A.O. has not pointed-out as to for which limb of Section 271(1)(c) of the I.T. Act, 1961, penalty proceedings are initiated i.e., whether for concealment of particulars of income or for furnishing inaccurate particulars of income. Therefore, the penalty notice is invalid and bad in Law and as such the entire proceedings are vitiated and no penalty is leviable against the assessee - Decided in favour of assessee.
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