AGR Investments Ltd. v. Addl. CIT (Del)

333 ITR 146High Court2011#2485 most cited

What is AGR Investments Ltd. v. Addl. CIT (Del) authority for?

For initiating reassessment proceedings under Section 147, the Assessing Officer must possess fresh tangible material or specific information, often from the investigation wing, which forms a direct nexus with the reason to believe that income has escaped assessment, demonstrating the application of mind. A prima facie reason, rather than a final verdict, is sufficient to assume jurisdiction for issuing a notice under Section 148.

47

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2025.

Also referred to as

AGR Investments Ltd. · Section 147 · Section 148 · reassessment · reason to believe · tangible material · fresh information · investigation wing information · live link · application of mind · prima facie reason · escaped assessment

Sections most often in play

Section 147Section 148Section 143(3)Section 131Section 133(6)Section 68Section 144Section 151

Issues it is cited on

section 2(40)section 147oflive linkpaper companyfresh tangible materialsection 148(2)beyond four yearsbogus ltcgmere change of opinionprice riggingchange of opinionsection 151(2)

Judgments citing AGR Investments Ltd. v. Addl. CIT (Del)

DCIT(CC)-8(3), MUMBAI , MUMBAI vs. JSW STEEL LIMITED, MUMBAI

In the result, all the above appeals of the assessee are partly allowed and Cross appeals of the Revenue are dismissed

ITA 5599/MUM/2024[2013-14]Status: DisposedITAT Mumbai08 Dec 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263

…IN THE INCOME-TAX APPELLATE TRIBUNAL“F” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No. 5585/MUM/2024 (A.Y. 2014-15) M/s JSW Steel Limited v/s. Deputy Commissioner of Income JSW Centre, Bandra Kurla बनाम Tax, Central Circle-8(3) Complex, Bandra (East), Aaykar Bhavan, 6th Floor, Room Mumbai – 400 051, No. 659, Maharishi Karve Road, Maharashtra Mumbai – 400 020, Maharashtra स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AAACJ4323N Appellant/अपीलाथी .. Respondent/प्रतिवादी ITA No. 5615/MUM/2024 (A.Y. 2014-15) Deputy Commissioner of Income v/s. M/s JSW St…

M/S. JSW STEEL LIMITED ,MUMBAI vs. DCIT, CENTRAL CIRCLE -8(3), MUMBAI

In the result, all the above appeals of the assessee are partly allowed and Cross appeals of the Revenue are dismissed

ITA 5585/MUM/2024[2014-15]Status: DisposedITAT Mumbai08 Dec 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263

…IN THE INCOME-TAX APPELLATE TRIBUNAL“F” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No. 5585/MUM/2024 (A.Y. 2014-15) M/s JSW Steel Limited v/s. Deputy Commissioner of Income JSW Centre, Bandra Kurla बनाम Tax, Central Circle-8(3) Complex, Bandra (East), Aaykar Bhavan, 6th Floor, Room Mumbai – 400 051, No. 659, Maharishi Karve Road, Maharashtra Mumbai – 400 020, Maharashtra स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AAACJ4323N Appellant/अपीलाथी .. Respondent/प्रतिवादी ITA No. 5615/MUM/2024 (A.Y. 2014-15) Deputy Commissioner of Income v/s. M/s JSW St…

RAMASAMY KANDASAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, the appeal of the assessee is allowed

ITA 2023/CHNY/2025[2012-13]Status: DisposedITAT Chennai19 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.2023/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 V. Ramasamy Kandasamy, The Ito, No.4/76, Sf No.927, Sukkaliyur, Ward-1, Karur-639 003. Karur. [Pan: Ajgpk 4945 H]

For Appellant: Mr.H. Yeshwanth KumarFor Respondent: Ms.R. Anitha, Addl.CIT
Section 143(2)Section 143(3)Section 147Section 151

…the contentions of the appellant that the AO worked mechanically on the information available with him for reopening of the case do not carry much force. Reliance is placed on the judicial pronouncement in the case of AGR Investments Ltd. vs. Addl. CIT (Del) 333 ITR 146 wherein Hon'ble Delhi High Court held that where Assessing Officer had specific information as regards transactions entered by assessee company with a number of concerns which had made accommodation entries and they were not genuine transactions, it could be said that there was material on basis of which notice under section 148 could be issued.…

