26 results for “disallowance”+ Section 274(2)clear
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In the result, appeal of the assessee is allowed and the appeal of the revenue
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay
274 read with section 271 was bad in law, as it did not specify under which limb of section 271(1)(c) penalty proceedings had been initiated, i.e., the notice failed to specify whether the penalty was imposed for concealment of income, furnishing inaccurate particulars, or both. As such the entire penalty proceeding is void-ab-initio and liable