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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

Income Tax Officer, Piramal Chambers vs. Dibya Trading Co LLP, Mumbai, Maharashtra

In the result, appeal of the revenue is dismissed and cross- objection of the assessee is also dismissed

ITA 4330/MUM/2024[2015-16]Status: DisposedITAT Mumbai02 Jan 2025AY 2015-16

Bench: Shri Amarjit Singh & Shri Sunil Kumar Singhassessment Year: 2015-16 Income Tax Officer Dibya Trading Co. Llp

For Appellant: Shri Madhur Agrawal & Shri Jay BhahsaliFor Respondent: Shri R.R. Makwana, Sr. DR
Section 10(35)Section 250

Short Term Capital Loss of Rs. 3,41,02,141/-, by ignoring the fact that, a list of all beneficiaries was provided by the Investigation Wing of Income-Tax Department, in which the name of the instant assessee was also present, which proved that the assessee has invested and engaged ... redemption of mutual fund units might have set off during next Assessment years. A list of all the beneficiaries was furnished by the Investigation wing in which the name of the instant assessee was also present. 2.3.3. In the assessee’s case too, as evident from ITR filed

S.P. Singla Construction Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Chandigarh

In the result, the appeal is allowed

ITA 514/CHANDI/2023[2012-2013]Status: DisposedITAT Chandigarh02 Jan 2025AY 2012-2013

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Kusum Bansal, CIT-DR
Section 127Section 132Section 143(3)Section 147Section 148Section 148(2)Section 153Section 153A

Duties Rs. 4.48 4 Consumption of stores and spare parts Rs. 10.29 5 Other Expenses Rs. 174.23 On analysis of report of. the investigation wing and the return of income, it is clear that bogus expense of Rs. 36,10,58,438/- has been booked by the assessee company during

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2024[2017-18]Status: DisposedITAT Delhi02 Jan 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2024[2013-14]Status: DisposedITAT Delhi02 Jan 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH

ACIT, Faizabad vs. M/S. Saket Foods Pvt. Ltd., Bahraich

In the result, both appeals of the Revenue are dismissed

ITA 326/LKW/2020[2012-13]Status: DisposedITAT Lucknow31 Dec 2024AY 2012-13

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraacit, Gonda M/S. Shree Rameshwar V. Income Tax Office, Civil Lines, Lal Foods Pvt. Ltd Faizabad-224001. Chhawani Bazar, Bahraich-271801. Pan:Aancs3697P (Appellant) (Respondent) Acit, Gonda M/S. Saket Foods Pvt V. Income Tax Office, Civil Lines, Ltd Faizabad-224001. Chhawani Bazar, Bahraich-271801. Pan:Aadcs0365G (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Adv Respondent By: Shri Sanjeev Krishna Sharma, Addl. Cit(Dr) Date Of Hearing: 30 12 2024 Date Of Pronouncement: 31 12 2024 O R D E R

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Sanjeev Krishna Sharma, Addl
Section 143(3)Section 147Section 148

erred in law and on facts in comprehending that Assessing Officer had sufficient material in the form of report of investigation wing to make a reasonable belief that income chargeable to tax had ‘escaped assessment and merely because the case has already been assessed previously would not preclude him from ... Company. 6. The Ld. CIT (A) has erred in law and on facts in accepting the apparent facts as real while the actions of Investigation wing and subsequent data mining made by the assessing officer have proved that apparent is not real. 7. The Ld. CIT (A) has erred

ACIT, Faizabad vs. M/S. Shree Rameshwar Lal Foods Pvt. Ltd., Bahraich

In the result, both appeals of the Revenue are dismissed

ITA 325/LKW/2020[2012-13]Status: DisposedITAT Lucknow31 Dec 2024AY 2012-13

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraacit, Gonda M/S. Shree Rameshwar V. Income Tax Office, Civil Lines, Lal Foods Pvt. Ltd Faizabad-224001. Chhawani Bazar, Bahraich-271801. Pan:Aancs3697P (Appellant) (Respondent) Acit, Gonda M/S. Saket Foods Pvt V. Income Tax Office, Civil Lines, Ltd Faizabad-224001. Chhawani Bazar, Bahraich-271801. Pan:Aadcs0365G (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Adv Respondent By: Shri Sanjeev Krishna Sharma, Addl. Cit(Dr) Date Of Hearing: 30 12 2024 Date Of Pronouncement: 31 12 2024 O R D E R

