“levy of penalty”

PenaltySection 271Section 2715,057 judgments

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

Leading authorities on levy of penalty

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.

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.

Rashmikant Kundalia v. Union of India

54 Taxmann.com 200 · 2015 · High Court

702

citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

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.

CIT v. Manu Engg

122 ITR 306 · 1980 · High Court

505

citing judgments

When levying a penalty under Section 271(1)(c), the Assessing Officer must clearly specify whether it is for concealment of income or furnishing inaccurate particulars. An ambiguous notice or order using "and/or" for these limbs, or a standard proforma without striking irrelevant clauses, indicates non-application of mind and renders the penalty unsustainable.

Hindustan Steel Ltd. v. State of Orissa

83 ITR 26 · 1972 · Supreme Court

502

citing judgments

An order imposing penalty for failure to carry out a statutory obligation results from quasi-criminal proceedings. Penalty is not ordinarily imposed unless the party acted deliberately in defiance of law, was guilty of contumacious or dishonest conduct, or acted in conscious disregard of their obligation.

Judgments citing levy of penalty

Pristine Womens Hospital, Kolhapur vs. ACIT, CC-Kolhapur, Kolhapur

In the result both the appeals of the assessee are allowed for statistical purposes

ITA 848/PUN/2025[2014-15]Status: DisposedITAT Pune17 Jul 2025AY 2014-15

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.847-848/Pun/2025 धििाारण वर्ा / Assessment Years: 2016-2017 & 2014-15 Vs Acit, Central Circle, Pristine Womens Hospital, Kolhapur 395/2, E Ward Square 9 Building, Next To Basant- Bahar Talkies Assembly Road, Kolhapur-416001 Maharashtra Pan-Aacap7626A Appellant Respondent

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde-CIT

Section 250(6)Section 271(1)(c)

filing of the instant two appeals and admit the same for adjudication. 3. The sole greviance in both these appeals is against the levy of penalty ... orders of lower authorities. 6. We have heard rival contentions and perused the record placed before us. Assessee is aggrieved with the levy of penalty u/s 271(1)(c) of the Act for A.Y. 2016-17 and 2014-15. Admittedly various notices of hearing were given

Pristine Womens Hospital, Kolhapur vs. The Assistant Commissioner of Income Tax, Central Circle, Kolhapur

In the result both the appeals of the assessee are allowed for statistical purposes

ITA 847/PUN/2025[2016-17]Status: DisposedITAT Pune17 Jul 2025AY 2016-17

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde-CIT

Section 250(6)Section 271(1)(c)

Yuksom Breweries Ltd., Sikim vs. Addl./Joint CIT, Range - 2, Siliguri

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

ITA 1921/KOL/2024[2018-2019]Status: DisposedITAT Kolkata16 Jul 2025AY 2018-2019

Bench: Sri Pradip Kumar Choubey & Sri Rakesh Mishra

Section 143(3)Section 250Section 269TSection 271ESection 273BSection 274

that the Ld. CIT(A) was not justified in upholding the order passed by the National Faceless Assessment Centre u/s 271E levying a penalty of Rs. 63,82,872/- for the alleged violation of section 269T. (b) For that the Ld. CIT(A) ought to have quashed the order passed ... 271E for non-recording of satisfaction for levy of penalty and non-initiation of penalty in the assessment order passed u/s 143(3). 2. For that on the facts and in the circumstances of the case, the Ld. CIT(A) was not justified in confirming the penalty

