2021 (10) TMI 358 - Income Tax

Levy of penalty u/s 271(1)(c) r/w Explanation 1(A) - Defective notice u/s 274 - non specification of one charge - addition of notional interest income accruing on alleged deposit with LGT Bank Liechtenstein in the name of Ambrunova Trust - HELD THAT:- We find that the Assessing Officer did not strike off either of the two limbs namely whether the assessee concealed the particulars of income or furnished inaccurate particulars of such income, although, even if it was to be levied, it was a case of furnishing of inaccurate particulars of income.

Also in the case of M/s.Bhavya Shashank Shanbhag v. Dy. Commissioner of Income Tax [2021 (7) TMI 381 - ITAT MUMBAI] the Co-ordinate Bench has deleted the similar issue of penalty based on defective notices issued by the AO. - Decided in favour of assessee.