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“furnishing inaccurate particulars of income”

PenaltySection 271(1)(c)Section 271(1)(c)1,616 judgments

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

Leading authorities on furnishing inaccurate particulars 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 furnishing inaccurate particulars of income

Shring Construction Company Pvt. Ltd., Dehradun vs. DCIT, Circle-2, Muzaffarnagar

In the result, the appeal filed by the Assessee stands allowed

ITA 7056/DEL/2018[2011-12]Status: DisposedITAT Delhi19 Dec 2025AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri Brajesh Kumar Singh, Hon’Blea.Y. : 2011-12

For Appellant: Sh. Ankit Gupta, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 271Section 271(1)(c)Section 274

cause as to why a penalty u/s. 271(1)(c) may not be imposed for concealing the particulars of his income and furnished inaccurate particulars of income. Aggrieved by the assessment order, assessee filed an appeal before the CIT(A) who vide his order dated confirmed the additions amounting ... abeyance. Hence, AO noted that it appears that assessee has nothing to say regarding the concealment of particulars of his income and furnishing inaccurate particulars of income in respect of aforesaid additions made to its income. In view of above, it was held that assessee is liable for penalty

Classic Share & Stock Broking Services Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 7(1), Mumbai

In the result, appeal filed by the assessee stands dismissed

ITA 4962/MUM/2025[2012-13]Status: DisposedITAT Mumbai18 Dec 2025AY 2012-13

Bench: Shri Sandeep Gosain, () & Shri Girish Agrawal, ()

Section 250Section 271(1)(c)Section 274

revenue authorities, submitted that penalty proceedings u/s 271(1)(c) of the Act were rightly initiated by the AO for furnishing “Inaccurate particulars of income”. It was further submitted that in the order of Assessment itself the AO had clearly mentioned that notice of penalty u/s 274 r.w.s ... under ‘business activity’ under the head income from business and profession. Therefore, penalty proceedings u/s 271(1)(c) were initiated for furnishing inaccurate particulars of income. 9. Although assessee challenged the additions, but Ld. CIT(A) also confirmed the disallowance of expenses to the extent

Rohini Maruti Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1839/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

29/09/2016. Ld.AO assessed the income at ₹ 64,91,229/- and initiated the penalty proceedings u/s. 271(1)(c) of the Act for furnishing inaccurate particulars of income at ₹63,80,243/-. Subsequently, penalty proceedings were initiated by issuing notice u/s. 274 of the Act and vide penalty order dated 18/05/2018

Tulsabai Vasant Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1838/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

29/09/2016. Ld.AO assessed the income at ₹ 64,91,229/- and initiated the penalty proceedings u/s. 271(1)(c) of the Act for furnishing inaccurate particulars of income at ₹63,80,243/-. Subsequently, penalty proceedings were initiated by issuing notice u/s. 274 of the Act and vide penalty order dated 18/05/2018

Amol Vasant Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1837/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

29/09/2016. Ld.AO assessed the income at ₹ 64,91,229/- and initiated the penalty proceedings u/s. 271(1)(c) of the Act for furnishing inaccurate particulars of income at ₹63,80,243/-. Subsequently, penalty proceedings were initiated by issuing notice u/s. 274 of the Act and vide penalty order dated 18/05/2018

Cinepolis India Pvt. Ltd., Gurgaon vs. ITO Ward - 1(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 829/DEL/2021[2016-17]Status: DisposedITAT Delhi16 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Ms. Renu Jauhri[Assessment Year: 2016-17] Cinepolis India Pvt. Ltd., Additional / Joint/ Deputy / 10Th Floor, Dlf Two Horizon Assistant Deputy Centre, Dlf V, Vs Commissioner Of Income Tax, Gold Course Road, Income Tax Officer, Gurugram-122002, National E-Assessment Haryana, India. Centre, Delhi. Pan- Aadcc2076J Assessee Revenue

Section 143(3)Section 271(1)(c)Section 92Section 92C

case and in law, the AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act for furnishing inaccurate particulars of income. Each of the above grounds are independent and without prejudice to the other grounds of appeal preferred by the Appellant. The Appellant prays for leave

