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2020 (7) TMI 127 - AT - Income TaxPenalty u/s 271(1)(c) - non specification of charge - defective notice - Disallowance on account of interest - AO has to prove that there was concealment of particulars of income or that the assessee has furnished inaccurate particulars of such income - HELD THAT:- A bare perusal of the notices issued to the assessee u/s 274 read with section 271(1)(c) of the Act goes to prove that assessee has not been called upon to explain if it has concealed the particulars of income or furnished inaccurate particulars of such income. As relying on Manjunatha Cotton [2013 (7) TMI 620 - KARNATAKA HIGH COURT] we are of the considered view that when the assessee has not been specifically made aware of the charges leveled against it as to whether there is a concealment of income or furnishing of inaccurate particulars of income on his part, the penalty u/s 271(1)(c) of the Act is not sustainable. - Decided in favour of assessee.
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