“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

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

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

citing judgments

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

AGR Investment v. Additional Commissioner

197 Taxmann 177 · 2011 · High Court

citing judgments

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

56 (Guj.) (para 6) v. Aaspas Multimedia Ltd. v. Dy. CIT

83 Taxmann.com 82 · 2017 · High Court

citing judgments

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

Aradhna Estate Pvt. Ltd. v. DCIT

91 Taxmann.com 119 · 2018 · High Court

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

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 63/RJT/2014[2011-12]Status: DisposedITAT Rajkot10 Feb 2026AY 2011-12

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

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 407/RJT/2014[2011-12]Status: DisposedITAT Rajkot10 Feb 2026AY 2011-12

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR

Section 132Section 143(3)Section 153ASection 271A

Shri Vashrambhai Ghelabhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Cen.Cir.-2, Rajkot-Gujarat

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

ITA 451/RJT/2013[2008-09]Status: DisposedITAT Rajkot10 Feb 2026AY 2008-09

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR

Section 132Section 143(3)Section 153ASection 271A

Mr. Saurabh Anil Gandhi, Mumbai vs. Income Tax Officer Ward 42(3)(3), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 8437/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Feb 2026AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailmr. Saurabh Anil Gandhi A-502 Chanakya Chs Ltd. Mahavir Nagar, Opp. Ekta Nagar, New Link Road, Kandivali West, Mumbai- 400067 ............... Appellant Pan: Aelpg7302J

For Appellant: Shri Nikhil Tiwari a/wFor Respondent: Shri Pravin Salunkhe, Sr. DR

Section 132Section 147Section 148Section 153CSection 250Section 35Section 80Section 80G

respect of donation made to the Navjeevan Charitable Trust. Subsequently, on the basis of the information received from the Investigation Wing regarding the search action under section 132 of the Act conducted on the Navjeevan Charitable Trust, wherein it was noticed that all the expenses of the Trust were mere ... same. 8. The learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee on this issue and held that the Investigation Wing’s findings demonstrate an organised modus operandi, whereby the donations received via cheque/RTGS were returned to the donor in cash after deducting commission. The learned

Income Tax Officer-17(1)(1), Mumbai vs. Anantam, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 6661/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Feb 2026AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarincome Tax Officer – 17(1)(1), V/S. Anantam 233, Kautilya Bhavan, Bandra बनाम 76, Bombay Mutual Fund, Kurla Complex, Bandra (East), Sir Pm Road, Fort, Mumbai Mumbai 400051, Maharashtra – 400 001, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aajfa7749R Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri D.C. Jain, ARFor Respondent: Shri Surendra Mohan (Sr. DR)

Section 115BSection 147Section 69C

establish the impugned purchase as bogus through any independent enquiry and proper verification. The AO totally relied upon the information received from the Investigation Wing. Even, he had not conducted any cross examination to verify the veracity of the information. Accordingly, the entire addition of Rs.1 ... details and evidences. However, the AO failed to point out any infirmity therein as also the book results. He merely placed reliance on the Investigation wing report without making any independent inquiry or investigation into the matter at all. Therefore, he failed to bring on record any corroborative evidence

DCIT Circle 2(3)(1), Mumbai vs. Tata Steel Limited, Mumbai

The appeal of the Revenue is dismissed

ITA 6471/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Feb 2026AY 2010-11

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokardcit Circle-2(3)(1) Tata Steel Limited 552, 5Th Floor, Aayakar Bombay House, 24, Bhavan, M. K. Road, Vs. Homi Mody Street, Mumbai-400 020 Fort, Mumbai, Gpo, Mumbai-400 001 Pan/Gir No. Aaacb1247M (Applicant) (Respondent) Revenue By Shri Ritesh Misra, Ld. Dr Assessee By Ms. Jasmin Amalasadvala, Ld. Ar Date Of Hearing 27.01.2026 Date Of Pronouncement 10.02.2026