Foods and Inns Limited, Mumbai vs. DCIT, Circle 2(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4926/MUM/2025[2015-16]Status: DisposedITAT Mumbai15 Dec 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Nitin KulkarniFor Respondent: Ms. Kavita Kaushik, Sr. DR
Section 143(3)Section 271(1)Section 271(1)(c)Section 36(1)(iii)

without appreciating that the penalty order had not given any finding or reasons of coming to the conclusion that assessee had furnished inaccurate particulars of income or the particulars furnished by the assessee are false or misleading or erroneous. c. In disregarding that penalty order has been passed ... assets, which, according to him, was not allowable till the date such assets were put to use. Holding that the assessee had furnished inaccurate particulars of income, the Assessing Officer levied penalty at 100% of the tax sought to be evaded, amounting to ₹1,19,060/-. 4. Before the learned

Corteva Agriscience Seeds Pvt. Ltd.(Formerly Known As Phi Seeds Private Limited), Telangana vs. ACIT, Circle-4(2), New Delhi

The appeal of the assessee is allowed

ITA 1422/DEL/2023[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharmacorteva Agriscience Vs. Additional/Joint/Deputy Seeds Pvt. Ld. (Formerly Assistant Commissioner Of Known As Phi Seeds Pvt. Ltd.) Income Tax, Circle 4(2) V- Ascendas, Atria Block, Cr Building 12Th Floor, Plot 17, New Delhi Software Units Layout, Madhapur, Hyderabad Telangana India – 500081 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaccp3920F Appellant .. Respondent

For Appellant: Sh. Sandeep Bansal, CAFor Respondent: Ms. Pooja Swaroop, CIT, DR
Section 10Section 10(1)Section 143Section 143(3)Section 2Section 270ASection 271(1)(c)

additions the ld. AO initiated the penalty proceeding under Section 271(1)(c) of the Act for the reason that assessee had furnished ‘inaccurate particulars’ of income. The impugned penalty order mentions that a show cause on 23.02.2021 was issued followed by reminders calling response. Show cause notice, copy ... Agriscience Seeds Pvt. Ltd.(AY:2016-17) of the paper book, establishes that assesseee was called upon to show cause for having ‘furnished inaccurate particular’ of income. 9. However, the impugned penalty order shows that going beyond the notice calling upon assessee to show cause for filing response to allegation

Sukhdev Raj, Sirsa vs. Income Tax Officer, Sirsa

In the result, the appeal of the assessee is dismissed

ITA 632/CHANDI/2025[2013-2014]Status: DisposedITAT Chandigarh10 Dec 2025AY 2013-2014

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Lalit Mohan, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 10(37)Section 147Section 234ASection 234BSection 253Section 28Section 56(2)(viii)Section 57

144B at a total taxable income of Rs. 24,73,033/-, and simultaneously initiating penalty proceedings under Section 271(1)(c) for furnishing inaccurate particulars of income. 9. Against the assessment order passed by the Assessing Officer, the assessee preferred an appeal before the Ld. CIT(A). After examining

Everest Kanto Cylinder Ltd, Mumbai vs. DCIT Circle 3(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5790/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Dec 2025AY 2010-11

Bench: Shri Rahul Chaudhary & Shri Prabhash Shankareverest Kanto Cylinder V/S. Deputy Commissioner Of Ltd. बनाम Income Tax, Circle – 3(4), 204,Raheja Centre, Free World Trade Centre 1, Cuffe Press Journal Marg, Parade, Mumbai – 400005, Nariman Point, Mumbai – Maharashtra 400 021, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaace0836F Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Shekhar Gupta,ARFor Respondent: Shri Hemanshu Joshi, (Sr.DR)
Section 115JSection 143(3)Section 271(1)Section 271(1)(c)Section 274

notice u/s. 271(1)(c) was valid although the said notice did not indicate whether there is concealment of income or furnishing inaccurate particulars of income. 3. Briefly stated facts of the case are that the assessee filed return declaring income of Rs 18.36 cr. under normal provisions ... issued notice u/s 271(1)(c)/274 of the Act, stating that: “you have concealed the particulars of your income by furnishing inaccurate particulars of income.". These are both limbs of the notice, that is, "concealment of income" and for "furnishing inaccurate particulars

Unipatch Rubber Limited, Delhi vs. DCIT/ACIT, Circle 25(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 4439/DEL/2025[2014-15]Status: DisposedITAT Delhi10 Dec 2025AY 2014-15

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.4439/Del/2025 िनधा"रणवष"/Assessment Year: 2014-15 बनाम Unipatch Rubber Limited, Dcit/Acit, Building No.10, Community Centre, Vs. Circle 25(1), Saket, Delhi. Delhi. Pan No.Aaacu0325P अपीलाथ" Appellant ""यथ"/Respondent