SAMIR PATODIA (HUF),FADIA BUILDING ,RAMWADI, MUMBAI vs. DCIT-CC-7(2),MUMBAI, AAYAKAR BHAWAN,MUMBAI

In the result, assessee's appeal is dismissed

ITA 5733/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarsamir Patodia (Huf), V/S. Deputy Commissioner Of Fadia Building No. 3, Caval बनाम Income Tax, Central Circle – Cross Lane 4 Ramwaldi, 7(2), Aayakar Bhavan, Kalbadevi Road, Mumbai – Mumbai – 400020, 400 002, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aajhs8769K Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Prateek Jain,ARFor Respondent: Shri Bhagirath Ramawat (Sr. DR)
Section 131Section 147Section 148

…dent that the department was in possession of fresh information which led the AO to arrive at reasons to believe necessary to invoke the provisions of section 147 of the Act. The Hon’ble Delhi High Court in the case of AGR Investments Ltd. vs. Addl. CIT (Del) 333 ITR 146 held that that where Assessing Officer had specific information from DDIT (Investigation) as regard transactions entered into by assessee company with a number of concerns whichhad made accommodation entries and they were not genuine transactions, it could be said that there was material on basis of which notice under section 148 of the Act could…

SUNIL PATODIA (HUF),RAMWALDI, KALBADEVI RD. MUMBAI vs. DCIT-CC-7(2), MUMBAI, AAYAKAR BHAWAN,MUMBAI

In the result, assessee's appeal is dismissed

ITA 5732/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Nov 2025AY 2018-19
For Appellant: \nShri Prateek Jain,ARFor Respondent: \nShri Bhagirath Ramawat, (Sr. DR)
Section 131Section 147Section 148

…that the department was in\npossession of fresh information which led the AO to arrive at reasons to\nbelieve necessary to invoke the provisions of section 147 of the Act. The\nHon'ble Delhi High Court in the case of AGR Investments Ltd. vs.\nAddl. CIT (Del) 333 ITR 146 held that that where Assessing Officer\nhad specific information from DDIT (Investigation) as regard\ntransactions entered into by assessee company with a number of\nconcerns which had made accommodation entries and they were not\ngenuine transactions, it could be said that there was material on basis of\nwhich notice under section 148 of the Act…

KAJAL BATRA,DELHI vs. ACIT,CIRCLE-52(1), DELHI

In the result, the appeal of the assessee stands dismissed as above

ITA 2419/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 151Section 68Section 69A

…eciated that if the information received from the investigation wing and the notices issued pursuant to such information the reopening was held valid and get as mentioned in the judicial pronouncement as under- 1. AGR Investments Ltd. Vs Addl. CIT& Anr. (Del) 333 ITR 146 2. Shalimar Buildcon (P) Ltd. Vs ITO (ITAT, Jaipur) 136 TTJ 701 d. Further, it may be appreciated that what is necessary to re-open an assessment is not final verdict but a prima facie reason and once such a reason is recorded by assessing authority he assumes jurisdiction to issue notice u/s 148 as has been in judicial pronouncements as under: 1…

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 497/PUN/2025[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

…he assessee recorded reasons and thereafter had issued notice u/s 148, therefore, such re- assessment proceedings are in accordance with law. 45. Referring to the decision of the Hon'ble Delhi High Court in the case of AGR Investment Ltd. vs. Addl.CIT (2011) 333 ITR 146 (Del), he submitted that the Hon'ble High Court in the said decision has held that where the Assessing Officer had specific information from office of DIT (Investigation) as regards transactions entered into by assesses-company with a number of concerns which had made accommodation entries and they were not genuine transactions, it could be said…

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 1565/PUN/2024[2018-19]Status: DisposedITAT Pune27 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

