Failure to Strike Relevant Limb: ITAT Mumbai Quashes Section 271(1)(c) Penalty Order

Smt. Smita Ashok Thakkar Vs DCIT (ITAT Mumbai) In the case of Smt. Smita Ashok Thakkar vs. DCIT (ITAT Mumbai), the assessee challenged the order passed by the Commissioner of Income Tax (Appeals)-54, Mumbai, related to Assessment Year 2012–13. The dispute arose from a penalty of ₹5,28,234 levied under Section 271(1)(c) of the Income Tax Act. This penalty followed a search conducted on the Thakkar Group, during which jewellery worth ₹26.98 lakhs (with an additional ₹10.02 lakhs on a protective basis) was found in a locker and deemed unexplained under Section 69A. The assessee argued tha...