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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

ITO, Ward - 11(1), Kolkata vs. Sumangal Forex & Travels Pvt Ltd, Kolkata

ITA 2211/KOL/2024[2018-19]Status: DisposedITAT Kolkata11 Feb 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.2211/Kol/2024 Assessment Year: 2018-19 Ito, Ward-11(1), Kolkata …………………………………………….…..……Appellant Vs. Sumangal Forex & Travels Pvt. Ltd…………...........……........……...…..…..Respondent 9, Baliaghata Road, Kol-700015. [Pan: Aavcs1781J] C.O. No.60/Kol/2024 (Arising Out Of I.T.A. No.2211/Kol/2024 Assessment Year: 2018-19 Sumangal Forex & Travels Pvt. Ltd ……………….………………..….…..Cross-Objector 9, Baliaghata Road, Kol-700015. [Pan: Aavcs1781J] Vs. Ito, Ward-11(1), Kolkata................................................……........……...…..…..Respondent Appearances By: Shri Srikumar Banerjee, Ar, Appeared On Behalf Of The Assessee. Shri Arun Kr. Tiwari, Cit- Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : February 10, 2024 Date Of Pronouncing The Order : February 11, 2024 Order Per Sonjoy Sarma: The Revenue Has Filed An Appeal Against The Order Dated 25.07.2024 By The National Faceless Appeal Centre [Hereinafter Referred To As The ‘Cit(A)’] & The Assessee Has Filed The Corresponding Cross- Objection Relating To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Is A Company & Engaged In Foreign Currency Exchange Business As Forex Dealer. The Assessee Filed Its Return Of Income For Assessment Year 2018-19 Declaring Total Income Of Rs.1,45,236/-. Since, The Assessee Was Non-Responsive Before The Investigation Wing As Well As Before The Assessing Officer, The

Section 142(1)Section 147Section 148Section 69A

return of income for assessment year 2018-19 declaring total income of Rs.1,45,236/-. Since, the assessee was non-responsive before the investigation wing as well as before the Assessing Officer, the I.T.A. No.2211/Kol/2024 & C.O. No.60/Kol/2024 Assessment Year: 2018-19 Sumangal Forex & Travels Pvt. Ltd case of the assessee

Rajendra Goyal, New Delhi vs. ITO Ward-41(2), New Delhi

Appeals of the assessee are allowed

ITA 1941/DEL/2019[2013-14]Status: DisposedITAT Delhi11 Feb 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2011-12] Shri Umesh Kumar Bajaj, Vs Dcit, R-5/21, Raj Nagar, Central Circle, Ghaziabad-201002. Ghaziabad Pan-Abcpb4457B Appellant Respondent [Assessment Year : 2011-12] Acit, Vs Umesh Kumar Bajaj, Central Circle, House No.21, Sector-5, Ghaziabad Raj Nagar, Ghaziabad-201002. Pan-Abcpb4457B Appellant Respondent

Section 1

fact that the as per the CBDT guideline F. No. 286/161/2006-IT (Inv. II) dt. 22.12.2006, copy of appraisal report is shared by Investigation Wing with both that the assessing officer and Joint CIT. In fact, CBDT guideline dt. 22.12.2006 (Copy enclosed) on the subject of the search and Seizure Assessments

Deputy Commissioner O F Income Tax, Raipur vs. Balajee Loha Pvt. Ltd., Raipur

ITA 356/RPR/2024[2014-15]Status: DisposedITAT Raipur10 Feb 2025AY 2014-15

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 356/Rpr/2024 (िनधा"रण वष" Assessment Year: 2014-15)

For Appellant: Shri Amit M. Jain, Advocate &For Respondent: Shri S. L. Anuragi, CIT-DR
Section 143(3)Section 68

Income Tax & Ors. Vs. Krishna Devi & Ors (2021) 110 CCH 0009 Del HC, it was held that Reliance placed on the report of investigation wing. Without further corroboration on the basis of cogent material. does not Justify AO's conclusion that the transaction is bogus. sham and nothing other than

