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“investigation wing”

ReassessmentSection 147Section 14712,584 judgments

The decision most relied on for investigation wing is PCIT v. RMG Polyvinyl (I) Ltd. (396 ITR 5), cited in 272 judgments on BharatTax.

Leading authorities on investigation wing

PCIT v. RMG Polyvinyl (I) Ltd.
396 ITR 5 · 2017 · High Court
272
citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

109 TTJ 700 (Del) SMC Share Brokers Ltd. v. DCIT
293 ITR 43 · 2007 · High Court
264
citing judgments

Where an assessment order is merely a copy-paste of observations from an investigation wing's appraisal report without independent verification, it is not a valid basis for making additions to income.

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

ITO, 19(3) (4) Mumbai v. Shamim M Bharwani
69 Taxmann.com 65 · 2016 · Reported
142
citing judgments

Long Term Capital Gains (LTCG) from penny stock transactions are liable to be treated as bogus and added back under Section 68 as unexplained cash credits, especially when evidence suggests the involvement of entry operators providing accommodation entries.

1. Harikishan S. Virmani v. DCIT
394 ITR 146 · 2017 · High Court
97
citing judgments

Reassessment proceedings under section 147 cannot be initiated by the Assessing Officer based on borrowed satisfaction, vague information from the Investigation Wing, or incorrect jurisdictional facts without independent application of mind. Reopening beyond four years from the end of the relevant assessment year, especially where an original assessment was completed under section 143(3), requires specific conditions relating to the assessee's failure to disclose material facts.

ITO v. Purushottam Das Bangur
224 ITR 362 · 1997 · Supreme Court
90
citing judgments

Information received from the investigation wing constitutes valid 'reason to believe' for initiating reassessment proceedings under Sections 147/148, provided the Assessing Officer applies their mind to the material and does not act mechanically. Prompt issuance of a notice based on such information does not automatically imply a lack of due diligence or borrowed satisfaction.

AGR Investment v. Additional Commissioner
197 Taxmann 177 · 2011 · High Court
81
citing judgments

A reassessment under Section 147/148 is valid if initiated based on specific, non-vague information, even from an investigation wing, provided the Assessing Officer applies independent mind to form a 'reason to believe' that income has escaped assessment.

56 (Guj.) (para 6) v. Aaspas Multimedia Ltd. v. Dy. CIT
83 Taxmann.com 82 · 2017 · High Court
78
citing judgments

Information received from the Investigation Wing, identifying the assessee as a beneficiary of accommodation entries through share application from a third party, constitutes valid tangible material and 'reasons to believe' for initiating reassessment proceedings under Section 147 of the Income Tax Act.

Judgments citing investigation wing

DCIT, Jaipur vs. Amrapali Jewels Pvt. Ltd., Jaipur

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

ITA 740/JPR/2024[2021]Status: DisposedITAT Jaipur19 Feb 2025

Bench: Him.

For Appellant: Sh. Sanjay Jhanwar, Sr. AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 145(3)Section 153DSection 251Section 69B

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

Manoj Madanlal Chhajed, Pune vs. The Assistant Commissioner of Income Tax, Central Circle-1(1), Pune

In the result, both the appeals filed by the assessee are allowed

ITA 2017/PUN/2024[2011-12]Status: DisposedITAT Pune19 Feb 2025AY 2011-12

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Suhas P Bora, H G Sharma
Section 132Section 132(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

Q.24 I am now showing you're the statement recoded of Shri Parveen Agarwal, Shri Anuj Agarwal and Shri jeevendra Mishra recorded by the Investigation Wing, Kolkata. In these statements your attention is invited to the fact that the above unsecured lenders have been declared as bogus shell companies providing ... shell companies based in Kolkata and such unsecured loan entries are to the tune of Rs.10,42,46,375/-. It was proved by the Investigation Wing that these companies from whom the assessee obtained loans are shell companies and are not doing any business. Therefore, the case of the assessee

Shri Manoj Madanlal Chhajed, Pune vs. The Assistant Commissioner of Income Tax, Central Circle-1(1), Pune

ITA 1178/PUN/2023[2011-12]Status: DisposedITAT Pune19 Feb 2025AY 2011-12

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 132Section 132(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

Q.24 I am now showing you're the statement recoded of Shri Parveen Agarwal, Shri Anuj Agarwal and Shri jeevendra Mishra recorded by the Investigation Wing, Kolkata. In these statements your attention is invited to the fact that the above unsecured lenders have been declared as bogus shell companies providing ... shell companies based in Kolkata and such unsecured loan entries are to the tune of Rs.10,42,46,375/-. It was proved by the Investigation Wing that these companies from whom the assessee obtained loans are shell companies and are not doing any business. Therefore, the case of the assessee