Shshank Varshne, Chandausi vs. ITO, Chandausi

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

ITA 2116/DEL/2025[2013-14]Status: DisposedITAT Delhi16 Jul 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita No.4220/Del/2024 (Assessment Year 2013-14) Shshank Varshney, Income Tax Officer, Jyoti Seets, Brahm Bazar, Ward-2(5), Dist:-Sambhal, Vs. Chandausi. Uttar Pradesh-244412. Pan-Cmcpk9337C (Appellant) (Respondent) Assessee By Ca Ramsha Department By Shri Dheeraj Kumar Jaiswal, Sr. Dr Date Of Hearing 30/06/2025 Date Of Pronouncement 16/07/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against Two Separate Orders Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Ld. Cit” In Short) Arising Out Of The Order Of Assessing Officer Passed U/S 147 R.W.S 144 & 271F Of The Income Tax Act, 1961 (The Act) For Assessment Year 2013-14. 2. Brief Facts Of The Case Are That The Assessee Has Filed The Appeal Delayed By 592 Days Before The Ld. Cit(A) Against The Order U/S 147 R.W.S. 144 Of The Act & Also Filed Appeal Delayed By 427 Days Against Penalty Order U/S 271F Of The Act. The Ld. Cit(A) Has Not Admitted Both The Appeals Of The Assessee On Account Of Delay By Not Condoning The Delay In Filing The Appeals. Shashank Varshne Vs. Ito 3. Against These Separate Orders Of Ld. Cit(A), The Assessee Is In Appeal Before Us By Stating That The Assessee Has Not Received The Notices Issued By The Ao As Well As Cit(A) As The Notices Were Stated To Have Being Sent On The Email Address” Chinto1411988@Gmail.Com Which Was Neither Belong To Assessee Nor His Earlier Counsel. As The Notices Issued From Time To Time Were Not Received By The Assessee, The Necessary Compliance Could Not Be Made Before The Lower Authorities. Assessee Also Filed An Affidavit In Support Of The Contentions Raised For The Delay Before The Ld. Cit(A) Which Reads As Under: Shashank Varshne Vs. Ito

Section 147Section 271F

aside proceedings. In view of above, the grounds of appeal partly allowed for statistical purposes. 7. This appeal is against the levy of penalty u/s 271F of the Act for non- filing of return which is initiated in the assessment order passed u/s 147 r.w.s 144 of the Act dated

Shshank Varshney, Chandausi vs. Income Tax Officer, Ward 2(5), Chandausi

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

ITA 4220/DEL/2024[2013-2014]Status: DisposedITAT Delhi16 Jul 2025AY 2013-2014

Section 147Section 271F

Vijaybhai Patel, Vadodara vs. The ITO, Ward-1(3)(3), Vadodara

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 859/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2011-12

Bench: Shri T.R Senthil Kumar & Shri Narendra Prasad Sinha

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri Kamal Deep Singh, Sr. DR

Section 271(1)(c)

against ex-parte appellate order dated 10.02.2025 passed by the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre(NFAC), Delhi, confirming the levy of penalty u/s.271(1)(c) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] relating to the Asst. Year

Deputy Commissioner of Income Tax, Circle-2(1)(1), Vadodara vs. M/S. Sun Pharmaceuticals Industries Ltd, Vadodara

In the result, the appeal filed by the Assessee in ITA No

ITA 1785/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2009-10

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

For Appellant: Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, ARFor Respondent: Shri Prathvi Raj Meena, CIT-DR

Section 115Section 115JSection 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274

appellate order dated 27-09-2019 passed by the Commissioner of Income Tax (Appeals)-2, Vadodara [CIT(A) in short] partially confirming the levy of penalty u/s.271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as "the Act"). ITA No.1750/Ahd/2019 is filed by the assessee as against ... from partnership firm for determination of Book Profits u/s.115JB | 574950297 | 65141869 | 195425607 | | | Total | 66215043 | 198645129 | After considering the facts of the case, I levy a penalty of ₹ 14700000/-, (Rupees One Crore Forty Seven lakhs only) as against maximum penalty of 43992351/- for furnishing inaccurate particulars under the General Provisions

Sun Pharmaceuticals Industries Limited, Vadodara vs. The Deputy Commissioner of Income Tax, Central Circle-2(1)(1), Baroda

