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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

Deputy Commissioner of Income Tax, Central Circle-4, Jaipur vs. Jitendra Kumar Daga, Jaipur

In the result, the appeal is treated as allowed

ITA 1171/JPR/2024[2012-13]Status: DisposedITAT Jaipur05 May 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Siddharth Ranka, AdvFor Respondent: Smt. Runi Pal, CIT a
Section 132Section 142(1)Section 143(2)Section 147Section 148Section 153C

accounts and that the brokerage received for such unrecorded cash transactions was also not offered for taxation by the group. As per the information, investigation wing carried out an investigation and names of lender were identified out of the names which were recorded in the said data ... accounts and that the brokerage received for such unrecorded cash transactions was also not offered for taxation by the group. As per the information, investigation wing carried out an investigation and names of lender were identified out of the names which were recorded in the said data

M/S Abhman Distributor Pvt. Ltd., Kolkata vs. NFAC, Delhi

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

ITA 1410/KOL/2023[2013-14]Status: DisposedITAT Kolkata02 May 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 131Section 143(3)Section 148Section 151Section 250Section 68

filing of return but the AO to satisfy his conscience that above transactions must have some profitability and on the basis of report from Investigation wing the AO made the addition without bringing any cogent material on record. 2. For that the Ld. CIT(A) erred in confirming the order ... income for AY 2013-14 on 13.03.2014 declaring total income of Rs. 15,310/-. Credible information was received by the Ld. AO from the investigation wing of the Department that the assessee is a private limited company with Mr. Devendra Mondal and Mr. Soumitra Sinha as beneficial owners. There were

Lakshmi Rao, Mumbai vs. ITO 22(2)(1), Mumbai

In the result, the grounds of appeal filed by the assessee are allowed for statistical purpose

ITA 6607/MUM/2024[2012-13]Status: DisposedITAT Mumbai02 May 2025AY 2012-13

Bench: Shri Pawan Singh, Hon’Bleshri Girish Agrawal, Hon’Ble(Physical Hearing) Lakshmi Rao Ito – Ward – 22(1)(4) (Now Ito-Ward-22(1)(1) A3102 Lodhabellissimo Piramal Chambers Off: N.M. Joshi Marg Vs Mumbai – 400012 Mahalakshmi, Mumbai – 400013 Maharashtra Maharashtra

Section 144Section 147Section 148Section 234Section 250Section 254(1)Section 271

various grounds of appeal on merit. The Ld.AR of the assessee submits that case of assessee was reopened on the basis of information from investigation wing about Client Code Modification (CCM) in National Stock Exchange and that assessee was one of the person who had allegedly received benefit of such

Smt Saroj Agarwal, Ranchi vs. ITO Ward 3(1), Ranchi

In the result, all the captioned appeals of the assessee are allowed

ITA 80/RAN/2023[2011-12]Status: DisposedITAT Ranchi01 May 2025AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A Nos.24 & 25/Ran/2023 Assessment Years: 2013-14 & 2015-16 &

For Appellant: Shri Debesh Podder, AdvocateFor Respondent: Shri Shadab Ahmed, CIT, DR
Section 10(38)Section 147Section 153ASection 250

case of the assessee, it is noticed that the Assessing Officer has relied on certain investigation report of the Investigation Wing of the Department and had disallowed the assessee’s claim of exemption u/s. 10(38) of the Act. No evidence whatsoever connecting the assessee to such alleged manipulation

Apurva Natvar Parikh & Co. Pvt Ltd, Mumbai vs. The Principle Commissioner of Income Tax, Mumbai-6, Mumbai

In the result, the appeal of the assessee is

ITA 2646/MUM/2024[2018-19]Status: DisposedITAT Mumbai01 May 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Madhur Agarwal, ARFor Respondent: Dr. K.R. Subhash, (CIT-DR)
Section 143(3)Section 14ASection 263

Ld.PCIT, however, did not accept the above said contentions of the assessee. He held that the enquiries conducted by different official (the Investigation Wing) cannot be considered as the enquiry of AO and hence, it cannot be said that there was application of mind by the AO. The Ld.PCIT also

Jayesh Sojpar Karnia HUF, Mumbai vs. Income Tax Officer-Ward 30(1)(5), Mumbai

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

ITA 4034/MUM/2023[2014-15]Status: DisposedITAT Mumbai01 May 2025AY 2014-15

Bench: Shri Narender Kumar Choudhryassessment Year: 2014-15

For Appellant: Shri Shashank Mehta, Ld. A.RFor Respondent: Shri Srinivas P., Ld. Sr.D.R
Section 10(38)Section 250Section 68Section 69C