…he assessee recorded reasons and thereafter had issued notice u/s 148, therefore, such re- assessment proceedings are in accordance with law. 45. Referring to the decision of the Hon'ble Delhi High Court in the case of AGR Investment Ltd. vs. Addl.CIT (2011) 333 ITR 146 (Del), he submitted that the Hon'ble High Court in the said decision has held that where the Assessing Officer had specific information from office of DIT (Investigation) as regards transactions entered into by assesses-company with a number of concerns which had made accommodation entries and they were not genuine transactions, it could be said…

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 1555/PUN/2024[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

For Respondent: S/Shri Suchek Anchaliya and
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

…he assessee recorded reasons and thereafter had issued notice u/s 148, therefore, such re- assessment proceedings are in accordance with law. 45. Referring to the decision of the Hon'ble Delhi High Court in the case of AGR Investment Ltd. vs. Addl.CIT (2011) 333 ITR 146 (Del), he submitted that the Hon'ble High Court in the said decision has held that where the Assessing 37 ITA Nos.1555/PUN/2024 & Ors CO Nos.2 to 5/PUN/2025 Officer had specific information from office of DIT (Investigation) as regards transactions entered into by assesses-company with a number of concerns which had made accommodation entries an…

RAHEJA DEVELOPERS LIMITED, NEW DELHI vs. DCIT, CENTRAL CIRCLE 19, NEW DELHI

ITA 2284/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

…ities are intangible material to record to initiate valid assessment proceedings as held in PCIT vs. Paramount Communications Pvt. Ltd (2017) 392 ITR 444. Similar ratio has been laid down in the case of in A.G.R Investment Ltd. Vs. Addl. CIT and anr. [2011] 333 ITR 146 and in the case of Avirat Stat Homes Venure (P.) Ltd. Vs. Income-tax Officer [2019] 102 taxmann.com 60 (Bombay). 10. Thus, in our considered opinion, A.O. was indeed having prima facie tangible material on record on the basis of which formed reason to believe that income of appellant has escaped assessment. As the material and the reason to b…

RAHEJA DEVELOPERS LIMITED,NEW DELHI vs. ACIT, CENTRAL CIRCLE 19, DELHI

ITA 2283/DEL/2023[2011-12]Status: DisposedITAT Delhi17 Oct 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

…ities are intangible material to record to initiate valid assessment proceedings as held in PCIT vs. Paramount Communications Pvt. Ltd (2017) 392 ITR 444. Similar ratio has been laid down in the case of in A.G.R Investment Ltd. Vs. Addl. CIT and anr. [2011] 333 ITR 146 and in the case of Avirat Stat Homes Venure (P.) Ltd. Vs. Income-tax Officer [2019] 102 taxmann.com 60 (Bombay). 10. Thus, in our considered opinion, A.O. was indeed having prima facie tangible material on record on the basis of which formed reason to believe that income of appellant has escaped assessment. As the material and the reason to b…

M/S REAL TIME CONSULTANTS PVT. LTD.,MUMBAI vs. ITO 15(3)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed for\nstatistical purposes

ITA 3290/MUM/2019[2011-12]Status: DisposedITAT Mumbai05 Sept 2025AY 2011-12
For Appellant: \nShri Rushabh Mehta,ARFor Respondent: \nShri Uma Shankar Prasad, (CIT DR)
Section 131Section 143(3)Section 147

…that the department was in possession of\nfresh information which led the AO to arrive at reasons to believe\nnecessary to invoke the provisions of section 147 of the Act. The Hon'ble\nDelhi High Court in the case of AGR Investments Ltd. vs. Addl. CIT\n(Del) 333 ITR 146 held that that where Assessing Officer had specific\ninformation from DDIT (Investigation) as regard transactions entered\ninto by assessee company with a number of concerns whichhad made\nPage 8\nITA No. 3290/Mum/2019\nA.Y. 2011-12\nM/s Real Time Consultants Pvt. Ltd.\naccommodation entries and they were not genuine transactions, it could\nbe sa…

UNIVERSAL DRINKS,NEW DELHI vs. ACIT, CIRCLE-42(1), NEW DELHI

ITA 2283/DEL/2019[2015-16]Status: HeardITAT Delhi25 Mar 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

