“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

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

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.

Judgments citing investigation wing

Kolors Healthcare LLP, Hyderabad vs. ACIT, Central Circle-3(4), Hyderabad

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

ITA 938/HYD/2024[2016-17]Status: DisposedITAT Hyderabad23 Jan 2025AY 2016-17

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ. अपी.सं / Ita Nos.930 To 936/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2013-14 To 2019-20) M/S. Kolors Healthcare India Pvt. Ltd., Hyderabad. Pan:Aadck8392B (Appellant) Vs. Asst. Commissioner Of Income Tax, Central Circle-3(4), Hyderabad. (Respondent) C.O. Nos.15 To 21/Hyd/2024 (In Ita Nos.930 To 936/Hyd/2024) (निर्धारण वर्ष/Assessment Years:2013-14 To 2019-20) (By Revenue) आ.अपी.सं / Ita Nos.937 To 941/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2015-16 To 2019-20) M/S. Kolors Healthcare Llp, Asst. Commissioner Of Income Tax, Hyderabad. Vs. Central Circle-3(4), Pan:Aaofk6305L Hyderabad. (Appellant) (Respondent) C.O. Nos.22 To 26/Hyd/2024 (In Ita Nos.937 To 941/Hyd/2024) (निर्धारण वर्ष/Assessment Years:2015-16 To 2019-20) (By Revenue) निर्धारिती द्वारा/Assessee By: Shri P. Murali Mohan Rao, C.A. राजस्व द्वारा/Revenue By: Ms.K. Haritha, Cit-Dr सुनवाई की तारीख /Date Of Hearing: | 04/12/2024 घोषणा की तारीख / Pronouncer G/Pronouncement: 23/01/2025 आदेश/Order Per Bench : All These Appeals Filed By M/S. Kolors Healthcare India Pvt. Ltd. (“Assessee") & M/S. Kolors Healthcare Llp & Cross Objections Filed By Revenue, Are Arising Out Of Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad (“Ld. Cit(A)") As Detailed Above. Since Identical Issues Are Involved In These Appeals & Cross Objections ("C.O.”), They Are Heard Together & Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Ms.K. Haritha, CIT-DR

Section 44A

that, the Ld. AO at page nos.56 to 58, para nos.10.4.3 to 10.4.3.4 of his order merely relied upon the observation made by the investigation wing to the following effect : " 10.4.3 The third contention of Sri Vijaya Krishna is that the amounts in 'total paid' columns in collection reports were ... Vijaya Krishna in his statement. Accordingly, the search team considered the 'total paid' column of collection reports for arriving the sales turnovers. 10.4.3.2 The Investigation Wing observed that there was merit in his submission. It was observed that the figures/amounts in 'total paid' columnwere accumulating automatically in respect of some

Kolors Healthcare India Private Limited, Hyderabad vs. ACIT., Central Circle-3(4), Hyderabad

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

ITA 935/HYD/2024[2018-19]Status: DisposedITAT Hyderabad23 Jan 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ. अपील सं./Ita Nos.930 To 936/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2013-14 To 2019-20) M/S. Kolors Healthcare India Pvt. Ltd., Hyderabad. Pan:Aadck8392B (Appellant) Vs. Asst. Commissioner Of Income Tax, Central Circle-3(4), Hydrabad. (Respondent) C.O. Nos.15 To 21/Hyd/2024 (In Ita Nos.930 To 936/Hyd/2024) (निर्धारण वर्ष/Assessment Years:2013-14 To 2019-20) (By Revenue) आ. अपील सं./Ita Nos.937 To 941/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2015-16 To 2019-20) M/S. Kolors Healthcare Llp, Hydrabad. Pan:Aaofk6305L (Appellant) Vs. Asst. Commissioner Of Income Tax, Central Circle-3(4), Hydrabad. (Respondent) C.O. Nos.22 To 26/Hyd/2024 (In Ita Nos.937 To 941/Hyd/2024) (निर्धारण वर्ष/Assessment Years:2015-16 To 2019-20) (By Revenue) निर्धारिती द्वारा/Assessee By: Shri P. Murali Mohan Rao, C.A. राजस्व द्वारा/Revenue By: Ms.K. Haritha, Cit-Dr सुनवाई की तारीख /Date Of Hearing: 04/12/2024 घोषणा की तारीख / Pronouncement: 23/01/2025 आदेश/Order Per Bench : All These Appeals Filed By M/S. Kolors Healthcare India Pvt. Ltd. ("Assessee") & M/S. Kolors Healthcare Llp & Cross Objections Filed By Revenue, Are Arising Out Of Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-11, Hydrabad ("Ld. Cit(A)") As Detailed Above. Since Identical Issues Are Involved In These Appeals & Cross Objections ("C.O.”), They Are Heard Together & Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Ms.K. Haritha, CIT-DR