Investigation, Kolkata and the mode of acquisition of the shares by the Assessee and unusual rise in the prices of share, findings of the investigation wing at Mumbai, analysis of transactions, failure of the Assessee to discharge his onus, ignorance of the Assessee about shares and penny stock companies, financial ... into consideration the volatility of the share price of the script sold by the assessee, was justified in relying upon the report of the Investigation Wing of Kolkata as well as the fact that the SEBI has suspended the transaction of the said script for some time and accordingly

Karuna Jain, Jaipur vs. ITO WD 2(1), Jpr, Jaipur

In the result, grounds raised by the assessee are dismissed

ITA 190/JPR/2025[2015-16]Status: DisposedITAT Jaipur30 Apr 2025AY 2015-16

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Amit Kumar Jain, CA, Ld. ARFor Respondent: Mr. Anup Singh, Addl. CIT, Ld. DR
Section 10(38)Section 133ASection 139(4)Section 250Section 250(6)

subscribing the IPO of M/s. HPC Bio Sciences Ltd. and consequently, sale of the same. Of late, Searches have been conducted by the Investigation Wing of the Department at various places throughout the country. During the searches & as per the information made public by the SEBI, it is discovered that ... volume became disproportionate to real financial position of the company.” 8. In his assessment order the AO reproduced the statement taken by the Investigation Wing, Kolkata of Mr. Sanjay Vora vide para 3.4.6, wherein he further confirmed in response to question no. 60, the name of the company

Vtp Foods, Pune vs. ITO Ward 7 (3), Pune

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

ITA 2878/PUN/2024[2017-18]Status: DisposedITAT Pune30 Apr 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Arvind Desai, Addl CIT DR
Section 143(2)

Cash deposits into banks are out of collection for sales as duly reflected in cash books. Same was duly explained and verified by Investigation wing during Oct 2017 to Jan 2018. 9. As all the receipts are explained and duly recorded in regular books of accounts we request your honour ... with regard to addition of Rs.50,99,000/-. The appellant has argued that the matter was explained to the Investigation Wing of the Department. This argument is not a valid argument. It was his duty to explain the matter before the Assessing Officer. Moreover, he has not explained it before

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Parasuraman Karthik Iyer, Chennai

In the result, appeals in ITA

ITA 31/HYD/2020[2010-11]Status: DisposedITAT Hyderabad30 Apr 2025AY 2010-11

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1796 To 1798/Hyd/2019 & Ita Nos.30 & 31/Hyd/2020 (िनधा"रण वष"/Assessment Years: 2008-09 To 2010-11) Dy. Cit Vs. Shri Parasuraman Karthik Iyer, Chennai Circle 16(2) Pan:Aftpk1261M Hyderabad (Appellant) (Respondent) राज" व "ारा/Revenue By:: Smt. M. Narmada, Cit(Dr) िनधा""रती "ारा/Assessee By: Shri A. Srinivas, Ca सुनवाई की तारीख/Date Of Hearing: 06/02/2025 घोषणा की तारीख/Pronouncement: 30/04/2025 आदेश/Order Per Vijay Pal Raothese 5 Appeals Filed By The Department Are Directed Against The Separate Orders Of The Learned Cit (A)-4, Hyderabad, Out Of Which 3 Appeals Are Arising From The Orders Passed U/S 143(3) R.W.S. 147 Of The I.T. Act, 1961 For The A.Y 2008-09 To 2010-11 & 2 Appeals Are Arising From The Penalty Order Passed U/S 271(1)(C) Of The Act, For The A.Ys 2009-10 & 2010-11 Respectively. In The Quantum Appeals, The Department Has Raised

For Appellant: Shri A. Srinivas, CAFor Respondent: : Smt. M. Narmada, CIT(DR)
Section 143(1)Section 143(3)Section 148Section 271(1)(c)Section 80G

Shri N. Venkatanathan, alias Rajamani, Life Member of M/s. South Indian Educational Society Trust and Personal Secretary of Sri V Shankar recorded by the Investigation Wing of the Department during the survey conducted at the said Society Trust. The assessee contended that when the assessee was not given the opportunity ... from whom the statements were recorded. The Assessing Officer has made it clear to the assessee that the said statements were recorded by the Investigation Wing at Mumbai and therefore, the opportunity to cross examine the persons cannot be given to the assessee by the Assessing Officer. The learned