Abans Metals Private Ltd, Mumbai vs. Assistant Commissioner of Income Tax -4(3), Mumbai

In the result, in view of judgment in ITA No

ITA 3519/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 Feb 2025AY 2018-19

Bench: Shri Narender Kumar Choudhryassessment Year: 2018-19 M/S. Abans Enterprises Ltd., Assistant Commissioner 36, 37, 38A Nariman Bhavan, Of Income Tax-4(3), Backbay Reclamation, (1) Office Of The Acit-4(3), Central Circle, 19Th Floor, Nariman Point, Mumbai Air India Building, Maharashtra – 400 021 Mumbai – 400 021 Pan: Aaacm3843L Vs. (2) Kautilya Bhawan, Avenue 3, Near Videsh Bhavan, G Block, Bandra Kurla Complex Bandra East, Mumbai (Mah) – 400 051 (Appellant) (Respondent) -A N D- Assessment Year: 2018-19

For Appellant: Shri Suyog Bhave, Ld. A.RFor Respondent: Shri Srinivas P., Ld. Sr. D.R
Section 133ASection 250

director of the company, Mr. Hardik Gandhi, attended the summons proceedings, thus the information is factually incorrect. This fact is not commented upon by investigation wing. The assessing officer did not carry out any investigation or reverification. D. Specific Allegations for Yogdarshan 1. Inquiry was Based on the information provided ... Soni, a director is not men of means. Further, the director sought adjournment to another date, but no fresh date was given by the investigation wing during COVID. AO also did not seek his attendance in assessment proceedings. F. Alleged allegations for Trishna 1. Based on returns The income shown

Abans Enterprises Ltd., Mumbai vs. ACIT, Central Circle-4(3), Mumbai

In the result, in view of judgment in ITA No

ITA 3498/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 Feb 2025AY 2018-19

Bench: Shri Narender Kumar Choudhryassessment Year: 2018-19 M/S. Abans Enterprises Ltd., Assistant Commissioner 36, 37, 38A Nariman Bhavan, Of Income Tax-4(3), Backbay Reclamation, (1) Office Of The Acit-4(3), Central Circle, 19Th Floor, Nariman Point, Mumbai Air India Building, Maharashtra – 400 021 Mumbai – 400 021 Pan: Aaacm3843L Vs. (2) Kautilya Bhawan, Avenue 3, Near Videsh Bhavan, G Block, Bandra Kurla Complex Bandra East, Mumbai (Mah) – 400 051 (Appellant) (Respondent) -A N D- Assessment Year: 2018-19

For Appellant: Shri Suyog Bhave, Ld. A.RFor Respondent: Shri Srinivas P., Ld. Sr. D.R
Section 133ASection 250

director of the company, Mr. Hardik Gandhi, attended the summons proceedings, thus the information is factually incorrect. This fact is not commented upon by investigation wing. The assessing officer did not carry out any investigation or reverification. D. Specific Allegations for Yogdarshan 1. Inquiry was Based on the information provided ... Soni, a director is not men of means. Further, the director sought adjournment to another date, but no fresh date was given by the investigation wing during COVID. AO also did not seek his attendance in assessment proceedings. F. Alleged allegations for Trishna 1. Based on returns The income shown

Mustansir Moiz Boriawala, United Arab Emirates vs. Income Tax Officer (International Tax), Mumbai

In the result, the appeal filed by the Assessee stands allowed for statistical purposes

ITA 1899/MUM/2024[2012-2013]Status: DisposedITAT Mumbai19 Feb 2025AY 2012-2013

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Nikhil Zaveri, ARFor Respondent: Shri Srinivas P., Sr.DR
Section 115JSection 139Section 147Section 148Section 195Section 250Section 68

hereinafter referred to as ‘the Act’). 2 2. In this case, an information was received from the office of Dy. Director of Income Tax (Investigation) Wing, Unit-7(3), Mumbai to the effect that the Assessee has done share trading of BSE in the scrip namely M/s. VMS Industries ... also no objection whatsoever to the action proposed in the notice issued. The AO thereafter analyzing the information received and the findings of the investigation wing for analysis of penny stock and at least 3 considering the peculiar facts that the Assessee till date of passing the assessment order

