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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

Assistant Commissioner of Income, Central Circle - 4(10, Kolkata vs. Sri Balaji Minerals Private Limited, Kolkata

In the result, all the appeals of the revenue are dismissed and the cross-objections of the assessee are also dismissed being infructuous

ITA 97/KOL/2025[2017]Status: DisposedITAT Kolkata02 Jul 2025

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 139Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 68

subsequently refunded back. The AO has made addition of Rs. 15,00,000/- pertaining to M/s SSSTC u/s 68 merely relying on report of investigation wing that assessee is the beneficiary of the sum received as trade advance. It is relevant to mention that the assessee had received trade advance

Assistant Commissioner of Income Tax, Central Circle - 4(1), Kolkata vs. Sri Balaji Minerals Private Limited, Kolkata

In the result, all the appeals of the revenue are dismissed and the cross-objections of the assessee are also dismissed being infructuous

ITA 96/KOL/2025[2016]Status: DisposedITAT Kolkata02 Jul 2025

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 139Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 68

subsequently refunded back. The AO has made addition of Rs. 15,00,000/- pertaining to M/s SSSTC u/s 68 merely relying on report of investigation wing that assessee is the beneficiary of the sum received as trade advance. It is relevant to mention that the assessee had received trade advance

Assistant Commissioner of Income Tax, Central Circle - 4(1), Kolkata vs. Sri Balaji Minerals Private Limited, Kolkata

In the result, all the appeals of the revenue are dismissed and the cross-objections of the assessee are also dismissed being infructuous

ITA 95/KOL/2025[2015]Status: DisposedITAT Kolkata02 Jul 2025

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 139Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 68

subsequently refunded back. The AO has made addition of Rs. 15,00,000/- pertaining to M/s SSSTC u/s 68 merely relying on report of investigation wing that assessee is the beneficiary of the sum received as trade advance. It is relevant to mention that the assessee had received trade advance

Asstt. Commissioner of Income Tax -19(3), Mumbai vs. Sanjay Prakashmal Jain, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 2992/MUM/2025[2008-09]Status: DisposedITAT Mumbai02 Jul 2025AY 2008-09

Bench: Shri Pawan Singh

Section 133ASection 143(1)Section 147Section 254(1)Section 68

recorded wherein he admitted that his concerns were providing accommodation bills to various parties. The assessing officer on the basis of report of Investigation Wing made addition of Rs. 25,00,000/- of loan received from Basant Dia Jewels and the interest payment of Rs. 1,03,279/-, thus, aggregating ... investigation report, Basant Jain admitted that he was issuing accommodation bills. His case was solely reopened on the basis of report of Investigation Wing. The assessee stated that he availed loan through banking transaction and repaid through normal banking transaction. All the transactions are recorded on his books of account

Principal Commissioner of Income Tax Udaipur vs. Emote Wealth Private Limited

Accordingly, the appeal fails and is dismissed

ITAT/123/2025HC Calcutta01 Jul 2025

Bench: : The Hon’Ble The Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Chaitali Chatterjee (Das) Dated : 1St July, 2025 Appearance: Mr. Aryak Dutt, Adv. Mr. Soumen Bhattacharjee, Adv. Mr. Ankan Das, Adv. Ms. Shradhya Ghosh, Adv. ..For Appellant Mr. Sanjay Dixit, Adv. Mr. Rajeev Kumar Agarwal, Adv. ..For Respondent

Section 147Section 148Section 151Section 260ASection 4

under section 148 of the Income Tax Act, 1961 was duly issued by the Assessing Officer after considering/examining the information so received from the Investigation wing vis-à-vis the material available on his record forming his “reasons to 3 believe” for such re-opening of assessment under the purview

Harsh Comtrade Pvt Ltd, Surat vs. Income Tax Officer, Ward 5(4), Kolkata

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 225/KOL/2024[2012-13]Status: DisposedITAT Kolkata01 Jul 2025AY 2012-13