Section 132Section 44A

that, the Ld. AO at page nos.56 to 58, para nos.10.4.3 to 10.4.3.4 of his order merely relied upon the observation made by the investigation wing to the following effect : "10.4.3 The third contention of Sri Vijaya Krishna is that the amounts in 'total paid' columns in collection reports were ... Total 1133128944 1039133591 93995353 10.4.3.2 The Investigation Wing observed that there was merit in his submission. It was observed that the figures/amounts in 'total paid' columnwere accumulating automatically in respect of some of the customers. It was agreed to sum-up the modes of payments columns of the collection reports

Kolors Healthcare India Private Limited, Hyderabad vs. ACIT., Central Circle-3(4), Hyderabad

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

ITA 934/HYD/2024[2017-18]Status: DisposedITAT Hyderabad23 Jan 2025AY 2017-18

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ. अपील सं / Ita Nos.930 To 936/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2013-14 To 2019-20) M/S. Kolors Healthcare India Pvt. Ltd., Hyderabad. Pan:Aadck8392B (Appellant) Vs. Asst. Commissioner Of Income Tax, Central Circle-3(4), Hyderabad. (Respondent) C.O. Nos.15 To 21/Hyd/2024 (In Ita Nos.930 To 936/Hyd/2024) (निर्धारण वर्ष/Assessment Years:2013-14 To 2019-20) (By Revenue) आ. अपील सं / Ita Nos.937 To 941/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2015-16 To 2019-20) M/S. Kolors Healthcare Llp, Hyderabad. Pan:Aaofk6305L Vs. Asst. Commissioner Of Income Tax, Central Circle-3(4), Hyderabad. (Appellant) (Respondent) C.O. Nos.22 To 26/Hyd/2024 (In Ita Nos.937 To 941/Hyd/2024) (निर्धारण वर्ष/Assessment Years:2015-16 To 2019-20) (By Revenue) निर्धारिती द्वारा/Assessee By: Shri P. Murali Mohan Rao, C.A. राजस्व द्वारा/Revenue By: Ms.K. Haritha, Cit-Dr सुनवाई की तारीख /Date Of Hearing: 04/12/2024 घोषणा की तारीख / Pronouncement: 23/01/2025 आदेश/Order Per Bench : All These Appeals Filed By M/S. Kolors Healthcare India Pvt. Ltd. (“Assessee") & M/S. Kolors Healthcare Llp & Cross Objections Filed By Revenue, Are Arising Out Of Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad ("Ld. Cit(A)") As Detailed Above. Since Identical Issues Are Involved In These Appeals & Cross Objections ("C.O."), They Are Heard Together & Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Ms.K. Haritha, CIT-DR

Section 44A

that, the Ld. AO at page nos.56 to 58, para nos.10.4.3 to 10.4.3.4 of his order merely relied upon the observation made by the investigation wing to the following effect : "10.4.3 The third contention of Sri Vijaya Krishna is that the amounts in 'total paid' columns in collection reports were ... Vijaya Krishna in his statement. Accordingly, the search team considered the 'total paid' column of collection reports for arriving the sales turnovers. 10.4.3.2 The Investigation Wing observed that there was merit in his submission. It was observed that the figures/amounts in 'total paid' columnwere accumulating automatically in respect of some