ACIT, CC- 18, New Delhi vs. Shrey Properties Pvt. Ltd., New Delhi

Appeal is dismissed

ITA 5182/DEL/2017[2011-12]Status: DisposedITAT Delhi19 Feb 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2014-15 Vs. National Rupali Gupta, Faceless Appeal 273, Budhana Gate, Meerut, Centre, Delhi Uttar Pradesh Pan: Ajcpg6194L (Appellant) (Respondent) Assessee By None Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 13.10.2025 Date Of Pronouncement 13.10.2025 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2014-15, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1068639287(1), Dated 12.09.2024 Involving Proceedings Under Section 147 R.W.S. 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Case Called Twice. None Appears At The Assessee’S Behest. She Had Also Not Put In Appearance On All The Earlier Five Opportunities Of Hearing As Well. The Assessee Is Accordingly Proceeded Ex-Parte. 2. It Next Transpires With The Able Assistance Coming From The Revenue Side That Both The Learned Lower Authorities Have Inter Alia Treated The Assessee’S Alleged Capital Gains Derived From Sale Of Shares Amounting To Rs.48,28,090/- As Bogus Followed By 5% Commission Expenditure Thereupon Coming To Rs.2,41,405/- As Unexplained Under Section 69C; Respectively, In Assessment Order Dated 28Th March, 2022 & Upheld In The Lower Appellate Discussion, As Followed: “4. The Present Appeal Was Filed By The Appellant On 21.04.2022 By Raising 20 Grounds Of Appeal. During The Course Of Appeal Proceedings, Hearing Notices Were Sent On 15.07.2024, 01.08.2024 & 20.08.2024. In Response To The Notices Issued The Appellant Filed Only A Brief Written Submission As Under:

Section 147Section 68Section 69C

Appeal. The appellant had filed the return of income on 22.03.2015 by declaring a total income of The AO received clearcut information from the Investigation Wing that she had traded in the scrips of M/S Presha Metallurgical Ltd. for the total value of As per the information ... speaking order by detecting the entire modus operandi. 8. As a result, this appeal.” 3. It has come on record that the department’s investigation wing has found several evidence that there had been an artificial price rigging involving M/s. Presha Metallurgical Ltd. And also that the market regulator, namely

ACIT, New Delhi vs. Smt. Shashi Mehta, New Delhi

ITA 271/DEL/2015[2011-12]Status: DisposedITAT Delhi19 Feb 2025AY 2011-12

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1 ITA Nos. 2713-2714/Del/2023; ITA Nos. 7,51,271/Del/2024 etc. Super Cassettes Industries Pvt. Ltd. IN THE INCOME

The DCIT, Central Circle-1(1), Ahmedabad vs. Shri Rajendra J Keshwani (HUF), Ahmedabad

The appeal of the Revenue is dismissed

ITA 30/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad18 Feb 2025AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.30/Ahd/2021 िनधा"रण वष" /Assessment Year : 2015-16 The Dcit Shri Rajendra J. Keshwani बनाम/ Central Circle-1(1) (Huf) V/S. Ahmedabad-380 009 44, Asopalav Bungalows Nr.Muktidham Jain Temple Thaltej, Ahmedabad "थायी लेखा सं./Pan: Aaehk 1973 J अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri Kavan Limbasiya, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/02/2025 घोषणा की तारीख /Date Of Pronouncement: 18/02/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri Kavan Limbasiya, Sr.DR
Section 10(38)Section 143(1)Section 143(2)Section 68

Vakil [2014] 41 taxmann.com 425 and Pr. CIT v. Maheshchandra G. Vakil [2013] 40 taxmann.com 326, has held that mere reliance on the Investigation Wing’s report and abnormal price fluctuations cannot justify an addition under Section 68 unless there is specific material to prove that the transaction

Candor Renewable Energy Private Limited, Mumbai, Maharashtra vs. Income Tax Officer Circle 3(3), Mumbai, Kautilya Bhavan

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

ITA 6600/MUM/2024[2010-11]Status: DisposedITAT Mumbai18 Feb 2025AY 2010-11

Bench: Shri Narender Kumar Choudhry, Jm & Shri Prabhash Shankar, Am

For Appellant: Shri Mani Jain, ARFor Respondent: 11/02/2025
Section 144Section 147Section 148Section 250

return and even physical service through Inspector could not be done as the assessee was not found traceable. As per the information by the Investigation wing of the department, the assessee was found to have purchased shares of certain Penny stock company for a sum of Rs 90 lakh

Jayantilal Rajmal Seth, Mumbai vs. Dy. Commission of Income Tax, Central Circle 4(3), Mumbai

