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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

DCIT, New Delhi vs. M/S. Majestic Properties Pvt. Ltd., New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 1748/DEL/2014[2009-10]Status: DisposedITAT Delhi27 Jun 2025AY 2009-10

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

purchase of paintings and sits in their office. The assessee also filed an affidavit of Mr. Saudagar Shah to this effect before the Investigation Wing during the course of post search investigation by the Asstt. Director of Income Tax, Investigation and submitted the copy of the same ... hands of Mr. Rajat Gupta. Before the ld CIT(A), the assessee reiterated that Mr. Saudagar Shah had 18. indeed filed an affidavit before Investigation Wing itself to the Asst. Director of Income Tax (Investigation) during post search enquiry duly owning up the said slip pad marked as Annexure

M/S. Majestic Properties Pvt. Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 1623/DEL/2014[2009-10]Status: DisposedITAT Delhi27 Jun 2025AY 2009-10

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

purchase of paintings and sits in their office. The assessee also filed an affidavit of Mr. Saudagar Shah to this effect before the Investigation Wing during the course of post search investigation by the Asstt. Director of Income Tax, Investigation and submitted the copy of the same ... hands of Mr. Rajat Gupta. Before the ld CIT(A), the assessee reiterated that Mr. Saudagar Shah had 18. indeed filed an affidavit before Investigation Wing itself to the Asst. Director of Income Tax (Investigation) during post search enquiry duly owning up the said slip pad marked as Annexure

DCIT, New Delhi vs. Sh. Rajat Gupta, New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 3525/DEL/2013[2008-09]Status: DisposedITAT Delhi27 Jun 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

purchase of paintings and sits in their office. The assessee also filed an affidavit of Mr. Saudagar Shah to this effect before the Investigation Wing during the course of post search investigation by the Asstt. Director of Income Tax, Investigation and submitted the copy of the same ... hands of Mr. Rajat Gupta. Before the ld CIT(A), the assessee reiterated that Mr. Saudagar Shah had 18. indeed filed an affidavit before Investigation Wing itself to the Asst. Director of Income Tax (Investigation) during post search enquiry duly owning up the said slip pad marked as Annexure

DCIT, New Delhi vs. M/S. Majestic Properties Pvt. Ltd., New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 3289/DEL/2013[2008-09]Status: DisposedITAT Delhi27 Jun 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

purchase of paintings and sits in their office. The assessee also filed an affidavit of Mr. Saudagar Shah to this effect before the Investigation Wing during the course of post search investigation by the Asstt. Director of Income Tax, Investigation and submitted the copy of the same ... hands of Mr. Rajat Gupta. Before the ld CIT(A), the assessee reiterated that Mr. Saudagar Shah had 18. indeed filed an affidavit before Investigation Wing itself to the Asst. Director of Income Tax (Investigation) during post search enquiry duly owning up the said slip pad marked as Annexure

M/S Majestic Properties Pvt. Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 3233/DEL/2013[2008-09]Status: DisposedITAT Delhi27 Jun 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

purchase of paintings and sits in their office. The assessee also filed an affidavit of Mr. Saudagar Shah to this effect before the Investigation Wing during the course of post search investigation by the Asstt. Director of Income Tax, Investigation and submitted the copy of the same ... hands of Mr. Rajat Gupta. Before the ld CIT(A), the assessee reiterated that Mr. Saudagar Shah had 18. indeed filed an affidavit before Investigation Wing itself to the Asst. Director of Income Tax (Investigation) during post search enquiry duly owning up the said slip pad marked as Annexure

Deputy Commissioner of Income Tax, Central Circle-2, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 274/JPR/2025[2017-18]Status: DisposedITAT Jaipur26 Jun 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Tax, Central Circle-02, Jaipur Vs. Kiran Fine Jewellers Private Limited F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri R. K. Bhatra, CA राजस्व

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

this satisfaction of the AO as revealed from the reference letter is based on the information and document received from the Investigation Wing, Jaipur. Therefore, even if the said correspondence is considered as part of the proceedings of investigation carried out by the Jaipur Investigation Wing in case of Shri ... Sehgal, the limitation will reckon when the said investigation proceedings were completed and thereafter the information was sent by the Investigation Wing to the AO of the assessee. The Hon'ble Jurisdictional High Court in case of M.A. Press tressed Works (supra), has considered the aspect of initiation of penalty

Deputy Commissioner of Income Tax, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 271/JPR/2025[2017-18]Status: DisposedITAT Jaipur26 Jun 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Tax, Central Circle-02, Jaipur Vs. Kiran Fine Jewellers Private Limited F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri R. K. Bhatra, CA राजस्व