Section 115JSection 131Section 133(6)Section 147Section 148Section 153ASection 250Section 268ASection 68

total income at Rs. 636,97,12,178/-.Thereafter, reassessment proceedings were initiated under section 148 on 29.03.2017 based on information received from the Investigation Wing alleging that the assessee was beneficiary of accommodation entries from M/s P.K. Enterprises. 3. The Assessing Officer made the following additions ... circumstances of the case, the Learned CIT(A) failed to consider that the Assessing Officer, based on credible inputs from the Investigation Wing, undertook detailed inquiries including summons under section 131 and inquiry under section 133(6), which established the non-genuineness of the transactions, cancelation of VAT registration

DCIT - 19(1), Mumbai, Lalbaugh vs. Bharat Ramji Bhai Manek, Grant Road Mumbai

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

ITA 4339/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Feb 2026AY 2014-15

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Ronak DoshiFor Respondent: Shri Leyaqat Ali Aafaqui, (SR DR)

Section 10(38)Section 143(3)Section 250

LTCG bogus. Rebuttal to CIT(A): The CIT(A) failed to consider the holistic evidence, including SEBI's confirmation of price rigging and the Investigation Wing's report on accommodation entries. Accepting documentation without probing intent overlooks the artificial structure, as the transaction was executed solely to claim tax-exempt ... Bharat Ramji Bhai Manek Failure to Appreciate the "Penny Stock" Modus Operandi: The CIT(A) failed to consider the holistic picture painted by the Investigation Wing. The detailed modus operandi-preferential allotment, price rigging through circular trading, use of exit providers, and statements of entry operators like Shri Raj Kumar

Krishan Pal, Gurgaon vs. ITO, Ward 2(2)-Gurgaon, Gurgaon

Appeal is allowed

ITA 139/DEL/2026[2014-15]Status: DisposedITAT Delhi10 Feb 2026AY 2014-15

Bench: Sh. Satbeer Singh Godaraita No. 139/Del/2026 : Asstt. Year: 2014-15 Krishan Pal, Vs Income Tax Officer, C/O Ca M R Sahu, Ward-2(2), House No. 651, 1St Floor, Sector- Gurgaon, 10A, Near G. D. Goenka Public Haryana-22001 School, Gurgaon-122001 (Appellant) (Respondent) Pan No. Asqpk6236J Assessee By: Sh. M. R. Sahu, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2014-15 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1068016367(1) Dated 27.08.2024, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. R. Sahu, CAFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 142(1)Section 147Section 148Section 151ASection 80C

assessee was re-opened u/s 147 of the Act. The Assessing Officer (hereinafter referred to as ld. 'AO') received information from the investigation wing, Kolkata wherein it was mentioned that in course of the investigation in the case of M/s. Darsh Coke Trading Pvt. Ltd., it was revealed that

Manoj Saboo, New Delhi vs. ITO- Ward 58(2), New Delhi

ITA 4816/DEL/2025[2011-12]Status: DisposedITAT Delhi10 Feb 2026AY 2011-12

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

therefore, dismissed as not pressed. 3. Brief facts of the case: The AO had received information from the DDIT (Inv) Unit-4, Investigation Wing vide letter F.No. 03/DDIT (Inv) /Unit-4(1)/2017-18/190 dated 09.03.2018 that the following credits were made in the Bank account of Shri Amit Gupta (PAN AJTPG0879R ... case of appellant of Rs.46,12,28,028/- was on the basis of facts gathered during the DRI search proceedings and investigation by the Investigation Wing of the Income-tax Department where conclusive finding has been made that the appellant and Shri Naveenkumar Goyal played an active role in depositing

Shankar Rice Mill, Mahasamund vs. ITO, Mahasamund

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

ITA 628/RPR/2025[2014-15]Status: DisposedITAT Raipur09 Feb 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.628/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 Shankar Rice Mill Kh. No.161, Lakhagarh, Kishanpur B.O., Shanti Nagar, Pithora, Mahasamund Pan: Acffs3275C

