Section 271(1)(c) penalty based on estimated addition & Defective notice is unsustainable

Jatin Enterprises Vs ACIT (ITAT Mumbai) Introduction: In the case of Jatin Enterprises vs. ACIT (ITAT Mumbai), the Income Tax Appellate Tribunal (ITAT) delivered a significant ruling regarding the validity of a penalty notice. The appeal was directed against the order of the Commissioner of Income Tax (Appeals) confirming the levy of a penalty under section 271(1)(c) of the Income Tax Act, 1961. Detailed Analysis: The crux of the matter revolved around the addition of Rs. 1,00,15,634/- on account of alleged bogus purchases made by the Assessing Officer. Despite the CIT(A) restricting the addit...