Kolors Healthcare India Private Limited, Hyderabad vs. ACIT., Central Circle-3(4), Hyderabad

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

ITA 933/HYD/2024[2016-17]Status: DisposedITAT Hyderabad23 Jan 2025AY 2016-17

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ. अपी.सं / Ita Nos.930 To 936/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2013-14 To 2019-20) M/S. Kolors Healthcare India Pvt. Ltd., Hyderabad. Pan:Aadck8392B (Appellant) Vs. Asst. Commissioner Of Income Tax, Central Circle-3(4), Hyderabad. (Respondent) C.O. Nos.15 To 21/Hyd/2024 (In Ita Nos.930 To 936/Hyd/2024) (निर्धारण वर्ष/Assessment Years:2013-14 To 2019-20) (By Revenue) आ.अपी.सं / Ita Nos.937 To 941/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2015-16 To 2019-20) M/S. Kolors Healthcare Llp, Asst. Commissioner Of Income Tax, Hyderabad. Vs. Central Circle-3(4), Pan:Aaofk6305L Hydearabad. (Appellant) (Respondent) C.O. Nos.22 To 26/Hyd/2024 (In Ita Nos.937 To 941/Hyd/2024) (निर्धारण वर्ष/Assessment Years:2015-16 To 2019-20) (By Revenue) निर्धारिती द्वारा/Assessee By: Shri P. Murali Mohan Rao, C.A. राजस्व द्वारा/Revenue By: Ms.K. Haritha, Cit-Dr सुनवाई की तारीख /Date Of Hearing: 04/12/2024 घोषणा की तारीख / Pronouncer G/Pronouncement: 23/01/2025 आदेश/Order Per Bench : All These Appeals Filed By M/S. Kolors Healthcare India Pvt. Ltd. ("Assessee") & M/S. Kolors Healthcare Llp & Cross Objections Filed By Revenue, Are Arising Out Of Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad ("Ld. Cit(A)") As Detailed Above. Since Identical Issues Are Involved In These Appeals & Cross Objections ("C.O."), They Are Heard Together & Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Ms.K. Haritha, CIT-DR

Section 44A

that, the Ld. AO at page nos.56 to 58, para nos.10.4.3 to 10.4.3.4 of his order merely relied upon the observation made by the investigation wing to the following effect : "10.4.3 The third contention of Sri Vijaya Krishna is that the amounts in 'total paid' columns in collection reports were ... report reflects the sales turnover. Accordingly, the search team considered the 'total paid' column of collection reports for arriving the sales turnovers. 10.4.3.2 The Investigation Wing observed that there was merit in his submission. It was observed that the figures/amounts in 'total paid' columnwere accumulating automatically in respect of some

Kolors Healthcare India Private Limited., Hyderabad vs. ACIT., Central Circle-3(4), Hyderabad

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

ITA 932/HYD/2024[2015-16]Status: DisposedITAT Hyderabad23 Jan 2025AY 2015-16

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.930 To 936/Hyd/2024 (निर्धारण वर्ा/Assessment Years:2013-14 To 2019-20) M/S. Kolors Healthcare India Pvt. Asst. Commissioner Of Income Tax, Vs. Ltd., Hyderabad. Central Circle-3(4), Pan:Aadck8392B Hyderabad. (Respondent) (Appellant) C.O. Nos.15 To 21/Hyd/2024 (In Ita Nos.930 To 936/Hyd/2024) (निर्धारण वर्ा/Assessment Years:2013-14 To 2019-20) (By Revenue)

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Ms.K. Haritha, CIT-DR

Section 44A

that, the Ld. AO at page nos.56 to 58, para nos.10.4.3 to 10.4.3.4 of his order merely relied upon the observation made by the investigation wing to the following effect : “ 10.4.3 The third contention of Sri Vijaya Krishna is that the amounts in 'total paid' columns in collection reports were ... Vijaya Krishna in his statement. Accordingly, the search team considered the 'total paid' column of collection reports for arriving the sales turnovers. 10.4.3.2 The Investigation Wing observed that there was merit in his submission. It was observed that the figures/amounts in 'total paid' columnwere accumulating automatically in respect of some

