← All Phrases

“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
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.

PCIT v. M/s. Kesoram Industries 57
417 ITR 334 · 2019 · High Court
96
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
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.

Aradhna Estate Pvt. Ltd. v. DCIT
91 Taxmann.com 119 · 2018 · High Court
56
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

Suchismita Dhal, Odisha vs. ITO 1 Korba, Korba

In the result, appeal of the assessee in ITA No

ITA 17/RPR/2026[2019-20]Status: HeardITAT Raipur06 Feb 2026AY 2019-20

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.16 & 17/Rpr/2026 "नधा"रण वष" /Assessment Years : 2019-20 Suchismita Dhal Co Saraj Kanta Dhal, Block Chowk, Behind Lic Office, Sonepur Raj Sonepur, Balangir (Odisha)-767017 Pan: Aorpd4399C .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1, Korba (C.G.) ……""यथ" / Respondent

For Appellant: None (Petition filed)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 132Section 147Section 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

Suchismita Dhal, Odisha vs. ITO 1 Korba, Korba

In the result, appeal of the assessee in ITA No

ITA 16/RPR/2026[2019-20]Status: HeardITAT Raipur06 Feb 2026AY 2019-20

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.16 & 17/Rpr/2026 "नधा"रण वष" /Assessment Years : 2019-20 Suchismita Dhal Co Saraj Kanta Dhal, Block Chowk, Behind Lic Office, Sonepur Raj Sonepur, Balangir (Odisha)-767017 Pan: Aorpd4399C .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1, Korba (C.G.) ……""यथ" / Respondent

For Appellant: None (Petition filed)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 132Section 147Section 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

ACIT19(3), Mumbai vs. Yogeshkumar Pravinkumar Shah, Mumbai

ITA 6163/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Feb 2026AY 2014-15

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Respondent: Revenue by
Section 143(3)

recorded any adverse findings with regard to the details submitted. Though the AO has elaborated the modus operandi and the findings of investigation wing, the AO in the assessment order did not record anything that links the assessee to the exit providers or entry operators or the assessee's involvement

DCIT (CC)-8(4), Mumbai vs. Reena Ratnesh Jain, Mumbai

In the result, the appeal is dismissed

ITA 3888/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardcit(Cc)-8(4) Reena Ratnesh Jain Room No. 659, 6Th Floor, 902/903, A Wing, Kalinga Tower, Aayakar Bhavan, M. K. Road, Vs. Nirmal Nagar, Near D-Mart, Mumbai-400 020 Mulund (W), Mumbai-400 080 Pan/Gir No. Aeapj 6605 C (Appellant) : (Respondent) Appellant By : Shri Bhadresh Doshi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 03.02.2026 Date Of Pronouncement : 06.02.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Department, Against Order Dated 26.03.2025 Of Learned Commissioner Of Income Tax (Appeals), Mumbai (‘Ld.Cit(A) For Short), Pertaining To The Assessment Year (A.Y.) 2016-17. 2. Though, The Department Has Raised Multiple Grounds, However, The Dispute In Short Is In Relation To Deletion Of Addition Made Of Rs.80,23,019/-, Being Bogus Long Term Capital Gain (‘Ltcg’ For Short) Added U/S. 68 Of The Income Tax Act, 1961 (‘The Act’ For Short) & Addition Of An Amount Of Rs.80,230/-, Being Commission Paid By The Assessee For Arranging The Accommodation Entry Of Bogus Ltcg.