Sunita Jajoo, Surat vs. ITO Ward 2(2)(4), Surat

In the result, assessee’s appeal is allowed

ITA 882/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

From the reasons recorded, the following facts and sequence of events are observed: (a) Credible information was received by the AO from the DDIT Investigation Wing, Kolkata, regarding BSE listed Penny stock. ITA Nos.552 & 882/SRT/2024 (A.Y.11-12) Rambilash R Jajoo & Sunita Jajoo (b) The AO has noted that the information received ... from the DDIT Investigation Wing, Kolkata, has revealed that assessee has sold 5000 shares of Rs.3,85,006/- in the scrip Global Capital Market Limited. (c) The Assessing Officer specified the code number. (d) The AO noted that assessee has claimed exemption wrongly. (e) The AO finally recorded the reasons

Rambilash Rajaram Jajoo, Surat vs. Income Tax Officer Ward-2(2)(4), Surat

ITA 552/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) Rambilash Rajaram Jajoo (Physical Court Hearing) 429-432, Golden Point, Falsawadi, Ring Road, Surat City, Surat-395 002 [Pan : Aampj 0040 K] अपीलार्थी/Appellant Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 प्रत्यर्थी / Respondent आयकर अपील सं./Ita No. 882/Srt/2024 (Ay 2011-12) Sunita Jajoo 429-432, Golden Point, Near Bsnl Office, Falsawadi, Ring Road, Surat-395 002 [Pan: Aampj 0040 K] बनाम Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 अपीलार्थी/Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से /Assessee By Ms. Richa Toshniwal. Ca राजस्व की ओर से /Revenue By Shri Minal Kamble, Sr. Dr सुनवाई की तारीख/Date Of Hearing 23.01.2025 उद्घोषणा की तारीख/Date Of Pronouncement 10.02.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. These Two Appeals By Separate Assessee Are Directed Against The Separate Orders Of Addl/Jcit(A)-7, Kolkata/National Faceless Appeal Centre, Delhi [For Short To As "Nfac/Ld.Cit(A)] Dated 21.03.2024 & 21.04.2023 For Same

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

High Court in the case of Aradhan Estate (P) Ltd. vs. Dy. Commissioner of Income-tax wherein it was held that report received from investigation wing has a live link for formation of belief in respect of income escaped assessment. 4. In view of the above, I have reason ... From the reasons recorded, the following facts and sequence of events are observed: (a) Credible information was received by the AO from the DDIT Investigation Wing, Kolkata, regarding BSE listed Penny stock. (b) The AO has noted that the information received from the DDIT Investigation Wing, Kolkata, has revealed that

Deputy Commissioner of Income Tax Central Circle -1(2), Nagpur vs. Vidarbha Infotech Private Limited, Nagpur

In the result, appeal by the Revenue is dismissed

ITA 76/NAG/2024[2016-17]Status: DisposedITAT Nagpur10 Feb 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke
Section 133(6)Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 250Section 263Section 44ASection 69C

expenditure. 4. Facts in Brief:– The assessee is a company. On 26/12/2019, a survey under section 133A of the Act was conducted by the Investigation Wing, Income Tax Department, Nagpur. The assessee company is engaged in the business of construction, wholesale and retail trade and other services. On 17/10/2016

Asstt Commissioner of Income Tax Circle-2(1)(1) Agra, Sanjay Place vs. Mamta Agarwal, Bhagwati International

In the result, the appeal of the revenue is dismissed

ITA 399/AGR/2024[2014-15]Status: DisposedITAT Agra07 Feb 2025AY 2014-15

Bench: Shri M. Balaganesh**

For Appellant: Shri Amol Sinha, AdvFor Respondent: Shri Shailender Shrivastava, Sr. DR
Section 147Section 148Section 148A

filed by the assessee on 26.09.2014 declaring total income of Rs. 29,70,464/-. The ld AO on the basis of information received from Investigation Wing pertaining to one Prakash Gupta and his proprietorship concern namely Shri Trading Company, had initiated the reassessment proceedings in the case of the assessee ... Company as ingenuine is that Shri Prakash Gupta had not filed his return of income for AY 2013-14 and summons issued by the Investigation Wing on the said party remained unserved. The efforts of the Income Tax Inspector posted with the Investigation Wing also could not fructify as concern