Kolors Healthcare India Private Limited, Hyderabad vs. ACIT., Central Circle-3(4), Hyderabad

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

ITA 931/HYD/2024[2014-15]Status: DisposedITAT Hyderabad23 Jan 2025AY 2014-15

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Ms.K. Haritha, CIT-DR

Section 44A

Burdwan Irone & Steel Company Private Limited, Kolkata vs. Income Tax Ward 1(1)Kolkata, Kolkata

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

ITA 936/KOL/2024[2012-2013]Status: DisposedITAT Kolkata23 Jan 2025AY 2012-2013

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 148

assessee are that the assessee filed return of income declaring total income of Rs. 31,06,311/-. Subsequently on the information received from the Investigation Wing, the case was reopened by issuing notice u/s 148 of the Act. Assessee did neither file return nor any compliance of the notice

Gold Ancher Exim Private Limited, Khar West - Mumbai vs. Income Tax Officer Ward 12(2)(1), Aaykar Bhavan

In the result, appeal of the assessee is allowed

ITA 5464/MUM/2024[2013-14]Status: DisposedITAT Mumbai23 Jan 2025AY 2013-14

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

For Appellant: Ms. Ritu Panjabi, A/RFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R

Section 143(2)Section 143(3)Section 147Section 148Section 69C

| आयकर अपीलीय अिधकरण "ायपीठ, मुंबई | IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SAKTIJIT DEY, HON’BLE VICE

Smt. Usha Satish Salvi, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle

In the result, the appeals of the assessee for all the three years

ITA 4239/MUM/2023[2012-13]Status: DisposedITAT Mumbai23 Jan 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Satish ModiFor Respondent: Mr. Ankush Kapoor, CIT-DR

Section 132Section 143(3)Section 153ASection 153CSection 153DSection 69C

such type of cases, regular discussion between the range head and AO happened regularly whenever needed. Appraisal report or other communication with the investigation wing of the department and seized/impounded materials explored and discussed from time to time and thereafter assessment order finalised after approval from the range head

Smt. Usha Satish Salvi, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

In the result, the appeals of the assessee for all the three years

ITA 4238/MUM/2023[2014-15]Status: DisposedITAT Mumbai23 Jan 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Satish ModiFor Respondent: 06/11/2024

Section 132Section 143(3)Section 153C

needed. Appraisal report or other communication with the needed. Appraisal report or other communication with the needed. Appraisal report or other communication with the investigation wing of the department and seized/impounded investigation wing of the department and seized/impounded investigation wing of the department and seized/impounded materials explored and discussed from

Smt. Usha Satish Salvi, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

In the result, the appeals of the assessee for all the three years

ITA 4237/MUM/2023[2013-2014]Status: DisposedITAT Mumbai23 Jan 2025AY 2013-2014

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Satish ModiFor Respondent: 06/11/2024

Section 132Section 143(3)Section 153C

Achla Malhotra, Delhi vs. ITO, Ward-24(1), Delhi

ITA 4252/DEL/2024[2014-15]Status: DisposedITAT Delhi23 Jan 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

impugned Order passed by the Ld. CIT(A) ignoring the fact that Sh. Himanshu Verma is a regular offender who has been covered by investigation wing by conducting a search operation u/s 132 of the Income Tax Act, 1961 on 29.03.2012, 13.04.2017 & 17.11.2021. In all the search operations, several incriminating

