https://www.taxtmi.com/caselaws?id=776241 The ITAT Mumbai held that penalty proceedings under section 270A require valid initiation by the AO at the time of assessment to assume jurisdiction. The CIT(A) cannot assume dual jurisdiction to levy penalty on the same facts once the AO has initiated penalty proceedings. In this case, although the AO had assumed jurisdiction regarding surrendered income disclosed in a revised return, the CIT(A) issued penalty notice and order without valid jurisdiction, rendering the penalty levy invalid. The appeal was allowed, and the penalty imposed by the CIT(A) was quashed. en-us Fri, 03 Jan 2025 00:00:00 +0530 Wed, 06 Aug 2025 12:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776241 The ITAT Mumbai held that penalty proceedings under section 270A require valid initiation by the AO at the time of assessment to assume jurisdiction. The CIT(A) cannot assume dual jurisdiction to levy penalty on the same facts once the AO has initiated penalty proceedings. In this case, although the AO had assumed jurisdiction regarding surrendered income disclosed in a revised return, the CIT(A) issued penalty notice and order without valid jurisdiction, rendering the penalty levy invalid. The appeal was allowed, and the penalty imposed by the CIT(A) was quashed. Case-Laws Income Tax Fri, 03 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776241