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Sanjeev Krishna Sharma, Addl
Section 143(3)Section 147Section 148

erred in law and on facts in comprehending that Assessing Officer had sufficient material in the form of report of investigation wing to make a reasonable belief that income chargeable to tax had ‘escaped assessment and merely because the case has already been assessed previously would not preclude him from ... Company. 6. The Ld. CIT (A) has erred in law and on facts in accepting the apparent facts as real while the actions of Investigation wing and subsequent data mining made by the assessing officer have proved that apparent is not real. 7. The Ld. CIT (A) has erred

Saanvi Developers & Realtors Pvt. Ltd., Kolkata vs. ITO, Ward-1(3), Kol, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1330/KOL/2023[2010-11]Status: DisposedITAT Kolkata31 Dec 2024AY 2010-11

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 148Section 250

rate of commission @1% in stead of 0.10-0.15% of turn over ignoring the reality that the same has already been accepted by the Investigation Wing on the statement given by the director. The Ld. Counsel further submits that the statement given by the director before the Investigation Wing

Income Tax Officer, Chennai vs. Rohitkumar Nemchand Piparia, Chennai

The appeal stand allowed in terms of our above order

ITA 1344/CHNY/2023[2008-09]Status: DisposedITAT Chennai31 Dec 2024AY 2008-09

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1344/Chny/2023 (िनधा*रण वष* / Assessment Year: 2008-09) Ito Shri Rohitkumar Nemchand Piparia बनाम International Taxation Ward-2(1) #34 (Old #77), Meddox Street, / Vs. Chennai. Choolai, Chennai-600 112. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Akzpp-0661-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri T. Banusekar & Ms. Samyuktha Banusekar (Advocates) - Ld. Ars " थ"कीओरसे/Revenue By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2024 घोषणाकीतारीख /Date Of Pronouncement : 31-12-2024 आदेश / O R D E R

For Appellant: Shri T. Banusekar & Ms. SamyukthaFor Respondent: Shri Nilay Baran Som (CIT) - Ld. DR
Section 143(3)Section 148Section 234BSection 234C

shares of an entity by the name M/s Rajesh Exports Ltd. was identified. The case was reopened pursuant to receipt of information from investigation wing that the assessee entered into high value share transactions for Rs.155 Crores but the income was not reported in the Income Tax return. The assessee ... gains were not reflected by the assessee in its return of income. Therefore, the case was reopened on receipt of such information from investigation wing and an assessment was framed against the assessee on 25-02-2016 wherein STCG was brought to tax and the same was computed at Rs.52.10

ITO (It), Ward 2(1), Chennai vs. Rohitkumar Nemchand Piparia, Chennai

The appeal stands allowed for statistical purposes

ITA 1326/CHNY/2023[2008-09]Status: DisposedITAT Chennai31 Dec 2024AY 2008-09

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1326/Chny/2023 (िनधा*रण वष* / Assessment Year: 2008-09) Income Tax Officer Shri Rohitkumar Nemchand Piparia बनाम International Taxation Ward-2(1), #34 (Old #77), Meddox Street, / Vs. Chennai. Choolai, Chennai-600 112. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Akzpp-0661-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri T. Banusekar & Ms.Samyuktha Banusekar (Advocates) - Ld. Ars " थ"कीओरसे/Revenue By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2024 घोषणाकीतारीख /Date Of Pronouncement : 31-12-2024 आदेश / O R D E R

For Appellant: Shri T. Banusekar & Ms.SamyukthaFor Respondent: Shri Nilay Baran Som (CIT) - Ld. DR
Section 143(3)Section 148Section 271(1)(c)

shares of an entity by the name M/s Rajesh Exports Ltd. was identified. The case was reopened pursuant to receipt of information from investigation wing that the assessee entered into high value share transactions for Rs.155 Crores but the income was not reported in the Income Tax return. The assessee ... Commercial Bank Ltd. (Bank). The assessee has filed regular return of income wherein these transactions were not reported. Pursuant to receipt of information from investigation wing that the assessee carried out these transactions, the case was reopened and the assessee filed return of income wherein these transactions were not again

ACIT 19(1), Mumbai vs. M/S. Orbit Financial Capital, Mumbai

In the result, appeal filed by the Revenue is dismissed as infructuous and Cross Objection of the assessee is allowed

ITA 5812/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Dec 2024AY 2015-16
Section 143(3)Section 147

through M/s. APAR Finance Ltd. 2 by trading in equity derivatives, without appreciating that the disallowance was made, after analyzing credible information received from Investigation Wing, wherein it was proved beyond doubt that manipulated transactions are being executed to avail artificial losses?" 3. "Whether on the facts and circumstances ... Ld.CIT(A) was right in deleting the entire disallowance addition made by AO, without appreciating the fact that, during the survey proceedings of Investigation wing, Mrs. Mausami Deb Roy, proprietor of M/s. Goodluck securities, admitted in her statement on oath that her firm was involved in creating artificial profits