Bench: Shri George Mathanआयकर अपील सं/Ita No.225/Kol/2024 (नििाारण वर्ा / Assessment Year :2012-2013) Harsh Comtrade Private Limited, Vs Ito, Ward-5(4), Kolkata 1/A, Stuti Apartment, Near Ashok Panhouse, City Light, Surat, Gujarat Pan No. :Aabcg 8847 C (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Mehul Shah, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri S.B. Chakraborthy, Addl. Cit-Sr.Dr सुनवाई की तारीख / Date Of Hearing : 01/07/2025 घोषणा की तारीख/Date Of Pronouncement : 01/07/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 28.12.2023, Passed In Din & Order No.Itba/Nfac/S/250/2023-24/1059161646(1) For The Assessment Year 2012-2013. 2. Shri Mehul Shah, Ld. Ar Appeared On Behalf Of The Assessee & Shri S.B.Chakraborthy, Ld.Sr. Dr Appeared On Behalf Of The Revenue. 3. At The Time Of Hearing, Ld. Ar Submitted That He Has Filed Written Submissions Before The Tribunal Which Has Been Placed In The Paper Book At Pages 90 To 104 Which Reads As Follows :- Before Income Tax Appellate Tribunal, Kolkata - 'Smc' Bench In The Case Of Harsh Comtrade Pvt. Ltd Sub: Written Submission For A.Y. 2012-13 Ref: Assessee'S Appeal No. 225/Kol/2024 Date Of Hearing: 21.08.2024 May It Please To Your Honour 1. In This Case, The Case Is Re-Opened On The Basis Of Reasons For Reopening Recorded On 23.03.2018. The Same Is Reproduced

For Respondent: Shri S.B. Chakraborthy, Addl. CIT-Sr.DR
Section 148

reasons itself mentions that the Assessing Officer has himself documented that he has re-opened the case on the ground of "suspicion" raised by Investigation Wing and the same suspicion is relied upon by the Assessing Officer. Further, it is undisputed that after suspicion, no inquiry is made ... gone through the record. In this case, firstly, the reopening has been made merely on suspicion and solely on the basis of report of Investigation Wing by the Assessing Officer without correlating the said information with the accounts/assessment records of the assessee. As pointed out, had the Assessing Officer

Annu Anil Agrawal, Mumbai vs. Assistant Commissioner of Income-Tax, Central Circle 4(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5473/MUM/2024[2011-2012]Status: DisposedITAT Mumbai01 Jul 2025AY 2011-2012

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarआयकर अपील सुं./Ita No. 5473/Mum/2024 (नििाारण वर्ा / Assessment Year :2011-12) Annu Anil Agrawal V/S. Acit Cc 4(3), Mumbai Due C-3401/3402 Oberoi बिाम To Restructuring Current Esquire, Mohan Gokhale Jurisdiction Of Appellant Road, Off W. E. Highway, Lies With Acit 41(4)(1), Oberoi Garden City, Mumbai Goregaon East, Mumbai- Kautilya Bhawan, Bkc, 400063 Bandra (E), Mumbai- 400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Admpa0248F Appellant/अपीलार्थी Respondent/प्रनिवादी ..

For Appellant: Shri Suchek Anchaliya, Ms. RubyFor Respondent: Shri Aditya Rai
Section 10(38)Section 250Section 68Section 69

Limited. The Statement is enclosed as Exhibit II consisting of 09 pages. iii. These transactions form part of the penny stock scam unearthed by Investigation Wing of Kolkata.” 7. It is apparent that the reasons recorded by the AO for reopening of the assessment proceedings are factually incorrect, non-existing ... done these transactions in a bona fide manner, one cannot reject this submission based on surmises and conjectures. As the report of investigation wing suggests, there are many beneficiaries of LTCG. Each case has to be assessed based on principles of legal import laid down by the Courts

Suresh Chandra Sadh, New Delhi vs. Circle 4(1)(1), Aligarh

In the result, the appeal of the assessee is partly allowed

ITA 178/AGR/2024[2016-17]Status: DisposedITAT Agra30 Jun 2025AY 2016-17

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2016-17]

