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“investigation wing”

ReassessmentSection 147Section 14712,584 judgments

The decision most relied on for investigation wing is Sarthak Securities Co. Pvt. Ltd. v. ITO (329 ITR 110), cited in 217 judgments on BharatTax.

Leading authorities on investigation wing

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.

PCIT v. M/s. Kesoram Industries 57
417 ITR 334 · 2019 · High Court
96
citing judgments

An assessment completed under Section 143(3) cannot be reopened after four years solely based on third-party information or opinions, such as from an Investigation Wing, without the Assessing Officer applying their own independent mind to the material and having new, independent material on record.

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.

Aradhna Estate Pvt. Ltd. v. DCIT
91 Taxmann.com 119 · 2018 · High Court
56
citing judgments

The Assessing Officer is justified in reopening assessment proceedings based on information received from the Investigation Wing, even when recording findings also rely on documents already on record, provided all procedural requirements for reassessment are met.

Judgments citing investigation wing

DCIT, Central Circle, Ghaziabad vs. Shri Irfan S/O Sh. Meharban, Bulandshahar

In the result, ground No.4 raised by the revenue is dismissed

ITA 3520/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Ms. Bharti Sharma, Adv &For Respondent: Ms. Amish S Gupt, CIT DR
Section 143(3)Section 153ASection 263Section 68

However, the ld. AO, without appreciating the responses and supporting evidence filed by the assessee, merely relying on the investigation done by the Investigation wing post requisition proceedings and based on various conjectures and surmises, made the following additions in the assessment order passed

DCIT, Central Circle, Ghaziabad vs. Shri Irfan S/O Sh. Meharban, Bulandshahr

In the result, ground No.4 raised by the revenue is dismissed

ITA 3519/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Ms. Bharti Sharma, Adv &For Respondent: Ms. Amish S Gupt, CIT DR
Section 143(3)Section 153ASection 263Section 68

However, the ld. AO, without appreciating the responses and supporting evidence filed by the assessee, merely relying on the investigation done by the Investigation wing post requisition proceedings and based on various conjectures and surmises, made the following additions in the assessment order passed

Sanjay Rawat, Dehradun vs. ACIT Central Cricle, Dehradun

In the result, appeal of the assessee is allowed

ITA 95/DDN/2024[2013-14]Status: DisposedITAT Dehradun11 Feb 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

invalid. 9. Ld.AR further submits that AO has recorded the reasons on the basis of borrowed satisfaction, based on the information received from Investigation Wing in the case of Amit Sharma, Ram Asrey Sharma Group and no independent inquiry or verification was made before reaching to the conclusion that such ... that the AO has proceeded to re-open the assessment solely on the basis of borrowed satisfaction and the information received from the Investigation wing ITA Nos.90, 95 & 104/DDN/2024 that during the course of survey in the case of Shri Amit Sharma, loose papers bearing No. LP.184 & 186 were impounded

Sanjay Rawat, Dehradun vs. ACIT Central Circle, Dehradun

In the result, appeal of the assessee is allowed

ITA 90/DDN/2024[2015-16]Status: DisposedITAT Dehradun11 Feb 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

invalid. 9. Ld.AR further submits that AO has recorded the reasons on the basis of borrowed satisfaction, based on the information received from Investigation Wing in the case of Amit Sharma, Ram Asrey Sharma Group and no independent inquiry or verification was made before reaching to the conclusion that such ... that the AO has proceeded to re-open the assessment solely on the basis of borrowed satisfaction and the information received from the Investigation wing ITA Nos.90, 95 & 104/DDN/2024 that during the course of survey in the case of Shri Amit Sharma, loose papers bearing No. LP.184 & 186 were impounded

Sh.Sanjay Rawat, Dehradun vs. ACIT, Circle, Dehradun

In the result, appeal of the assessee is allowed

ITA 104/DDN/2024[2013-14]Status: DisposedITAT Dehradun11 Feb 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

invalid. 9. Ld.AR further submits that AO has recorded the reasons on the basis of borrowed satisfaction, based on the information received from Investigation Wing in the case of Amit Sharma, Ram Asrey Sharma Group and no independent inquiry or verification was made before reaching to the conclusion that such ... that the AO has proceeded to re-open the assessment solely on the basis of borrowed satisfaction and the information received from the Investigation wing ITA Nos.90, 95 & 104/DDN/2024 that during the course of survey in the case of Shri Amit Sharma, loose papers bearing No. LP.184 & 186 were impounded