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Parasuraman Karthik Iyer, Chennai

In the result, appeals in ITA

ITA 30/HYD/2020[2009-10]Status: DisposedITAT Hyderabad30 Apr 2025AY 2009-10

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1796 To 1798/Hyd/2019 & Ita Nos.30 & 31/Hyd/2020 (िनधा"रण वष"/Assessment Years: 2008-09 To 2010-11) Dy. Cit Vs. Shri Parasuraman Karthik Iyer, Chennai Circle 16(2) Pan:Aftpk1261M Hyderabad (Appellant) (Respondent) राज" व "ारा/Revenue By:: Smt. M. Narmada, Cit(Dr) िनधा""रती "ारा/Assessee By: Shri A. Srinivas, Ca सुनवाई की तारीख/Date Of Hearing: 06/02/2025 घोषणा की तारीख/Pronouncement: 30/04/2025 आदेश/Order Per Vijay Pal Raothese 5 Appeals Filed By The Department Are Directed Against The Separate Orders Of The Learned Cit (A)-4, Hyderabad, Out Of Which 3 Appeals Are Arising From The Orders Passed U/S 143(3) R.W.S. 147 Of The I.T. Act, 1961 For The A.Y 2008-09 To 2010-11 & 2 Appeals Are Arising From The Penalty Order Passed U/S 271(1)(C) Of The Act, For The A.Ys 2009-10 & 2010-11 Respectively. In The Quantum Appeals, The Department Has Raised

For Appellant: Shri A. Srinivas, CAFor Respondent: : Smt. M. Narmada, CIT(DR)
Section 143(1)Section 143(3)Section 148Section 271(1)(c)Section 80G

Shri N. Venkatanathan, alias Rajamani, Life Member of M/s. South Indian Educational Society Trust and Personal Secretary of Sri V Shankar recorded by the Investigation Wing of the Department during the survey conducted at the said Society Trust. The assessee contended that when the assessee was not given the opportunity ... from whom the statements were recorded. The Assessing Officer has made it clear to the assessee that the said statements were recorded by the Investigation Wing at Mumbai and therefore, the opportunity to cross examine the persons cannot be given to the assessee by the Assessing Officer. The learned

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Parasuraman Karthik Iyer, Chennai

In the result, appeals in ITA

ITA 1798/HYD/2019[2010-11]Status: DisposedITAT Hyderabad30 Apr 2025AY 2010-11

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1796 To 1798/Hyd/2019 & Ita Nos.30 & 31/Hyd/2020 (िनधा"रण वष"/Assessment Years: 2008-09 To 2010-11) Dy. Cit Vs. Shri Parasuraman Karthik Iyer, Chennai Circle 16(2) Pan:Aftpk1261M Hyderabad (Appellant) (Respondent) राज" व "ारा/Revenue By:: Smt. M. Narmada, Cit(Dr) िनधा""रती "ारा/Assessee By: Shri A. Srinivas, Ca सुनवाई की तारीख/Date Of Hearing: 06/02/2025 घोषणा की तारीख/Pronouncement: 30/04/2025 आदेश/Order Per Vijay Pal Raothese 5 Appeals Filed By The Department Are Directed Against The Separate Orders Of The Learned Cit (A)-4, Hyderabad, Out Of Which 3 Appeals Are Arising From The Orders Passed U/S 143(3) R.W.S. 147 Of The I.T. Act, 1961 For The A.Y 2008-09 To 2010-11 & 2 Appeals Are Arising From The Penalty Order Passed U/S 271(1)(C) Of The Act, For The A.Ys 2009-10 & 2010-11 Respectively. In The Quantum Appeals, The Department Has Raised

For Appellant: Shri A. Srinivas, CAFor Respondent: : Smt. M. Narmada, CIT(DR)
Section 143(1)Section 143(3)Section 148Section 271(1)(c)Section 80G

Shri N. Venkatanathan, alias Rajamani, Life Member of M/s. South Indian Educational Society Trust and Personal Secretary of Sri V Shankar recorded by the Investigation Wing of the Department during the survey conducted at the said Society Trust. The assessee contended that when the assessee was not given the opportunity ... from whom the statements were recorded. The Assessing Officer has made it clear to the assessee that the said statements were recorded by the Investigation Wing at Mumbai and therefore, the opportunity to cross examine the persons cannot be given to the assessee by the Assessing Officer. The learned

