“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

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

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

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

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

Ravi Nandan Kr. Sinha, Patna vs. DCIT, C.Circle-5, Patna

In the result, all the captioned appeals of the assessee including quantum and penalty are allowed for statistical purposes

ITA 249/PAT/2006[1992-93]Status: DisposedITAT Patna21 Apr 2025AY 1992-93

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthi

Section 144Section 148Section 148(1)(a)Section 271(1)(c)

Ravi Nandan Kumar Sinha based on information gathered by the Investigation Wing for alleged receipts of payment without actual supplying of goods. After considering the facts, we find merit in the submissions of the legal heir of the assessee as no opportunity was given at all to present supporting evidences

ITO Ward 4(1), Kolkata vs. Tribute Trading and Finance Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 11/KOL/2025[2013-14]Status: DisposedITAT Kolkata21 Apr 2025AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 148

different securities. During A.Y.2013-14, it has shown income of Rs.30,26,790/-. (ii) In this case, on the basis of information received from Investigation Wing for same A.Y. i.e 2013-14, assessment has been done on 28.03.2016, by making addition of Rs.78,25,188/- as bogus losses, on shares ... Tuni Textiles Ltd and M/s. Blue Circle Ltd. (iv) Assessing Officer has reopened this case again, only on ground of information received from Investigation Wing regarding fictitious losses in respect of KCCL Plastics Ltd which amounted to Rs.4,52,000/- only, but has made addition of all the balance amount

Kailash Regency Pvt. Ltd., Kolkata vs. I.T.O., Ward - 12(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2514/KOL/2024[2009-2010]Status: DisposedITAT Kolkata21 Apr 2025AY 2009-2010

Bench: Shri Rajesh Kumar, Am

Section 143(3)Section 147Section 148

income at ₹nil. The case of the assessee was reopened u/s 147 of the Act on the basis of report / information made by the investigation wing, Ahmedabad, in respect of client code modification after recording the reasons to believe and obtaining the permission from the competent authority. The statutory notices ... perusal of the above reason it is observed that the Id. AO has merely reproduced in Para no.2, the information received from the investigation wing qua client code modification and in para 3, he concluded that he has reason to believe that the income has escaped assessment to the extent

ACIT, Circle-5.1, Kolkata vs. Yadav Prasad Tosniwal, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1730/KOL/2024[2010-11]Status: DisposedITAT Kolkata21 Apr 2025AY 2010-11

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.1730/Kol/2024 (नििाारण वर्ा / Assessment Years : 2010-2011) Acit, Circle-5.1, Kolkata Vs Yadav Prasad Tosniwal, 638, Basanmoyee Apartment Rabindra Sarani, Bagbazar, Kolkata-700003 Pan No. :Acipt6576E (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. राजस्वकीओरसे /Revenue By : Ms. Madhumita Sas, Addl.Cit नििााररतीकीओरसे /Assessee By : Shri Siddharth Kejriwal, Ar सुनवाई की तारीख / Date Of Hearing : 17/04/2025 घोषणा की तारीख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R This Is The Appeal Filed By The Revenue Against The Order Dated 18.03.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2010-2011. 2. As Per The Office Record, It Is Noted That The Appeal Is Filed Belatedly By 89 Days. In This Regard, The Revenue Has Filed Condonation Application Stating Therein Sufficient Reasons For Condonation Of Delay. Considering The Reasons Stated In The Application Of The Revenue, The Delay Of 89 Days In Filing The Present Appeal Is Condoned & The Appeal Is Admitted For Hearing. 3. The Revenue Has Raised The Following Grounds :- 1. Whether On The Facts & Circumstances Of The Case & In Law The Ld. Cit(A) Erred In Deleting The Additions To The Tune Of Rs 17,75,988/- Made U/S 68 Of The I.T. Act Made On Account Of Unaccounted Transactions, Ignoring The Evidences Brought On Record By The Assessing Officer To Establish That The Genuineness Of The Transaction & Creditworthiness Could Not Be Satisfactorily Proved In This Case?

