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“investigation wing”

ReassessmentSection 147Section 14712,584 judgments

The decision most relied on for investigation wing is PCIT v. RMG Polyvinyl (I) Ltd. (396 ITR 5), cited in 272 judgments on BharatTax.

Leading authorities on investigation wing

PCIT v. RMG Polyvinyl (I) Ltd.
396 ITR 5 · 2017 · High Court
272
citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

109 TTJ 700 (Del) SMC Share Brokers Ltd. v. DCIT
293 ITR 43 · 2007 · High Court
264
citing judgments

Where an assessment order is merely a copy-paste of observations from an investigation wing's appraisal report without independent verification, it is not a valid basis for making additions to income.

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.

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.

Judgments citing investigation wing

Income Tax Officer, Ward-1, Jalna vs. Omprakash Asaram Mantri, Jalna

In the result, all the appeals filed by the Revenue are dismissed

ITA 141/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

shares of M/s. Nivyah Infrastructure & Telecom Services Ltd. The learned AO has formed the said opinion on the basis of information received from Investigation Wing communicating that M/s. Nivyah Infrastructure & Telecom Services Ltd. is a penny stock listed on the Bombay Stock Exchange and appellant is one of the beneficiary ... reasons, information was received from the Investigation Wing regarding the share of M/s. Nivyah Infrastructure & Telecom Services Ltd. However, it is submitted that the appellant has not dealt with shares of M/s. Nivyah Infrastructure & Telecom Services Ltd. In fact appellant has sold shares of M/s. S. V. Electricals Ltd. during

Income Tax Officer, Ward-1, Jalna vs. Omprakash Asaram Mantri, Jalna

In the result, all the appeals filed by the Revenue are dismissed

ITA 140/PUN/2024[2011]Status: DisposedITAT Pune17 Jul 2025

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

shares of M/s. Nivyah Infrastructure & Telecom Services Ltd. The learned AO has formed the said opinion on the basis of information received from Investigation Wing communicating that M/s. Nivyah Infrastructure & Telecom Services Ltd. is a penny stock listed on the Bombay Stock Exchange and appellant is one of the beneficiary ... reasons, information was received from the Investigation Wing regarding the share of M/s. Nivyah Infrastructure & Telecom Services Ltd. However, it is submitted that the appellant has not dealt with shares of M/s. Nivyah Infrastructure & Telecom Services Ltd. In fact appellant has sold shares of M/s. S. V. Electricals Ltd. during

Dy. Commissioner of Income Tax (International Taxation), Jaipur, Highcourt Circle vs. Late Vandana Agarwal Through Legal Heir Sh. Nishit Agarwal, Jaipur

In the result the appeal of the revenue is allowed for statistical

ITA 1237/JPR/2024[2017-18]Status: DisposedITAT Jaipur16 Jul 2025AY 2017-18
For Appellant: Sh. Ashish Sharma, Adv. &For Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)

that the deposit of cash was out of withdrawal made. It was also contended by the assessee that the issue was raised by the investigation wing and there also the assessee contended that the deposit of cash was out of earlier withdrawal made by the assessee. The assessee in support ... bank account was required to be opened in IDBI Bank, the appellant has stated that extensive queries were made by the Investigation Wing about the nature/ source of their deposits and a detailed reply along with all the necessary documents was duly filed before the DDIT(Investigation). A copy

Income Tax Officer, Delhi vs. Akash Deep Sethi, Delhi

In the result, the appeal filed by the Revenue is dismissed and at the same time, the cross objections filed by the assessee are also dismissed