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Parasuraman Karthik Iyer, Chennai

In the result, appeals in ITA

ITA 1797/HYD/2019[2009-10]Status: DisposedITAT Hyderabad30 Apr 2025AY 2009-10

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1796 To 1798/Hyd/2019 & Ita Nos.30 & 31/Hyd/2020 (िनधा"रण वष"/Assessment Years: 2008-09 To 2010-11) Dy. Cit Vs. Shri Parasuraman Karthik Iyer, Chennai Circle 16(2) Pan:Aftpk1261M Hyderabad (Appellant) (Respondent) राज" व "ारा/Revenue By:: Smt. M. Narmada, Cit(Dr) िनधा""रती "ारा/Assessee By: Shri A. Srinivas, Ca सुनवाई की तारीख/Date Of Hearing: 06/02/2025 घोषणा की तारीख/Pronouncement: 30/04/2025 आदेश/Order Per Vijay Pal Raothese 5 Appeals Filed By The Department Are Directed Against The Separate Orders Of The Learned Cit (A)-4, Hyderabad, Out Of Which 3 Appeals Are Arising From The Orders Passed U/S 143(3) R.W.S. 147 Of The I.T. Act, 1961 For The A.Y 2008-09 To 2010-11 & 2 Appeals Are Arising From The Penalty Order Passed U/S 271(1)(C) Of The Act, For The A.Ys 2009-10 & 2010-11 Respectively. In The Quantum Appeals, The Department Has Raised

For Appellant: Shri A. Srinivas, CAFor Respondent: : Smt. M. Narmada, CIT(DR)
Section 143(1)Section 143(3)Section 148Section 271(1)(c)Section 80G

Shri N. Venkatanathan, alias Rajamani, Life Member of M/s. South Indian Educational Society Trust and Personal Secretary of Sri V Shankar recorded by the Investigation Wing of the Department during the survey conducted at the said Society Trust. The assessee contended that when the assessee was not given the opportunity ... from whom the statements were recorded. The Assessing Officer has made it clear to the assessee that the said statements were recorded by the Investigation Wing at Mumbai and therefore, the opportunity to cross examine the persons cannot be given to the assessee by the Assessing Officer. The learned

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Parasuraman Kathik Iyer, Chennai

In the result, appeals in ITA

ITA 1796/HYD/2019[2008-09]Status: DisposedITAT Hyderabad30 Apr 2025AY 2008-09

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1796 To 1798/Hyd/2019 & Ita Nos.30 & 31/Hyd/2020 (िनधा"रण वष"/Assessment Years: 2008-09 To 2010-11) Dy. Cit Vs. Shri Parasuraman Karthik Iyer, Chennai Circle 16(2) Pan:Aftpk1261M Hyderabad (Appellant) (Respondent) राज" व "ारा/Revenue By:: Smt. M. Narmada, Cit(Dr) िनधा""रती "ारा/Assessee By: Shri A. Srinivas, Ca सुनवाई की तारीख/Date Of Hearing: 06/02/2025 घोषणा की तारीख/Pronouncement: 30/04/2025 आदेश/Order Per Vijay Pal Raothese 5 Appeals Filed By The Department Are Directed Against The Separate Orders Of The Learned Cit (A)-4, Hyderabad, Out Of Which 3 Appeals Are Arising From The Orders Passed U/S 143(3) R.W.S. 147 Of The I.T. Act, 1961 For The A.Y 2008-09 To 2010-11 & 2 Appeals Are Arising From The Penalty Order Passed U/S 271(1)(C) Of The Act, For The A.Ys 2009-10 & 2010-11 Respectively. In The Quantum Appeals, The Department Has Raised

For Appellant: Shri A. Srinivas, CAFor Respondent: : Smt. M. Narmada, CIT(DR)
Section 143(1)Section 143(3)Section 148Section 271(1)(c)Section 80G

Shri N. Venkatanathan, alias Rajamani, Life Member of M/s. South Indian Educational Society Trust and Personal Secretary of Sri V Shankar recorded by the Investigation Wing of the Department during the survey conducted at the said Society Trust. The assessee contended that when the assessee was not given the opportunity ... from whom the statements were recorded. The Assessing Officer has made it clear to the assessee that the said statements were recorded by the Investigation Wing at Mumbai and therefore, the opportunity to cross examine the persons cannot be given to the assessee by the Assessing Officer. The learned