For Appellant: Shri Bikram Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(3)Section 147Section 148Section 69C

bogus concern M/s.Shri Shyam Trading. It was observed by the A.O that the PAN of assessee was present in list of beneficiaries, provided by Investigation wing. The A.O has issued statuary notices, in response the assessee reiterated that the assessee firm had not purchased any bogus bills. In the absence

Abhimanyu Gupta, Patiala vs. Dy. Commissioner of Income Tax, Circle-Patiala, Patiala

In the result, the appeal of the assessee is allowed

ITA 979/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh09 Feb 2026AY 2018-19

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

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 115BSection 144BSection 147Section 148Section 153CSection 69

Rs.6,46,83,775/-. Subsequently, proceedings were initiated under section 147 of the Income-tax Act, 1961, based on information received from the Investigation Wing pursuant to a search conducted under section 132 in the case of Homeland Group of cases. 3.1 The Assessing Officer noted that during the course

Hasmukh Ugarchand Gadhecha, HUF, Ahmedabad vs. The ITO, Ward-5(2)(2), Ahmedabad

The appeal of the assessee stands allowed

ITA 591/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.591/Ahd/2025 िनधा"रण वष" /Assessment Year : 2013-14 Hasmukh Ugarchand The Ito बनाम/ Gadhecha, Huf Ward-5(2)(2) V/S. 3Rd Floor, Anjalee House Ahmedabad – 380 015 Cg Road Navrangpura Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aaahg 7194 K (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Hargovind Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/11/2025 घोषणा की तारीख /Date Of Pronouncement: 09/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 26/12/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2013-2014. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Hasmukh Ugarchand Gadhecha, Huf Vs. Ito Asstt.Year : 2013-14 2 “1. That The Ld.Cit(A) Erred In Law & In The Facts Of The Case In Confirming The Order Of The Ao In Reopening Assessment U/S.147 Of The Act.

For Appellant: Shri Deepak R. Shah, ARFor Respondent: Shri Hargovind Singh, Sr.DR

Section 10(38)Section 143(3)Section 147Section 148Section 153CSection 250Section 68Section 69C

truly all material facts. Upon perusal of the reasons recorded by the AO, we find that the AO relied on information from the Investigation Wing regarding a search on Shri Shirish Chandra Shah, alleging that the assessee was a beneficiary of accommodation entries. However, such information disseminated on the Insight ... proceeded to estimate the net profit by enhancing the same by Rs.1,00,000/-. The AO sat silently on the information received from Investigation Wing for four years and did not make any effort to verify the aforesaid information and re-open the assessment. After the lapse of four years

Income Tax Officer Ward 7.2.1 Ahmedabad, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1268/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR

Section 143(1)(a)Section 148Section 250

expenditure / job work expenses for M/s. V. Nitin, Surat who had business transactions with Kiran Gems Pvt. Ltd, Surat, as had been ascertained by Investigation wing of the Department. No evidence was provided by the assessee of having incurred any genuine expenditure? (b) Whether on the facts ... this case, a STR in the case of V. Nitin was received by the investigation wing, Surat Thereafter, the STR report was prepared by the o/o, the DDIT(Inv), Unit-2, Surat and disseminated the information in the case of its beneficiaries in category of High Risk Transaction CRIU/VRU Information

Income Tax Officer Ward 7.2.1 Ahmedabad, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1267/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR

Section 143(1)(a)Section 148Section 250

Income Tax Officer, Ward 7.2.1, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1266/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR

Section 143(1)(a)Section 148Section 250

Choksi Ranchhodlal Kishordas, Ahmedabad vs. The Pr. CIT, Ahmedabad-1, Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 558/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: us, A.Y. 2013-14, in the case of the assessee. According to the Ld. PCIT, the reasons for which the case of the assessee was reopened was not properly inquired into by the AO and, therefore, the assessment order, according to him, was erroneous causing prejudice to the Revenue for not having made any addition on account of income which was believed to have escaped assessment in the case of the assessee. The reopening, it transpires, was resorted to on finding that the assessee had received