For Appellant: Shri Siddharth Kejriwal, ARFor Respondent: Ms. Madhumita Sas, Addl.CIT

Section 147Section 148Section 68

appellant has claimed that the re-assessment is erroneous and unlawful, that re- opening merely done on the basis of information received from Investigation Wing without tangible evidence is erroneous. It is also claimed that the AO did not dispose the objection before proceeding with the assessment. Ground ... also stated that NMCE Stock Exchange does not allow share transaction. The AO has passed a two line order on borrowed information from Investigation Wing. It is also claimed that the basis of addition of Rs. 17,75,988/- is not there in the assessment order as against reasons recorded

Income Tax Officer -5(3)(1), Mumbai vs. M/S. Shree Sundha Steels Private Limited, Mumbai

In the result, the appeal filed by the revenue bearing ITA 1756/Mum/2025

ITA 1756/MUM/2025[2008]Status: HeardITAT Mumbai21 Apr 2025

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeincome-Tax Officer -5(3)(1), Vs M/S Shree Sundha Steels Private Mumbai, Limited, 5Th Room No.526, Floor, 15/16, D-Wing,Groundfloor, Gora Aayakar Bhawan, Mumbai-400 Gandhi Palace, 122, Khetwadi Back 020 Road, Khetwadi, Mumbai-400 004 Pan: Aaics1816M Appellant Respondent

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Asif Karmali (SR. DR.)

Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 250

completed under section 143(3) of the Act. Thereafter, notice under section 148 of the Act was issued based on information received from the Investigation Wing of the Income Tax Department regarding alleged bogus purchase transactions undertaken by the assessee during the relevant assessment year. The assessee is engaged

Innocent Infrastructure Private Limited, Mumbai vs. ITO Ward 12(2)(4), Mumbai

ITA 1236/MUM/2025[2014-15]Status: DisposedITAT Mumbai21 Apr 2025AY 2014-15

Bench: SHRI PAWAN SINGH (Judicial Member)

Section 143(3)Section 147Section 243(3)Section 250Section 254(1)

loan. The Ld. AR of the assessee submits that case of assessee for AY 2014-15 was reopened on the basis of information of Investigation Wing (Mumbai) that such action was carried out on Gautam Jain and his group on 30.10.2013. It was revealed in the search action that Gautam ... loan of Rs. 34,00,000/- received from Maniratnam Exim Pvt. Ltd. The AO while making such addition solely relied upon the report of investigation wing (Mumbai) that Maniratnam Exim Pvt. Ltd. was engaged in providing accommodation entry. I find that in response to show-cause notice dated

DCIT, Circle 42(1)(1), Income Tax Department vs. Ghanshyam Rasiklal Shah, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 4707/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Apr 2025AY 2012-13

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeedcit, Circle 42(1)(1), Mumbai Vs Ghanshyam Rasiklal Shah Room 732, 7Th Floor, B-1408, Shankar Park, Agrawal Kautilya Bhavan, Bkc, Bandra Residency, Shankar Lane, Kandivali East, Mumbai-400 051 West, Mumbai-400 067 Pan: Aafps1306Q Appellant Respondent

For Appellant: Shri Subodh Ratnaparkhi - CAFor Respondent: Shri BhangepatilPushkaraj Ramesh

Section 132Section 143(3)Section 147Section 148Section 153CSection 250Section 69A

makes no reference whatsoever to the alleged cash receipt. It is clear that the Ld. AO, having received information from the Investigation Wing, Thane, thoroughly examined the matter and concluded that no such cash receipt existed in the appellant’s case. Accordingly, no addition was made on that count

ACIT-24(1), Mumbai vs. Dipti Sureshchandra Bajaj, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 3769/MUM/2024[2014]Status: DisposedITAT Mumbai21 Apr 2025

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

Section 10(38)Section 143(3)Section 147Section 148Section 14A

ASPL,  the value of total transactions in USE currency derivative loss is Rs. 51,28,985/-  In second para, he mentions about SEBI and Investigation Wing have proved that scrip of M/S ASHLAR SECURITIES PVT. LTD. has been used for providing bogus long term capital gain and losses and some

ACIT-24(1), Mumbai vs. Dipti Sureshchandra Bajaj, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 3767/MUM/2024[2015-16]Status: DisposedITAT Mumbai21 Apr 2025AY 2015-16

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

Section 10(38)Section 143(3)Section 147Section 148Section 14A

Madhu Goyal, Raipur vs. Income Tax Officer, Ward-2(1), Raipur

In the result, appeal of the assessee is allowed

ITA 496/RPR/2024[2014-15]Status: HeardITAT Raipur17 Apr 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.496/Rpr/2024 "नधा"रण वष" /Assessment Year : 2014-15 Smt. Madhu Goyal D-36, Wallfort City, Bhatagaon, Raipur-492 001 (C.G) Pan: Aeypg1038E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-4(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Sakshi Gopal Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 10(38)Section 143(2)Section 143(3)Section 144BSection 148Section 68

liable to be quashed on account of following defects:- i. That the reasons to believe was formed merely on basis of report of investigation wing without conducting any independent enquiry thus failing to form his own formation of believe. ii. That reasons to believe was based on wrong facts that ... void-ab-initio and liable to be quashed as the reason to believe was formed merely on basis of report of investigation wing without conducting any independent enquiry thus failing to form his own formation of believe and was based on wrong facts that the transaction of sale of share

