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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

Maanwati Agarwal, Jaipur vs. ITO, Ward 1(4), Jaipur

In the result, the appeal of the assessee is partly allowed as indicated hereinabove

ITA 1329/JPR/2024[2013-14]Status: DisposedITAT Jaipur01 Apr 2025AY 2013-14

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

For Appellant: Shri Mukesh Khandelwal, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT-Sr. DR a
Section 101Section 143(1)Section 143(3)

elaborated in detail that a search and survey action was carried out in the case of Sri Bhanwarlal Jain and his Group by the Investigation wing, Mumbai and a key person of the group concern, in his sworn statement admitted that he and his group were engaged in providing accommodation ... case was selected for scrutiny and notice u/s 143(2) was issued on 03/09/14 The Id. AO had received information from investigation wing. Mumbai about a search conducted on Bhanwar Lal Jain and group revealing that the loan of Rs. 75,00.000/- taken by the appellant from three concerns namely

Dinesh Kumar Keswani, Jaipur vs. ITO, Ward 5(1), Jaipur

19. In view of the above discussion, all these three appeals, in respect of assessment year 2015-16, 2016-17 & 2017-18 are allowed

ITA 1318/JPR/2024[2017-18]Status: DisposedITAT Jaipur01 Apr 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Praveen Sarswat, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 143(2)Section 147Section 148Section 69A

Assessing Officer made an addition of Rs. 1,78,000/-. Assessment proceedings were initiated on the basis of information received from Investigation Wing of the department that the assessee had deposited cash to the tune of Rs. 1,78,000/-, during said assessment year, in his bank account with State ... regards assessment year 2017-18 , on the basis of information received from Investigation Wing of the department, the Assessing Officer conducted assessment proceedings and made addition of Rs. 2,80,000/- u/s 69A of the Act, having found that the assessee had deposited said amount during the year under consideration

Dinesh Kumar Keswani, Jaipur vs. ITO, Ward 5(1), Jaipur

19. In view of the above discussion, all these three appeals, in respect of assessment year 2015-16, 2016-17 & 2017-18 are allowed

ITA 1317/JPR/2024[2016-17]Status: DisposedITAT Jaipur01 Apr 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Praveen Sarswat, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 143(2)Section 147Section 148Section 69A

Assessing Officer made an addition of Rs. 1,78,000/-. Assessment proceedings were initiated on the basis of information received from Investigation Wing of the department that the assessee had deposited cash to the tune of Rs. 1,78,000/-, during said assessment year, in his bank account with State ... regards assessment year 2017-18 , on the basis of information received from Investigation Wing of the department, the Assessing Officer conducted assessment proceedings and made addition of Rs. 2,80,000/- u/s 69A of the Act, having found that the assessee had deposited said amount during the year under consideration

Dinesh Kumar Keswani, Jaipur vs. ITO, Ward 5(1), Jaipur

19. In view of the above discussion, all these three appeals, in respect of assessment year 2015-16, 2016-17 & 2017-18 are allowed

ITA 1316/JPR/2024[2015-16]Status: DisposedITAT Jaipur01 Apr 2025AY 2015-16

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Praveen Sarswat, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 143(2)Section 147Section 148Section 69A

Assessing Officer made an addition of Rs. 1,78,000/-. Assessment proceedings were initiated on the basis of information received from Investigation Wing of the department that the assessee had deposited cash to the tune of Rs. 1,78,000/-, during said assessment year, in his bank account with State ... regards assessment year 2017-18 , on the basis of information received from Investigation Wing of the department, the Assessing Officer conducted assessment proceedings and made addition of Rs. 2,80,000/- u/s 69A of the Act, having found that the assessee had deposited said amount during the year under consideration

