The Supreme Court, on 31 July 2026, found no grounds to interfere with the High Court judgment and dismissed SLP (C) No. Revenue’s High Court ArgumentBefore the Bombay High Court, the Revenue attempted to distinguish Mohd. Bombay High Court FindingThe Bombay High Court rejected the Revenue’s attempt to distinguish the Full Bench decision. The Full Bench held that an ambiguous section 274 notice cannot form the foundation for valid imposition of penalty under section 271(1)(c). Supreme Court — Subsequent DevelopmentThe Revenue challenged the Bombay High Court judgment before the Supreme Court through SLP (C) No.26281/2026 @ Diary No.31777/2026.