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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

Shalinee Chopra, New Delhi vs. ACIT, Circle-54(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 435/DEL/2023[2012-13]Status: DisposedITAT Delhi10 Dec 2024AY 2012-13

Bench: Shri Vikas Awasthy & Smt. Renu Jauhri[Assessment Year : 2012-13] Shalinee Chopra, Vs Acit, A-11, Dda Commercial Complex, Circle-54(1), Ring Road, Defence Colony, New Delhi. New Delhi -110024. Pan-Aafpc1989D Appellant Respondent Appellant By Shri Mani Bhadra Jain, Adv. Respondent By Shri Sahil Kumar Bansal, Sr. Dr Date Of Hearing 03.12.2024 Date Of Pronouncement 10.12.2024

Section 143(1)Section 143(3)Section 148Section 151Section 16(3)Section 68Section 69C

invalid. 4. That Ld. AO has recorded reasons on the basis of borrowed belief, suspicion, preconceived notions, simply on the basis of information from Investigation wing and was not accompanied by any other material. 5. That in the facts and circumstances of the case, the Ld. AO recorded his reasons ... other sources during the year under consideration. The return was processed u/s 143(1) of the Act. Subsequently, upon receipt of information from the Investigation Wing that the assessee is a beneficiary of accommodation entry provided by one Shri Varun Garg, a notice u/s 148 of the Act was issued

Mohan Garg, Faridabad vs. DCIT Central Circle-2, Faridabad

In the result, the appeal of the assessee is allowed

ITA 3659/DEL/2023[2017-18]Status: DisposedITAT Delhi10 Dec 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshmohan Garg, Vs. Dcit, H. No. 905, Sector-15, So Central Circle-2, Faridabad, Sector-16A, Faridabad Faridabad, Haryana (Appellant) (Respondent) Pan: Ahlpg2577N

For Appellant: Shri Ved Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT DR
Section 115Section 132Section 153Section 153ASection 153CSection 68

depositing the cash, funds were transferred by layering of funds to SRS limited or other sister concerns. During the course of inquiries by the investigation wing, 71 shell concerns and the 91 own bogus concerns were identified to be used by the SRS group to route its funds. M/s Destiny

Ashok Kumar Gupta, Delhi vs. ITO Ward 56(4), Delhi

In the result, the appeal of the assessee is allowed

ITA 3657/DEL/2019[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshashok Kumar Gupta, Vs. Ito, B-3, West Gorkh Park, Ward-56(4), Shahadra, Delhi New Delhi (Appellant) (Respondent) Pan: Agjpg4741M

For Appellant: Shri Prince Mohan Singh, AdvFor Respondent: Shri Poojan Rana, Sr. DR
Section 143(3)Section 147

with M/s Global Trade Corporation during the year under consideration in the form of purchase, which was to be treated as non-genuine. The Investigation Wing report revealed that Global Trade Corporation was a bogus entity and accordingly they had supplied bogus bills to the assessee and assessee had transacted ... maintenance of bank account in ICICI bank by the assessee instead the learned AO had only relied on the information received from investigation wing that M/s Global trade corporation was a bogus entity and the assessee had made some purchases from such bogus entity which had resulted in escapement

Assistant Commissioner of Income Tax, Central Circle-4(2), Kolkata, Aayakar Bhawan Poorva vs. Mansamata Vyapaar Private Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 2054/KOL/2024[2013-14]Status: HeardITAT Kolkata09 Dec 2024AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 139Section 143(2)Section 143(3)Section 147Section 148Section 148ASection 151Section 68

completed on 28.12.2017 determining total income of the assessee at Rs.93,940/-. Further, a credible information was received by the AO from the investigation wing that the assessee company had taken accommodation entry from one M/s Subhlakshmi Vanijya Pvt. Ltd. which was a shell company controlled by a well- known ... department has preferred the present appeal. 6. We have perused the order of AO and find that on the receiving credible information from the Investigation Wing that the assessee company had taken accommodation entry from one M/s Subhlaxmi Vanijya Pvt. Ltd. being controlled by the well-known entry operator namely

Income Tax Officer 22(3)(1), Mumbai, Piramal Chambers, Parel Mumbai vs. Reliance Metafab, Santacruz Mumbai

In the result, both the appeals of the assessee are partly allowed and both the appeals of the Revenue are dismissed

