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“investigation wing”

ReassessmentSection 147Section 14712,584 judgments

The decision most relied on for investigation wing is Sarthak Securities Co. Pvt. Ltd. v. ITO (329 ITR 110), cited in 217 judgments on BharatTax.

Leading authorities on investigation wing

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

ITO, 19(3) (4) Mumbai v. Shamim M Bharwani
69 Taxmann.com 65 · 2016 · Reported
142
citing judgments

Long Term Capital Gains (LTCG) from penny stock transactions are liable to be treated as bogus and added back under Section 68 as unexplained cash credits, especially when evidence suggests the involvement of entry operators providing accommodation entries.

1. Harikishan S. Virmani v. DCIT
394 ITR 146 · 2017 · High Court
97
citing judgments

Reassessment proceedings under section 147 cannot be initiated by the Assessing Officer based on borrowed satisfaction, vague information from the Investigation Wing, or incorrect jurisdictional facts without independent application of mind. Reopening beyond four years from the end of the relevant assessment year, especially where an original assessment was completed under section 143(3), requires specific conditions relating to the assessee's failure to disclose material facts.

PCIT v. M/s. Kesoram Industries 57
417 ITR 334 · 2019 · High Court
96
citing judgments

An assessment completed under Section 143(3) cannot be reopened after four years solely based on third-party information or opinions, such as from an Investigation Wing, without the Assessing Officer applying their own independent mind to the material and having new, independent material on record.

ITO v. Purushottam Das Bangur
224 ITR 362 · 1997 · Supreme Court
90
citing judgments

Information received from the investigation wing constitutes valid 'reason to believe' for initiating reassessment proceedings under Sections 147/148, provided the Assessing Officer applies their mind to the material and does not act mechanically. Prompt issuance of a notice based on such information does not automatically imply a lack of due diligence or borrowed satisfaction.

AGR Investment v. Additional Commissioner
197 Taxmann 177 · 2011 · High Court
81
citing judgments

A reassessment under Section 147/148 is valid if initiated based on specific, non-vague information, even from an investigation wing, provided the Assessing Officer applies independent mind to form a 'reason to believe' that income has escaped assessment.

56 (Guj.) (para 6) v. Aaspas Multimedia Ltd. v. Dy. CIT
83 Taxmann.com 82 · 2017 · High Court
78
citing judgments

Information received from the Investigation Wing, identifying the assessee as a beneficiary of accommodation entries through share application from a third party, constitutes valid tangible material and 'reasons to believe' for initiating reassessment proceedings under Section 147 of the Income Tax Act.

Aradhna Estate Pvt. Ltd. v. DCIT
91 Taxmann.com 119 · 2018 · High Court
56
citing judgments

The Assessing Officer is justified in reopening assessment proceedings based on information received from the Investigation Wing, even when recording findings also rely on documents already on record, provided all procedural requirements for reassessment are met.

Judgments citing investigation wing

ITO 19.3.1, MUMBAI, MUMBAI vs. SOURABH NAVALKISHOR GARG, MUMBAI

In the result the appeals filed by the revenue for both years under consideration stands dismissed

ITA 5804/MUM/2025[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 37Section 68Section 74

appreciated the fact action of the AO was based on information/report received from the Maharashtra VAT Department through DGIT (Investigation Wing), Mumbai that these groups, all are hawala traders who were indulged in the practice of providing accommodation entries of issuing bogus Sales/Purchase bill without supplying any goods ... appreciated the fact action of the AO was based on information/report received from the Maharashtra VAT Department through DGIT (Investigation Wing), Mumbai that these groups, all are hawala traders who were indulged in the practice of providing accommodation entries of issuing bogus Sales/Purchase bill without supplying any goods

DARBARI INDUSTRIES,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX - 41(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed on legal ground, and the reassessment order is quashed