Assistant Commissioner of Income Tax, Central Circle - 4(1), Kolkata vs. Sendoz Commercials Private Limited, Kolkata

The appeal of the revenue is hereby dismissed

ITA 28/KOL/2025[2017]Status: DisposedITAT Kolkata30 Apr 2025

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.28/Kol/2025 Assessment Year: 2017-18 Acit, Central Circle-4(1), Kolkata ………………………………….…..……Appellant Vs. Sendoz Commercials Pvt. Ltd…………..……...........……........……...…..…..Respondent 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] C.O. No.12/Kol/2025 (Arising Out Of I.T.A. No.28/Kol/2025) Assessment Year: 2017-18 Sendoz Commercials Pvt. Ltd …………..………….………………..….…..Cross-Objector 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] Vs. Acit, Central Circle-4(1), Kolkata.............................……........……...…..…..Respondent Appearances By: Shri A. K. Tulsyan, Fca & Deepak Mudhra, Aca, Appeared On Behalf Of The Assessee. Shri Prabhakar Prakash Ranjan, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 30, 2025 Date Of Pronouncing The Order : April 30, 2025 Order Per Sonjoy Sarma: The Revenue Has Filed An Appeal & The Assessee Has Filed The Corresponding Cross-Objection Against The Same Order Dated 27.08.2024 By The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The ‘Cit(A)’] Relating To Assessment Year 2017-18. 2. At The Outset, The Registry Has Informed That There Is A Delay Of 37 Days In Filing The Present Appeal. The Revenue Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case.

Section 115BSection 133(6)Section 143(2)Section 143(3)Section 148Section 69C

TCPL during course of the assessment proceedings. 6.2.4. It is noteworthy to mention that the AO had made said addition relying on report of investigation wing. It is observed that the AO had not done any independent enquiry to ascertain the veracity of the transactions entered into by the assessee

ITO Ward-1, Kolar vs. Sayedsaleem Sayedriyazahmed Savanur, Kolar

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

ITA 1479/BANG/2024[2017-18]Status: DisposedITAT Bangalore30 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri K. Yathish, CAFor Respondent: Shri Subramanian .S, JCIT-DR
Section 144Section 147Section 148Section 69A

brief facts of the case are that the assessee is doing the wholesale business of chewing tobacco and other related products. The investigating wing had sent several notices seeking the details for the deposits of cash made into the assessee’s bank account. The assessee also filed his responses ... thereafter no further proceedings were initiated by the investigation wing of the department. Subsequently, a notice u/s. 148 was issued and through several notices, details were called for by the AO in respect of the cash deposits made by the assessee. The assessee being an uneducated person

ACIT, Central Circle-1, Thane vs. Nakul Markhedkar, Thane

ITA 786/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Apr 2025AY 2015-16

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan - Sr. DR
Section 132Section 153ASection 56(2)(vii)

Valuation Reportfor FMV of shares of M/s Farista Financial. 6.9 On receipt of above submission, the assessing officer examined the material collected by the investigation wing, Kolkata and observed that M/s Ratangiri Financial Advisory Pvt Limited, M/s Deb Suppliers & Traders Pvt Limited, M/s Farista Financial Consultants Pvt Limited as well

ACIT, Central Circle-1, Thane vs. Nakul Markhedkar, Thane

ITA 785/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Apr 2025AY 2016-17

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan - Sr. DR
Section 132Section 153ASection 56(2)(vii)

Valuation Reportfor FMV of shares of M/s Farista Financial. 6.9 On receipt of above submission, the assessing officer examined the material collected by the investigation wing, Kolkata and observed that M/s Ratangiri Financial Advisory Pvt Limited, M/s Deb Suppliers & Traders Pvt Limited, M/s Farista Financial Consultants Pvt Limited as well

Rajendra, Mumbai vs. DCIT Circle 19(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 759/MUM/2025[AACPR4430M]Status: DisposedITAT Mumbai30 Apr 2025

Bench: Shri Pawan Singh & Shri Omkareshwar Chidara(Physical Hearing) बनाम Rajendra, Dcit Circle 19(3), Mumbai 317, Prasad Chamber, Opera House, Vs Piramal Chambers, Charni Road, Mumbai – 400004. Lalbaug, Parel, Pan No. Aacpr 4430 M Mumbai-400012. अपीलार्थी/Appellant प्रत्यर्थी /Respondent ननर्ाारितीकीओिसे /Assessee By Ms. Ruby Srivastava & Shri Bharat Kumar Ar’S िाजस्वकीओिसे /Revenue By Shri Anil Gupta, Sr. Dr Date Of Institution Of Appeal 03.02.2025 27.02.2025 सुनवाईकीतािीख/Date Of Hearing उद्घोषणाकीतािीख/Date Of 30.04.2025 Pronouncement Order Under Section 254(1) Of Income Tax Act