Section 10(38)Section 131Section 147Section 148Section 234BSection 68

dismissed the above legal ground by holding that the Assessing Officer initiated the assessment on the basis of information received from Investigation Wing and the assessee did not submit any documentary evidence to contend that the said information was unreliable or incorrect. The ld. CIT(A) also took note

Mandeep Singh S/O Sh. Narinder Singh Village and Post Office Tarmala Malout District Muktsar, Muktsar vs. The Income Tax Officer Ward 2(5) Muktsar Jao Income Tax Officer Ward 2(2) Muktsar, Muktsar

In the result appeal of the assessee is allowed

ITA 645/ASR/2024[2012-2013]Status: DisposedITAT Amritsar30 Jun 2025AY 2012-2013

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

Section 131Section 133(6)Section 147Section 148Section 151Section 250Section 282Section 69A

very much clear from the order of the Assessing Officer that the entire proceedings are based upon the information transferred from the Investigation Wing (Bathinda). There has to be independent formation of belief by the Assessing Officer and, which is not there in the present case and there being ... whole exercise I.T.A. No. 645/Asr/2024 8 Assessment Year: 2012-13 of re-opening of the case is based upon the information from the Investigation Wing and there is no application of mind by the AO. c) Reliance is being placed on the following judgments wherein it has been held that

Naresh Kumar Luhadia, Jaipur vs. DCIT Circle 7, Jaipur

In the result, the appeal of the assessee is allowed

ITA 35/JPR/2025[2010-11]Status: DisposedITAT Jaipur30 Jun 2025AY 2010-11

Bench: SHRI MANISH BORAD (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri S. L. Poddar (Adv.)For Respondent: Shri Sushil Kulhari, Addl. CIT
Section 133ASection 147Section 148

sufficient to hold the transactions to be genuine. He also submitted that ld. AO has specifically dealt with the information received from the investigation wing about the alleged bogus loss suffered by the assessee through client code modification. Naresh Kumar Luhadia vs. DCIT 8. We have heard the rival contentions ... vide order u/s 143(3) of the Act dated 15.12.2011 income assessed at Rs. 20,33,710/-. Thereafter, specifically based upon the information from investigation wing unit, Ahemedabad about some brokers allegedly admitted to have received commission for misusing of client code modification and the same having been used

Naresh Kumar Luhadia, Jaipur vs. DCIT Circle 7, Jaipur

In the result, the appeal of the assessee is allowed

ITA 34/JPR/2025[2009-10]Status: DisposedITAT Jaipur30 Jun 2025AY 2009-10

Bench: or at the time of hearing.

For Appellant: Shri S. L. Poddar (Adv.)For Respondent: Shri Sushil Kulhari, Addl. CIT
Section 133ASection 147Section 148

sufficient to hold the transactions to be genuine. He also submitted that ld. AO has specifically dealt with the information received from the investigation wing about the alleged bogus loss suffered by the assessee through client code modification. Naresh Kumar Luhadia vs. DCIT 8. We have heard the rival contentions ... vide order u/s 143(3) of the Act dated 15.12.2011 income assessed at Rs. 20,33,710/-. Thereafter, specifically based upon the information from investigation wing unit, Ahemedabad about some brokers allegedly admitted to have received commission for misusing of client code modification and the same having been used

Shanker Enterprises, Kanpur vs. DCIT-2, Kanpur

In the result, the appeal of the Assessee stands allowed for statistical purposes

ITA 221/LKW/2025[2012-13]Status: DisposedITAT Lucknow30 Jun 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2012-13 Shanker Enterprises V. The Dcit-2 Panki Industrial Area Kanpur Site-1, Kanpur Tan/Pan:Abffs2369Q (Appellant) (Respondent) Appellant By: Shri Swaran Singh, C.A. Respondent By: Shri Amit Kumar, D.R. Date Of Hearing: 09 06 2025 Date Of Pronouncement: 30 06 2025 O R D E R

For Appellant: Shri Swaran Singh, C.AFor Respondent: Shri Amit Kumar, D.R
Section 142(1)Section 143(3)Section 147Section 147oSection 153CSection 271(1)(c)

entries in the ITA No.221/LKW/2025 Page 2 of 9 form of unsecured loan as revealed in the search and seizure operation conducted by the Investigation Wing of Income Tax Department on 28.04.2015 in Rich Udyog Group of Cases. The AO observed that during the above search operation and also during

Ram Singh, District Kaithal, Haryana vs. Income Tax Officer, Ward-1, Kaithal, Income Tax Office, Ambala Road

The appeal of the assessee is dismissed

ITA 920/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh30 Jun 2025AY 2012-13

Bench: The Appeal Is Finally Heard Or Disposed Of.