Duraiswamy Chinnadurai, Coimbatore vs. ITO, Ncw-4(4), Coimbatore

In the result, the appeal is partly allowed

ITA 1782/CHNY/2024[2013-14]Status: DisposedITAT Chennai22 Jan 2025AY 2013-14

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1782 /Chny/2024 निर्ाारण वर्ा /Assessment Years: 2013-14 Duraiswamy Chinnadurai, Income Tax Officer, No.146, N.G.N.Street, Non Corp, Ward-4(4), New Siddhapudur, Coimbatore Coimbatore. [Pan: Acppc1349B] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri S.Ramachandran, Ca प्रत्यर्थी की ओर से /Revenue By : Ms.Sheila Parthasarthy, Addl.Cit सुिवाई की तारीख/Date Of Hearing : 02.12.2024 घोर्णा की तारीख /Date Of Pronouncement : 22.01.2025 आदेश / O R D E R Per Amitabh Shukla, A.M : This Appeal Is Filed Against The Order Bearing Din & Order No.Itba/Nfac/S/250/2024-25/1064762387(1) Dated 09.05.2024 Of The Learned Commissioner Of Income Tax [Herein After “Cit(A), National Faceless Appeal Center[Nfac], Delhi, For The Assessment Years 2013- 14. Through The Aforesaid Appeal The Assesse Has Challenged Order U/S 250 Dated 09.05.2024 Passed By Nfac, Delhi. 2.0 The Assessee Has Raised Altogether Seven Grounds Of Appeal, Of Which Grounds 1 To 4 Are Legal Grounds & Grounds 5 To 7 On Merits.

For Appellant: Shri S.Ramachandran, CAFor Respondent: Ms.Sheila Parthasarthy, Addl.CIT

Section 132Section 142(1)Section 143(3)Section 147Section 148Section 250Section 69ASection 69C

persons namely Shri Venkataraman and Shri Padmanabhan on 05.09.2013. During the course of search sworn statement of said Shri Venkataraman was recorded by investigation wing on 12.09.2013. Drawing reference to item no.11(2) of the reasons Page - 2 - of 7 :- 3 -: recorded for reopening assessment u/s. 147 dated ... written submissions objecting that no unsold sites were received from Krishna Nagar phase-7….”. He accordingly proceeded to rely upon information provided by the investigation wing, seized documents and statement of other persons. The Ld.First Appellate Authority confirmed Page - 3 - of 7 :- 4 -: the order of the Ld.AO vide

Income Tax Officer, Non Corporate Ward 22(1), Tambaram, Chennai vs. P Bhuvaneswari, India

In the result, the appeal of the Revenue is dismissed

ITA 1779/CHNY/2024[2017-18]Status: DisposedITAT Chennai22 Jan 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1779 /Chny/2024 निर्ाारण वर्ा /Assessment Years: 2017-18 Income Tax Officer, P.Bhuvaneswari, Non-Corp. Ward-22(1), No.2/128A, Braminar Street, Tambaram, Madurantakam, Chennai Chengalpet District, Tamil Nadu - 603 306. [Pan: Armpb3783A] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : None प्रत्यर्थी की ओर से /Revenue By : Shri Nathala Ravi Babu, Cit सुिवाई की तारीख/Date Of Hearing : 05.12.2024 घोर्णा की तारीख /Date Of Pronouncement : 22.01.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: NoneFor Respondent: Shri Nathala Ravi Babu, CIT

Section 142(1)Section 147Section 250Section 69A

assessee along with questionnaire and show cause but there was no response. The Ld. AO noted from the information provided by the investigation wing that the assessee had deposited an amount of Rs. 49,37,07,350/- . In the absence of no return of income filed by the assessee

Si Shraddha Realtors, Mumbai, Maharashtra, India vs. ITO 32(3)(3), Mumbai, India

ITA 2912/MUM/2024[2013-14]Status: DisposedITAT Mumbai22 Jan 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawal

For Appellant: Shri Ajay R Singh, Ld. A.R. &For Respondent: Shri Nayanjyoti Nath, Ld. Sr. D.R

Section 132Section 132(4)Section 133(6)Section 143(2)Section 250

obtaining accommodation entries purchase from Bhanwarlal Jain group. A search & seizure action u/s.132 of the I.T. Act 1961 was carried out by the Investigation Wing, Mumbai on Bhanwarlal Jain and Rajesh Bhanwarlal Jain and also covered certain namesake/ dummy directors/partners/proprietors of various concerns that were managed, controlled and operated ... observing and holding as under: “4.13 The facts revealed on the combined reading of the statement of the assessee the conclusion drawn by the Investigation Wing is again established as the assessee does not know anybody from whom he has taken unsecured loan and he has not been able