Unique Finance & Securities Pvt. Ltd., Kolkata vs. ACIT, Cir. 8(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 355/KOL/2024[2017-18]Status: DisposedITAT Kolkata01 Apr 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Unique Finance & Securities Acit, Cir. 8(2) Pvt. Ltd. Aayakar Bhawan P-7, Plot No. 35 11/1A/1 East Topsia Vs. Chowringhee Square, Kolkata, Road, Gobinda Khatick Road, West Bengal, 700069 Kolkata, West Bengal, 700046 (Appellant) (Respondent) Pan No. Aabcr2528L Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Ranu Biswas, Dr Date Of Hearing: 18.03.2025 Date Of Pronouncement : 01.04.2025

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ranu Biswas, DR
Section 131Section 133(6)Section 143(2)Section 143(3)Section 68

while dismissing the appeal of the assessee held that the ld. AO has righty made the addition based on the information received from the investigation wing which contained the statement given on oath by hawala operators, wherein it was disclosed that various entities operated by them engaged in giving accommodation ... also placed before the ld. Assessing Officer. The ld. AR submitted that the ld. AO had relied on the investigation Wing report that these loans creditors were engaged in providing hawala accommodation entries. however, strongly denied the fact that Shri Pravin Agarwal, whose statement was recorded

Aristocrat Residences LLP, Kolkata vs. Income Tax Officer Ward 34 (1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1118/KOL/2024[AY-2013-2014]Status: DisposedITAT Kolkata01 Apr 2025

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Income Tax Officer, Ward Aristocrat Residences Llp 34(1) 2 Oswal Chambers Church Lane Aaykar Bhavan, Bbd Bagh, Kolkata-700001 Vs. Kolkata-700107 West Bengal West Bengal (Appellant) (Respondent) Pan No. Aavfa9997R Assessee By : Dr. Kapil Goel, Ar Revenue By : H. Robindro Singh, Dr Date Of Hearing: 06.02.2025 Date Of Pronouncement : 01.04.2025

For Appellant: Dr. Kapil Goel, ARFor Respondent: H. Robindro Singh, DR
Section 132Section 139Section 142(1)Section 147Section 148Section 149Section 151Section 153Section 153ASection 153C

other hand relied on the order of the ld. lower authorities by submitting that in this case the credible information was received from the investigation wing that assessee is a beneficiary of bogus unsecured loans, accommodation entries to the tune of ₹1.00 crore and accordingly, the reopening of assessment ... Residences LLP; A.Y. 2013-14 information for reopening of assessment of the assessee u/s 147 of the Act was the material seized by the investigation wing during the course of search u/s 132(1) of the Act in case of Mukesh Banka and his related companies, which revealed that assessee

ACIT-Cir.20(1), Mumbai vs. Hitesh Joitkumar Jain, Mumbai

In the result, the appeal filed by the Revenue is dismissed and the appeal of the assessee is allowed

ITA 2639/MUM/2024[2017]Status: DisposedITAT Mumbai01 Apr 2025

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri Biswanth Das, CIT-DR
Section 68

report, the AO took the view that the purchases are not genuine purchases. The AO has also pointed out that the inspectors belonging to Investigation wing were deputed to locate the suppliers, but they could not locate the entities at the addresses given by them. Further, the AO examined ... hold that the purchases were not genuine. We notice that the AO has primarily relied upon the report given by the investigation wing, where in they had stated that certain concerns were providing only accommodation bills without actually supplying the materials. The investigation wing had recorded statements from many persons

Hitesh Joitkumar Jain, Mumbai Central vs. ACIT Circle-20(2) Mumbai, Piramal Chamber

ITA 2017/MUM/2024[2017-2018]Status: DisposedITAT Mumbai01 Apr 2025AY 2017-2018

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri Biswanth Das, CIT-DR
Section 68

