Sec. 271(1)(c) of Income Tax Act, 1961— Penalty —Concealment Penalty - ITAT was obliged to first decide the issue of jurisdiction to initiate the penalty proceedings, instead of simply remanding the matter to the Commissioner (Appeals) to decide the matter on the issue of jurisdiction as well as merits- ITAT has committed error of law which is apparent on the face of record in the sense that the core issue which was challenged by the revenue was about the jurisdiction of Assessment Officer in levying penalty without issuance of penalty proceedings. —GANGADHAR NARSINGAS AGRAWAL (HUF) vs. Asstt. CIT. [2020] 317 CTR 138 (BOM)