ACIT, Circlle-34, Kolkata vs. Subhas Kumar Kedia, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1677/KOL/2024[2016-17]Status: DisposedITAT Kolkata17 Apr 2025AY 2016-17

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1677/Kol/2024 (नििाारण वर्ा / Assessment Year : 2016-2017) Acit, Circle-34, Kolkata Vs Subhas Kumar Kedia, 41, N.S.Road, Kolkata Pan No. :Afnpk 9669 M (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Ms. Shreya Loyalka, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 21/01/2025 घोषणा की तारीख/Date Of Pronouncement : 17/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 05.06.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2016-2017, On The Following Grounds Of Appeal :- I) That On The Facts & In The Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order U/S.148A(D) & All Subsequent Proceedings. Ii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Failed To Acknowledge The Fact That The Assesse Had Not Expressed Any Grievance Against The Validity Of Order U/S 148A(D) By Moving Any Writ Petition Which Should Have Been Done In Case Of Any Grievance After Getting The Sald Order U/S.148A(D). Iii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order When The Ld. Cit(A) Has No Jurisdiction To Deal With The Question Whether The 148A(D) Order Was Passed Validly Or Properly As An Order U/S.148A(D) Is Not An Appealable Order Before Ld. Cit(A) As Per Section 246A.

For Appellant: Ms. Shreya Loyalka, ARFor Respondent: Shri P.N.Barnwal, CIT-DR

Section 148Section 148ASection 149Section 151Section 246ASection 3Section 69A

Dalmia v. UOI 150 taxmann.com 54 on the basis of the same search of Sanwaria and Kasera Group held that the report of the Investigation Wing which is based on "potential cash borrowings and 'possible' financial transactions is not called for and set aside the reassessment proceedings. Relevant portion ... department sought to make the addition. It is completely unjustified and uncalled for and in violation of principles of natural justice. Borrowed satisfaction of investigation wing and non application of own mind 6. After hearing the rival contentions of the parties and perusing the material available on record, we find

Income Tax Officer-1(2)(1), Mumbai vs. Lube Distributing Company Pvt. Ltd, Mumbai

In the result, the appeal by the Revenue and the application by the assessee under Rule 27 of the ITAT Rules, 1963 are dismissed

ITA 3405/MUM/2024[2015]Status: DisposedITAT Mumbai16 Apr 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailincome Tax Officer-1(2)(1), Room No.536, 5Th Floor, Aayakar Bhawan, M.K. Road, Mumbai - 400020 ............... Appellant

For Appellant: Shri Devendra JainFor Respondent: Shri Ram Krishn Kedia, Sr.DR

Section 132Section 144BSection 147Section 148Section 250

without appreciating the fact that the entry providing company M/s Culminating Management Put. Ltd. is a shell/ paper/dummy company as per information received from Investigation wing." 2. The appellant prays that the order of the CIT(A) on the above ground be set aside and that ... assessment order, the AO, without considering any of these evidences, made the impugned addition merely relying upon the information received from the Investigation Wing, Kolkata. Further, we find that the AO also did not make any independent investigation or inquiry in respect of the transaction entered into by the assessee

Bses Rajdhani Power Ltd., New Delhi vs. ACIT, Cicle- 5(1), New Delhi

ITA 4850/DEL/2017[2007-08]Status: DisposedITAT Delhi16 Apr 2025AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 132Section 143(1)Section 143(2)Section 148

failed to appreciate that there is no information of conduct of any audit/investigation by SEBI/RBI, while the search conducted by Investigation Wing brought out substantial evidence about actual financial conduct of these entry operators, masquerading in the guise of NBFC. 6. Ld. CIT(A) has ignored the evidence collected

Harikrishna Jewels, Surat vs. Pr. Commissioner of Income Tax, Surat

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

ITA 354/SRT/2023[2012-13]Status: DisposedITAT Surat15 Apr 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.354/Srt/2023 Assessment Year: 2012-13 (Physical Court Hearing) Harikrishna Jewels, Principal Commissioner Of 201, Sunstar Building, Opp. बनाम/ Income Tax-1,, Surat, Room New Patidar Bhavan, No.123, Aaykar Bhawan, Near Vs. Mahidharpura, Surat-395 Majura Gate, Opp. New Civil 003 Hospital, Surat -395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagfh 3864 F (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By Shri Rasesh Shah, Ca राज" की ओर से /Revenue By Shri Ravi Kant Gupta, Cit-Dr सुनवाई की तारीख/Date Of Hearing 10.02.2025 उद्घोषणा की तारीख/Date Of Pronouncement 15.04.2025