H J Enterprise, Rajkot vs. ACIT, Circle-1(1), Rajkot

In the result, the appeal of the assessee is partly allowed, in above terms

ITA 543/RJT/2025[2009-10]Status: DisposedITAT Rajkot11 Feb 2026AY 2009-10

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. A.RFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 147Section 148Section 44ASection 68Section 69C

finalised vide order passed u/s. 143(3) of the Act dated 29.11.2011 accepting returned income as such. On the basis of information received from Investigation Wing regarding outcome of search proceeding carried out at the business premises of one Shri Prakash Bagrecha, a director of the Company M/s. Bhumidev Credit ... dated 29.11.2011 on total income of Rs.58,28,760/- vide order u/s.143(3) of the Act. On the basis of information received from Investigation wing by AO that in search proceeding carried out at the business premises of one Shri Prakash Bagrecha, a director of M/s. Bhumidev Credit Corporation

Gopal Krishan Bansal, Mandi Gobindgarh, Punjab vs. ITO Ward -1, Mandi Gobindgarh, Sirhind

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

ITA 614/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh11 Feb 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 148Section 149

were no proper reason to believe that the income of the assessee has escaped assessment and only relied upon the information received from the investigation wing. 3. That the Ld. CIT(A) has erred in making disallowance in respect of the purchases made from above said parties to the extent ... case of the assessee was a subject to reopening u/s 148 on account of certain information received from Investigation Wing that the assessee had made purchases from the following three parties, which were bogus. In fact, the bogus purchases have been booked from the parties as under :- S.No. Name

Income Tax Office, Ward-I Mandi Gobindgarh Hq Sirhind vs. Gopal Krishan Bansal, Aggarwal Steel Tubes

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

ITA 478/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh11 Feb 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 148Section 149

were no proper reason to believe that the income of the assessee has escaped assessment and only relied upon the information received from the investigation wing. 3. That the Ld. CIT(A) has erred in making disallowance in respect of the purchases made from above said parties to the extent ... case of the assessee was a subject to reopening u/s 148 on account of certain information received from Investigation Wing that the assessee had made purchases from the following three parties, which were bogus. In fact, the bogus purchases have been booked from the parties as under :- S.No. Name

Vikul Panchal, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, the appeal (ITA No2138/Ahd/2025) filed by the assessee is allowed for statistical purposes

ITA 2340/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad11 Feb 2026AY 2013-14

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumarita No.2340/Ahd/2025 (Assessment Year : 2013-14)

For Appellant: Ms. Apporva Bhardwaj, ARFor Respondent: Shri Uday Kakne Kisanrao
Section 143(1)Section 147Section 148Section 271(1)(c)

30/11/2013 declaring total income of Rs.12,95,510/-. The return was processed u/s.143(1) of the Act, then based on the Investigation Wing report, that the assessee entered into financial transaction with foreign entities and received a sum of Rs.39,99,642/- which is not offered for taxation. Therefore

Vikul Panchal, Ahmedabad, Gujarat vs. ITO, Ward 3(2)(10), Ahmedabad, Gujarat

In the result, the appeal (ITA No2138/Ahd/2025) filed by the assessee is allowed for statistical purposes

ITA 2138/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad11 Feb 2026AY 2013-14

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumarita No.2340/Ahd/2025 (Assessment Year : 2013-14)

For Appellant: Ms. Apporva Bhardwaj, ARFor Respondent: Shri Uday Kakne Kisanrao
Section 143(1)Section 147Section 148Section 271(1)(c)

30/11/2013 declaring total income of Rs.12,95,510/-. The return was processed u/s.143(1) of the Act, then based on the Investigation Wing report, that the assessee entered into financial transaction with foreign entities and received a sum of Rs.39,99,642/- which is not offered for taxation. Therefore

Jinesh Lalit Jain, Raigad vs. Income Tax Officer, Ward 5, Panvel, Raigad

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

ITA 2127/PUN/2025[2011-12]Status: DisposedITAT Pune11 Feb 2026AY 2011-12

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2127/Pun/2025 िनधा"रण वष" / Assessment Year : 2011-12 Jinesh Lalit Jain, Vs. Ito, Ward-5, Panvel. 110, Mcch Society Ltd., Panvel Raigarh, Panvel- 410206. Pan : Acwpj0187B Appellant Respondent Assessee By : Shri Manthan Ruparelia Revenue By Shri Basavaraj Hiremath : Date Of Hearing : 06.01.2026 Date Of Pronouncement : 11.02.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 15.07.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2011-12. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Hon'Ble Cit(A), Nfac Erred In Not Considering The Assessment Order Is Bad In Law As Reopening U/S 147 Was Based Merely On Third-Party Information Without Independent Verification Or Recorded Reasons Furnished To The Appellant. 2. The Hon'Ble Cit(A), Nfac Erred By Not Providing Proper Opportunity Breached The Principles Of Natural Justice. 3. The Hon'Ble Cit(A), Nfac Erred In Confirming The Addition Of Rs. 53,12,313/- Ignoring The Appellant'S Reconciliations, Contra