For Appellant: Shri Bhadresh DoshiFor Respondent: Shri Annavaram Kosuri (Sr. AR)
Section 147Section 68

assessee had filed her return of income on 16.10.2016, declaring income of Rs.9,15,160/-. Subsequently, the Assessing Officer received information from the Investigation Wing of the department that the LTCG and Short Term Capital Gain (STCG for short) offered by the assessee from sale of shares M/s Goenka Business ... submitted, the assessee cannot be expected to explain the increase in share price through any supporting evidence. 9. He submitted, the report of the Investigation Wing is primarily based on the order passed by the Security Exchange Board of India (SEBI) suspending trading in scrip of M/s Goenka Business

DCIT Central Circle 1, New Delhi vs. Udai Shanker Awasthi, New Delhi

ITA 5347/DEL/2025[2018-19]Status: DisposedITAT Delhi06 Feb 2026AY 2018-19

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 132Section 153CSection 68

indeed retracted. 8. The Learned DR took us to the various questions posted to Shri Rajeev Saxena by the Enforcement Directorate and the Investigation Wing of the Income Tax Department and the replies given by him thereon and the contents of the seized documents which was the basis of making

DCIT Central Circle 1, New Delhi vs. Udai Shanker Awasthi, New Delhi

ITA 5346/DEL/2025[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 132Section 153CSection 68

indeed retracted. 8. The Learned DR took us to the various questions posted to Shri Rajeev Saxena by the Enforcement Directorate and the Investigation Wing of the Income Tax Department and the replies given by him thereon and the contents of the seized documents which was the basis of making

DCIT, Central Circle 1, New Delhi vs. Udai Shanker Awasthi, New Delhi

ITA 5345/DEL/2025[2015-16]Status: DisposedITAT Delhi06 Feb 2026AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 132Section 153CSection 68

indeed retracted. 8. The Learned DR took us to the various questions posted to Shri Rajeev Saxena by the Enforcement Directorate and the Investigation Wing of the Income Tax Department and the replies given by him thereon and the contents of the seized documents which was the basis of making

DCIT, Central Circle 1, New Delhi vs. Udai Shankar Awasthi, New Delhi

ITA 5344/DEL/2025[2014-15]Status: DisposedITAT Delhi06 Feb 2026AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Revenue byFor Respondent: Date of Hearing
Section 132Section 153CSection 68

indeed retracted. 8. The Learned DR took us to the various questions posted to Shri Rajeev Saxena by the Enforcement Directorate and the Investigation Wing of the Income Tax Department and the replies given by him thereon and the contents of the seized documents which was the basis of making

DCIT Central Circle-1, New Delhi vs. Udai Shanker Awasthi, New Delhi

ITA 4691/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CA Ms. Rinky Sharma, ITP Shri Anmol Jha, AdvFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 1Section 132Section 153CSection 68

indeed retracted. 8. The Learned DR took us to the various questions posted to Shri Rajeev Saxena by the Enforcement Directorate and the Investigation Wing of the Income Tax Department and the replies given by him thereon and the contents of the seized documents which was the basis of making

Ravindra Dhaka, Gurgaon vs. PCIT, Faridabad

In the result, the appeal of the assessee is dismissed

ITA 2332/DEL/2025[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2020-21] Ravindra Dhaka Vs Pr.Cit, H.No.-420F, Sector-38, Faridabad Gurgaon-122001 Pan-Afqpd9356P Appellant Respondent Appellant By Shri Vijay Kumar Singla, Ca & Shri Kinshuk Gautam, Ca Respondent By Shri Jitender Singh, Cit Dr Date Of Hearing 04.12.2025 Date Of Pronouncement 06.02.2026

Section 132Section 143(3)Section 153CSection 263

during the course of assessment proceedings, the Faceless AO asked the JAO to provide legible copies of the documents relied upon by the Investigation Wing to allege that assessee has made cash payment of INR 44,68,000/- [wrongly mentioned as INR 48,64,000/-] in acquisition of property. However ... more particularly when the Faceless AO had specifically asked the Jurisdictional AO to provide the legible copies of all the material supplied by the Investigation Wing. Under these circumstances, in our considered opinion, the assessment order so passed, is without proper investigation and inquiries on the material available on record

Makam Industries Private Limited, New Delhi vs. Deputy Commissioner of Income Tax Central Circle 29, New Delhi