ITA 205/MUM/2026[2019-20]Status: DisposedITAT Mumbai21 Apr 2026AY 2019-20

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokardarbari Industries Acit - 41(1)(1) 110, Champaklal 8Th Floor, Kautilya Udyog Bhavan, Sion Vs. Bhavan, C-41-43, Koliwada Road, Sion Avenue 3, Near Videsh (West), Mumbai – Bhavan, G-Block, Bkc, 400 022. Bandra Kurla Complex, Bandra East, Mumbai- 400 051 Pan/Gir No. Aaafd3277E (Applicant) (Respondent) Assessee By Shri Bhupendra Shah, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 16.04.2026 Date Of Pronouncement 21.04.2026

Section 115BSection 139(1)Section 142(1)Section 144BSection 147Section 148Section 148ASection 250Section 270ASection 68

principles of natural justice. 4. The Assessing Officer, however, was not convinced with the explanation of the assessee. Relying upon the information received from investigation wing and statements recorded during search proceedings, it was held that the entities from whom loans were obtained were engaged in providing accommodation entries

RAJDHANI TEXTILES PRIVATE LIMITED ,MUMBAI vs. ACIT, CIRCLE 5(1)(2), MUMBAI

In the result, both the appeals of the assessee are allowed

ITA 8902/MUM/2025[2012-13]Status: DisposedITAT Mumbai21 Apr 2026AY 2012-13
Section 143(3)Section 147Section 68

Gumanmal Lodha and M/s Dhawalgiri Properties Pvt. Ltd. could be treated as unexplained cash credits merely on the strength of information received from the Investigation Wing, Ahmedabad and on certain inferences drawn by the Assessing Officer from the balance sheets of the said parties, despite the assessee having placed ... materials in support of the loans. 3. The brief facts are that the assessments were reopened on the basis of information received from the Investigation Wing, Ahmedabad alleging doubtful creditworthiness of Shri Mahendra Gumanmal Lodha, who is one of the directors of the assessee company, and of M/s Dhawalgiri Properties

RAJDHANI TEXTILES PRIVATE LIMITED (SINCE DISHA INFIN CONSULTANTS PVT LTD) ,MUMBAI vs. ASST.CIT CIRCLE 5(1)(2), MUMBAI

In the result, both the appeals of the assessee are allowed

ITA 7362/MUM/2025[2013-14]Status: DisposedITAT Mumbai21 Apr 2026AY 2013-14
Section 143(3)Section 147Section 68

Gumanmal Lodha and M/s Dhawalgiri Properties Pvt. Ltd. could be treated as unexplained cash credits merely on the strength of information received from the Investigation Wing, Ahmedabad and on certain inferences drawn by the Assessing Officer from the balance sheets of the said parties, despite the assessee having placed ... materials in support of the loans. 3. The brief facts are that the assessments were reopened on the basis of information received from the Investigation Wing, Ahmedabad alleging doubtful creditworthiness of Shri Mahendra Gumanmal Lodha, who is one of the directors of the assessee company, and of M/s Dhawalgiri Properties

ITO 19.3.1, MUMBAI vs. SOURABH NAVALKISHOR GARG, MUMBAI

In the result the appeals filed by the revenue for both years under consideration stands dismissed

ITA 5803/MUM/2025[2009-10]Status: DisposedITAT Mumbai21 Apr 2026AY 2009-10

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 37Section 68Section 74

appreciated the fact action of the AO was based on information/report received from the Maharashtra VAT Department through DGIT (Investigation Wing), Mumbai that these groups, all are hawala traders who were indulged in the practice of providing accommodation entries of issuing bogus Sales/Purchase bill without supplying any goods ... appreciated the fact action of the AO was based on information/report received from the Maharashtra VAT Department through DGIT (Investigation Wing), Mumbai that these groups, all are hawala traders who were indulged in the practice of providing accommodation entries of issuing bogus Sales/Purchase bill without supplying any goods