Section 250oSection 271(1)Section 271(1)(c)Section 274Section 80ISection 94(7)

without striking off the irrelevant portion and without clearly specifying whether the penalty was being levied for concealment of income or for furnishing inaccurate particulars of income, thereby violating the principles laid down in judicial precedents.” 2. Before us the Ld. AR pointed out the facts through a Paper book

DCIT, Aurangabad vs. Bg Li in Electricals Limited, Aurangabad

In the result, the appeal of the Revenue is dismissed

ITA 1087/PUN/2024[2016-17]Status: DisposedITAT Pune09 Dec 2025AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Smt. Deepa KhareFor Respondent: Richa Gulati (Virtually)
Section 142(1)Section 143(2)Section 143(3)Section 271(1)(c)Section 35

actual expenditure incurred is allowed. Penalty proceedings u/s 271(1)(c) of the Income tax Act, for concealment of particulars of income/ furnishing inaccurate particulars of income are initiated separately. [Addition: Rs.2,02,54,110/-].” 3. Aggrieved, the assessee preferred an appeal before the Ld. CIT(A)/NFAC. Before

T.L. Sritharan, Chennai vs. ACIT, Ncc-14, Chennai

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

ITA 2634/CHNY/2025[2014-15]Status: DisposedITAT Chennai04 Dec 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.2634/Chny/2025 िनधा;रण वष; /Assessment Year: 2014-15 T.L. Sritharan, The Asst. Commissioner Of New No.13, Old No.1, Vs. Income Tax, Swaminathan Street, Non Corporate Circle-14, West Mambalam, Chennai. Chennai – 600 033. Pan: Aepps 6766J

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri R.Raghupathy, Addl.CIT
Section 143(3)Section 271(1)(c)Section 45Section 50C

levied penalty of Rs. 4,04,156/- u/s 271(1)(c) of the Act for furnishing inaccurate particulars of income in the computation of LTCG, after the addition was confirmed by the Ld. CIT(A). On appeal, the Ld. CIT(A) further confirmed the penalty. TL Sritharan ... specified under which limb of Section 271(1)(c) of the Act, the penalty has been initiated whether for furnishing inaccurate particulars of income or for concealment of income. He also argued that the penalty has been levied merely on the re-computation of capital gains on exchange of plots

Dhaval Vinod Gada, Pune vs. DCIT Circle-5, Pune

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

ITA 1817/PUN/2025[2013-14]Status: DisposedITAT Pune03 Dec 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14 Dhaval Vinod Gada Dcit, Circle – 5, Pune 101, New Timber Market, Vs. Bhawani Peth, Pune – 411042 Pan: Anjpg4733A (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak Department By : Shri A D Kulkarni Date Of Hearing : 26-11-2025 Date Of Pronouncement : 03-12-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Nikhil S PathakFor Respondent: Shri A D Kulkarni
Section 131Section 133(6)Section 142(1)Section 143(2)Section 271(1)(c)Section 40A(2)(b)Section 68

assessee had made layer transaction for accommodating undisclosed funds. Penalty u/s. 271(1)(c) of the Act is also initiated for furnishing inaccurate particulars of income. For the remaining amount of Rs.1.62, crore, of which Shri Morgen Vinod Gada is beneficiary, the information in this respect will be intimated

Proton Positive Health Care India Private Limited, Hyderabad vs. ACIT., Circle -16(2), Hyderabad

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

ITA 812/HYD/2025[2016-17]Status: DisposedITAT Hyderabad03 Dec 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.812/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Proton Positive Health Vs. Assistant Commissioner Care India Private Limited, Of Income Tax, Hyderabad. Circle-16(2), Pan: Aafcp6862K Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Date Of 03/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) (For Short, “Cit(A)”) Dated 07/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 271(1)(C) Of The Income-Tax Act, 1961 (For Short, “Act”) Dated 28/06/2019 For Ay 2016-17. The Assessee Has Assailed The Impugned Order Passed By The Cit(A) On The Following Grounds Of Appeal Before Us:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(1)Section 271(1)Section 271(1)(c)Section 56(2)(viib)

addition with respect to trade creditors which is already recorded in the Books of accounts, and it does not tantamount to furnishing inaccurate particulars of income which leads to penalty U/s 271(1). 5. The Assessing Officer is not justified in levy of penalty without recording any proper satisfaction ... Assessment order ie., whether for furnishing inaccurate particulars of income or for concealment of income and hence invalid. 6. The Assessing Officer erred in levying penalty for furnishing inaccurate particulars with regard to addition under Section 56(2)(viib) being a deemed income. 7. The appellant craves leave