ITA 4973/DEL/2024[2021-22]Status: DisposedITAT Delhi16 Jul 2025AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri S. Rifaur Rahmanincome Tax Officer, Vs. Akash Deep Sethi, Delhi. B-236, Derawal Nagar, Model Town, Delhi – 110 009. (Pan : Abyps8933P) Co No.26/Del/2025 (In Ita No.4973/Del/2024) (Assessment Year: 2021-22) Akash Deep Sethi, Vs. Income Tax Officer, B-236, Derawal Nagar, Delhi. Model Town, Delhi – 110 009. (Pan : Abyps8933P) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate Shri Aman Garg, Ca Ms. Kirti, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 27.05.2025 Date Of Order : 16.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133(6)Section 139Section 142(1)Section 143(2)Section 143(3)Section 44A

hawala bills. • BELMARKS METAL WORKS, C/O SARKAR & ASSOCIATES VERSUS ITO, WARD-32 (2), NEW DELHI In this case also, information was received from the Investigation Wing which was based on information forwarded by Maharashtra VAT Department that the assessee has availed Hawala entry of bogus bill purchases in the financial

Sulphur Securities Private Limited, Faridabad vs. ITO Ward-24(3), New Delhi

Appeal is dismissed

ITA 1210/DEL/2023[2012-13]Status: DisposedITAT Delhi16 Jul 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2012-13 Vs. Income Tax Officer, Sulphur Securities Pvt. Ltd., 3198/15, 4Th Floor, Gali No.1, Ward-24(3), Sangatrashan, Paharganj, New Delhi New Delhi Pan: Aaqcs9353M (Appellant) (Respondent) Assessee By None Department By Sh. Mahesh Kumar, Cit(Dr)

Section 139Section 143(3)Section 147Section 148Section 151Section 68

case records, more particularly, the assessment order dated 27.12.2019 indicates that the learned Assessing Officer had received relevant information from the department’s Investigation Wing that it had unearthed a web of dummy companies floated, controlled and managed by one Mr. Jain and provided accommodation entries to various parties including

Bsas Infortech Limited, Surat vs. Assistant Commissioner of Income Tax, Circle - 1(1)(1), Surat

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

ITA 226/SRT/2024[2016-17]Status: DisposedITAT Surat15 Jul 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri P M Jagasheth, CAFor Respondent: Shri Ajay Uke, Sr. DR
Section 147Section 148Section 68Section 69

declaring total income of Rs. 2,25,570/-. The case of the assessee was reopened on the basis of information received from Investigation Wing, Mumbai after obtaining necessary approval under Section 148 of the Act. During the course of re-assessment proceedings, the Assessing Officer noted that on perusal ... Vanguard Jewels Pvt. Ltd. during the impugned year under consideration. The Assessing Officer noted that he was in possession of information received from Investigation Wing, Mumbai in which search and seizure action under Section 132 of the Act was carried out in the case of Shri Pravin Kumar Jain

Bsas Infotech Limited, Surat vs. Dy. Commissioner of Income Tax, Circle - 1(1)(1), Surat

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

ITA 225/SRT/2024[2015-16]Status: DisposedITAT Surat15 Jul 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri P M Jagasheth, CAFor Respondent: Shri Ajay Uke, Sr. DR
Section 147Section 148Section 68Section 69

declaring total income of Rs. 2,25,570/-. The case of the assessee was reopened on the basis of information received from Investigation Wing, Mumbai after obtaining necessary approval under Section 148 of the Act. During the course of re-assessment proceedings, the Assessing Officer noted that on perusal ... Vanguard Jewels Pvt. Ltd. during the impugned year under consideration. The Assessing Officer noted that he was in possession of information received from Investigation Wing, Mumbai in which search and seizure action under Section 132 of the Act was carried out in the case of Shri Pravin Kumar Jain

Bsas Infotech Limited, Surat vs. Dy. Commissioner of Income Tax, Circle -1(1)(1), Surat