In the result, the appeal filed by the Assessee in ITA No

ITA 1750/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2009-10

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

For Appellant: Shri S.N. Soparkar, Sr.Advocate &For Respondent: Shri Prathvi Raj Meena, CIT-DR

Section 115Section 115JSection 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274

Vadodara ITA Nos.1741 & 1750/Ahd/2019 (by Assessee) and Sun Pharmaceutical Industries Ltd. vs. DCIT Asst.Year- 2009-10 [CIT(A) in short] partially confirming the levy of penalty u/s.271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as "the Act"). ITA No.1750/Ahd/2019 is filed by the assessee as against ... remuneration received from partnership firm for determination of Book Profits u/s.115JB Total 66215043 198645129 After considering the facts of the case, I levy a penalty of ₹ 14700000/-, (Rupees One Crore Forty Seven lakhs only) as ITA Nos.1741 & 1750/Ahd/2019 (by Assessee) and Sun Pharmaceutical Industries Ltd. vs. DCIT Asst.Year

Sun Pharmaceuticals Industries Limited, Vadodara vs. The Deputy Commissioner of Income Tax, Central Circle-2(1)(1), Baroda

In the result, the appeal filed by the Assessee in ITA No

ITA 1741/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2009-10

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

For Appellant: Shri S.N. Soparkar, Sr.Advocate &For Respondent: Shri Prathvi Raj Meena, CIT-DR

Section 115Section 115JSection 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274

Natarajan Thangavel, Tiruppur vs. The Income Tax Officer Ward 2(4), Tiruppur

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 967/CHNY/2025[2017-18]Status: DisposedITAT Chennai15 Jul 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:967/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Natarajan Thangavel, The Income Tax Officer, 3/19, Kottamangalam Post, Vs. Ward -2(4), Vellampalayam, Tirupur. Udumalpet – 642 201. [Pan:Afzpt-0315-F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Dr. S. Sankar Ganesh, C.A. (Virtual) ""थ" की ओर से/Respondent By : Shri. Kumar Chandan, Jcit

For Appellant: Dr. S. Sankar Ganesh, C.A. (Virtual)For Respondent: Shri. Kumar Chandan, JCIT

Section 143(1)Section 143(3)Section 69A

assessee was unaware of as the entire proceeding was conducted online and in a faceless manner and recently upon receiving notices proposing levy of penalty for the impugned AY, and he became aware that his appeal has been dismissed by the CIT(A). Hence, there was a delay in filing

Vgn Infra India Pvt. Ltd., Chennai vs. ITO, Corporate Ward-3(3), Chennai

In the result, the appeal of the Assessee is allowed

ITA 573/CHNY/2025[2017-18]Status: DisposedITAT Chennai15 Jul 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 573/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18

For Appellant: Shri. G. Baskar & Shri. I. Dinesh, AdvocatesFor Respondent: Ms. Sita Krishnamoorthy, J.C.I.T

Section 139(1)Section 143(2)Section 143(3)Section 270ASection 270A(6)Section 36(1)(va)

appellant having disclosed all the facts regarding the deduction claimed and having claimed the same on a bona fide reason, the levy of penalty is incorrect and the CIT(A) ought to have deleted the same by considering the provisions of section 270A(6) of the Act. 7. Any other

Mohan Tryambak Pawar, Nashik vs. ACIT, Circle 1, Nashik

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

ITA 2521/PUN/2024[2011-12]Status: DisposedITAT Pune14 Jul 2025AY 2011-12

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2521/Pun/2024 "नधा"रण वष" / Assessment Year : 2011-12

For Appellant: Shri Sanket M. Joshi

Section 143(3)Section 250Section 250(6)Section 271(1)(c)

