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The High Court in [2022] 447 ITR 743 (Bom) reiterated that even if there was an order recording satisfaction for imposing penalty on one or the other, or on both grounds as mentioned in section 271(1)(c) of the said Act, if the show- cause notice suffers from the vagueness the same would fail. 


Thus it is essential that the show-cause notice issued to the assessee should be in accordance with law else it would not survive. 


In this case penalty notice did not  specify whether the assessee had concealed particulars of his income or had furnished inaccurate particulars of the same hence the challenge. 

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