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

ITA 1673/DEL/2025[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri Muneesh Rajani, Sr. DR
Section 147Section 148Section 151Section 153CSection 68

assessee company. 5. Subsequent to the assessment, the return was again selected for reassessment proceedings on the basis of information received form the Investigation Wing and notice u/s 148 of the Act dated 30.03.2021 was Page 2 of 5 ITA No. 1673/DEL/2025 [A.Y. 2013-14]) Makam Industries Vs ACIT issued

DCIT, Vikash Bhawan Delhi vs. Rajan Kumar, Laxmi Nagar, Delhi

In the result, the appeal of the Revenue appeal is dismissed and the cross objection filed by the assessee is allowed in the aforesaid manner

ITA 130/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri Sudhir Kumar & Smt. Renu Jauhridcit Vs Rajan Kumar Room No. 218-D Block, 31,Vijay Block Laxmi Vikash Bhawan, Nagar Delhi-110092 Delhi- 110 002 Pan: Caapk8381E

Section 132Section 142(1)Section 143(1)Section 147Section 148Section 69A

disposed-off, on the ground the assessee opted the scheme Vivad se Vishwas scheme and settled the dispute. 4. Further information received from the investigation wing that a search action u/s 132 of the Act was carried out at premise of M/s Skylark Group of cases ... assessment u/s 147/148 is contrary to law in the absence of any incriminating material to form reason to believe, as per the report of Investigation Wing and AO relied on, which only directs that the AO has examine the details and after this examination only to determine whether there could

ACIT, New Delhi vs. Sparsh Property Private Limited, Delhi

In the result, the Revenue’s appeal as well as Assessee’s cross objection stand dismissed

ITA 5849/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Shri Mahavir Singh & Shri Krinwant Sahayacit, Vs. M/S Sparsh Property Room No. 261-A, 2Nd Floor, Private Limited, E-2, Jhandewalan Extn., 43, Community Center, New Delhi – 110 055 New Friends Colony, S.O. Zakir Nagar, South East Delhi, New Delhi – 110 025 (Pan: Aabcs8660C) (Appellant) (Respondent) C.O. No. 56/Del/2025 (Ita No. 5849/Del/2024) (Ay 2016-17)

For Appellant: Sh. Biren Shah, CA & Sh. Rohit Aggarwal, CAFor Respondent: Sh. Mahesh Kumar, CIT(DR)
Section 132Section 143(1)Section 148Section 68

failed to appreciate that there is no information of conduct of any audit / investigation by SEBI/RBI , while the search conducted by Investigation Wing brought out substantial evidence about actual financial conduct of these entry operators, masquerading in the guise of NBFC. In view of above, he submitted that the addition

Income Tax Officer, Aaykar Bhawan vs. Shiv Shankar Rice Mills, Gogripur Road

In the result, the appeal of the Revenue is dismissed

ITA 4630/DEL/2024[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year: 2013-14]

Section 143(3)Section 147Section 148Section 151

vide order dated 09.03.2015 assessing total income at Rs.2,02,310/-. Later on receipt of the information from the office of DDIT(Investigation Wing), Karnal, the case was reopened and the notice under section 148 was issued 21.04.2020. In the reassessment order passed under section 147/144B ... mentioned above, appellant has contended that the case of the appellant has been re-opened solely on the basis of statement recorded by the Investigation Wing of third party without proper enquiry and without providing the statement of the party to the appellant in spite of specific request and denying

DCIT, Central Circle-6, Third Floor vs. Rama Shankar Khemka, Ganesh Bazar

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1005/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR
Section 132Section 132(4)

noteworthy that the assessee raised the same arguments (as were raised subsequently during the assessment and appellate proceedings) regarding the property transactions before the Investigation Wing immediately (almost within a week) after the initiation of search and also filed copies of documents supporting its claim. Moreover, the Assessing Officer ... offer any adverse comments to the above submission of theassessee filed before the investigation wing. 4.1.36 The Assessing Officer submitted during the appellate proceedings that his comments may be considered and appeal filed by the assessee may be decided on merits of case. It is noteworthy to mention that