Komal Exim Pvt Ltd | 13200000 | | | | 531432000 | The AO noticed that out of the above, following six concerns have been identified by the Investigation Wing as concerns providing accommodation entries only without actually supplying materials:- | | | | |---|---|---| | 1. | Sejal Diamond Pvt. Ltd. | 47350000 | | 2. | Santosh Gems Pvt. Ltd. | 55050000 | | 3. | Kudrat Impex ... another person, named, Shri Praveen Jain. Further, it was noticed that the above said Ramesh Soni and Praveen Jain had admitted before the Investigation Wing that they were providing only accommodation entries. The AO also noticed that the assessee had purchased diamonds on credit and he has paid the money

Ankush Goel, Delhi vs. ITO Ward 59(8), Delhi

In the result, the appeal of the assessee is allowed

ITA 1424/DEL/2024[2021-22]Status: DisposedITAT Delhi01 Apr 2025AY 2021-22

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

Section 132(4)Section 143(3)Section 69A

income was filed on 24.10.2019 declaring total income at Rs. 67,54,440/- A search and seizure operation was carried out by the Investigation Wing of Department on M/s Faquir Chand Lockers and Vaults Pvt. Ltd. Group of cases on 06.12.2018 and during the course of search, Rajesh Bubna

ACIT, Circle-4(1)(1), Aligarh vs. Mohd. Intzar, Aligarh

The appeal stand dismissed

ITA 318/AGR/2024[2014-15]Status: DisposedITAT Agra28 Mar 2025AY 2014-15

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.318/Agr/2024 (िनधा"रणवष" / Assessment Year: 2014-15) Acit Circle 4(1)(1) Mohd. Intzar बनाम/ Aligarh 202001 140, Sarai Mitan Vs. Delhi Gate, Aligarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aagpi-7161-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Dr. Arun Kumar Yadav – Ld. Cit-Dr ""थ"कीओरसे/Respondent By : Shri Deepak Singh (Advocate) – Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025

For Appellant: Dr. Arun Kumar Yadav – Ld. CIT-DRFor Respondent: Shri Deepak Singh (Advocate) – Ld. AR
Section 143(3)Section 147Section 148Section 69C

under. 2. The returned income of Rs.9.28 Lacs was accepted in scrutiny assessment u/s 143(3). However, pursuant to receipt of certain information from investigation wing that the assessee made unexplained purchases, the case was reopened and notice u/s 148 was issued on 30- 03-2021. The assessee objected ... simply changed his opinion qua purchases which is impermissible in law. The case was reopened merely by blindly relying upon the information received from investigation wing without conducting any independent enquiry that the income chargeable to tax had escaped assessment. Further, there were no new material facts before

Bipin Babu Agrawal, Mathura vs. ACIT, Central Circle, Agra

The appeal stands partly allowed

ITA 149/AGR/2022[2019-20]Status: DisposedITAT Agra28 Mar 2025AY 2019-20

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.149/Agr/2022 (िनधा"रणवष" / Assessment Year: 2019-20) Shri Bipin Babu Agarwal Dcit / Acit बनाम/ 16, Kamla Vihar Colony Central Circle Vs. Masani, Mathura 281 001 Agra "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aawpa-0864-C (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri M. M. Agrawal (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Arun Kumar Yadav – Ld. Cit-Dr सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2019-20 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Kanpur-4 [Cit(A)] Dated 28-06-2022 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 30-09-2021. Having Heard Vehement Arguments Of Both The Sides & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under. During The Year, The Assessee Being Resident Individual Carried Out Business Activities In Proprietorship Concern Namely M/S Parshant Silver Handicrafts. Assessment Proceedings 2.1 The Assessee’S Return Of Income Was Scrutinized Pursuant To Search Action On R.S. Bullion & Jewellers Group Of Cases At Mathura

For Appellant: Shri M. M. Agrawal (CA) – Ld. ARFor Respondent: Dr. Arun Kumar Yadav – Ld. CIT-DR
Section 132Section 143(3)

that sales invoices were unsigned, it was stated that the same were not found in the seized documents but the same were submitted to investigation wing after search. Since the volume was high, the assessee took fresh print-outs and submitted the same instead of submitting photocopies of such invoices ... search and the explanation which was given by the appellant after the 4 months of the search was not found genuine by the Investigation Wing as well as by the AO, therefore can be considered to be generated from such stock which was purchased out of books. 6.18 The appellant