ITA 3771/MUM/2024[2011-12]Status: DisposedITAT Mumbai09 Dec 2024AY 2011-12

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

For Appellant: Shri Rajesh ShahFor Respondent: Shri R.R. Makwana, Sr.DR
Section 133(6)Section 148

partnership firm. It is engaged in the business of manufacturing/fabrication/dealing in Cable Trays, Gratings, Electrical items etc. The AO received information from the Investigation wing that certain parties have provided only accommodation bills without actually supplying materials and the assessee is one of the beneficiaries who availed accommodation bills. Accordingly ... assessments of AY 2010-11 and 2011-12 by issuing notice u/s 148 of the Act. As per the information given by the Investigation wing, the assessee has taken accommodation bill from the following parties:- Assessment year Name of Party Amount 2010-11 Hitech Impex

ITO 22(3)(1), Piramal Chambers, Mumbai vs. Reliance Metafab, Santa Cruz Mumbai

In the result, both the appeals of the assessee are partly allowed and both the appeals of the Revenue are dismissed

ITA 3736/MUM/2024[2010-11]Status: DisposedITAT Mumbai09 Dec 2024AY 2010-11

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

For Appellant: Shri Rajesh ShahFor Respondent: Shri R.R. Makwana, Sr.DR
Section 133(6)Section 148

partnership firm. It is engaged in the business of manufacturing/fabrication/dealing in Cable Trays, Gratings, Electrical items etc. The AO received information from the Investigation wing that certain parties have provided only accommodation bills without actually supplying materials and the assessee is one of the beneficiaries who availed accommodation bills. Accordingly ... assessments of AY 2010-11 and 2011-12 by issuing notice u/s 148 of the Act. As per the information given by the Investigation wing, the assessee has taken accommodation bill from the following parties:- Assessment year Name of Party Amount 2010-11 Hitech Impex

Reliance Metafab, Santacruz(West), Mumbai vs. Ward 22(3)(1), Mumbai, Parel

In the result, both the appeals of the assessee are partly allowed and both the appeals of the Revenue are dismissed

ITA 3686/MUM/2024[2010-11]Status: DisposedITAT Mumbai09 Dec 2024AY 2010-11

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

For Appellant: Shri Rajesh ShahFor Respondent: Shri R.R. Makwana, Sr.DR
Section 133(6)Section 148

partnership firm. It is engaged in the business of manufacturing/fabrication/dealing in Cable Trays, Gratings, Electrical items etc. The AO received information from the Investigation wing that certain parties have provided only accommodation bills without actually supplying materials and the assessee is one of the beneficiaries who availed accommodation bills. Accordingly ... assessments of AY 2010-11 and 2011-12 by issuing notice u/s 148 of the Act. As per the information given by the Investigation wing, the assessee has taken accommodation bill from the following parties:- Assessment year Name of Party Amount 2010-11 Hitech Impex

Reliance Metafab, Santacruz(West), Mumbai vs. Ward 22(3)(1), Mumbai, Parel

In the result, both the appeals of the assessee are partly allowed and both the appeals of the Revenue are dismissed

ITA 3685/MUM/2024[2011-12]Status: DisposedITAT Mumbai09 Dec 2024AY 2011-12

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

For Appellant: Shri Rajesh ShahFor Respondent: Shri R.R. Makwana, Sr.DR
Section 133(6)Section 148

partnership firm. It is engaged in the business of manufacturing/fabrication/dealing in Cable Trays, Gratings, Electrical items etc. The AO received information from the Investigation wing that certain parties have provided only accommodation bills without actually supplying materials and the assessee is one of the beneficiaries who availed accommodation bills. Accordingly ... assessments of AY 2010-11 and 2011-12 by issuing notice u/s 148 of the Act. As per the information given by the Investigation wing, the assessee has taken accommodation bill from the following parties:- Assessment year Name of Party Amount 2010-11 Hitech Impex

Shri Rajesh Bhavarlal Jain, Mumbai vs. Incometax Officer 21(3)(1), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 3605/MUM/2024[2011-12]Status: DisposedITAT Mumbai09 Dec 2024AY 2011-12

Bench: Shri Amarjit Singh & Shri Sunil Kumar Singhassessment Year: 2011-12

For Appellant: Shri Nisheeth DoshiFor Respondent: Shri R.R. Makwana, Sr. DR
Section 143(3)Section 234ASection 274Section 69C

view of the following: a) Re-opening of the assessment is done without independent application of mind relying on the information received from the Investigation Wing without there being any incriminating document corroborating the allegation that the transactions were not genuine. b) The Ld. Assessing Officer has not established ... view of the following: a) Re-opening of the assessment is done without independent application of mind relying on the information received from the Investigation Wing without there being any incriminating document corroborating the allegation that the transactions were not genuine. b) The Ld. Assessing Officer has not established