Section 132(4)Section 143(1)Section 148Section 254(1)Section 68Section 69C

also relied on the statement of other directors in the entities of Shri Naresh Jain. On the basis of such statement and finding of investigation wing, the assessing officer made two additions in the return of income of assessee and added the amount of Rs. 11,97,290/- under section ... enquiry was conducted by assessing officer no specific evidence for linking the addition for price manipulation is brought on record. The statement recorded by Investigation Wing was not provided to the assessee. No opportunity of cross examination was provided to the assessee. Financial performance of the company during relevant period

M/S Mississippi It Services Privte Limited, Mumbai vs. Deputy Commissioner of Income Tax -Circle 1, Thane

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

ITA 5549/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Apr 2025AY 2013-14

Bench: Ms. Padmavathy S. & Shri Raj Kumar Chauhanm/S. Mississippi It Services Dcit Circle-1, Private Limited. Qureshi Mansion Road, 215, New Nirmal Nagar, Jantanagar Vs. Thane, Maharashtra – 400 Road, Nr. Station, Nr. Podar School, 604 Bhayander West, Thane, Maharashtra - 401101 Pan: Aagcm4216K (Appellant) (Respondent)

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)

reopening was challenged on the ground that it has been reopened on the statement of director of another company which was borrowed from investigation wing. It was the case of change in opinion as all the details related to sales and purchases along with details of debtors and creditors were ... truly all materials facts necessary for assessment does not get satisfied. The proceedings were initiated solely on the basis of opinion/borrowed satisfaction of the investigation wing without forming a reasonable belief under Section 148 of the Act that income of the appellant had escaped taxation; M/s. Mississippi IT Services Private

Assistant Commissioner of Income Tax-42(1)(1), Mumbai vs. Jekin Enterprise, Mumbai

In the result, the appeals of the revenue are dismissed, and the cross objections of the assessee are allowed

ITA 3111/MUM/2024[2011-12]Status: DisposedITAT Mumbai30 Apr 2025AY 2011-12

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 3111/Mum/2024 (निर्धारण वर्ा / Assessment Year :2011-12) आयकर अपील सं./Ita No. 3110/Mum/2024 (निर्धारण वर्ा / Assessment Year :2012-13) आयकर अपील सं./Ita No. 3105/Mum/2024 (निर्धारण वर्ा / Assessment Year :2013-14) आयकर अपील सं./Ita No. 3109/Mum/2024 (निर्धारण वर्ा / Assessment Year :2014-15) आयकर अपील सं./Ita No. 3107/Mum/2024 (निर्धारण वर्ा / Assessment Year :2015-16) Acit-42(1), Mumbai V/S. Jekin Enterprise Room No. 732, 7Th Floor, बिधम A 604, Prem Nagar, Kautilya Bhavan, G. Block, Building No. 5, Bkc, Bandra East, Mandepeshwar Road, Mumbai-400051 Boriwali (W.), Mumbai, Maharashtra-400092 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaafj0648R Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी प्रनि आपत्ति सं./ Co No. 177/Mum/2024 (Arising Out Of Ita No. 3111/Mum/2024) (निर्धारण वर्ा / Assessment Year :2011-12) प्रनि आपत्ति सं./ Co No. 176/Mum/2024 (Arising Out Of Ita No. 3110/Mum/2024) (निर्धारण वर्ा / Assessment Year :2012-13) प्रनि आपत्ति सं./ Co No. 173/Mum/2024 (Arising Out Of Ita No. 3105/Mum/2024)

For Appellant: Shri Anant paiFor Respondent: Ms. Kavitha Kaushik
Section 147Section 250Section 68

change of opinion without appreciating that the AO made the reason to believe on the receipt of new information viz cash deposits from Investigation Wing." 2. "On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.3 ... vide order dated 26.02.2016. Subsequently, Ld. Assessing Officer (AO) reopened the case on the basis of information received from the Investigation Wing, Mumbai with regard to the cash deposits made by the assessee in its bank account with Ratanakar Bank and also a loan of Rs. 40,00,000/- received