For Appellant: Shri Nikhil Goyal, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 234ASection 69

that the assessee filed his return of income for AY 2012–13, which was processed u/s 143(1). Based on information received from the Investigation Wing regarding substantial cash deposits, a notice u/s 148 was issued on 25.03.2019. The reassessment was completed u/s 143(3) r.w.s. 147 on 27.12.2019 assessing ... Counsel for the assessee vehemently submitted that the reopening of the assessment was initiated merely on the basis of information received from the Investigation Wing. The reasons recorded do not reveal any independent application of mind by the AO. It is a settled law that the AO must form

M/S. Rkr Graphite Private Limited, Kolkata vs. ITO Ward 12(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 64/KOL/2025[2014-15]Status: DisposedITAT Kolkata30 Jun 2025AY 2014-15

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 148Section 148ASection 68

assessee are that the assessee filed return of income declaring total income at Rs. 24,84,990/-. Subsequently, on an information received from Investigation Wing that the assessee had taken accommodation entry in form of bogus billing amounting to Rs. 1,41,68,122/- through sham transaction with paper entities

ACIT, Central Circle-4(3), Kolkata vs. Citizen Umbrella Manufacturers Limited, Kolkata

In the result, the appeal of the revenue is dismissed and the cross-objection of the assessee is also dismissed as infructuous

ITA 306/KOL/2025[2020-21]Status: DisposedITAT Kolkata30 Jun 2025AY 2020-21

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 133ASection 139Section 142(1)Section 143(2)Section 143(3)Section 36(1)(va)Section 69A

Daga were recorded on 19.02.2020 however the said statements were immediately retracted by them on 24.02.2020 and was informed to the DDIT of the Investigation wing on 24.02.2020 itself vide affidavit filed. It is observed that against the query raised by the AO in course of the assessment proceedings

Steven Angelo Pinto, Mumbai vs. ITO Int Tax 3(3)(2), Mumbai

In the result, the addition so made is directed to be deleted

ITA 922/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2022-23 Steven Angelo Pinto, Income Tax Officer, A-11, Tahnee Heights, (International Taxation)-3(3)(2) Nepean Sea Road, Vs. Kautilya Bhavan, Mumbai-400006. Bandra Kurla Complex, Pan : Aihpp2373C Bandra (East), Mumbai-400051. (Appellant) (Respondent) Assessee By : Shri Mihir Naniwadekar (Virtually Present) Shri Ruturaj Gurjar Revenue By : Shri Krishna Kumar, J.Cit Date Of Hearing : 05-06-2025 Date Of Pronouncement : 30-06-2025

For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri Krishna Kumar, J.CIT
Section 133(6)Section 143(3)Section 144C(13)Section 270ASection 69A

placed on record have been rebutted by the AO. 14. Further, we find that the AO has merely referred to the report of the Investigation Wing and has held that since the whatsapp message was sent on 30-08-2021 which falls during the financial year relevant to the impugned ... assessment year, the amount is liable to tax for the year under consideration. We find that even in the report of the Investigation Wing, there is a reference to the whatsapp message only and no other finding has been recorded either in terms of physical cash, deposits in the bank

Pkh Ventures Limited, Mumbai, Maharashtra vs. The Deputy Commissioner Income Tax, Aaykar Bhavan, Churchgate

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 3322/MUM/2025[2012-2013]Status: DisposedITAT Mumbai30 Jun 2025AY 2012-2013