For Appellant: Shri Manthan Ruparelia
Section 142(1)Section 147Section 148Section 44ASection 69

assessee is an individual and has not furnished his return of income for the year under consideration. On the basis of information received from Investigation Wing, Thane the case of the assessee was reopened and notice u/s 148 was issued. The information indicated that there were credits of Rs.32

ACIT Circle-12, Pune vs. Dhiraj Bhausaheb Nikam, Pune

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

ITA 1375/PUN/2025[2014-15]Status: DisposedITAT Pune11 Feb 2026AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15 Acit, Circle – 12, Pune Dhiraj Bhausaheb Nikam Vs. 515/516, Purva Plaza, Sadashiv Peth, Pune – 411030 Pan: Aahpn5137C (Appellant) (Respondent) Assessee By : None Department By : Shri Deepak Kumar Kedia, Jcit (Through Virtual) Date Of Hearing : 10-02-2026 Date Of Pronouncement : 11-02-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: NoneFor Respondent: Shri Deepak Kumar Kedia, JCIT
Section 10(38)Section 142(1)Section 143(2)Section 2(47)

said party. The Assessing Officer also conducted enquiries on entry operators / share broker/sub- brokers and also went through the data received from the investigation wing in the ITS window in the ITD system of the department. Although the assessee made various submissions on different dates but the assessee was unable ... been verified by M/s. Mountain View Developers Pvt Ltd. The Assessing Officer further noted that during the course of enquiries by the investigation wing it has been admitted by a number of entry operators and share broker/sub-brokers that the share prices of M/s. Anukaran Commercial Enterprises Ltd has been jagged

Impressive Trading Private Limited, Mumbai vs. Income Tax Officer 10(1)(1), Mumbai

In the result, all the above appeals in ITA Nos

ITA 7300/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Feb 2026AY 2015-16

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Ketan Vajani, CAFor Respondent: Shri Virabhadra S. Mahajan, (Sr. DR)
Section 147Section 147oSection 148Section 148ASection 151A

Appeals) has erred in confirming the reopening of the assessment by the ld. A.O. merely on the basis of vague information received from the Investigation Wing and no independent inquiry was made by him. 2. On the facts and under the circumstances of the case ... Commissioner of Income Tax (Appeals) has erred in confirming in reopening the assessment merely on the basis of vague information received from the Investigation Wing and no independent inquiry was made by him. Therefore impugned re-assessment order is bad in law and void abinitio. 4. On the facts

Impressive Trading Private Limited, Mumbai vs. Income Tax Officer 10(1)(1), Mumbai

In the result, all the above appeals in ITA Nos

ITA 7299/MUM/2025[2014-15]Status: DisposedITAT Mumbai11 Feb 2026AY 2014-15

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Ketan Vajani, CAFor Respondent: Shri Virabhadra S. Mahajan, (Sr. DR)
Section 147Section 147oSection 148Section 148ASection 151A

Appeals) has erred in confirming the reopening of the assessment by the ld. A.O. merely on the basis of vague information received from the Investigation Wing and no independent inquiry was made by him. 2. On the facts and under the circumstances of the case ... Commissioner of Income Tax (Appeals) has erred in confirming in reopening the assessment merely on the basis of vague information received from the Investigation Wing and no independent inquiry was made by him. Therefore impugned re-assessment order is bad in law and void abinitio. 4. On the facts

Impressive Trading Pvt. Ltd., Mumbai vs. Income Tax Officer 10(1)(1), Mumbai

ITA 7298/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Feb 2026AY 2013-14
Section 147Section 148Section 148ASection 151A

Appeals) has erred in confirming the reopening of the assessment by the ld. A.O. merely on the basis of vague information received from the Investigation Wing and no independent inquiry was made by him. 2. On the facts and under the circumstances of the case ... Commissioner of Income Tax (Appeals) has erred in confirming in reopening the assessment merely on the basis of vague information received from the Investigation Wing and no independent inquiry was made by him. Therefore impugned re-assessment order is bad in law and void abinitio. 4. On the facts