In the result the appeal filed by the assessee stands partly allowed

ITA 5776/MUM/2024[2017-18]Status: DisposedITAT Mumbai18 Feb 2025AY 2017-18

Bench: Smt. Beena Pillai () I.T.A. No.5776/Mum/2024 Assessment Year: 2017-18

Section 115BSection 131Section 132Section 142(1)Section 143(2)Section 143(3)Section 153ASection 69A

return of income 30/01/2018 declaring total income at Rs. 23,65,750/-. It is submitted that an information was received on 19/12/2016 by the Investigation wing Mumbai, from police inspector that cash of Rs. 25 lacs was found in possession of assessee during an interception on 16/12/2016. 2.1 Based

Meena Hasmukh Savla, Matunga Mumbai vs. Assessment Unit, National Faceless Assessment Centre

In the result the appeal filed by the assessee is

ITA 2910/MUM/2024[2016-17]Status: DisposedITAT Mumbai18 Feb 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain

Section 10Section 10(38)Section 143Section 143(1)Section 143(2)Section 147Section 148Section 151Section 250Section 68

Appellant had sold shares in scrip M/s. Ojas Asset Reconstruction Co. Ltd [new name is Toyam Industries Ltd]. In the meanwhile, the Director of Investigation Wing, Delhi had carried out country wide investigation in order to unearth the organized racket generating Long Term Capital Gain which is exempt from Income ... Assessing Officer, after the examination of the information provided by the Investigation Wing and return of income of the Appellant, the case of the Appellant was reopened under section 147 of Income Tax Act, 1961 and notice under section 148 was issued on 22/07/2022. 2.4 Thereafter, various notices under section

Mukta Agriculture Limited, Mumbai vs. ITO Ward 10(3)(3), Mumbai

In the result, ground no. 3 with its sub grounds is allowed

ITA 3211/MUM/2023[2013-14]Status: DisposedITAT Mumbai18 Feb 2025AY 2013-14

Bench: Shri Narender Kumar Choudhryassessment Year: 2013-14

For Appellant: Shri N.R. Agrawal, Ld. C.AFor Respondent: Shri Srinivas P., Ld. Sr. D.R
Section 133(1)(d)Section 133(6)Section 143(1)Section 145(3)Section 250

show caused the Assessee accordingly and in the meanwhile, issued a commission u/s 133(1)(d) of the Act, to the ITO, investigation wing, Rajkot on dated 11.03.2016 to verify physical existence of these companies and the genuineness of sales and purchases transactions of these companies with the Assessee company

DCIT 19(1), Mumbai vs. Pavan Kumar B Chandan, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 2592/MUM/2023[2015-16]Status: DisposedITAT Mumbai18 Feb 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Devendra Jain,ARFor Respondent: Shri Mahesh Pamnani (Sr.DR)
Section 143(3)Section 68Section 69

disallowance of Long Term Capital Gains of Rs. 92,19,830/- without considering the fact that Assessing Office relying on the report of Investigation wing which is premier investigation authority of Income tax department and the onus is on the assessee to establish the genuineness of the price hike ... some of these shares deriving LTCG. 3.1 In the assessment order passed u/s 143(3) of the Act, the AO noted that the Kolkata Investigation Wing had undertaken investigation into 84 penny stocks which identified shares of STL as a penny stock. The AO took note of the modus operandi

ITO-19(3)(1), Mumbai vs. S P International, Mumbai

In the result the appeal filed by the revenue stands dismissed

ITA 6580/MUM/2024[2010-11]Status: DisposedITAT Mumbai17 Feb 2025AY 2010-11

Bench: Smt. Beena Pillai () I.T.A. No.6580/Mum/2024 Assessment Year: 2010-11

Section 132(4)

purchases from M/s. Andi & Kalash Enterprises, by ignoring the fact that action of the Assessing officer was based on the information of the DGIT (Investigation Wing) Mumbai, proved beyond doubt with the evidences/documents that M/s Andi & Kalash Enterprises, both are paper/dummy companies, managed and controlled by Mr. Rajendra Jain Sanjay ... that, the said group concerns were engaged in providing accommodation entry of bogus purchases and sales/bogus unsecured loan are advanced to various beneficiaries. The investigation wing found that the assessee has 4 ITA 6580/Mum/2024 A.Y. 2010-11 obtained accommodation entry in the form of bogus purchases during the financial year

Cle Private Limited, Mumbai vs. DCIT Central Circle -3(4), Mumbai

In the result, appeal of the Revenue is dismissed and cross objection of the assessee is allowed