Dy. Commissioner of Income Tax, Bilaspur vs. Ms Mayura Saria Pvt. Ltd., Bilaspur

ITA 430/RPR/2024[2015-16]Status: DisposedITAT Raipur07 Feb 2025AY 2015-16

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 430/Rpr/2024 ("नधा"रण वष" Assessment Year: 2015-16)

For Appellant: Shri G. S. Agrawal, CAFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 115JSection 132Section 142(1)Section 147Section 148Section 148ASection 250

Gujarat), 2018-TIOL-857-HC-AHM-IT, it was held that AO's fishing inquiry is valid if he receives certain information from the Investigation Wing and forms an opinion before issuance of reassessment 8 DCIT, Bilaspur Vs. M/s Mayura Saria Pvt. Ltd. notice. The appellant stressed that its submissions ... proceeded to add the amount i.e., Rs. 38104820/- being (credit Rs. 33804820/- and debit Rs. 4300000/-) on the basis of the report of the Investigation Wing and has not made any independent enquiry to substantiate that the submission of the assessee is not acceptable and that rejection of the submission

Ganraj Homes LLP, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, all the three appeals filed by the assessee are allowed

ITA 879/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Khairnar CIT-DR &
Section 132Section 133ASection 143(2)Section 153A

have received any on-money and neither he was confronted subsequently nor any of the customers who are identifiable were examined either by the Investigation Wing during the course of search or post- search enquiries or by the Assessing Officer at the time of assessment proceedings ... such on-money. Further, neither he was confronted subsequently nor any of the buyers / customers who are identifiable were examined/confronted either by the Investigation Wing during the course of search or post-search enquiries or by the Assessing Officer at the time of assessment proceedings. So far as the decision

Ganraj Homes LLP, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, all the three appeals filed by the assessee are allowed

ITA 878/PUN/2024[2017-18]Status: DisposedITAT Pune07 Feb 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Khairnar CIT-DR &
Section 132Section 133ASection 143(2)Section 153A

have received any on-money and neither he was confronted subsequently nor any of the customers who are identifiable were examined either by the Investigation Wing during the course of search or post- search enquiries or by the Assessing Officer at the time of assessment proceedings ... such on-money. Further, neither he was confronted subsequently nor any of the buyers / customers who are identifiable were examined/confronted either by the Investigation Wing during the course of search or post-search enquiries or by the Assessing Officer at the time of assessment proceedings. So far as the decision

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for

ITA 877/PUN/2024[2019-2020]Status: DisposedITAT Pune07 Feb 2025AY 2019-2020

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 132Section 143(2)Section 153A

have received any on-money and neither he was confronted subsequently nor any of the customers who are identifiable were examined either by the Investigation Wing during the course of search or post- search enquiries or by the Assessing Officer at the time of assessment proceedings ... such on-money. Further, neither he was confronted subsequently nor any of the buyers / customers who are identifiable were examined/confronted either by the Investigation Wing during the course of search or post-search enquiries or by the Assessing Officer at the time of assessment proceedings. So far as the decision

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for

ITA 876/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 132Section 143(2)Section 153A

have received any on-money and neither he was confronted subsequently nor any of the customers who are identifiable were examined either by the Investigation Wing during the course of search or post- search enquiries or by the Assessing Officer at the time of assessment proceedings ... such on-money. Further, neither he was confronted subsequently nor any of the buyers / customers who are identifiable were examined/confronted either by the Investigation Wing during the course of search or post-search enquiries or by the Assessing Officer at the time of assessment proceedings. So far as the decision

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for assessment years 2017-18 and 2018-19 are allowed and the appeal for assessment year 2019-20 is partly allowed