Shri Chetan Harilal Bhalodiya, Rajkot vs. The ACIT Central Circle-1, Rajkot

In the result, appeals filed by the assessee ( in ITA Nos

ITA 25/RJT/2023[2015-16]Status: DisposedITAT Rajkot28 Mar 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 429, 430/Rjt/2017 & 358/Rjt/2018 ("नधा"रण वष"/Assessment Year: (2009-10 To 2011-12) Prashant Ramjibhai Kandoliya, Income Tax Officer, Sanjay & Company, Premjis, Ward-2(1)(4), Vs. Rajput Para Main Road, Rajkot Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Auhpk6407E (अपीलाथ"/Assessee) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos. 16 To 25/Rjt/2023 ("नधा"रण वष"/Assessment Year: (2006-07 To 2015-16) Chetankumar Haribhai The Acit, Bhalodiya, Prop. Of Yash Central Circle-1 Vs. Enterprise, 202, Darshan Rajkot Complex, Opp. Bombay Garage, Gondal Road, Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adypb7423K (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, A.R. राज"व क" ओर से/Respondent By : Shri Sanjay Punglia, Cit-D.R. सुनवाई क" तार"ख/ Date Of Hearing : 27/03/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/03/2025 आदेश / O R D E R Per Bench: Captioned 13 Appeals Filed By The Different Assessees, Pertaining To Different Assessment Years, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn

For Appellant: Shri Sunny Mehta, A.RFor Respondent: Shri Sanjay Punglia, CIT-D.R
Section 129Section 142(1)Section 143(3)Section 147Section 148

Courts, then at least the commission income should be taxed in the hands of the assessee. The assessee himself has admitted before the Investigation Wing that he is ITA No.429/RJT/2017& Others A Y:2009-10& Others earning 1% commission on cheque issue in lieu of cash. Now without prejudice ... Besides, the Hon`ble Gujarat High Court in some of the recent judgments has held reopening on the basis of the information of the Investigation Wing is valid. In the case of Peass Industrial Engineers Pvt. Ltd 73 taxmannn.com 185(2016) (Gujarat) it was held whether at the instance

Shri Chetan Harilal Bhalodiya, Rajkot vs. The ACIT Central Circle-1, Rajkot

In the result, appeals filed by the assessee ( in ITA Nos

ITA 24/RJT/2023[2014-15]Status: DisposedITAT Rajkot28 Mar 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 429, 430/Rjt/2017 & 358/Rjt/2018 ("नधा"रण वष"/Assessment Year: (2009-10 To 2011-12) Prashant Ramjibhai Kandoliya, Income Tax Officer, Sanjay & Company, Premjis, Ward-2(1)(4), Vs. Rajput Para Main Road, Rajkot Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Auhpk6407E (अपीलाथ"/Assessee) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos. 16 To 25/Rjt/2023 ("नधा"रण वष"/Assessment Year: (2006-07 To 2015-16) Chetankumar Haribhai The Acit, Bhalodiya, Prop. Of Yash Central Circle-1 Vs. Enterprise, 202, Darshan Rajkot Complex, Opp. Bombay Garage, Gondal Road, Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adypb7423K (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, A.R. राज"व क" ओर से/Respondent By : Shri Sanjay Punglia, Cit-D.R. सुनवाई क" तार"ख/ Date Of Hearing : 27/03/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/03/2025 आदेश / O R D E R Per Bench: Captioned 13 Appeals Filed By The Different Assessees, Pertaining To Different Assessment Years, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn

For Appellant: Shri Sunny Mehta, A.RFor Respondent: Shri Sanjay Punglia, CIT-D.R
Section 129Section 142(1)Section 143(3)Section 147Section 148

Courts, then at least the commission income should be taxed in the hands of the assessee. The assessee himself has admitted before the Investigation Wing that he is ITA No.429/RJT/2017& Others A Y:2009-10& Others earning 1% commission on cheque issue in lieu of cash. Now without prejudice ... Besides, the Hon`ble Gujarat High Court in some of the recent judgments has held reopening on the basis of the information of the Investigation Wing is valid. In the case of Peass Industrial Engineers Pvt. Ltd 73 taxmannn.com 185(2016) (Gujarat) it was held whether at the instance

Shri Chetan Harilal Bhalodiya, Rajkot vs. The ACIT Central Circle-1, Rajkot

In the result, appeals filed by the assessee ( in ITA Nos

ITA 23/RJT/2023[2013-14]Status: DisposedITAT Rajkot28 Mar 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 429, 430/Rjt/2017 & 358/Rjt/2018 ("नधा"रण वष"/Assessment Year: (2009-10 To 2011-12) Prashant Ramjibhai Kandoliya, Income Tax Officer, Sanjay & Company, Premjis, Ward-2(1)(4), Vs. Rajput Para Main Road, Rajkot Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Auhpk6407E (अपीलाथ"/Assessee) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos. 16 To 25/Rjt/2023 ("नधा"रण वष"/Assessment Year: (2006-07 To 2015-16) Chetankumar Haribhai The Acit, Bhalodiya, Prop. Of Yash Central Circle-1 Vs. Enterprise, 202, Darshan Rajkot Complex, Opp. Bombay Garage, Gondal Road, Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adypb7423K (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, A.R. राज"व क" ओर से/Respondent By : Shri Sanjay Punglia, Cit-D.R. सुनवाई क" तार"ख/ Date Of Hearing : 27/03/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/03/2025 आदेश / O R D E R Per Bench: Captioned 13 Appeals Filed By The Different Assessees, Pertaining To Different Assessment Years, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn

For Appellant: Shri Sunny Mehta, A.RFor Respondent: Shri Sanjay Punglia, CIT-D.R
Section 129Section 142(1)Section 143(3)Section 147Section 148

Courts, then at least the commission income should be taxed in the hands of the assessee. The assessee himself has admitted before the Investigation Wing that he is ITA No.429/RJT/2017& Others A Y:2009-10& Others earning 1% commission on cheque issue in lieu of cash. Now without prejudice ... Besides, the Hon`ble Gujarat High Court in some of the recent judgments has held reopening on the basis of the information of the Investigation Wing is valid. In the case of Peass Industrial Engineers Pvt. Ltd 73 taxmannn.com 185(2016) (Gujarat) it was held whether at the instance

Shri Chetan Harilal Bhalodiya, Rajkot vs. The ACIT Central Circle-1, Rajkot

In the result, appeals filed by the assessee ( in ITA Nos

ITA 22/RJT/2023[2012-13]Status: DisposedITAT Rajkot28 Mar 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 429, 430/Rjt/2017 & 358/Rjt/2018 ("नधा"रण वष"/Assessment Year: (2009-10 To 2011-12) Prashant Ramjibhai Kandoliya, Income Tax Officer, Sanjay & Company, Premjis, Ward-2(1)(4), Vs. Rajput Para Main Road, Rajkot Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Auhpk6407E (अपीलाथ"/Assessee) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos. 16 To 25/Rjt/2023 ("नधा"रण वष"/Assessment Year: (2006-07 To 2015-16) Chetankumar Haribhai The Acit, Bhalodiya, Prop. Of Yash Central Circle-1 Vs. Enterprise, 202, Darshan Rajkot Complex, Opp. Bombay Garage, Gondal Road, Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adypb7423K (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, A.R. राज"व क" ओर से/Respondent By : Shri Sanjay Punglia, Cit-D.R. सुनवाई क" तार"ख/ Date Of Hearing : 27/03/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/03/2025 आदेश / O R D E R Per Bench: Captioned 13 Appeals Filed By The Different Assessees, Pertaining To Different Assessment Years, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn

For Appellant: Shri Sunny Mehta, A.RFor Respondent: Shri Sanjay Punglia, CIT-D.R
Section 129Section 142(1)Section 143(3)Section 147Section 148

Courts, then at least the commission income should be taxed in the hands of the assessee. The assessee himself has admitted before the Investigation Wing that he is ITA No.429/RJT/2017& Others A Y:2009-10& Others earning 1% commission on cheque issue in lieu of cash. Now without prejudice ... Besides, the Hon`ble Gujarat High Court in some of the recent judgments has held reopening on the basis of the information of the Investigation Wing is valid. In the case of Peass Industrial Engineers Pvt. Ltd 73 taxmannn.com 185(2016) (Gujarat) it was held whether at the instance

Shri Chetan Harilal Bhalodiya, Rajkot vs. The ACIT Central Circle-1, Rajkot

In the result, appeals filed by the assessee ( in ITA Nos

ITA 21/RJT/2023[2011-12]Status: DisposedITAT Rajkot28 Mar 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 429, 430/Rjt/2017 & 358/Rjt/2018 ("नधा"रण वष"/Assessment Year: (2009-10 To 2011-12) Prashant Ramjibhai Kandoliya, Income Tax Officer, Sanjay & Company, Premjis, Ward-2(1)(4), Vs. Rajput Para Main Road, Rajkot Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Auhpk6407E (अपीलाथ"/Assessee) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos. 16 To 25/Rjt/2023 ("नधा"रण वष"/Assessment Year: (2006-07 To 2015-16) Chetankumar Haribhai The Acit, Bhalodiya, Prop. Of Yash Central Circle-1 Vs. Enterprise, 202, Darshan Rajkot Complex, Opp. Bombay Garage, Gondal Road, Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adypb7423K (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, A.R. राज"व क" ओर से/Respondent By : Shri Sanjay Punglia, Cit-D.R. सुनवाई क" तार"ख/ Date Of Hearing : 27/03/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/03/2025 आदेश / O R D E R Per Bench: Captioned 13 Appeals Filed By The Different Assessees, Pertaining To Different Assessment Years, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn

For Appellant: Shri Sunny Mehta, A.RFor Respondent: Shri Sanjay Punglia, CIT-D.R
Section 129Section 142(1)Section 143(3)Section 147Section 148

Courts, then at least the commission income should be taxed in the hands of the assessee. The assessee himself has admitted before the Investigation Wing that he is ITA No.429/RJT/2017& Others A Y:2009-10& Others earning 1% commission on cheque issue in lieu of cash. Now without prejudice ... Besides, the Hon`ble Gujarat High Court in some of the recent judgments has held reopening on the basis of the information of the Investigation Wing is valid. In the case of Peass Industrial Engineers Pvt. Ltd 73 taxmannn.com 185(2016) (Gujarat) it was held whether at the instance

