Section 271(1)(c) of Income Tax Act, 1961—Penalty—Concealment penalty — It is crystal clear that the charge for which penalty is proposed to be levied under section 271(1)(c), whether for concealment of income, or for furnishing of inaccurate particulars of income, is not specific and the law mandates that the authority, who is proposing to impose penalty, shall be certain as to the basis on which the penalty is being levied and the notice must reflect that specific reason, so that the assessee, to whom such notice is given, can prepare himself regarding the defence, which he would like to take to support his case — Risha Tour & Travels vs. ITO [2020] 78 ITR [Trib] 77 (Lucknow)