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“concealment of income”

PenaltySection 271(1)(c)Section 271(1)(c)2,901 judgments

The decision most relied on for concealment of income is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on concealment of income

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 248 · 2016 · Supreme Court
953
citing judgments

A notice issued under Section 274 read with Section 271(1)(c) is invalid if it fails to specify whether penalty proceedings are for concealment of particulars of income or furnishing inaccurate particulars of income. Such lack of specificity vitiates the penalty proceedings.

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Mr. Mohd. Farhan A. Shaikh v. ACIT
434 ITR 1 · 2021 · High Court
672
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify the exact charge by not striking off the irrelevant limb (concealment of income or furnishing inaccurate particulars of income). Such an omnibus or vague notice renders the penalty proceedings bad in law, and any penalty imposed on its basis is liable to be quashed.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing concealment of income

The ACIT CC-38, Mumbai vs. M/S. United Phosphorous Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 1822/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

dated 28.02.2006, the AO has no strike out inappropriate portion of notice by specifying as to whether the penalty has been initiated for concealment of income or filing inaccurate particulars of income. The ld AR of the assessee submits that she has already filed copy of such show cause notice ... additional grounds of appeal. On merits, the ld AR of the assessee submits that assessee has neither filed inaccurate particulars of income nor concealed the income all the facts were duly disclosed in the Notes to the computation of income that such expenditures are 37 CO no. 257/MUM/2006 M/s. United

M/S. United Phosphorus Ltd(Now Known As Uniphos Enterprises Ltd), Mumbai vs. The DCIT Cen Cir-38, Mumbai

In the result, the appeal of assessee is allowed

ITA 1787/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

dated 28.02.2006, the AO has no strike out inappropriate portion of notice by specifying as to whether the penalty has been initiated for concealment of income or filing inaccurate particulars of income. The ld AR of the assessee submits that she has already filed copy of such show cause notice ... additional grounds of appeal. On merits, the ld AR of the assessee submits that assessee has neither filed inaccurate particulars of income nor concealed the income all the facts were duly disclosed in the Notes to the computation of income that such expenditures are 37 CO no. 257/MUM/2006 M/s. United

Jatin Arora, New Delhi vs. ITO Ward-30(5), New Delhi

In the result, appeal of the assessee is allowed as indicated above

ITA 1833/DEL/2023[2012-13]Status: DisposedITAT Delhi30 May 2025AY 2012-13

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Ms. Rano Jain, AdvFor Respondent: Shri Om Parkash, Sr. DR
Section 139(1)Section 142(1)Section 143(3)Section 147Section 148Section 234BSection 44ASection 68

because a notice under Section 148 was issued and the assessee filed a return under Section 44AD, it cannot be the basis of concealment of income. 5 ITA No.-1794/Del/2023 Dhanuka Agritech Ltd. 6.2 Moreover, the AR vehemently argued that it is nowhere written in the law that

Income Tax Officer, Ward-1, Mehsana vs. Shri Meu Juth Vividh Karykari Sahakari Mandali Limited, Mehsana

ITA 2188/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad29 May 2025AY 2019-20

Bench: Smt. Annapurna Gupta, Accountant Amember & Shri T.R. Senthil Kumar

Section 69A

assessee's returned income under the head "Income from other sources," and penalty proceedings under section 271(1)(c) were initiated for concealment of income. 4.3 I have gone through the assessment order and record available. In the instant case, the appellant has argued that Loans given to members under

Incometax Officer, Ward-1, Mehsana vs. Shri Meu Juth Vividh Karyakari Sahkari Mandali Limited, Mehsana

ITA 2187/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad29 May 2025AY 2016-17

Bench: Smt. Annapurna Gupta, Accountant Amember & Shri T.R. Senthil Kumar

Section 69A

assessee's returned income under the head "Income from other sources," and penalty proceedings under section 271(1)(c) were initiated for concealment of income. 4.3 I have gone through the assessment order and record available. In the instant case, the appellant has argued that Loans given to members under

Income Tax Officer, Ward-1, Mehsana vs. Shri Meu Juth Vividh Karyakari Sahkari Mandali Limited, Mehsana

ITA 2179/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad29 May 2025AY 2015-16

Bench: Smt. Annapurna Gupta, Accountant Amember & Shri T.R. Senthil Kumar

Section 69A

assessee's returned income under the head "Income from other sources," and penalty proceedings under section 271(1)(c) were initiated for concealment of income. 4.3 I have gone through the assessment order and record available. In the instant case, the appellant has argued that Loans given to members under