SHRI SANDIP HARKISHAN MARWADI,RAJKOT vs. THE ACIT, CIRCLE-1,, RAJKOT

In the result, the appeal of the assessee is allowed

ITA 164/RJT/2023[2009-10]Status: DisposedITAT Rajkot17 Apr 2026AY 2009-10

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 164/Rjt/2023 "नधा"रणवष" / Assessment Year: (2009-10) (Hybrid Hearing) Sandip Harkishan Marwadi Vs. Assistant Commissioner Of C/O. Sarda & Sarda, Cas, Income Tax, Circle - 2(1), 1St Floor, "Sakar", Income Tax Office, Racecourse Dr. Radhakrishnan Road, Road, Sadar, Rajkot - 360001. Opp. Rajkumar College, Gujarat Rajkot-360001,(Gujarat) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adbpm1302R (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 26 / 03 /2026 Date Of Pronouncement : 17/ 04 /2026

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. SR. DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 148Section 250

materials brought on record. We note that assessing officer reopened the case of the assessee merely on the basis of information received from the Investigation Wing, which does not pertain to the assessee, but pertain to other brokers/persons. The information mentioned in the reasons recorded, does not pertain

PREETI GUPTA, HYDERABAD vs. DCIT., CIRCLE - 9(1), I.T. TOWERS, HYDERABAD.

In the result, the appeal of the assessee in ITA No

ITA 1175/HYD/2025[2014-15]Status: DisposedITAT Hyderabad17 Apr 2026AY 2014-15

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1174 & 1175/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15) Smt. Preeti Gupta Vs. Dy. Cit Hyderabad Circle 9(1) Pan: Abmpm7172Q Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri Madhukar Aves, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/04/2026 घोषणा की तारीख/Pronouncement: 17/04/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Shri Madhukar Aves, Sr. AR
Section 111ASection 144BSection 147Section 148Section 151ASection 69A

gain of Rs.10,43,677/- under section 111A of the Income Tax Act, 1961 (“the Act”). Subsequently, 4 based on information received from the Investigation Wing, Hyderabad, that M/s. Vandana Knitwear Limited was a penny stock company and that the assessee was one of the beneficiaries, the Learned Assessing Officer ... under section 69A of the Act. It was submitted that the addition has been made merely on the basis of information received from the Investigation Wing, Hyderabad, without any independent enquiry by the Ld. AO and is based on mere suspicion and presumption. The Ld. AR further submitted that

PREETI GUPTA,HYDERABAD vs. DCIT., CIRCLE - 9(1), I.T. TOWERS, HYDERABAD.

In the result, the appeal of the assessee in ITA No

ITA 1174/HYD/2025[2013-14]Status: DisposedITAT Hyderabad17 Apr 2026AY 2013-14

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1174 & 1175/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15) Smt. Preeti Gupta Vs. Dy. Cit Hyderabad Circle 9(1) Pan: Abmpm7172Q Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri Madhukar Aves, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/04/2026 घोषणा की तारीख/Pronouncement: 17/04/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Shri Madhukar Aves, Sr. AR
Section 111ASection 144BSection 147Section 148Section 151ASection 69A

gain of Rs.10,43,677/- under section 111A of the Income Tax Act, 1961 (“the Act”). Subsequently, 4 based on information received from the Investigation Wing, Hyderabad, that M/s. Vandana Knitwear Limited was a penny stock company and that the assessee was one of the beneficiaries, the Learned Assessing Officer ... under section 69A of the Act. It was submitted that the addition has been made merely on the basis of information received from the Investigation Wing, Hyderabad, without any independent enquiry by the Ld. AO and is based on mere suspicion and presumption. The Ld. AR further submitted that

SNEHALATHA SINGHI ,BANGALORE vs. DCIT, CIRCLE-1(1)(2), BANGALORE

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

ITA 1175/BANG/2025[2012-13]Status: DisposedITAT Bangalore17 Apr 2026AY 2012-13

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2012-13

For Respondent: Shri K R Pradeep, Advocate &
Section 143(3)Section 147Section 148Section 234ASection 68Section 69C

form of bogus LTCG. The AO had also relied on the findings of the Investigation Directorate of Kolkata and Mumbai in which the Investigation Wing of the Directorate had elaborately conducted the investigation and also statements of the Director during the course of survey proceedings u/s. 133A was recorded