ITA 875/PUN/2024[2017-18]Status: DisposedITAT Pune07 Feb 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Kharnar CIT-DR &
Section 132Section 143(2)Section 153A

have received any on-money and neither he was confronted subsequently nor any of the customers who are identifiable were examined either by the Investigation Wing during the course of search or post- search enquiries or by the Assessing Officer at the time of assessment proceedings ... such on-money. Further, neither he was confronted subsequently nor any of the buyers / customers who are identifiable were examined/confronted either by the Investigation Wing during the course of search or post-search enquiries or by the Assessing Officer at the time of assessment proceedings. So far as the decision

Ganraj Homes LLP, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, all the three appeals filed by the assessee are allowed

ITA 874/PUN/2024[2019-20]Status: DisposedITAT Pune07 Feb 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Khairnar CIT-DR &
Section 132Section 133ASection 143(2)Section 153A

have received any on-money and neither he was confronted subsequently nor any of the customers who are identifiable were examined either by the Investigation Wing during the course of search or post- search enquiries or by the Assessing Officer at the time of assessment proceedings ... such on-money. Further, neither he was confronted subsequently nor any of the buyers / customers who are identifiable were examined/confronted either by the Investigation Wing during the course of search or post-search enquiries or by the Assessing Officer at the time of assessment proceedings. So far as the decision

Meenamani Ganga Builder LLP, Pune vs. Assistant Commissioner of Income Tax, Central Circle 2(3), Pune

In the result, all the three appeals filed by the assessee are partly allowed

ITA 872/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri Amol Kharnar CIT-DR
Section 132Section 143(2)Section 153A

have received any on-money and neither he was confronted subsequently nor any of the customers who are identifiable were examined either by the Investigation Wing during the course of search or post- search enquiries or by the Assessing Officer at the time of assessment proceedings ... such on-money. Further, neither he was confronted subsequently nor any of the buyers / customers who are identifiable were examined/confronted either by the Investigation Wing during the course of search or post-search enquiries or by the Assessing Officer at the time of assessment proceedings. So far as the decision

M/S Suncity Niketan Pvt.Ltd., Kolkata vs. Income Tax Officer, 5(1), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 2101/KOL/2024[2013-14]Status: DisposedITAT Kolkata07 Feb 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.2101/Kol/2024 Assessment Year: 2013-14 M/S Suncity Niketan Pvt. Ltd………………....….......…....………....Appellant 5, Clive Row, Kolkata -1. [Pan: Aapcs4157E] Vs. Ito, Ward-5(1), Kolkata......................................................…..…..... Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Appellant. Shri Subhendu Datta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 12, 2024 Date Of Pronouncing The Order : February 07, 2025 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 06.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Is Aggrieved By The Action Of The Ld. Cit(A) In Confirming The Addition Of Rs.17,99,28,555/- Made By The Assessing Officer By Treating Credits In The Account Of The Assessee As Income Of The Assessee From Unexplained Sources. The Assessee Apart From Challenging The Validity Of The Additions Made/Confirmed By The Lower Authorities On Merits, Has Also Contested The Very Validity Of The Reopening Of The Assessment Order As Well As The Validity Of The Assessment Order For Want Of Issue Of Notice U/S 143(2) Of The Act.

Section 143(2)Section 147Section 250

income. I.T.A. No.2101/Kol/2024 Assessment Year: 2013-14 M/s Suncity Niketan Pvt. Ltd ii. From the recorded reasons mentioned above it transpires that the Investigations wing has presumed that we are a beneficiary person which is without any iota of evidence or without any conclusive proof of any wrong doing ... part. iii. The reasons recorded by you for issue of Notice under section 148 are not your reasons but borrowed satisfaction from Investigation Wing and the re-assessment proceedings based on such borrowed reasons is without jurisdiction, illegal and void ab initio and is liable to be dropped. iv. There