Mahendra Rathi, Bikaner vs. ITO, Bikaner

ITA 299/JODH/2024[2010-11]Status: DisposedITAT Jodhpur28 May 2025AY 2010-11

Bench: Dr. Mitha Lal Meena, Hon'Ble & Dr. S. Seethalakshmi, Hon'Ble

IN THE INCOME TAX APPELLATE TRIBUNAL JODHPUR BENCH (Virtual) JODHPUR BEFORE DR. MITHA LAL MEENA, HON'BLE ACCOUNTANT MEMBER AND

L T Foods Ltd., New Delhi vs. Addl.CIT, Special Range-5, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1444/DEL/2019[1999-2000]Status: DisposedITAT Delhi28 May 2025AY 1999-2000

Bench: Shri Ramit Kochar & Shri Sudhir Kumar

For Appellant: Sh. Rohit Jain, AdvocateFor Respondent: Sh. Abhishek Deval, Sr. DR
Section 271(1)Section 271(1)(c)Section 80Section 80GSection 80HSection 80I

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘I’: NEW DELHI) BEFORE SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER AND SHRI SUDHIR

Gunjan Agarwal, Surat vs. ITO, Ward 1(2)(2), Surat

In the result, the appeal of the assessee is hereby allowed

ITA 59/SRT/2025[2008-09]Status: DisposedITAT Surat27 May 2025AY 2008-09

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita No.59/Srt/2025 िनधा"रण वष" /Assessment Year : 2008-09 Gunjan Agarwal The Ito बनाम/ (Prop. Shree Grih Shobha Ward-1(2)(2) V/S. Sarees Surat 457, Millennium Textile Market-2 Ring Road, Surat - 395 002 "थायी लेखा सं./Pan: Aewpa 8182 K (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Ms. Dalzin Madan, Ca Revenue By : Shri Mukesh Jain, Cit (Dr) सुनवाई की तारीख/Date Of Hearing : 30/04/2025 घोषणा की तारीख /Date Of Pronouncement: 27/05/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 21/11/2024 For The Assessment Year (Ay) 2008-09. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. On Facts & Circumstances Of The Case & In Law, The Learned Cit(A), Nfac Has Grossly Erred In Passing The Impugned Appellate Order On An Ex- Gunjan Agarwal Vs. Ito Asst. Year : 2008-09

For Appellant: Ms. Dalzin Madan, CAFor Respondent: Shri Mukesh Jain, CIT (DR)
Section 271(1)(c)

respect of additions made purely on estimate, guesswork, conjectures and surmises without appreciating that there is neither concealment of income nor furnishing of inaccurate particulars in respect thereof. Hence, the impugned penalty levied u/s 271(1)(c) of the Act, is absolutely erroneous, incorrect and bad-in-law and needs ... view, does not warranted levy of penalty u/s.271(1)(c) of the Income Tax Act, 1961. Therefore, it is not a case of concealment of income or furnishing of inaccurate particulars of income. The impugned order of penalty is, therefore, not sustainable and the same is set aside

M/S Pazhayangadi G Gold, Kannur vs. ITO Ward 1 & Tps, Kannur

In the result, the appeal by the assessee is dismissed

ITA 187/COCH/2023[2018-19]Status: DisposedITAT Cochin27 May 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhailassessment Year : 2018-19 Pazhayangadi G Gold, Ito, Ward-1& Tps, Eazhome Pazhayangadi, Kannur Kannur-670303 Vs. Pan : Aaufp9485G (Appellant) (Respondent) For Assessee : Shri Arun Raj S. Adv. For Revenue : Shri Sanjit Kumar Das, Cit-Dr (Heard In Hybrid Bench) Date Of Hearing : 25-03-2025 Date Of Pronouncement : 27-05-2025 O R D E R

For Appellant: Shri Arun Raj S. AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 142(1)Section 143Section 143(1)Section 143(2)Section 143(3)Section 263Section 270ASection 271ASection 68Section 69

that "on examination of the records, it is found that the Assessing Officer had in the assessment order established that the Assessee had concealed his income by filing inaccurate particulars". There is no such finding in the order of assessment. The Principal Commissioner seems to have distorted the order ... Commissioner is to that extent perverse. 15. In our view, in the absence of any finding of the Assessing Officer with regard to concealment of income or with regard to furnishing of inaccurate particulars of income, the Commissioner clearly erred in holding that omission to record satisfaction to initiate penalty

Vikas Vijay Gupta, Ahmedabad vs. The Pr. CIT, Ahmedabad-1, Ahmedabad

In the result, the appeal filed by the Assessee is hereby

ITA 404/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad27 May 2025AY 2017-18