Shri Chetan Harilal Bhalodiya, Rajkot vs. The ACIT Central Circle-1, Rajkot

In the result, appeals filed by the assessee ( in ITA Nos

ITA 20/RJT/2023[2010-11]Status: DisposedITAT Rajkot28 Mar 2025AY 2010-11

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 429, 430/Rjt/2017 & 358/Rjt/2018 ("नधा"रण वष"/Assessment Year: (2009-10 To 2011-12) Prashant Ramjibhai Kandoliya, Income Tax Officer, Sanjay & Company, Premjis, Ward-2(1)(4), Vs. Rajput Para Main Road, Rajkot Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Auhpk6407E (अपीलाथ"/Assessee) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos. 16 To 25/Rjt/2023 ("नधा"रण वष"/Assessment Year: (2006-07 To 2015-16) Chetankumar Haribhai The Acit, Bhalodiya, Prop. Of Yash Central Circle-1 Vs. Enterprise, 202, Darshan Rajkot Complex, Opp. Bombay Garage, Gondal Road, Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adypb7423K (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, A.R. राज"व क" ओर से/Respondent By : Shri Sanjay Punglia, Cit-D.R. सुनवाई क" तार"ख/ Date Of Hearing : 27/03/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/03/2025 आदेश / O R D E R Per Bench: Captioned 13 Appeals Filed By The Different Assessees, Pertaining To Different Assessment Years, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn

For Appellant: Shri Sunny Mehta, A.RFor Respondent: Shri Sanjay Punglia, CIT-D.R
Section 129Section 142(1)Section 143(3)Section 147Section 148

Courts, then at least the commission income should be taxed in the hands of the assessee. The assessee himself has admitted before the Investigation Wing that he is ITA No.429/RJT/2017& Others A Y:2009-10& Others earning 1% commission on cheque issue in lieu of cash. Now without prejudice ... Besides, the Hon`ble Gujarat High Court in some of the recent judgments has held reopening on the basis of the information of the Investigation Wing is valid. In the case of Peass Industrial Engineers Pvt. Ltd 73 taxmannn.com 185(2016) (Gujarat) it was held whether at the instance

Shri Chetan Harilal Bhalodiya, Rajkot vs. The ACIT Central Circle-1, Rajkot

In the result, appeals filed by the assessee ( in ITA Nos

ITA 19/RJT/2023[2009-10]Status: DisposedITAT Rajkot28 Mar 2025AY 2009-10

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 429, 430/Rjt/2017 & 358/Rjt/2018 ("नधा"रण वष"/Assessment Year: (2009-10 To 2011-12) Prashant Ramjibhai Kandoliya, Income Tax Officer, Sanjay & Company, Premjis, Ward-2(1)(4), Vs. Rajput Para Main Road, Rajkot Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Auhpk6407E (अपीलाथ"/Assessee) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos. 16 To 25/Rjt/2023 ("नधा"रण वष"/Assessment Year: (2006-07 To 2015-16) Chetankumar Haribhai The Acit, Bhalodiya, Prop. Of Yash Central Circle-1 Vs. Enterprise, 202, Darshan Rajkot Complex, Opp. Bombay Garage, Gondal Road, Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adypb7423K (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, A.R. राज"व क" ओर से/Respondent By : Shri Sanjay Punglia, Cit-D.R. सुनवाई क" तार"ख/ Date Of Hearing : 27/03/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/03/2025 आदेश / O R D E R Per Bench: Captioned 13 Appeals Filed By The Different Assessees, Pertaining To Different Assessment Years, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn

For Appellant: Shri Sunny Mehta, A.RFor Respondent: Shri Sanjay Punglia, CIT-D.R
Section 129Section 142(1)Section 143(3)Section 147Section 148

Courts, then at least the commission income should be taxed in the hands of the assessee. The assessee himself has admitted before the Investigation Wing that he is ITA No.429/RJT/2017& Others A Y:2009-10& Others earning 1% commission on cheque issue in lieu of cash. Now without prejudice ... Besides, the Hon`ble Gujarat High Court in some of the recent judgments has held reopening on the basis of the information of the Investigation Wing is valid. In the case of Peass Industrial Engineers Pvt. Ltd 73 taxmannn.com 185(2016) (Gujarat) it was held whether at the instance