Assessment Year 2011-12 framed on 20.12.2016 by the ACIT, Circle-2, Nashik. 2. The issue in the instant appeal relates to levy of penalty u/s 271(1)(c) of the Act. However Ld. Counsel for the assessee, at the outset, stated that on account of delay of 341 days ... assessee. 4. We have heard rival contentions and perused the records placed before us. The issue raised in this appeal against the levy of penalty u/s 271(1)(c) vide order dated 01.02.2022. As per the submission made before us, the penalty order dated 01.02.2022 was served on the email

Dinar Umeshkumar More, Malegaon vs. ITO Ward 1, Malegaon

In the result, appeal of the assessee is allowed

ITA 2125/PUN/2024[2011-12]Status: DisposedITAT Pune14 Jul 2025AY 2011-12

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Ramnath P Murkunde

Section 143(3)Section 250Section 271(1)(c)Section 275

r.w.s.274 of the Act. 2. Assessee has raised following grounds of appeal: “1] The learned CIT(A) erred in confirming the levy of penalty u/s 271(1)(c) of Rs. 10,34,167 in respect of addition of Rs.50,21,520 made in the asst. order w/s 143(3) r.w.s.254 ... gains on transfer of immovable property on the ground that the appellant had concealed the particulars of his income without appreciating that the levy of penalty was not justified on facts and in law. 2 Dinar Umeshkumar More 2] The learned CIT(A) erred in not appreciating that the penalty

Deputy Commissioner of Income Tax, Circle-6(1)(1), Bangalore vs. Santosh Shivaji Lad, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 1522/BANG/2024[2013-14]Status: DisposedITAT Bangalore14 Jul 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2013-14

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Murali Mohan M, CIT (DR)

Section 271(1)(c)Section 274Section 36(1)(vii)Section 36(2)Section 57

assessment year 2013-14. 2. The only issue raised by the revenue is that the learned CIT(A) erred in confirming the levy of penalty under section 271(1)(c) of the Act. Page 2 of 16 3. The facts, in brief, are that the assessee is an individual ... Furthermore, the assessee submitted that any addition or disallowance made in the assessment order does not, per se, empower the AO to levy a penalty under section 271(1)(c) of the Act. The assessee contended that, in the present case, he had made advances to companies in which

M/S Kumaon Mandal Vikash Nigam Ltd., Nanital vs. ACIT, Circle-3, Nanital

In the result, the appeal of the assesse is allowed

ITA 44/DDN/2025[2013-14]Status: DisposedITAT Dehradun09 Jul 2025AY 2013-14

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 271Section 271(1)(c)Section 274(1)

income and concealment of income and penalty was levied for furnishing inaccurate particulars of income and concealment of income, therefore, the order of levy of penalty deserves to be upheld and merely for not struck off the limb in the penalty notice, such order should not be canceled ... Karnataka High Court in the case of CIT vs. Manjunatha Cotton & Ginning Factory reported in [2013] 359 ITR 565 (Kar) observed that the levy of penalty has to be clear as to the limb under which it is being levied. As per Hon'ble High Court, where the Assessing Officer

Ankit Nautiyal, Dehradun vs. ITO, Dehradun

In the result, the Appeal of the Appellant is partly allowed for

ITA 197/DDN/2024[2016-17]Status: DisposedITAT Dehradun09 Jul 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 144

communicated to the Assessee on time and the Assessee came to know about passing of the order impugned only when the notice for levy of penalty was served on him. Thus, sought for condoning the delay. 4. For the reason stated in the application for condonation of delay mentioned supra

Kajal Nimishbhai Sinojia, Rajkot vs. ITO WD 1(1)(1), RKT, Rajkot

Appeal is allowed for statistical purpose

ITA 664/RJT/2024[2015-16]Status: DisposedITAT Rajkot09 Jul 2025AY 2015-16

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.664/Rjt/2024 "नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Kajal Nimishbhai Sinojia Vs. Income-Tax Officer, B-21 Shreeji Haridwar Society,Nr Ito Ward – 1(1)(1), Gokuldham, Aaykar Bhavan, Rajkot - 360004 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bsups2455J (Appellant) (Respondent) Appellant By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri K. L. Solanki, Ld. Sr. Dr Date Of Hearing : 24 / 04 /2025 Date Of Pronouncement : 09 / 07/2025