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

this satisfaction of the AO as revealed from the reference letter is based on the information and document received from the Investigation Wing, Jaipur. Therefore, even if the said correspondence is considered as part of the proceedings of investigation carried out by the Jaipur Investigation Wing in case of Shri ... Sehgal, the limitation will reckon when the said investigation proceedings were completed and thereafter the information was sent by the Investigation Wing to the AO of the assessee. The Hon'ble Jurisdictional High Court in case of M.A. Press tressed Works (supra), has considered the aspect of initiation of penalty

Deputy Commissioner of Income Tax, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 270/JPR/2025[2014-15]Status: DisposedITAT Jaipur26 Jun 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

this satisfaction of the AO as revealed from the reference letter is based on the information and document received from the Investigation Wing, Jaipur. Therefore, even if the said correspondence is considered as part of the proceedings of investigation carried out by the Jaipur Investigation Wing in case of Shri ... Sehgal, the limitation will reckon when the said investigation proceedings were completed and thereafter the information was sent by the Investigation Wing to the AO of the assessee. The Hon'ble Jurisdictional High Court in case of M.A. Press tressed Works (supra), has considered the aspect of initiation of penalty

Deputy Commissioner of Income Tax, Central Circle-2, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 268/JPR/2025[2013-14]Status: DisposedITAT Jaipur26 Jun 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं./ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Kiran Fine Jewellers Private Tax, Vs. Limited Central Circle-02, Jaipur F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Shri R. K. Bhatra, CA राजस्व की

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

this satisfaction of the AO as revealed from the reference letter is based on the information and document received from the Investigation Wing, Jaipur. Therefore, even if the said correspondence is considered as part of the proceedings of investigation carried out by the Jaipur Investigation Wing in case of Shri ... Sehgal, the limitation will reckon when the said investigation proceedings were completed and thereafter the information was sent by the Investigation Wing to the AO of the assessee. The Hon'ble Jurisdictional High Court in case of M.A. Press tressed Works (supra), has considered the aspect of initiation of penalty

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2472/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Jun 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

Mumbai vide an order dated 17/01/2018, rather in para 4 therein, the AO has mentioned that after receipt of the information received from the Investigation Wing, the return of income of the assessee for the AY 2011-12 has been analysed, particularly when he could not possess the said return ... issue was undertaken. Various tools / data bases available were examined including ITD data, BSE data, money control website, court rulings, internet as well as investigation wing report and findings of the SEBI in ascertaining the correctness of the LTCG claim. 31. Then in para 6.1.3, the AO goes to rely

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2471/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Jun 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

Mumbai vide an order dated 17/01/2018, rather in para 4 therein, the AO has mentioned that after receipt of the information received from the Investigation Wing, the return of income of the assessee for the AY 2011-12 has been analysed, particularly when he could not possess the said return ... issue was undertaken. Various tools / data bases available were examined including ITD data, BSE data, money control website, court rulings, internet as well as investigation wing report and findings of the SEBI in ascertaining the correctness of the LTCG claim. 31. Then in para 6.1.3, the AO goes to rely

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2470/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Jun 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

Mumbai vide an order dated 17/01/2018, rather in para 4 therein, the AO has mentioned that after receipt of the information received from the Investigation Wing, the return of income of the assessee for the AY 2011-12 has been analysed, particularly when he could not possess the said return ... issue was undertaken. Various tools / data bases available were examined including ITD data, BSE data, money control website, court rulings, internet as well as investigation wing report and findings of the SEBI in ascertaining the correctness of the LTCG claim. 31. Then in para 6.1.3, the AO goes to rely

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2469/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Jun 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

Mumbai vide an order dated 17/01/2018, rather in para 4 therein, the AO has mentioned that after receipt of the information received from the Investigation Wing, the return of income of the assessee for the AY 2011-12 has been analysed, particularly when he could not possess the said return ... issue was undertaken. Various tools / data bases available were examined including ITD data, BSE data, money control website, court rulings, internet as well as investigation wing report and findings of the SEBI in ascertaining the correctness of the LTCG claim. 31. Then in para 6.1.3, the AO goes to rely

Hemendra Ramji Vira, Mumbai vs. DCIT CC-4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2468/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Jun 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

Mumbai vide an order dated 17/01/2018, rather in para 4 therein, the AO has mentioned that after receipt of the information received from the Investigation Wing, the return of income of the assessee for the AY 2011-12 has been analysed, particularly when he could not possess the said return ... issue was undertaken. Various tools / data bases available were examined including ITD data, BSE data, money control website, court rulings, internet as well as investigation wing report and findings of the SEBI in ascertaining the correctness of the LTCG claim. 31. Then in para 6.1.3, the AO goes to rely

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2467/MUM/2025[2013-14]Status: DisposedITAT Mumbai26 Jun 2025AY 2013-14
Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