INCOME TAX OFFICER, WARD-5(1),KOLKATA, KOLKATA vs. M/S. FAITHFUL TRADERS PRIVATE LIMITED, KOLKATA

In the result, the appeal filed by the Revenue is dismissed

ITA 2177/KOL/2024[2012-13]Status: DisposedITAT Kolkata17 Apr 2026AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 148Section 250

return of income on 26.03.2013 declaring the total income of ₹1,150/- for the AY 2012-13. An information was received from the Investigation wing, Kolkata that the assessee company was beneficiary of ₹36,50,000/- by way of raising bogus loss through layering of funds through accounts of other

SURESHBHAI VASHRAMBHAI KHUNT,SURAT vs. INCOME TAX OFFICER, WARD 2(3)(4) , AAYAKAR BHAVAN

In the result, the appeal of the assessee for A

ITA 659/SRT/2024[2010-11]Status: DisposedITAT Rajkot15 Apr 2026AY 2010-11

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Mukesh Jain, CIT.DRFor Respondent: Shri Rasesh Shah, AR
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 69A

brief facts of the case are that the assessee is an individual. As per the information received from the Investigation Wing, it was noticed that the assessee was maintaining a bank account with IDBI Bank, Surat Branch since July 2009, which was subsequently closed. The said account was triggered

SURESHBHAI VASHRAMBHAI KHUNT,SURAT vs. INCOME TAX OFFICER, WARD 2(3)(4), AAYAKAR BHAVAN

In the result, the appeal of the assessee for A

ITA 658/SRT/2024[2009-10]Status: DisposedITAT Rajkot15 Apr 2026AY 2009-10

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Mukesh Jain, CIT.DRFor Respondent: Shri Rasesh Shah, AR
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 69A

brief facts of the case are that the assessee is an individual. As per the information received from the Investigation Wing, it was noticed that the assessee was maintaining a bank account with IDBI Bank, Surat Branch since July 2009, which was subsequently closed. The said account was triggered

INCOMETAX OFFICER WARD-2 3 4, SURAT vs. SURESHBHAI VASHRAMBHAI KHUNT, SURAT

In the result, the appeal of the assessee for A

ITA 379/SRT/2024[2009-10]Status: DisposedITAT Rajkot15 Apr 2026AY 2009-10

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Mukesh Jain, CIT.DRFor Respondent: Shri Rasesh Shah, AR
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 69A

brief facts of the case are that the assessee is an individual. As per the information received from the Investigation Wing, it was noticed that the assessee was maintaining a bank account with IDBI Bank, Surat Branch since July 2009, which was subsequently closed. The said account was triggered

SURESHBHAI VASHRAMBHAI KHUNT,SURAT vs. INCOME TAX OFFICER, WARD 2(3)(4) , AAYAKAR BHAVAN

In the result, the appeal of the assessee for A

ITA 659/SRT/2024[2010-11]Status: DisposedITAT Surat15 Apr 2026AY 2010-11

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Mukesh Jain, CIT.DRFor Respondent: Shri Rasesh Shah, AR
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 69A

brief facts of the case are that the assessee is an individual. As per the information received from the Investigation Wing, it was noticed that the assessee was maintaining a bank account with IDBI Bank, Surat Branch since July 2009, which was subsequently closed. The said account was triggered

SURESHBHAI VASHRAMBHAI KHUNT,SURAT vs. INCOME TAX OFFICER, WARD 2(3)(4), AAYAKAR BHAVAN

In the result, the appeal of the assessee for A

ITA 658/SRT/2024[2009-10]Status: DisposedITAT Surat15 Apr 2026AY 2009-10

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Mukesh Jain, CIT.DRFor Respondent: Shri Rasesh Shah, AR
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 69A

brief facts of the case are that the assessee is an individual. As per the information received from the Investigation Wing, it was noticed that the assessee was maintaining a bank account with IDBI Bank, Surat Branch since July 2009, which was subsequently closed. The said account was triggered

INCOMETAX OFFICER WARD-2 3 4, SURAT vs. SURESHBHAI VASHRAMBHAI KHUNT, SURAT

In the result, the appeal of the assessee for A

ITA 379/SRT/2024[2009-10]Status: DisposedITAT Surat15 Apr 2026AY 2009-10

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Mukesh Jain, CIT.DRFor Respondent: Shri Rasesh Shah, AR
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 69A

brief facts of the case are that the assessee is an individual. As per the information received from the Investigation Wing, it was noticed that the assessee was maintaining a bank account with IDBI Bank, Surat Branch since July 2009, which was subsequently closed. The said account was triggered