DCIT, Central Circle-6, Third Floor vs. Rajesh Rani Khemka, Ganesh Bazar

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1004/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR
Section 132Section 132(4)

noteworthy that the assessee raised the same arguments (as were raised subsequently during the assessment and appellate proceedings) regarding the property transactions before the Investigation Wing immediately (almost within a week) after the initiation of search and also filed copies of documents supporting its claim. Moreover, the Assessing Officer ... offer any adverse comments to the above submission of theassessee filed before the investigation wing. 4.1.36 The Assessing Officer submitted during the appellate proceedings that his comments may be considered and appeal filed by the assessee may be decided on merits of case. It is noteworthy to mention that

DCIT, Central Circle-6, Income Tax Department vs. Payal Khemka, K

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1000/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR
Section 132Section 132(4)

noteworthy that the assessee raised the same arguments (as were raised subsequently during the assessment and appellate proceedings) regarding the property transactions before the Investigation Wing immediately (almost within a week) after the initiation of search and also filed copies of documents supporting its claim. Moreover, the Assessing Officer ... offer any adverse comments to the above submission of theassessee filed before the investigation wing. 4.1.36 The Assessing Officer submitted during the appellate proceedings that his comments may be considered and appeal filed by the assessee may be decided on merits of case. It is noteworthy to mention that

Assistant Commissioner of Income Tax, Circle-1(1), Bilaspur vs. Anuj Prakash Gupta, Rajasthan

In the result, appeal of the Revenue is dismissed

ITA 11/RPR/2026[2019-20]Status: DisposedITAT Raipur05 Feb 2026AY 2019-20

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.11/Rpr/2026 "नधा"रण वष" /Assessment Year : 2019-20 The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.)

For Appellant: Shri Anuj Prakash Gupta, AssesseeFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 132Section 147Section 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

Ambuja Cements Limited, Mumbai vs. PCIT, Mumbai-3, Mumbai

ITA 3474/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Sourabh Soparkar, AR (virtually appear)For Respondent: Shri Rajesh Kumar Yadav, (CIT-DR)
Section 143(3)Section 14ASection 263

entries and that the assessee had received such entries. The notice did not enclose any supporting evidence, such as bank trail, ledger trail, statements, Investigation Wing report, search material, or any document linking the assessee to the alleged entry providers. In response, the assessee asked for underlying evidence, to respond ... associate of Shri Robin Goenka (Sankalp Group), who was subjected to search and seizure action by the Investigation Directorate, Ahmedabad on 30.10.2018.The Investigation Wing had recorded statements, seized diaries, and compiled beneficiary lists identifying the assessee company as one of the recipients of accommodation entries. This crucial information was available

Mukesh Agarwal, Rourkela vs. Income Tax Office, Ward 1, Rourkela

Appeal of the assessee is allowed

ITA 631/CTK/2025[2015-16]Status: DisposedITAT Cuttack04 Feb 2026AY 2015-16

Bench: Shri George Mathan & Shri Laxmi Prasad Sahuआयकर अपील सं/Ita No.631/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2015-2016) Mukesh Agarwal, Vs Ito Ward-1, Rourkela O-18, Civil Township, Rourkela-769004 Pan No. : Adipa 0575 D (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Ayush Agarwal, Ar राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 04/02/2026 घोषणा की तारीख/Date Of Pronouncement : 04/02/2026 आदेश / O R D E R Per George Mathan, Jm :

For Appellant: Shri Ayush Agarwal, ARFor Respondent: Shri Vijay Singh, Sr. DR
Section 10(38)

hold that the said orders of SEBI is no evidence against the assessee, much less to speak of direct evidence. The enquiry by the Investigation Wing and/or the statements of several persons recorded by the Investigation Wing in connection with the alleged bogus transactions in the shares of KAFL also