Meghji Mansukhlal Dodhia, Bhiwandi vs. DCIT-CC-3, Thane

ITA 2224/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Feb 2026AY 2013-14

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. It(Ss)A No. 2226/Mum/2025 S.A. No. 79/Mum/2025 (Assessment Year: 2012-13) Mansukhlal Meghji Dodhia House No. 104, Dodhia House, New Mavji Compound, Narpoli, Maharashtra-421 302 (Applicant) Dcit Cc-3, Thane Vs. Room No. 12, A Wing, 6Th Floor, Ashar It Park, Thane, West, Maharashtra - 400 604 Pan/Gir No. Aaspd6746L (Respondent) 2. Ita No. 2224/Mum/2025 S.A. No. 80/Mum/2025 (Assessment Year: 2013-14) 3. It(Ss)A No. 2223/Mum/2025 S.A. No. 81/Mum/2025 & 4. It(Ss)A No. 2222/Mum/2025 S.A. No. 82/Mum/2025 (Assessment Year: 2015-16) 5. It(Ss)A No. 2225/Mum/2025 S.A. No. 83/Mum/2025 (Assessment Year: 2016-17) Meghji Mansukhlal Dodhia House No. 104, Dodhia House, New Mavji Compound, Narpoli, Maharashtra-421 302 (Applicant) Dcit Cc-3, Thane Vs. Room No. 12, A Wing, 6Th Floor, Ashar It Park, Thane, West, Maharashtra - 400 604 Pan/Gir No. Aaspd6746L (Respondent) (2) It(Ss)A No. 2226, 2223, 2222 & 2225/Mum/2025 &

Section 132Section 143(3)Section 153ASection 68Section 69D

Commissioner of Income Tax (Appeals) erred in not quashing the assessment order as it was entirely based on borrowed information from Investigation Wing and without application of mind on the part of the Ld. Assessing Officer. 2. On the facts and in the circumstances of the appellant's case ... respect of unsecured loan received from M/s Vinam Finance Private Limited has been made solely on the basis of statements recorded by the Investigation Wing from Shri Sushil Goyal, an alleged entry operator, certain alleged dummy directors namely Shri Bhavik Jakharia and Shri Minesh Dodhia, and Shri Bhadresh Dodhia

Vikas Agarwal, Bulandshahr vs. ACIT, Central Circle, Meerut

The appeal of the assessee is allowed for statistical purposes

ITA 6486/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: NoneFor Respondent: Sh. Akhilesh Yadav, Sr. DR
Section 133(6)Section 143(3)Section 272A(2)(c)

that a search and seizure operation was carried out on the premises of the appellant comprising of Sh. Vipin Kumar & others on 05.02.2017, by investigation wing, Ghaziabad. The name of the appellant was also in the search warrant and a search was also conducted on his joint family home situated

Abhimanyu Nath, New Delhi vs. ITO Ward 30(1), Delhi

In the result, appeal of assessee in ITA No

ITA 4930/DEL/2025[2012-13]Status: DisposedITAT Delhi11 Feb 2026AY 2012-13

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Ms. Roli Choubey, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 147Section 148

year under consideration on 15.09.2012 declaring total income of Rs. 52,40,220/-. 3. The AO of the assessee received information from the Investigation Wing Department that M/s Keshav Cloth, Prop. Anita Rani Singhal, located Shop No. 2, Ground Floor, East Guru Angad Nagar, Delhi-110092, had provided accommodation purchase ... submitted that there is no independent application of mind by the LdAO. It is based simply on the information supplied by the Investigation Wing. It is submitted that the enquiry regarding the existence of M/s Keshav Cloth was made only during the assessment proceedings and not before framing the reasons

Nileshkumar M Bhalodi, Rajkot vs. The Income Tax Officer, Ward - 2(1)(1), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 7/RJT/2026[2015-16]Status: DisposedITAT Rajkot10 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Ms Devina Patel, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 250

filed u/s 139(1) of the Act, dated 23.06.2017. 4. In this case, the information was received by the assessing officer from the Investigation Wing, which suggests that the assessee had two bank accounts maintained with Axis Bank bearing A/c No.: 9150100294731338 913020001527257 in the name of Shri Nilesh Mansukhlal

Shri Kamlesh Vashrambhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Central Circle-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 65/RJT/2014[2010-11]Status: DisposedITAT Rajkot10 Feb 2026AY 2010-11

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No.451/Rjt/2013 (Assessment Years: (2008-2009) Shri Vashrambhai Ghelabhai Ramani, Vs. The Dcit, 22, Ranchodnagar Society, Kuvadava Central Circle-2, Road, Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bflpr5056N आयकर अपील सं./Ita Nos.65/Rjt/2014 (Assessment Years: (2010-11) & आयकर अपील सं./Ita Nos. 63/Rjt/2014 &407/Rjt/2014 (Assessment Year: 2011-2012) Shri Kamlesh Vashrambhai Ramani, Deputy Commissioner Of Income-Tax, Prop. Marutinandan Petroleum, 22, Vs. Central Circle-2, Ranchodnagar Society,Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahqpr2043D

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR
Section 132Section 143(3)Section 153ASection 271A

assessee, vide letter dated 08.11.2012, filed written submission. The assessee also filed copy of affidavit dated 30.6.2010, claimed to have been filed before the Investigation Wing, and also filed copy of a letter dated 25.01.2012 in which he has retracted from disclosure of additional income. The assessee Page