Deputy Commissioner of Income Tax, Central Circle 1(1), Kolkata vs. Axis Overseas Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2425/KOL/2024[2013-14]Status: DisposedITAT Kolkata03 Dec 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dy. Commissioner Of Income Tax, Cc 1(1), Kolkata Axis Overseas Limited Aaykar Bhawan Poorva, 21A, Shakespeare Sarani, Vs. 3Rd Floor, Kolkata-700107, Kolkata-700107, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aagca7497L Assessee By : Shri Siddharth Agarwal, Ar Revenue By : Shri P.N. Barnwal, Dr Date Of Hearing: 13.11.2025 Date Of Pronouncement: 03.12.2025

For Appellant: Shri Siddharth Agarwal, ARFor Respondent: Shri P.N. Barnwal, DR
Section 133(6)Section 68

Penalty U/s 271(1)(c) is being initiated separately for concealment of income by way of furnishing inaccurate particulars of income. So, for sake of consistency in department stand on the issue, addition of notional interest is made @ 12% amounting to Rs 2,67,75,667/- on total advances

DCIT 19.1 Mumbai, Lalbag Mumbai vs. Ambika Diamonds, Bkc Mumbai

In the result, appeal of the assessee is allowed

ITA 5873/MUM/2025[2012-13]Status: DisposedITAT Mumbai02 Dec 2025AY 2012-13

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: None
Section 143(2)Section 144Section 144rSection 147Section 148Section 250Section 271(1)(c)

struck off the irrelevant portion in the penalty notice and the penalty notice has been issued for both i.e. furnishing inaccurate particulars of income and for concealment of income. The appellant has relied upon catena of judgements of Hon’ble higher courts as well as the binding judgements

Keshav Kumar Nachani, Indore vs. DCIT-1(1), Indore

ITA 162/IND/2025[2009-10]Status: DisposedITAT Indore28 Nov 2025AY 2009-10

Bench: Shri B.M. Biyani

Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)Section 274

161And/2025 A.Ys.: 2009-10, 2010-11 & 2012-13 mentioning that the assessee has “concealed the particulars of income” or “furnished inaccurate particulars of income”. Further, in the notice of AY 2012-13, the AO has not specified any charge against assessee at all. 7. Ld. AR thereafter submitted that ... notice of AY 2009-10, we find that the same contains both of the charges viz. “concealed the particulars of income” or “furnished inaccurate particulars of income” and AO has not stricken-off any one. Further, the notice of AY 2012-12 does not contain any charge at all. Therefore

Keshav Kumar Nachani, Indore vs. DCIT-1(1), Indore

ITA 161/IND/2025[2012-13]Status: DisposedITAT Indore28 Nov 2025AY 2012-13

Bench: Shri B.M. Biyani

Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)Section 274

161And/2025 A.Ys.: 2009-10, 2010-11 & 2012-13 mentioning that the assessee has “concealed the particulars of income” or “furnished inaccurate particulars of income”. Further, in the notice of AY 2012-13, the AO has not specified any charge against assessee at all. 7. Ld. AR thereafter submitted that ... notice of AY 2009-10, we find that the same contains both of the charges viz. “concealed the particulars of income” or “furnished inaccurate particulars of income” and AO has not stricken-off any one. Further, the notice of AY 2012-12 does not contain any charge at all. Therefore

Keshav Kumar Nachani, Indore vs. DCIT-1(1), Indore

ITA 137/IND/2025[2010-11]Status: DisposedITAT Indore28 Nov 2025AY 2010-11

Bench: Shri B.M. Biyani

Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)Section 274

161And/2025 A.Ys.: 2009-10, 2010-11 & 2012-13 mentioning that the assessee has “concealed the particulars of income” or “furnished inaccurate particulars of income”. Further, in the notice of AY 2012-13, the AO has not specified any charge against assessee at all. 7. Ld. AR thereafter submitted that ... notice of AY 2009-10, we find that the same contains both of the charges viz. “concealed the particulars of income” or “furnished inaccurate particulars of income” and AO has not stricken-off any one. Further, the notice of AY 2012-12 does not contain any charge at all. Therefore