For Appellant: Shri Rushin Patel, ARFor Respondent: Shri Rignesh Das, CIT.DR

Section 143(3)Section 147Section 263

this case was held on the basis of ITA No.558/Ahd/2024 [Choksi Ranchhodlal Kishordas vs. PCIT] A.Y. 2013-14 - 13 – some information received from Investigation Wing, whereby, the Assessing Officer asked the assessee to furnish the necessary details from time to time which were duly furnished by the assessee and after

Jhv Construction Co. Pvt. Ltd., Kolkata vs. D.C.I.T., CC - 2(2), Kolkata

In the result, the appeal filed by the assessee is partly allowed but the order of the Pr

ITA 1289/KOL/2024[2014-2015]Status: DisposedITAT Kolkata09 Feb 2026AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 132Section 143(3)Section 153ASection 2(22)(e)Section 263Section 68

evader of Income-tax and other taxes. 9. On the basis of the fact of the case, as per the report submitted by the investigation wing and the investigation carried out at the assessment stage, it is held that satisfactory explanation was not offered by the assessee towards the loan

Nova Elevators Private Limited, Mumbai vs. ITO-13(1)(1), Mumbai

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

ITA 7248/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarnova Elevators Private Vs Ito -13(1)(1), Mumbai Limited Maharashtra-400020 402, Dimple Apts., 4E, Asha Nagar, Kandivali East, Mumbai-400101 Pan: Aadcn0305K Appellant Respondent Assessee By : Shri Sharad Patel, Ca Respondent By : Shri Leyaqat Ali Aafaqui, (Sr Ar) Date Of Hearing : 29/01/2026 Date Of Pronouncement : 09/02/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-51, Mumbai [For Brevity ‘The Ld. Cit(A)], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2014-15, Date Of Order 12.09.2025. The Impugned Order Emanated From The Order Of The Ld. Income-Tax Officer Ward-13(1)(1), Mumbai

For Appellant: Shri Sharad Patel, CAFor Respondent: Shri Leyaqat Ali Aafaqui, (SR AR)

Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

Assessing Officer erred in the reopening under section 147 of the Act. The reasons recorded were based merely on borrowed satisfaction from the Investigation Wing/ DCIT (Central Circle) without any independent application of mind or a live nexus to the assessee's own transaction. Accordingly, the reassessment is invalid

Income Tax Officer, Kalyan vs. Kala Eswaran Iyr, Dombivali

In the result, the appeal filed by the Revenue is dismissed

ITA 6237/MUM/2025[2020-2021]Status: DisposedITAT Mumbai09 Feb 2026AY 2020-2021

Bench: Shri Anikesh Banerjee & Shri Jagadish

Section 115BSection 132Section 143(3)Section 69A

filed declaring total income of ₹48,87,520/-. The case was selected for complete scrutiny on the basis of information received from the Investigation Wing, Ahmedabad, consequent to a search conducted under section 132 in the case of Shri Sanjay Govindram Aggarwal alias Sanjay Tiberwal, who was stated ... engaged in providing accommodation entries. Relying upon Annexure-A forwarded by the Investigation Wing and the statement of the said person recorded during search proceedings, the Assessing Officer treated the assessee as a beneficiary of accommodation entries and made an addition of ₹20,00,130/- under section

Income Tax Officer, Korba vs. Naushad Hassan, Raigarh

In the result, appeal of the Revenue is dismissed

ITA 19/RPR/2026[2019-20]Status: DisposedITAT Raipur06 Feb 2026AY 2019-20

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.19/Rpr/2026 "नधा"रण वष" /Assessment Year : 2019-20 The Income Tax Officer, Korba (C.G.)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 132Section 147Section 148Section 80G

Samajwadi Party (Secular) was found to be one of the entities that was involved in providing accommodation entries. Based on the information received from Investigation Wing, Ahmedabad that the said political party was involved in providing accommodation entries of bogus donation, the case of the assessee was reopened u/s.147/148 ... obtained a printed receipt. However, there is also no dispute that the said political party was one of the entities identified by the Investigation Wing as engaged in circular accommodation transactions. Statements of key functionaries recorded on oath admitted to the refund of donations after retaining commission. On the other