Shanti Prime Publication Pvt. Ltd.
Sec. 271(1)(c) of Income Tax Act, 1961— Penalty — Failure to specify the charge in the ‘Show cause’ notice clearly reflects the non application of mind by the A.O, and would resultantly render the order passed under Sec. 271(1)(c) in the backdrop of the said serious infirmity as invalid and void ab initio- A.O had clearly failed to discharge his statutory obligation of fairly putting the assessee to notice as regards the default for which he was being proceeded against, therefore, the penalty under Sec. 271(1)(c) imposed by him in clear violation of the mandate of Sec. 274(1) cannot be sustained. - PARDEEP KUMAR SAREEN V/s ITO - [2020] 206 TTJ 012 (UO)(ITAT-AMRITSAR)