No Section 271(1)(c) Penalty if AO’s Addition Lacks Jurisdiction

DCIT Vs Milan Kavinchandra Parikh (ITAT Mumbai) Introduction: The Income Tax Appellate Tribunal (ITAT) Mumbai recently delivered a pivotal judgment in the case between the Deputy Commissioner of Income Tax (DCIT) and Milan Kavinchandra Parikh. The judgment raises key questions surrounding the jurisdiction of penalties levied under section 271(1)(c) of the Income Tax Act, 1961. This article offers a comprehensive analysis of the case, focusing on the grounds raised by the Revenue and the reasoning provided by the Tribunal for dismissing the appeal. Grounds Raised by the Revenue: The Revenue c...