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar, Judicial Member\nITA No. 404/Ahd/2024\nAssessment Year 2017-18\nVikas Vijay Gupta\nPrincipal Commissioner\n604 Sarap,\nof Income Tax,\nOpp. Navjivan Press Vs Ahmedabad-1,\nP.O. Navjivan,\nAhmedabad\nAhmedabad-380014,\nGujarat\n(Respondent)\nPAN: AEOPG6723L\n(Appellant)\nAssessee Represented: Shri Jaimin Shah, A.R.\nRevenue Represented: Shri R. N. Dsouza, CIT-DR\nDate of hearing : 27-02-2025\nDate of pronouncement : 27-05-2025\nआदे

Section 115BSection 147Section 263Section 271Section 271(1)(c)Section 271ASection 274Section 69A

However in the concluding part of the reassessment order the AO recorded ‘Notice issued for 271(1)(c) of the Act for concealment of income' and also issued notice dated 29-03-2022 for penalty u/s.274 r.w.s.271(1)(c) of the Act. 2. 1. In response the assessee ... Allahabad High Court but given a finding that the AO has to record his satisfaction or establish that the assessee has concealed his income by filing inaccurate particulars of income. In the absence of the same, the Hon'ble High Court held that the Tribunal has rightly set aside

Trustar Diamond, Bandra East vs. Ward 19(3)(5), Mumbai

In the result, the appeal is accordingly allowed in the

ITA 1542/MUM/2025[2009-10]Status: DisposedITAT Mumbai27 May 2025AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhan

Section 143(1)Section 143(3)Section 250Section 271(1)(c)

determining the total income of Rs.18,60,620/-. Further the penalty proceedings were initiated for furnishing inaccurate particulars of income leading to concealment of income chargeable to tax and levied penalty of Rs. 3,74,900/- i.e. 100% of tax sought to be evaded. 4. The said assessment order ... hence he has to be held responsible for furnishing inaccurate particulars of income and as such penalty imposed is justified. 8. What is concealment of income or inaccurate particulars of such income as contemplated by Section 271(1)(c), has been explained by the Hon'ble Supreme Court

ACIT I/C ITO - 22(2)(1), Mumbai, Piramal Chambers, Lalbaug vs. Naresh Manakchand Jain, Prabhadevi, Mumbai

In the result, the appeals of the assessee are partly allowed

ITA 1604/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 May 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Suchek Anchaliya, Ld. A.RFor Respondent: Shri Rakesh Ranjan, Ld. D.R
Section 153ASection 201Section 250

assessment orders, simultaneously initiated penalty proceedings detailed below: Assessment Penalty Reason Year proceedings u/s 2013-14 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2014-15 271(1)(c) of the Act For concealment of income and providing inaccurate particulars ... respect thereof 2015-16 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2016-17 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2017-18 270A of the Act Under reporting of income

ACIT I/C ITO - 22(2)(1), Mumbai, Piramal Chambers, Lalbaug vs. Naresh Manakchand Jain, Prabhadevi, Mumbai

In the result, the appeals of the assessee are partly allowed

ITA 1581/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 May 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Suchek Anchaliya, Ld. A.RFor Respondent: Shri Rakesh Ranjan, Ld. D.R
Section 153ASection 201Section 250

assessment orders, simultaneously initiated penalty proceedings detailed below: Assessment Penalty Reason Year proceedings u/s 2013-14 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2014-15 271(1)(c) of the Act For concealment of income and providing inaccurate particulars ... respect thereof 2015-16 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2016-17 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2017-18 270A of the Act Under reporting of income

ACIT I/C ITO - 22(2)(1), Mumbai, Piramal Chambers, Lalbaug vs. Naresh Manakchand Jain, Prabhadevi, Mumbai

In the result, the appeals of the assessee are partly allowed

ITA 1580/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 May 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Suchek Anchaliya, Ld. A.RFor Respondent: Shri Rakesh Ranjan, Ld. D.R
Section 153ASection 201Section 250

assessment orders, simultaneously initiated penalty proceedings detailed below: Assessment Penalty Reason Year proceedings u/s 2013-14 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2014-15 271(1)(c) of the Act For concealment of income and providing inaccurate particulars ... respect thereof 2015-16 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2016-17 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2017-18 270A of the Act Under reporting of income

ACIT I/C ITO - 22(2)(1), Mumbai, Piramal Chambers, Lalbaug vs. Naresh Manakchand Jain, Prabhadevi Mumbai

In the result, the appeals of the assessee are partly allowed

ITA 1579/MUM/2025[2014-15]Status: DisposedITAT Mumbai23 May 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Suchek Anchaliya, Ld. A.RFor Respondent: Shri Rakesh Ranjan, Ld. D.R
Section 153ASection 201Section 250

assessment orders, simultaneously initiated penalty proceedings detailed below: Assessment Penalty Reason Year proceedings u/s 2013-14 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2014-15 271(1)(c) of the Act For concealment of income and providing inaccurate particulars ... respect thereof 2015-16 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2016-17 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2017-18 270A of the Act Under reporting of income