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri K. L. Solanki, Ld. Sr. DR

Section 142(1)Section 147Section 148Section 271Section 271(1)(b)Section 272A(1)(d)Section 273BSection 69C

assessee regarding non-compliance of notices issued u/s 142(1) of the Act. That the AO completed the penalty proceedings and levied the penalty for non-compliance of notices u/s 142(1) of the Act dated 11.01.2023 & 06.04.2023 Kajal Nimishbhai Sinojia 4. That the assessee filed an appeal against ... imposing penalty of Rs 20,000/- under section 271(1)(b) for non-compliance does not call for any interference. Accordingly, the levy of penalty is confirmed. These grounds of appeal are dismissed. In the result, the appeal is dismissed.” 5. That the assessee field an appeal against the impugned

Saini Co-Operative Tharift and Credit Society Ltd., New Delhi vs. ITO, Ward-48(1), Delhi

In the result, appeal of the assessee is allowed

ITA 4912/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jul 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2016-17] Saini Co-Operative Tharift & Vs Ito, Credit Society, 2429-21, Ward-48(1), Bazar Kamra Bangash, Darya New Delhi Ganj, New Delhi-110002. Pan-Aabas8396K Appellant Respondent Shri K.Sampath, Adv. & Appellant By Shri V.Raj Kumar, Adv. Respondent By Shri Dheeraj Kumar Jaiswal, Sr.Dr 01.07.2025 Date Of Hearing Date Of Pronouncement 09.07.2025

Section 143(3)Section 250Section 271Section 271(1)(c)Section 271ASection 80P

further appeal was preferred against such order. The AO proceeded with the pending penalty proceedings u/s 271(1)(c) of the Act and levied the penalty at Rs. 18,30,970/- being 100% of the tax sought to be evaded on the concealed income of Rs. 52,90,600/-. Against ... concerned merely making of claim in view of interpretation of law supported by judgment of Hon’ble Supreme Court cant lead to levy of penalty u/s 271 (1) (c) of the IT Act. During covid period the office of the society was closed as it was in the congested

Jokhiram Durgadutt, Ranchi vs. DCIT, Circle-1, Ranchi

In the result, this appeal of the assessee is allowed

ITA 400/RAN/2024[2016-17]Status: DisposedITAT Ranchi07 Jul 2025AY 2016-17

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayjokhiram Durgadutt, D.C.I.T., 9, J.D. Corporate, Behind J.D. High Circle-1, Vs. Street, Main Road, Ranchi-834001 Ranchi. (Jharkhand) Pan No. Aabfj 2200 Q Appellant/ Assessee Respondent/ Revenue

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

receipts as royalty or business 4 ITA 400/Ran/2024 Jokhiram Durgadutt Vs DCIT income, addition made on difference of opinion could not lead to levy of penalty under section 271(1)(c)." It has been held in the case of Commissioner of Income Tax v S. Kumar Tyres Manufacturing

M/S Bharat Coking Coal Ltd, Dhanbad vs. ACIT Cir-1, Dhanbad

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

ITA 128/RAN/2018[12-13]Status: DisposedITAT Ranchi07 Jul 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 271Section 271(1)(c)Section 274Section 275

Karnataka High Court in CIT & Anr. vs. Manjunatha Cotton & Ginning Factory 359 ITR 565 (Kar.) wherein the court had enshrined that levy of penalty is altogether different from assessment procedures. The penalty cannot be levied in a routine manner. The principles of natural justice must be followed wherein the notice ... served on the assessee must clearly and unambiguously specify the charge on which the Department proposes to levy the penalty so that the assessee can be ready with his defence and prepare his case and submissions accordingly. 7. In view thereof, even without going into the merits of the extant