NARESH KUMAR PROP. YASHODA KHAL BHANDAR,NARWANA, JIND, HARYANA vs. ITO WARD-2, JIND, JIND, HARYANA

The appeal stand allowed

ITA 875/CHANDI/2025[2011-12]Status: DisposedITAT Chandigarh15 Apr 2026AY 2011-12
For Appellant: Sh. Nikhil Goyal & Sh. Ashok Goyal (Advocates) –For Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 44A

aggregated to Rs.30,70,400/-. 5. Upon further appeal, the Ld. CIT(A) justified the roepening on the ground that information was received from investigation wing which could be held to be tangible material. On merits, the assesseestated that the RTGS receipts represent realization from debtors and income

CHIRAG HIRALAL PATEL,GANDHINAGAR vs. THE INCOME TAX OFFICER, WARD 1, GANDHINAGAR, GANDHINAGAR

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

ITA 2697/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad15 Apr 2026AY 2020-21

Bench: Ms Suchitra Kambleआयकर अपील सं./Ita No. 2697/Ahd/2025 िनधा"रण वष"/Asstt. Year: 2020-2021 Chirag Hiralal Patel, The Income Tax Officer, बनामVs. Plot No.973/2, Ward-1, Sector 2C, Gandhinagar. Gandhinagar-382002. Pan: Avwpp9239K

For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri Girish Parihar, Sr. DR
Section 132(4)Section 144BSection 144B(8)Section 148Section 151Section 69A

without bringing any corroborative material on record to establish that any on-money was actually paid by the assessee. No statement recorded by the Investigation Wing has been brought on record wherein the name of the assessee or the shop number purchased by the assessee is referred to. Further

ACIT CENTRAL CIRCLE-13, NEW DELHI vs. MINDA CAPITAL PVT LTD, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 7919/DEL/2019[2011-12]Status: DisposedITAT Delhi15 Apr 2026AY 2011-12

Bench: Shri Mahavir Singh & Before Shri Mahavir Singh & Before Shri Before Shri Mahavir Singh & Mahavir Singh & Shri Shri Manish Agarwal Shri Shri Manish Agarwal Manish Agarwalmanish Agarwal

For Appellant: Shri Salil Aggarwal, Senior Advocate with Shri Madhur Aggarwal, ShriFor Respondent: Ms. Amisha S. Gupt, Senior DR
Section 142(1)Section 143(3)Section 147Section 153CSection 68

with the present assessee Minda Capital Pvt.Ltd. vide order of Hon’ble High Court dated 2nd July, 2013. Subsequently, information was received by ADIT, Investigation Wing 2(1), Kolkata that there is huge high value credit transactions in the banik account of Bhawani Enterprises and Ekdant Agency. As per ADIT

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4, NAGPUR, NAGPUR vs. SHIKHA INDRAKUMAR AGRAWAL, NAGPUR

In the result, appeal by the assessee stands allowed

ITA 239/NAG/2023[2015]Status: DisposedITAT Nagpur10 Apr 2026

Bench: Shri Pawan Singh & Shri Khettra Mohan Roy

For Appellant: Shri K.P. Dewani, AdvocateFor Respondent: Shri Surjit Kumar Saha, Sr. DR
Section 10(38)Section 143(2)Section 143(3)Section 250Section 68Section 69C

NFAC erred in allowing the appeal of the assessee ignoring the fact that investigation on the basis of information carried out by the Kolkata Investigation Wing and Mumbai on the basis of statement of various entry provider, share brokers, exist providers had unearthed the modus operandi of investments in penny ... assessable as unexplained cash credit under section 68 of the Income-tax Act, 1961 merely on the basis of general reports of the Investigation Wing or on the theory of human probabilities. The Tribunal further held that in the absence of any direct evidence linking the assessee with alleged price