ITA 6270/MUM/2024[2017-18]Status: DisposedITAT Mumbai17 Feb 2025AY 2017-18

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Shri Niraj Sheth a/w Jitendra SanghviFor Respondent: Shri R.A. Dhyani, CIT/DR &
Section 115JSection 133(6)Section 143(3)Section 147Section 68

action of re-opening of assessment by the Assessing Officer to be valid and as per law and supported by specific material from the investigation wing. The Appellant submits that the reopening of assessment on the basis of details / evidences received from the Investigation wing without providing the same ... Assessing Officer of passing the re-assessment order u/s. 143(3) r.w.s. 147 of the Act without providing the details / evidences received from the Investigation wing to the Appellant and without providing an opportunity for cross examination of the said information / party relied by the Assessing Officer, thereby passing

Cle Pvt Ltd, Mumbai vs. DCIT Central Circle 3(4), Mumbai

In the result, appeal of the Revenue is dismissed and cross objection of the assessee is allowed

ITA 6269/MUM/2024[2015-16]Status: DisposedITAT Mumbai17 Feb 2025AY 2015-16

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Shri Niraj Sheth a/w Jitendra SanghviFor Respondent: Shri R.A. Dhyani, CIT/DR &
Section 115JSection 133(6)Section 143(3)Section 147Section 68

action of re-opening of assessment by the Assessing Officer to be valid and as per law and supported by specific material from the investigation wing. The Appellant submits that the reopening of assessment on the basis of details / evidences received from the Investigation wing without providing the same ... Assessing Officer of passing the re-assessment order u/s. 143(3) r.w.s. 147 of the Act without providing the details / evidences received from the Investigation wing to the Appellant and without providing an opportunity for cross examination of the said information / party relied by the Assessing Officer, thereby passing

Chintan Shailesh Shah, Mumbai vs. ITO Ward-30(1)(2), Now ITO Ward-41(3)(1), Mumbai

In the result, the appeal filed by the assessee stands dismissed with no order as to cost

ITA 2469/MUM/2024[2014-15]Status: DisposedITAT Mumbai17 Feb 2025AY 2014-15

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankarchintan Shailesh Shah Vs. Ito, Ward 30(1)(2) Rushikesh, Shanti Nagar, (Now Ward 41(3)(1)) Adarsh Dugdhalaya Kautilya Bhavan, Bkc, Malad (W), Mumbai – Bandra (E), Mumbai – 400064. 400051. Pan/Gir No. Amzps2768Q (Applicant) (Respondent)

Section 10(38)Section 133(6)Section 250Section 68

taxmann.com 402 (Calcutta) and also by Hon'ble ITAT in Hemil Subhashbhai Shah ITA No.1121/Ahd/2018 dated 12/06/2023 regarding the furnishing of report of investigation wing to the assessees and the issue of cross-examination of persons whose statements were relied upon by the Department in such reports. In addition ... appellant's transactions cannot be accepted as genuine. 6.2.6 As has been brought out above, the AO had not merely relied upon report of Investigation wing or statement of third parties, he carried out extensive analysis of share price movement & financial data of the penny stock, he also recorded statement

Deputy Commissioner of Income Tax Central Circle-1(3), Nagpur vs. M/S. Fuelco Coal India Ltd., Nagpur

Appeal of the Revenue is dismissed

ITA 90/NAG/2022[2014-15]Status: DisposedITAT Nagpur14 Feb 2025AY 2014-15

Bench: Shri V. Durgarao & Shrik.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Sandipkumar Salunke
Section 143(2)Section 143(3)Section 36(1)(iii)Section 40Section 40aSection 68

that it can also be paid out of borrowed funds. It was also noted that the AO had referred the matter to Department's Investigation wing of Kolkata and the latter had the companies were in existence and had filed returns of income for concerned assessment year. These facts were

Anil Radheshyam Chokhani, Mumbai vs. Income Tax Officers 17(1)(2), Mumbai

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

ITA 6678/MUM/2024[2011-12]Status: DisposedITAT Mumbai14 Feb 2025AY 2011-12

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeeassessment Year : 2011-12

For Appellant: Shri Dharan GandhiFor Respondent: Shri Ram Krishn Kedia, Sr.DR
Section 148

documents furnished by the assessee, but proceeded to make addition on the basis of unverified information given by the ADIT (Investigation Wing). Since the assessee has proved the claim of purchases with necessary evidences, we are of the view that the impugned disallowance could not be sustained. Accordingly