Aashna Diamond, Shreeji Chambers vs. Income Tax Officer- 19(1)(1), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 5363/MUM/2024[2011-12]Status: DisposedITAT Mumbai31 Dec 2024AY 2011-12

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran

For Appellant: Shri Suchek AnchaliyaFor Respondent: Shri Suresh Periasamy, Sr.DR
Section 133(6)Section 148

statement recorded from Shri Rajendra Jain and certain other employees, they admitted that they were providing accommodation bills. It was noticed by the Investigation Wing that the assessee has also been given sales bills by the said group of companies in both the years under consideration as detailed below:- Name ... Maniprabha 1,86,10,550 1,80,00,000 ------------------ ---------------- Total 4,42,28,870 2,71,56,000 ============= =========== The Investigation Wing forwarded the above said information to the AO. Accordingly, the AO formed the view that the above said purchases are bogus in nature. Accordingly, the AO reopened the assessment

Aashna Diamond, Mumbai vs. ACIT Circle- 19(1), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 5361/MUM/2024[2012-13]Status: DisposedITAT Mumbai31 Dec 2024AY 2012-13

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran

For Appellant: Shri Suchek AnchaliyaFor Respondent: Shri Suresh Periasamy, Sr.DR
Section 133(6)Section 148

statement recorded from Shri Rajendra Jain and certain other employees, they admitted that they were providing accommodation bills. It was noticed by the Investigation Wing that the assessee has also been given sales bills by the said group of companies in both the years under consideration as detailed below:- Name ... Maniprabha 1,86,10,550 1,80,00,000 ------------------ ---------------- Total 4,42,28,870 2,71,56,000 ============= =========== The Investigation Wing forwarded the above said information to the AO. Accordingly, the AO formed the view that the above said purchases are bogus in nature. Accordingly, the AO reopened the assessment

Rahul Kumar Singh, Ghansoli, Navi-Mumbai vs. Assessing Officer Income Tax Department Ward 28(2)(1), Mumbai, Vashi, Navi-Mumbai

ITA 3112/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Dec 2024AY 2018-19
For Appellant: Shri Mohan Tandon, ARFor Respondent: Shri Manoj Kumar, Sr. DR
Section 133(6)Section 143(2)Section 144Section 148Section 148ASection 69Section 69A

various Banks and obtained the relevant information. The Ld. AO applied his mind by going through report of CGST, report of investigation wing. It was mentioned that the Investigation Wing of Income Tax Department received the report from CGST and Central Excise Commissioner-8, Belapur and it was reported that

Hitesh Mangilal Jain, Mumbai vs. ITO - 19(1)(5), Mumbai

ITA 262/MUM/2024[2014-15]Status: DisposedITAT Mumbai31 Dec 2024AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Ms. Ridisha Jain / Shri Karan JainFor Respondent: Shri Himanshu Joshi (Sr. DR)
Section 10(38)Section 143(3)Section 147Section 271(1)Section 68Section 69C

action taken by the Revenue u/s 147 of the Act, by claiming that the proceedings were initiated only on the basis of information from Investigation wing. However, in the course of appeal before us, the learned Counsel has not pressed the ground which accordingly is dismissed. 4.Ground ... subsequent appeal, the NFAC upheld the addition. 7.1 It is noticed that the AO made the above addition based on an investigation report of Investigation Wing of Kolkata. It was found that the above LTCG has been derived in respect of certain Penny Stocks companies. The said scrips were purchased

Hitesh Mangilal Jain, Mumbai vs. ITO 19(1)(5), Mumbai

Appeals of the assessee are partly allowed

ITA 261/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Dec 2024AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Ms. Ridisha Jain / Shri Karan JainFor Respondent: Shri Himanshu Joshi (Sr. DR)
Section 10(38)Section 143(3)Section 147Section 271(1)Section 68Section 69C

action taken by the Revenue u/s 147 of the Act, by claiming that the proceedings were initiated only on the basis of information from Investigation wing. However, in the course of appeal before us, the learned Counsel has not pressed the ground which accordingly is dismissed. 4.Ground ... subsequent appeal, the NFAC upheld the addition. 7.1 It is noticed that the AO made the above addition based on an investigation report of Investigation Wing of Kolkata. It was found that the above LTCG has been derived in respect of certain Penny Stocks companies. The said scrips were purchased