ACIT I/C ITO - 22(2)(1), Mumbai., Piramal Chambers, Lalbaug vs. Naresh Manakchand Jain, Prabhadevi

In the result, the appeals of the assessee are partly allowed

ITA 1578/MUM/2025[2013]Status: DisposedITAT Mumbai23 May 2025

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Suchek Anchaliya, Ld. A.RFor Respondent: Shri Rakesh Ranjan, Ld. D.R
Section 153ASection 201Section 250

assessment orders, simultaneously initiated penalty proceedings detailed below: Assessment Penalty Reason Year proceedings u/s 2013-14 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2014-15 271(1)(c) of the Act For concealment of income and providing inaccurate particulars ... respect thereof 2015-16 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2016-17 271(1)(c) of the Act For concealment of income and providing inaccurate particulars in respect thereof 2017-18 270A of the Act Under reporting of income

Jitendra Kumar Agarwal, Jamshedpur vs. Deputy Commissioner of Income Tax, Centralcircle, Jamshedpur

In the result, this appeal filed by the assessee is allowed

ITA 88/RAN/2022[2017-18]Status: DisposedITAT Ranchi22 May 2025AY 2017-18

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 132(1)Section 132(4)Section 153ASection 271(1)(c)Section 274

notice for levying penalty did not specifically point out as to whether the penalty was 2 Jitendra Kr. Agarwal Vs DCIT for the concealment of income or for furnishing inaccurate particular of income. Accordingly, the appellant submitted that the show cause notice was defective on which no penalty could ... defective in as much as the said notice did not specifically state as to whether it was for concealment of income or for furnishing of incorrect particulars of income. The assessee has placed reliance on various case laws in support of the contention that if certain show cause notice

M/S. Simero Vitrified P. Ltd., Morbi vs. The Pr. CIT-3, Rajkot

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 276/RJT/2019[2016-17]Status: DisposedITAT Rajkot22 May 2025AY 2016-17

Bench: Us Is A Private Limited Company & Engaged In The Business Of Manufacturing Of Vitrified Tiles. The Return Of Income Has Been E-Filed By The Assessee, On 10/09/2016 For Assessment Year (A.Y.) 2016-17, Reporting Loss Of Rs. 5,68,00,829/-, Which Was Later Revised On 09/03/2018, Declaring Total Loss Of Rs. 13,97,40,413/-, Claiming Investment Allowance U/S 32Ac Of The Income Tax Act. The Case Has Been Selected For Complete Scrutiny (Cass) Specifically To Examine The Followings: 1) Whether Outward Foreign Remittance Is From Disclosed Sources & Appropriate Withholding & Reporting Obligation Have Been Complied With; 2) Whether Investment & Income Relating To Properties Are Duly Disclosed; 3) Whether Receipt Of Foreign Remittance Has Been Correctly Offered For Tax And, 4) Whether Sundry Creditors Are Genuine. 4. The Assessment Order U/S 143(3) For The Assessment Year (A.Y.) 2016-17 Was Passed By Dcit, Morbi Circle, Morbi, Being The Assessing Officer (Ao), On 21/12/2018, Allowing The Loss Claimed Of Rs. 13,97,40,413/- To Be Carry Forward To Subsequent Years. 2

Section 143(3)Section 263Section 32ASection 68

credits u/s 68 and added back to the assessee's total income. Penalty u/s 271(1)(C) is initiated on these amounts for concealment of income. ii) Fresh unsecured loans accepted of Rs. 14,41,45,054/- (squared up or not as in 31a of Form 3CD). Since no documents ... credits u/s 68 and added back to the assessee's total income. Penalty u/s 271(1)(C) is initiated on these amounts for concealment of income. iii) Since the data relating additional creditors was not available on online record and assessee fails to prove the genuineness and creditworthiness of creditors

Diesh Kumar Goyal, Kota vs. ITO, Ward-1(1), Kota

In the result, the appeal of the assessee is partly allowed

ITA 32/JPR/2025[2010-11]Status: DisposedITAT Jaipur22 May 2025AY 2010-11
For Appellant: Sh. Rajendra Sisodia, Adv
Section 143(3)Section 271(1)(c)Section 274Section 68Section 69

were initiated along with the assessment order dated 29.09.2010, for filing inaccurate particulars of income and concealing the income. The assessee filed appeal against the assessment order and the ld.CIT(A) provided partial relief to the assessee. Consequent to the order passed by CIT(A) in the quantum proceedings ... passing the assessment order, the AO after discussing the additions made by him, stated after each addition - Penalty proceedings_u/s_271(1)(c) for concealing the income are initiated separately on this issue. After the decision of appeal in the Quantum proceedings, the AO issued a Show Cause Notice