Gautam Surendra Jaggi, Mumbai vs. ACIT, 27(1)-Vashi, Mumbai

In the result, appeal of the assessee is allowed

ITA 5545/MUM/2024[2013-14]Status: DisposedITAT Mumbai07 Feb 2025AY 2013-14

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Shailesh Shah, A/RFor Respondent: Shri Pushkaraj Bhangepatil, Sr. D/R
Section 142(1)Section 147Section 148Section 68

circumstances of the case, the Ld. CIT(Appeals) upheld the order of Ld. A.O wherein additions is made merely on the information received from investigation wing and without any cross-examination or providing any seized material. That the appellant craves leave to add, to amend, modify, rescind, supplement or alter

Rajarshi Motors Pvt. Ltd., Agartala vs. Deputy Commissioner of Income Tax, Circle- Agartala, Agartala

In the result, all the grounds of appeal raised by the Revenue in ITA Nos

ITA 186/GTY/2018[2014-15]Status: DisposedITAT Guwahati06 Feb 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Manomohan Dasआयकर अपील सं. / Ita Nos.117 To 123/Gty/2018 िनधा"रण वष" / Assessment Years : 2008-09 To 2014-15 Dcit, Rajarshi Motors Pvt. Ltd., Circle Agartala A.A. Road, Chandrapur, Vs. Agartala, Tripura Pan : Aaccr8033P अपीलाथ" / Appellant ""यथ" / Respondent

For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri Kaushik Ray, JCIT
Section 132Section 132(4)Section 142(1)Section 143(2)Section 153A

group no explanation could be given for a satisfactory reply. But, in reply to our letter dated 15-12-2015 to the DDIT, Investigation Wing, Unit- 1(1), Guwahati, it was verified via their letter dated 18-12-2015 that Swapan Kumar Paul, who is the MD of the assessee

Rajarshi Motors Pvt. Ltd., Agartala vs. Deputy Commissioner of Income Tax, Circle- Agartala, Agartala

In the result, all the grounds of appeal raised by the Revenue in ITA Nos

ITA 185/GTY/2018[2013-14]Status: DisposedITAT Guwahati06 Feb 2025AY 2013-14

Bench: Dr.Manish Borad & Shri Manomohan Dasआयकर अपील सं. / Ita Nos.117 To 123/Gty/2018 िनधा"रण वष" / Assessment Years : 2008-09 To 2014-15 Dcit, Rajarshi Motors Pvt. Ltd., Circle Agartala A.A. Road, Chandrapur, Vs. Agartala, Tripura Pan : Aaccr8033P अपीलाथ" / Appellant ""यथ" / Respondent

For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri Kaushik Ray, JCIT
Section 132Section 132(4)Section 142(1)Section 143(2)Section 153A

group no explanation could be given for a satisfactory reply. But, in reply to our letter dated 15-12-2015 to the DDIT, Investigation Wing, Unit- 1(1), Guwahati, it was verified via their letter dated 18-12-2015 that Swapan Kumar Paul, who is the MD of the assessee

Rajarshi Motors Pvt. Ltd., Agartala vs. Deputy Commissioner of Income Tax, Circle- Agartala, Agartala

In the result, all the grounds of appeal raised by the Revenue in ITA Nos

ITA 184/GTY/2018[2012-13]Status: DisposedITAT Guwahati06 Feb 2025AY 2012-13

Bench: Dr.Manish Borad & Shri Manomohan Dasआयकर अपील सं. / Ita Nos.117 To 123/Gty/2018 िनधा"रण वष" / Assessment Years : 2008-09 To 2014-15 Dcit, Rajarshi Motors Pvt. Ltd., Circle Agartala A.A. Road, Chandrapur, Vs. Agartala, Tripura Pan : Aaccr8033P अपीलाथ" / Appellant ""यथ" / Respondent

For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri Kaushik Ray, JCIT
Section 132Section 132(4)Section 142(1)Section 143(2)Section 153A

group no explanation could be given for a satisfactory reply. But, in reply to our letter dated 15-12-2015 to the DDIT, Investigation Wing, Unit- 1(1), Guwahati, it was verified via their letter dated 18-12-2015 that Swapan Kumar Paul, who is the MD of the assessee