Income Tax Officer, Mumbai vs. Hitesh Mangilal Jain, Mumbai

ITA 257/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Dec 2024AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Ms. Ridisha Jain / Shri Karan JainFor Respondent: Shri Himanshu Joshi (Sr. DR)
Section 10(38)Section 143(3)Section 147Section 271(1)Section 68Section 69C

action taken by the Revenue u/s 147 of the Act, by claiming that the proceedings were initiated only on the basis of information from Investigation wing. However, in the course of appeal before us, the learned Counsel has not pressed the ground which accordingly is dismissed. 4.Ground ... subsequent appeal, the NFAC upheld the addition. 7.1 It is noticed that the AO made the above addition based on an investigation report of Investigation Wing of Kolkata. It was found that the above LTCG has been derived in respect of certain Penny Stocks companies. The said scrips were purchased

Kamal Clearing and Forwarding Agency Private Limited, Mumbai vs. Income Tax Officer, Ward 6(3)(3), Mumbai

ITA 1576/MUM/2024[2010-11]Status: DisposedITAT Mumbai31 Dec 2024AY 2010-11

Bench: Ms. Kavitha Rajagopal () & Shri Omkareshwar Chidara () Assessment Year: 2010-11

For Appellant: Mr. Sukhsagar SyalFor Respondent: Ms. Sudha Ramachandran, Sr. DR
Section 68

beneficiary of the same. ompany is the beneficiary of the same. The Ld. AO received information from The Ld. AO received information from Investigation Wing Investigation Wing of Income- tax Department that Mr. Ravi Prakash is not traceable. As the tax Department that Mr. Ravi Prakash is not traceable

Navjyoti Farming Private Limited, Belapur vs. ITO, Ward -3, Panvel

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

ITA 1020/PUN/2024[2012-13]Status: DisposedITAT Pune30 Dec 2024AY 2012-13

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2012-13

For Appellant: Shri Ashwani KumarFor Respondent: Shri Amol Khairnar, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

addition has been made in their hands. Therefore, the reopening of assessment on the basis of information obtained from the Investigation Wing is nothing but a change of opinion. 10. Referring to the decision of the Hon’ble Bombay High Court in the case of Godrej Projects Development ... completed u/s 143(3) of the Act on 11.03.2015 accepting the returned income at Nil. Subsequently, on the basis of information obtained from the Investigation Wing, the Assessing Officer reopened the assessment by recording the following reasons: “11. Reasons for reopening of the assessment in the case of M/s Navjyoti

Winner Tradecom Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(2), Kolkata

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

ITA 2189/KOL/2024[2018-2019]Status: DisposedITAT Kolkata30 Dec 2024AY 2018-2019

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2189/Kol/2024 Assessment Year: 2018-2019 Winner Tradecom Pvt. Limited,……..…………Appellant 2/6, Sarat Bose Road, Suite-308, Central Plaza, Kolkata-700020 [Pan:Aabcw0321N] -Vs.- Income Tax Officer, ……………………………...Respondent Assessment Unit, Ward-6(2), Income Tax Department, Nfac, Delhi Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri S.K. Tulsian, Advocate, Appeared On Behalf Of The Assessee Shri Manoj Kumar Pati, Addl. Cit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 12, 2024 Date Of Pronouncing The Order: December 30, 2024 O R D E R

Section 147Section 148Section 148ASection 292CSection 68

filed its return of income for the assessment year 2018-19 declaring total income of Rs.78,750/-. As per the information received from the Investigation Wing that the assessee-company has received credits of Rs.15,00,000/- from one M/s. Sankalp Vincom Pvt. Limited. The case was selected for scrutiny ... delete the addition made by the ld. Assessing Officer. 6. On the other hand, ld. Departmental Representative has submitted that information received from the Investigation Wing, therefore, ld. Assessing Officer reopened the assessment and the assessee has not given any details about the receipt of Rs.15,00,000/- from

Pradip Kumar Jajodia, HUF, Kolkata vs. ITO, Ward-44(1), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 192/KOL/2024[2017-18]Status: DisposedITAT Kolkata30 Dec 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Manish Boradi.T.A. Nos.190 To 192/Kol/2024 Assessment Years: 2015-16 To 2017-18

Section 142(1)Section 147Section 148Section 250

prices to the scrip. The shares in which the assessee is reported to have traded in, have been identified as penny shares by the investigation wing of the Department. The shares do not have sound fundaments. Rather they are manipulated to reach high prices from negligible values. The same conclusion ... submitted that the aforesaid reasons were vague. That the AO did not apply his mind at all to the alleged information received from the Investigation Wing. That the satisfaction of the AO regarding escapement of the income of the assessee was a borrowed satisfaction. That there was no bona fide