Agricom Foods Private Limited, Mumbai vs. Principle Commissioner of Income Tax (Central) Mumbai-2, Mumbai

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

ITA 2716/MUM/2024[2019-20]Status: DisposedITAT Mumbai09 Dec 2024AY 2019-20

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Dharan GandhiFor Respondent: Dr.K.R.Subhash,CIT-DR
Section 132Section 143(3)Section 153ASection 263

both the years under consideration. 3. Before the Ld.PCIT, the assessee contended that the due enquiries were made by the Investigation Wing with regard to acquisition of the undertaking from M/s J S International. It was submitted that, during the course of search proceedings, a statement was recorded ... relating to purchase of the undertaking from M/s. J.S. International. It was submitted that the AO has gone through the reports and record of investigation wing in the current years and has accordingly allowed the claim of depreciation. Accordingly, it was contended that the claim of depreciation was allowed

Agricom Foods Private Limited, Mumbai vs. Principle Commissioner of Income Tax (Central)-2, Mumbai

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

ITA 2709/MUM/2024[2018-19]Status: DisposedITAT Mumbai09 Dec 2024AY 2018-19

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Dharan GandhiFor Respondent: Dr.K.R.Subhash,CIT-DR
Section 132Section 143(3)Section 153ASection 263

both the years under consideration. 3. Before the Ld.PCIT, the assessee contended that the due enquiries were made by the Investigation Wing with regard to acquisition of the undertaking from M/s J S International. It was submitted that, during the course of search proceedings, a statement was recorded ... relating to purchase of the undertaking from M/s. J.S. International. It was submitted that the AO has gone through the reports and record of investigation wing in the current years and has accordingly allowed the claim of depreciation. Accordingly, it was contended that the claim of depreciation was allowed

Hiren D Kubadia HUF, Dadar West vs. Income Tax Officer, Ward 21(1)(4), Mumbai

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

ITA 3084/MUM/2023[2013-14]Status: DisposedITAT Mumbai09 Dec 2024AY 2013-14

Bench: Shri B.R. Baskaran & Shri Sunil Kumar Singhassessment Year : 2013-14 Hiren D. Kubadia Huf, Income Tax Officer, 601, Sunshine Heights, Ward-21(1)(4), 243 P.L. Kale Guruji Marg, Vs. Piramal Chamber, Dadar (West) Mumbai. Mumbai Pan : Aachh9591P (Appellant) (Respondent)

For Appellant: Shri Aakash KumarFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 10(38)Section 131Section 68Section 69C

shares at Rs.91,27,800/-). The assessee claimed the same as exempt u/s 10(38) of the Act. 3. The AO noticed that the Investigation Wing of Kolkata has reported that the bogus capital gains were generated by rigging the price of shares of certain companies, which were named ... penny stocks”. It was noticed that M/s. Tuni Textiles Ltd. was identified as one of the penny stocks. The Investigation Wing had reported that the fundamentals and financial strength of the above said company do not justify the market value of shares. He also noticed from the report given

Manjula H. Vira, Mumbai vs. ACIT 27(2), Mumbai, Navi Mumbai

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

ITA 2923/MUM/2023[2015-2016]Status: HeardITAT Mumbai09 Dec 2024AY 2015-2016

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaranassessment Year : 2015-16 Manjula H. Vira, Acit-27(2), 1201, Kailash Palace, Tower No. 6, 4Th Floor, Upashray Lane, Vs. Vashi Railway Station Complex, Ghatkopar (East), Vashi, Mumbai. Navi Mumbai. Pan : Anips5867Q (Appellant) (Respondent) For Assessee : Shri Neelkanth Khandelwal, For Revenue : Shri R.R. Makwana, Sr.Dr Date Of Hearing : 04-12-2024 Date Of Pronouncement : 09-12-2024 O R D E R Per B.R. Baskaran, A.M : The Assesseee Has Filed This Appeal Challenging The Order Dated 04-08-2023 Passed By The Ld.Cit(A)-Nfac, Delhi & It Relates To The Assessment Year (Ay.) 2015-16. The Assessee Is Aggrieved By The Decision Of The Ld.Cit(A) In Confirming The Addition Of Rs.3.28 Crores Relating To Sale Prices Of Shares Added By The Ao U/S 68 Of The Income Tax Act, 1961 („The Act‟) & Also The Addition Of Rs.9,83,123/- Relating To Estimated Commission Expenses Made U/S 69C Of The Act.

