Failure to specify the exact limb of Section 270A(9) Vitiates

In a penalty dispute arising from revised income disclosure during assessment, the Tribunal ruled that a generic allegation of “under-reporting due to misreporting” without identifying the precise statutory limb is legally unsustainable. 

The absence of a specific charge deprives the assessee of a fair opportunity to respond, rendering the penalty void ab initio. The ruling reinforces procedural precision as a jurisdictional requirement in penalty proceedings.