…ities are intangible material to record to initiate valid assessment proceedings as held in PCIT vs. Paramount Communications Pvt. Ltd (2017) 392 ITR 444. Similar ratio has been laid down in the case of in A.G.R Investment Ltd. Vs. Addl. CIT and anr. [2011] 333 ITR 146 and in the case of Avirat Stat Homes Venure (P.) Ltd. Vs. Income-tax Officer [2019] 102 taxmann.com 60 (Bombay). 10. Thus, in our considered opinion, A.O. was indeed having prima facie tangible material on record on the basis of which formed reason to believe that income of appellant has escaped assessment. As the material and the reason to b…

INCOME TAX OFFICER, AYAKAR BHAVAN vs. SUKANIYA PROPERTIES PVT LTD, MUMBAI

In the result, appeal of the assessee is allowed and that of the\nrevenue is dismissed

ITA 3711/MUM/2024[2008-09]Status: HeardITAT Mumbai14 Feb 2025AY 2008-09
For Appellant: Shri Dharmesh Shah & Mitali Parekh, A/RsFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 147Section 148Section 150(1)Section 150(2)Section 250Section 68

…275 wherein it was held that information\nfrom Enforcement Directorate showing inflation of purchases could be a good ground\nfor issuing notice u/s.148 of the Act.\ne.\nDecision of the Hon'ble Delhi High Court in the case of AGR Investment\nLtd., reported in 333 ITR 146 and the decision of Jaipur Bench in the case of Shalimar\nBuildcon 136 TTJ 701 wherein it was held that the notice u/s.148 of the Act could be\nissued based on information from Investigation Wing about tainted transactions\ncarried out by the assessee.\n5.11.\nWe find that all the aforesaid case laws referred by the ld. DR did not address\non the…

M/S. SUKANIYA PROPERTIES, PVT. LTD,MUMBAI vs. DCIT, CENTRAL CIRCLE -3(4), MUMBAI

In the result, appeal of the assessee is allowed and that of the\nrevenue is dismissed

ITA 3309/MUM/2024[2008-09]Status: HeardITAT Mumbai14 Feb 2025AY 2008-09
For Appellant: Shri Dharmesh Shah & Mitali Parekh, A/RsFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 147Section 148Section 150(1)Section 150(2)Section 250Section 68

…275 wherein it was held that information\nfrom Enforcement Directorate showing inflation of purchases could be a good ground\nfor issuing notice u/s.148 of the Act.\ne. Decision of the Hon'ble Delhi High Court in the case of AGR Investment\nLtd., reported in 333 ITR 146 and the decision of Jaipur Bench in the case of Shalimar\nBuildcon 136 TTJ 701 wherein it was held that the notice u/s.148 of the Act could be\nissued based on information from Investigation Wing about tainted transactions\ncarried out by the assessee.\n5. 11. We find that all the aforesaid case laws referred by the ld. DR did not address\non th…

TIJARIA POLYPIPES LIMITED,JAIPUR vs. DCIT CIRLCE 4, JAIPUR

ITA 616/JPR/2024[2013-14]Status: DisposedITAT Jaipur30 Jan 2025AY 2013-14
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Anoop Singh, Addl.CIT-DR
Section 143(3)Section 147Section 148Section 68

…venue and are considered valid are the existence of tangible material or\ninformation in the light of the judgment in CIT v. Kelvinator of India [2010] 320 ITR\n561 (SC)\"\n1. In the judgement in the case of AGR Investment Ltd. vs. Additional CIT &Anr\n(2011) 333 ITR 146, Hon'ble High Court of Delhi, has held as under:-\n\"It is also noticeable that there was specific information received from the office of\nthe DIT (INV-V) as regards the transactions entered into by the assessee-\ncompany with number of concerns which had made accommodation entries and\nthey were not genuine transactions. As we perceive, it is n…

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

In the result, the appeal is dismissed

ITA 2892/MUM/2023[2016-17]Status: DisposedITAT Mumbai30 Sept 2024AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2016-17 Dy. Commissioner Of M/S. Small Industries Income Tax Circle- Development Bank Of 3(3)(1) India Room No. 609, Sme Development Centre, Aaykar Bhavan, C-11, G- Block, Vs. M. K. Road, Bandra Kurla Complex, Churchgate, Bandra (East), Mumbai- 400020. Pan: Aabcs3480N (Appellant) (Respondent)

