“live link”

Amit Kumar Bajaj, Mumbai vs. DCIT-24(1), Mumbai

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokaramit Kumar Bajaj Dcit-24(1), A-3001, Omkar, Off Dr. Piramal Chambers, Annie Besant Road, Near Vs. Lalbaug, Mumbai- Neelam Centre, Hanuman 400 012 Nagar, Worli, Maharashtra – 400 030 Pan/Gir No. Afrpb3442B (Applicant) (Respondent) Assessee By Shri Ravi Ganatra, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 29.01.2026

received sale consideration through banking channels, the addition made under section 68 was not sustainable in the absence of any direct evidence establishing a live link between the assessee and the alleged entry operators or exit providers. The learned AR emphasised that the co-ordinate Bench categorically held that mere ... high gains. 31. Thus, the entire edifice of the addition rests on suspicion, general investigation reports and assumptions about market behaviour, without establishing any live link between the assessee and the alleged accommodation entry mechanism. 32. The above view is fortified by the consistent judicial position laid down in similar

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

available, in the Officer recorded detailed reasons pointing out the material available, in the form of report from the Investigation Wing which had a live link with form of report from the Investigation Wing which had a live link with form of report from the Investigation Wing which ... live link with formation of belief formation of belief that the income chargeable to tax had escaped that the income chargeable to tax had escaped assessment. At this stage, as is often repeated, I assessment. At this stage, as is often repeated, I would not go into would

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan()

fallacious. The Assessing Officer recorded detailed reasons pointing out the material available, in the form of report from the Investigation Wing which had a live link with formation of belief that the income chargeable to tax had escaped assessment. At this stage, as is often repeated, I would ... share application money received by the assessee during the year under consideration. What is required is the existence of tangible material having a live link with the formation of belief that income has escaped assessment. 7.5 According to Id counsel for the assessee, recording of reasons to believe that income

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan()

fallacious. The Assessing Officer recorded detailed reasons pointing out the material available, in the form of report from the Investigation Wing which had a live link with formation of belief that the income chargeable to tax had escaped assessment. At this stage, as is often repeated, I would

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan()

fallacious. The Assessing Officer recorded detailed reasons pointing out the material available, in the form of report from the Investigation Wing which had a live link with formation of belief that the income chargeable to tax had escaped assessment. At this stage, as is often repeated, I would

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

available, in the Officer recorded detailed reasons pointing out the material available, in the form of report from the Investigation Wing which had a live link with form of report from the Investigation Wing which had a live link with form of report from the Investigation Wing which ... live link with formation of belief formation of belief that the income chargeable to tax had escaped that the income chargeable to tax had escaped assessment. At this stage, as is often repeated, I assessment. At this stage, as is often repeated, I would not go into would