Shri Chetan Harilal Bhalodiya, Rajkot vs. The ACIT Central Circle-1, Rajkot

In the result, appeals filed by the assessee ( in ITA Nos

ITA 18/RJT/2023[2008-09]Status: DisposedITAT Rajkot28 Mar 2025AY 2008-09

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 429, 430/Rjt/2017 & 358/Rjt/2018 ("नधा"रण वष"/Assessment Year: (2009-10 To 2011-12) Prashant Ramjibhai Kandoliya, Income Tax Officer, Sanjay & Company, Premjis, Ward-2(1)(4), Vs. Rajput Para Main Road, Rajkot Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Auhpk6407E (अपीलाथ"/Assessee) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos. 16 To 25/Rjt/2023 ("नधा"रण वष"/Assessment Year: (2006-07 To 2015-16) Chetankumar Haribhai The Acit, Bhalodiya, Prop. Of Yash Central Circle-1 Vs. Enterprise, 202, Darshan Rajkot Complex, Opp. Bombay Garage, Gondal Road, Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adypb7423K (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, A.R. राज"व क" ओर से/Respondent By : Shri Sanjay Punglia, Cit-D.R. सुनवाई क" तार"ख/ Date Of Hearing : 27/03/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/03/2025 आदेश / O R D E R Per Bench: Captioned 13 Appeals Filed By The Different Assessees, Pertaining To Different Assessment Years, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn

For Appellant: Shri Sunny Mehta, A.RFor Respondent: Shri Sanjay Punglia, CIT-D.R
Section 129Section 142(1)Section 143(3)Section 147Section 148

Courts, then at least the commission income should be taxed in the hands of the assessee. The assessee himself has admitted before the Investigation Wing that he is ITA No.429/RJT/2017& Others A Y:2009-10& Others earning 1% commission on cheque issue in lieu of cash. Now without prejudice ... Besides, the Hon`ble Gujarat High Court in some of the recent judgments has held reopening on the basis of the information of the Investigation Wing is valid. In the case of Peass Industrial Engineers Pvt. Ltd 73 taxmannn.com 185(2016) (Gujarat) it was held whether at the instance

Shri Chetan Harilal Bhalodiya, Rajkot vs. The ACIT Central Circle-1, Rajkot

In the result, appeals filed by the assessee ( in ITA Nos

ITA 17/RJT/2023[2007-08]Status: DisposedITAT Rajkot28 Mar 2025AY 2007-08

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 429, 430/Rjt/2017 & 358/Rjt/2018 ("नधा"रण वष"/Assessment Year: (2009-10 To 2011-12) Prashant Ramjibhai Kandoliya, Income Tax Officer, Sanjay & Company, Premjis, Ward-2(1)(4), Vs. Rajput Para Main Road, Rajkot Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Auhpk6407E (अपीलाथ"/Assessee) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos. 16 To 25/Rjt/2023 ("नधा"रण वष"/Assessment Year: (2006-07 To 2015-16) Chetankumar Haribhai The Acit, Bhalodiya, Prop. Of Yash Central Circle-1 Vs. Enterprise, 202, Darshan Rajkot Complex, Opp. Bombay Garage, Gondal Road, Rajkot "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adypb7423K (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, A.R. राज"व क" ओर से/Respondent By : Shri Sanjay Punglia, Cit-D.R. सुनवाई क" तार"ख/ Date Of Hearing : 27/03/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/03/2025 आदेश / O R D E R Per Bench: Captioned 13 Appeals Filed By The Different Assessees, Pertaining To Different Assessment Years, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn

For Appellant: Shri Sunny Mehta, A.RFor Respondent: Shri Sanjay Punglia, CIT-D.R
Section 129Section 142(1)Section 143(3)Section 147Section 148

Courts, then at least the commission income should be taxed in the hands of the assessee. The assessee himself has admitted before the Investigation Wing that he is ITA No.429/RJT/2017& Others A Y:2009-10& Others earning 1% commission on cheque issue in lieu of cash. Now without prejudice ... Besides, the Hon`ble Gujarat High Court in some of the recent judgments has held reopening on the basis of the information of the Investigation Wing is valid. In the case of Peass Industrial Engineers Pvt. Ltd 73 taxmannn.com 185(2016) (Gujarat) it was held whether at the instance