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

ITA 224/SRT/2024[2011-12]Status: DisposedITAT Surat15 Jul 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri P M Jagasheth, CAFor Respondent: Shri Ajay Uke, Sr. DR
Section 147Section 148Section 68Section 69

declaring total income of Rs. 2,25,570/-. The case of the assessee was reopened on the basis of information received from Investigation Wing, Mumbai after obtaining necessary approval under Section 148 of the Act. During the course of re-assessment proceedings, the Assessing Officer noted that on perusal ... Vanguard Jewels Pvt. Ltd. during the impugned year under consideration. The Assessing Officer noted that he was in possession of information received from Investigation Wing, Mumbai in which search and seizure action under Section 132 of the Act was carried out in the case of Shri Pravin Kumar Jain

Jaiprakash Yadav, Alwar vs. Income Tax Officer, WD, Behror

In the result, the appeal of the assessee is allowed

ITA 18/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Pranav Yadav, Adv. (Thr.VC)For Respondent: Shri Gaurav Awasthi, JCIT, Sr. DR
Section 147Section 148Section 151Section 56(2)(vii)Section 69Section 69A

SFIL Stock Broking Ltd. (2010) 325 ITR 285 (Del), reassessment proceedings were initiated on the basis of information received from investigation wing regarding alleged accommodation entries. It has been held by jurisdictional Delhi High Court that mere information received from DDIT(Inv) cannot constitute valid reasons for initiating reassessment proceedings ... case of Signature Hotels Pvt. Ltd. Vs ITO 338 ITR 51 (Del) notice u/s 148 issued based upon the report from investigation wing has been held to be invalid where the notice was issued by the A.O. without examining evidence. The head note of the judgement read as under :- Reassessment

Manish Ranjan, DCIT, Central Circle-1(2), Ahmedabad vs. Rashmin Kantilal Vakta, Ahmedabad

ITA 866/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2014-15

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri S.N. Divetia, AR and Shri Samir Vora, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 143(1)Section 143(3)Section 147Section 148Section 153CSection 68

attained finality. Subsequently, the case was reopened under section 147 for both years on the basis of specific information received from the Investigation Wing regarding large cash deposits in the assessee’s account with Shri Renuka Mata Multi-State Urban Co-operative Credit Society Ltd. The AO recorded reasons

Manish Ranjan, DCIT, Central Circle-1(2), Ahmedabad, Aaykar Bhawan Ashram Road vs. Rashmin Kantilal Vakta, Ellisbridge Ahmedabad Gujarat

ITA 865/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2013-14

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri S.N. Divetia, AR and Shri Samir Vora, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 143(1)Section 143(3)Section 147Section 148Section 153CSection 68

attained finality. Subsequently, the case was reopened under section 147 for both years on the basis of specific information received from the Investigation Wing regarding large cash deposits in the assessee’s account with Shri Renuka Mata Multi-State Urban Co-operative Credit Society Ltd. The AO recorded reasons

Rashmin Kantilal Vakta, Ahmedabad vs. The DCIT, Central Circle-1(2), Ahmedabad

ITA 830/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2014-15

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri S.N. Divetia, AR and Shri Samir Vora, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 143(1)Section 143(3)Section 147Section 148Section 153CSection 68

attained finality. Subsequently, the case was reopened under section 147 for both years on the basis of specific information received from the Investigation Wing regarding large cash deposits in the assessee’s account with Shri Renuka Mata Multi-State Urban Co-operative Credit Society Ltd. The AO recorded reasons

Rashmin Kantilal Vakta, Ahmedabad vs. The DCIT, Central Circle-1(2), Ahmedabad

ITA 829/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2013-14

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri S.N. Divetia, AR and Shri Samir Vora, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 143(1)Section 143(3)Section 147Section 148Section 153CSection 68

attained finality. Subsequently, the case was reopened under section 147 for both years on the basis of specific information received from the Investigation Wing regarding large cash deposits in the assessee’s account with Shri Renuka Mata Multi-State Urban Co-operative Credit Society Ltd. The AO recorded reasons