Mumbai vide an order dated 17/01/2018, rather in para 4 therein, the AO has mentioned that after receipt of the information received from the Investigation Wing, the return of income of the assessee for the AY 2011-12 has been analysed, particularly when he could not possess the said return ... issue was undertaken. Various tools / data bases available were examined including ITD data, BSE data, money control website, court rulings, internet as well as investigation wing report and findings of the SEBI in ascertaining the correctness of the LTCG claim. 31. Then in para 6.1.3, the AO goes to rely

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 6405/MUM/2024[2011-12]Status: DisposedITAT Mumbai26 Jun 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

Mumbai vide an order dated 17/01/2018, rather in para 4 therein, the AO has mentioned that after receipt of the information received from the Investigation Wing, the return of income of the assessee for the AY 2011-12 has been analysed, particularly when he could not possess the said return ... issue was undertaken. Various tools / data bases available were examined including ITD data, BSE data, money control website, court rulings, internet as well as investigation wing report and findings of the SEBI in ascertaining the correctness of the LTCG claim. 31. Then in para 6.1.3, the AO goes to rely

Amit Kumar, Delhi vs. Income Tax Officer, Ward 1(1), Guwahati, Income Tas Officer

ITA 33/GTY/2024[2021-22]Status: DisposedITAT Guwahati25 Jun 2025AY 2021-22

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 133(6)Section 250Section 69CSection 70

adversely dealt with. I.T.A. Nos. 32 & 33/GTY/2024 Amit Kumar (iii) The Ld. AO mechanically went about in respect of the information provided by the Investigation Wing and thereby depended on “borrowed satisfaction”. (iv) While the details of deposits were available with the Ld. AO, he did not apply his mind ... cloth on job-work basis - It filed return declaring certain taxable income Assessing Officer passed an order of assessment under section 143(3) - Subsequently, Investigation Wing of Department supplied a list of paper companies which had provided accommodation entries in form of share capital and share premium Assessing Officer found

Amit Kumar, Delhi vs. Income Tax Officer, Ward 1(1), Guwahati

ITA 32/GTY/2024[2017-18]Status: DisposedITAT Guwahati25 Jun 2025AY 2017-18

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 133(6)Section 250Section 69CSection 70

adversely dealt with. I.T.A. Nos. 32 & 33/GTY/2024 Amit Kumar (iii) The Ld. AO mechanically went about in respect of the information provided by the Investigation Wing and thereby depended on “borrowed satisfaction”. (iv) While the details of deposits were available with the Ld. AO, he did not apply his mind ... cloth on job-work basis - It filed return declaring certain taxable income Assessing Officer passed an order of assessment under section 143(3) - Subsequently, Investigation Wing of Department supplied a list of paper companies which had provided accommodation entries in form of share capital and share premium Assessing Officer found

Vivek Agarwal, Gurgaon vs. Income-Tax Officer, Ward-2, Tinsukia

Appeals of the assessee are allowed for statistical purposes

ITA 228/GTY/2024[2014-15]Status: DisposedITAT Guwahati25 Jun 2025AY 2014-15

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 250Section 271(1)(c)

concerns the Long-Term Capital Gains (LTCG) claimed on account of certain penny stocks which were under adverse notice by the Investigation Wing of the Income Tax Department. The LTCG claimed was disallowed by treating it as bogus and thereafter penalty under Section ... assessee has challenged the same. 3. Before us, the Ld. AR averred that the Ld. AO merely went by information received from the Investigation Wing and disregarded the documents in possession of the assessee regarding the impugned transactions. The Ld. AR also mentioned that since the assessee had relocated

Vivek Agarwal, Gurgaon vs. Income-Tax Officer, Ward-2, Tinsukia

Appeals of the assessee are allowed for statistical purposes

ITA 227/GTY/2024[2013-14]Status: DisposedITAT Guwahati25 Jun 2025AY 2013-14

Bench: the Ld. CIT(A). Needless to say, the assessee is aggrieved by the action of the Ld. Assessing Officer in all the three matters and has challenged the imposition of penalty in ITA No. 227 & 228/Gty/2024. He has also challenged the treatment of LTCG as bogus in the case of ITA No. 204/Gty/2018. For the A.Y. 2014-15 (ITA No. 204/Gty/2018) the assessee has filed revised grounds of appeal which deserve to be extracted for reference:

Section 143(3)Section 250Section 271(1)(c)

concerns the Long-Term Capital Gains (LTCG) claimed on account of certain penny stocks which were under adverse notice by the Investigation Wing of the Income Tax Department. The LTCG claimed was disallowed by treating it as bogus and thereafter penalty under Section ... assessee has challenged the same. 3. Before us, the Ld. AR averred that the Ld. AO merely went by information received from the Investigation Wing and disregarded the documents in possession of the assessee regarding the impugned transactions. The Ld. AR also mentioned that since the assessee had relocated