For Appellant: Shri Rakesh Joshi, A.RFor Respondent: Dr. Kishor Dhule- CIT D.R
Section 143(3)Section 147Section 148Section 250Section 36Section 36(1)Section 36(1)(viia)Section 36(1)(viii)

…lid is only to see whether there are reasonable grounds for the Income-tax Officer to believe and not whether the omission/ failure and the escapement of income is established. 4. It was held by the Hon'ble Delhi High court in AGR Investment Ltd. v. Addl. CIT 333 ITR 146 that "...... The words 'reason to believe' cannot mean that the 'Assessing Officer' should have finally ascertained the facts by legal evidence. They only mean that he forms a belief from the examination he makes and if he likes, from any information he receives. If he discovers or finds or M/s. Small Industries Development Bank Of India.; A. Y.2…

SHAH CONSTRUCTION COMPANY LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), MUMBAI

Appeal is allowed

ITA 859/MUM/2023[2008-09]Status: DisposedITAT Mumbai22 Apr 2024AY 2008-09

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri M. SubramanianFor Respondent: Dr. Kishor Dhule
Section 143(1)Section 143(3)Section 147Section 148Section 234BSection 36(1)(iii)

…IN THE INCOME TAX APPELLATE TRIBUNAL "G" BENCH, MUMBAI SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER Shah Construction Company Ltd., 11, Shah Industrial Estate, Opp. Anna Temple, New Link Road, Andheri (West)- Mumbai - 400053 [PAN: AAACS5207N] …………… Appellant Deputy Commissioner of Income Tax, Vs Central Circle 1(3), Mumbai, Income Tax Offices, Central Circle 1(3), Room No. 905 (9th Floor), Pratishtha Bhavan, Old CGO Annexe, ……………. Respondent M.K. Road, Mumbai - 400020 Appearance For the Appellant/Assessee : Shri M. Subramanian For the Respondent/Department : Dr. Kishor Dhule Date Co…

SNR ELECTRONICS LTD,NEW DELHI vs. ITO WARD - 24(1), NEW DELHI

In the result, the appeal of the assessee is dismissed

ITA 937/DEL/2020[2009-10]Status: DisposedITAT Delhi28 Feb 2024AY 2009-10

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: NoneFor Respondent: Ms. Deepti Chandola, Sr. DR
Section 143Section 147Section 148Section 151Section 292CSection 68Section 69C

…sessment in the case of appellant. Whether information received from Investigation Wing can be a basis for reopening the assessment proceedings or not, has been answered by Hon'ble jurisdictional High Court in the case AGR Investment Ltd. vs. Addl. CIT & Anr. 333 ITR 146, wherein on the similar facts, it was held that the specific information received from the office of the Directorate of Investigation as regards the transactions entered into by the assessee with a number of concerns which had made accommodation entries and they were not genuine transactions, was neither a change of opinion nor did it convey a pa…

SOCIETY FOR WELFARE AWARENESS RESEARCH AND GUIDANCE,DELHI vs. ITO (EXEMPTIONS), WARD 2(2), NEW DELHI

In the result, appeal of the assessee is allowed

ITA 4702/DEL/2019[2011-12]Status: DisposedITAT Delhi27 Apr 2022AY 2011-12

Bench: Shri R. K. Panda[Assessment Year: 2011-12]

Section 12ASection 133ASection 143(2)Section 147Section 148Section 68

…ssing Officer in discharge of official duties is information of notice under section 148. Notice under section 148 on the basis of letter issued from Investigation Wing has been held to be valid in the case of AGR Investigation Ltd. Vs. Additional CIT & Anr: [333 ITR 146 (Del)]. In the case under consideration this is more so since no return of income had been filed by the mandate for institutions claim'ng exemption under section 11 to file return of income. 4.3.3 In the case under consideration, the statement recorded during the survey operation under section 133A was used as information for reopening the case…

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