Section 10ASection 143(3)Section 148Section 263

Ld.PCIT called for the records and found thr case was reopened based on ITA No.354/SRT/2023 /AY 12-13 Harikrishna Jewels information from the Investigation Wing that the genuineness of transactions of the assessee with M/s Priyal Diam, Star Bright Gems, Shyama Exim, Divine Star, Fooks, H.K. Traders and K.K. Creations ... were not satisfactorily explained before the Investigation Wing. However, the AO finalized the assessment without any query to establish the genuineness of the transactions with the above parties. He also found that assessee has claimed huge deduction of Rs.5,51,33,350/- u/s 10AA. The assesse has incurred meagre expenses

M/S. Pushpak Bullion Pvt. Ltd., Ahmedabad vs. The DCIT, Circle-3(1)(1), Ahmedabad

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

ITA 1771/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad15 Apr 2025AY 2007-08

Bench: Jurisdictional High Court & The Hon’Ble Gujarat High Court Dismissed The Writ Petition Filed By The Assessee Vide Judgment Dated 27-06-2016 In Sca No. 18512 Of 2015 & Upheld The Validity Of The Reassessment Notice.

Section 133(6)Section 143(1)Section 147Section 148Section 68

much as the AO has not formed independently his belief about the escapement of income but is guided by the information received from the Investigation Wing without making any inquiry. 3. The assessment is reopened on the ground that M/s. Kunal Gems, M/s. Nathsha Enterprise and M/s. Mohit International have

Ajay Bakliwal, Kota vs. ACIT, Central Cirle, Kota

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

ITA 1277/JPR/2024[2015-16]Status: DisposedITAT Jaipur11 Apr 2025AY 2015-16

For Appellant: Shri Rajendra SisodiaFor Respondent: Shri Rajesh Ojha, CIT-DR

Section 132Section 132(1)Section 132(4)Section 139Section 143(3)Section 153ASection 250

during the search and retraction during assessment proceedings. By admitting the appellant during search and survey proceedings the assessee stopped further investigation by the investigation wing. The assessee prevented department to cause further enquiry in his case. Since, the appellant admitted that the amount was received from Shri Ram Kishan

Mohammed Saleem Abdulkader Kajalwala, Ahmedabad vs. The Income Tax Officer, Ward-3(1)(3), Vadodara

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

ITA 536/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad11 Apr 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 133(6)Section 143(3)

536/Ahd/2023 A.Y. 2015-16 Page No 5 Mohammed Saleem Abdulkader Kajalwala Vs. ITO Therefore after considering the relevant records including enquiry conducted by the Investigation wing, Kolkata and relevant case laws, the addition of Rs. 90,00,000/- is confirmed. This ground of appeal fails and is not allowed

Vinod Cotton Corp Private Limited, New Delhi vs. ITO Ward 25(1), New Delhi

In the result, appeal is dismissed

ITA 3407/DEL/2023[2015-16]Status: DisposedITAT Delhi09 Apr 2025AY 2015-16

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: NoneFor Respondent: Shri Om Parkash, Sr. DR

Section 143(2)Section 68

facts and circumstances of the case confirming the addition of Rs. 2,15,00,000/- on merely relying on the report of investigation wing in the case of S.K. Jain for A.Y. 2005-06 to 2011-12 when that report had absolutely no nexus with the transactions carried

DCIT, Central Circle-25, New Delhi vs. Hinanshu Verma, New Delhi

ITA 1956/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Apr 2025AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Sudesh Garg, Adv. &For Respondent: Sh. Surender Pal Singh, CIT-DR

Section 1Section 143(3)Section 153D

such type of cases, regular discussion between the range head and AO happened regularly whenever needed. Appraisal report or other communication with the investigation wing of the department and seized/impounded materials explored and discussed from time to time and thereafter assessment order finalised after approval from the range head

DCIT Central Circle-25, New Delhi vs. Himanshu Verma, New Delhi

ITA 1356/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Sudesh Garg, Adv. &For Respondent: Sh. Surender Pal Singh, CIT-DR

Section 1Section 143(3)Section 153D