Sajal Impex Pvt. Ltd., Kolkata vs. ITO, Ward 12(1), Kolkata

The appeal of the assessee is allowed

ITA 265/KOL/2025[2012-13]Status: DisposedITAT Kolkata15 Jul 2025AY 2012-13

Bench: Shri Duvvuru Rl Reddy & Shri Rakesh Mishraay 2012-13 Income Tax Officer, Sajal Impex Pvt. Ltd. Ward 12(1), 4, Synagogue Street, Vs. Aaykar Bhawan, Kolkata-700001, West Bengal P-7, Chowringhee Square, (Pan: Aahcs5794D) Kolkata-700069, West Bengal (Appellant) (Respondent) Present For: Appellant By : Shri Miraz D Shah, Ar Respondent By : Shri S.B. Chakraborty, Dr Date Of Hearing : 17.06.2025 Date Of Pronouncement : 15.07.2025 O R D E R Per Rakesh Mishra: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi (Hereinafter Referred To As “The Ld. Cit(A)”) Passed U/S. 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For Ay 2012-13 Dated 28.11.2024. 02. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Un- Der:

For Appellant: Shri Miraz D Shah, ARFor Respondent: Shri S.B. Chakraborty, DR
Section 133(6)Section 139(1)Section 142(1)Section 147Section 148Section 250Section 68

income u/s 139(1) of the Act on 29.09.2012, declaring total income of ₹12,240/-. Thereafter, the Ld. AO received information from the Investigation Wing that the assessee is a beneficiary of accommodation entries and accordingly, the assess- ment of the assessee was reopened ... Divyadrishti Merchants Private Ltd is a mere paper/shell company, having no real business. It was argued before the Ld. CIT(A) that the Investigation Wing failed to establish the correlation and linkage between the amount received against the supply of materials and the pri- mary facts upon which the conclusions

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalaore

ITA 372/BANG/2024[2018-19]Status: DisposedITAT Bangalore15 Jul 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

that date onwards, the said company is operating its business from the said 7th floor. In that circumstances, the Principal Director of Income Tax, Investigation Wing, Bangalore had issued a warrant of authorisation in Form No. 45 to search the premises of Shri V.G. Siddhartha, M/s. Coffee Day Enterprises

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

ITA 371/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Jul 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

that date onwards, the said company is operating its business from the said 7th floor. In that circumstances, the Principal Director of Income Tax, Investigation Wing, Bangalore had issued a warrant of authorisation in Form No. 45 to search the premises of Shri V.G. Siddhartha, M/s. Coffee Day Enterprises

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 370/BANG/2024[2016-17]Status: DisposedITAT Bangalore15 Jul 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

that date onwards, the said company is operating its business from the said 7th floor. In that circumstances, the Principal Director of Income Tax, Investigation Wing, Bangalore had issued a warrant of authorisation in Form No. 45 to search the premises of Shri V.G. Siddhartha, M/s. Coffee Day Enterprises

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

ITA 369/BANG/2024[2015-16]Status: DisposedITAT Bangalore15 Jul 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

that date onwards, the said company is operating its business from the said 7th floor. In that circumstances, the Principal Director of Income Tax, Investigation Wing, Bangalore had issued a warrant of authorisation in Form No. 45 to search the premises of Shri V.G. Siddhartha, M/s. Coffee Day Enterprises

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 368/BANG/2024[2014-15]Status: DisposedITAT Bangalore15 Jul 2025AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

that date onwards, the said company is operating its business from the said 7th floor. In that circumstances, the Principal Director of Income Tax, Investigation Wing, Bangalore had issued a warrant of authorisation in Form No. 45 to search the premises of Shri V.G. Siddhartha, M/s. Coffee Day Enterprises

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 367/BANG/2024[2013-14]Status: DisposedITAT Bangalore15 Jul 2025AY 2013-14

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

that date onwards, the said company is operating its business from the said 7th floor. In that circumstances, the Principal Director of Income Tax, Investigation Wing, Bangalore had issued a warrant of authorisation in Form No. 45 to search the premises of Shri V.G. Siddhartha, M/s. Coffee Day Enterprises