Sai Shraddha Realtors, Mumbai vs. Income Tax Officer 32(3)(2)), Mumbai

In the result, in view of our decision in ITA

ITA 2909/MUM/2024[2014-15]Status: DisposedITAT Mumbai22 Jan 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawal

For Appellant: Shri Ajay R Singh, Ld. A.R. &For Respondent: Shri Nayanjyoti Nath, Ld. Sr. D.R

Section 132Section 132(4)Section 143(2)Section 250

obtaining accommodation entries purchase from Bhanwarlal Jain group. A search & seizure action u/s.132 of the 1.T. Act 1961 was carried out by the Investigation Wing, Mumbai on Bhanwarlal Jain and Rajesh Bhanwarlal Jain and also covered certain namesake/ dummy directors/partners/proprietors of various concerns that were managed, controlled and operated ... observing and holding as under: “4.13 The facts revealed on the combined reading of the statement of the assessee the conclusion drawn by the Investigation Wing is again established as the assessee does not know anybody from whom he has taken unsecured loan and he has not been able

Suburban Builders Private Limited, Mumbai vs. ITO-8(2)(4), Mumbai

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

ITA 1135/MUM/2024[2007-08]Status: DisposedITAT Mumbai22 Jan 2025AY 2007-08

Bench: Shri Narender Kumar Choudhry & Ms. Renu Jauhriassessment Year: 2007-08

For Appellant: Shri Sanjay Kapadia, Ld. A.RFor Respondent: Ms. Monika H. Pande, Ld. Sr. DR

Section 143(3)Section 148Section 250

have been carefully considered. It must be mentioned here that it is a fact there was a search and seizure operation conducted by the Investigation Wing of Mumbai Unit on 01/10/2013 relating to Shri. Pravin Kumar Jain and its group of concerns wherein, it was revealed that the searched party

DCIT CC-4 vs. Pgf Ltd

In the result, appeal is dismissed

ITA 3407/DEL/2007[2001-2002]Status: DisposedITAT Delhi22 Jan 2025AY 2001-2002

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: NoneFor Respondent: Shri Om Parkash, Sr. DR

Section 143(2)Section 68

facts and circumstances of the case confirming the addition of Rs. 2,15,00,000/- on merely relying on the report of investigation wing in the case of S.K. Jain for A.Y. 2005-06 to 2011-12 when that report had absolutely no nexus with the transactions carried

Assistant Comissioner Central Circle 1(3), Nagpur vs. M/S Shrigopal Rameshkumar Sales Pvt. Ltd, Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 135/NAG/2018[2015-2016]Status: DisposedITAT Nagpur21 Jan 2025AY 2015-2016

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

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke

Section 132Section 132(1)Section 139Section 69C

search and seizure action under section 132(1) of the Income Tax Act, 1961 ("the Act") was conducted on 12/02/2015, by the Investigation Wing at the office, residential and factory premises of Rander Group. During the course of action under section 132, at the office premises of the assessee, certain ... list of unapproved entries for purchase and sale along with stock reconciliation. The appellant has filed a copy of reply submitted before the Investigation Wing for reconciling the stock vide page nos. 99 to 107 of its submission. I find that this submission also contain the date of entry

Tej Singh Sinsinwar, Jaipur vs. ITO Ward 1(2), Alwar

In the result, appeal of the assessee is allowed

ITA 1100/JPR/2024[2011-12]Status: DisposedITAT Jaipur21 Jan 2025AY 2011-12

For Appellant: Shri Vinod Kumar Gupta, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250

applicable in the facts of the present case because in the said case not only the accommodation entry were found by the investigation wing but the modus operandi was also detected and therefore it was found that the AO was having the sufficient material and information to form the believe ... applicable in the facts of the present case because in the said case not only the accommodation entry were found by the investigation wing but the modus operandi was also detected and therefore it was found that the AO was having the sufficient material and information to form the believe