Bench: SMT. BEENA PILLAI (Judicial Member), SMT. RENU JAUHRI (Accountant Member)

For Appellant: Shri Anirudh Dave (Instructed by Shri Piyush Agarwal)For Respondent: Mr. Virabhadra S. Mahajan, Sr
Section 143(3)Section 148Section 250Section 271(1)(c)

filed its return declaring income of Rs. 99,26,090/- for AY 2012-13 on 29.09.2012. Based on the information received from the Investigation Wing, the case was reopened by issue of notice u/s 148 of the Act and assessment was completed at an income

Balram Chainrai, Mumbai vs. Int Tax Ward 2(1)(1), Mumbai

In the result, the appeal of the revenue bearing ITA No 519/Mum/2025 is dismissed

ITA 1074/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jun 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Ravikant S. Pathak, ARFor Respondent: 24.06.2025
Section 143(3)Section 144BSection 147Section 148Section 148ASection 153Section 234BSection 270ASection 69A

revenue as penny stock and it is also fact on record that these scrips are categorized as penny stock as per the investigation wing, Kolkata reports and Ld. AO has heavily proceeded to disallow the claim made by the assessee on the business loss. In the impugned assessment order ... discussed various analysis made by the investigating wing of Kolkata and SEBI. In none of the statements or reports of Investigation Wing or orders of SEBI the name of the assessee was mentioned for manipulation. We also notice from the record that assessee has submitted all the relevant documents

Uniquestar Gems (India) Pvt. Ltd., Mumbai vs. The ITO, Ward 13(2)(1), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 1037/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jun 2025AY 2014-15

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 1037/Mum/2025 (नििाारण वर्ा / Assessment Year :2014-15) Uniquestar Gems (India) V/S. The Ito, Ward 13(2)(1), Pvt. Ltd. बिाम Mumbai Tara Niwas, M. Block, 2 Nd Aayakar Bhavan, M. K. Floor, J. S. S. Road, Opera Road, New Marine Lines, House, Maharahstra- Maharashtra-400020 400004 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcm6116D Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: None राजस्व की ओर से /Revenue By: Shri Vivek Perampurna

For Appellant: NoneFor Respondent: Shri Vivek Perampurna
Section 143(3)Section 148Section 250Section 690Section 69C

completed u/s 143(3) vide order dated 20.12.2016 at the same income. Subsequently, the case was reopened after receipt of information from the Investigation Wing regardingbogus imports, resulting in large foreign remittances detected by the P a g e | 3 A.Y. 2014-15 Uniquestar Gems (India) Pvt. Ltd. Enforcement Directorate

Dy. Commissioner of Income-Tax-1(1)(1), Mumbai vs. M/S. Chopra Strips Limited, Rajasthan

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

ITA 6818/MUM/2024[2012]Status: DisposedITAT Mumbai30 Jun 2025

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 6818/Mum/2024 (नििाारण वर्ा / Assessment Year :2012-13) Dcit-1(1)(1), Mumbai V/S. M/S. Chopra Strips Ltd. बिाम Room No. 579A, 5 Th Floor, D-194-195, Boranada Agro Aayakar Bhawan, Mumbai- Food Park, Jodhpur, 400020 Rajasthan-342008 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaccc3063C Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Vinod Kumar Bindal/Shri Satish Gupta राजस्व की ओर से /Revenue By: Shri Yogesh Kumar, Sr. Dr.

For Appellant: Shri Vinod Kumar Bindal/ShriFor Respondent: Shri Yogesh Kumar, Sr. DR
Section 143(1)Section 143(3)Section 148Section 68

terms of identity, creditworthiness and genuineness of the creditor, in view of specific information received from investigation wing regarding share capital received from Kolkata based accommodation entry operator. 2. Whether in the facts and circumstances of the case and in law the Ld. CIT(A) has failed to consider ... loss of Rs. 1,81,948/-. The return was processed u/s 143(1) of the Act. Subsequently, based on the information received from the Investigation Wing, Kolkata, a notice u/s 148 was issued on 18.03.2019. Therefore, AO completed the assessment u/s 143(3) r.w.s