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri R.R. Makwana, Sr.DR
Section 10(38)Section 131Section 68Section 69C

share. Consequently, the assessee received 20,00,000 shares of Re1.00 each in lieu of 2,00,000 shares of Rs.10/- each. The Investigation Wing had carried out investigation with regard to the price manipulations and generation of bogus long term capital gains in number of stocks, classified as penny ... shares for a consideration of Rs.3.28 crores and declared long term capital gains of Rs.3.21 crores. Relying fully upon the report given by the Investigation Wing, the AO took the view that the long term capital gain declared by the assessee on sale of shares of above mentioned company

Ava Builders Private Limited, Delhi vs. ITO Ward 1(1), New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 1855/DEL/2024[2012-13]Status: DisposedITAT Delhi09 Dec 2024AY 2012-13

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh[Assessment Year: 2012-13]

Section 143(2)Section 148Section 234ASection 271(1)(c)Section 68

Rs.3,93,963/- for AY 2012-13 and the assessment was completed on the returned income. Thereafter, on receipt of information from the Investigation Wing, Delhi, vide letter dated 08.03.2019 informing that the assessee company had provided loan of Rs.15 lakhs to Shri Vinay Vats, one of the Directors

Kay Power and Paper Limited, Satara vs. Income Tax Officer, Ward-2, Satara

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

ITA 1437/PUN/2024[2016-17]Status: DisposedITAT Pune06 Dec 2024AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Ashwani KumarFor Respondent: Shri Ramnath P Murkunde
Section 139Section 139(1)Section 143(1)Section 148Section 148A

initiating the re- assessment proceedings for escapement of income of Rs.2,67,66,750/-. The so called information / letter / intimation received from the Investigation Wing which was relied upon by the Assessing Officer, does not clearly show as to whether (i) it contained any tangible material / information to suggest that

Kay Power and Paper Limited, Satara vs. Income Tax Officer, Ward-2, Satara

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

ITA 1436/PUN/2024[2015-16]Status: DisposedITAT Pune06 Dec 2024AY 2015-16

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Ashwani KumarFor Respondent: Shri Ramnath P Murkunde
Section 139Section 139(1)Section 143(1)Section 148Section 148A

initiating the re- assessment proceedings for escapement of income of Rs.2,67,66,750/-. The so called information / letter / intimation received from the Investigation Wing which was relied upon by the Assessing Officer, does not clearly show as to whether (i) it contained any tangible material / information to suggest that

Dy Commissioner of Inocme Tax, Circle -2, Nagpur vs. M/S N Kumar Construction Co .Pvt.Ltd, Nagpur

ITA 252/NAG/2018[2012-13]Status: DisposedITAT Nagpur06 Dec 2024AY 2012-13

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

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Vikash Agrawal
Section 131Section 143(2)Section 148Section 68

simply brushed aside all the evidences, and relied on the statement given by one of the Directors of Prabhav Industries, before the investigation wing, which is any case makes no mention whatsoever of the appellant company or any dealings of the purported nature with the appellant company

Dy Commissioner of Inocme Tax, Circle -2, Nagpur vs. M/S N Kumar Construction Co .Pvt.Ltd, Nagpur

ITA 247/NAG/2018[2010-11]Status: DisposedITAT Nagpur06 Dec 2024AY 2010-11

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

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Vikas Agrawal
Section 131Section 148Section 68

companies to the appellant. The A.O. failed to conduct any scrutiny of documents and rested contents by placing reliance on a report of the Investigation wing, which was also not provided to the appellant for rebuttal. Therefore, in my opinion, the appellant has established the identity, creditworthiness of the parties ... simply brushed aside all the evidences, and relied on the statement given by one of the Directors of Prabhav Industries, before the investigation wing, which is any case makes no mention whatsoever of the appellant company or any dealings of the purported nature with the appellant company

Income Tax Officer Ward 20(1)(1) Mumbai, Mumbai vs. Divesh Ashok Bafna, Mumbai

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

ITA 5410/MUM/2024[2015-16]Status: HeardITAT Mumbai05 Dec 2024AY 2015-16

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaranassessment Year : 2015-16 Income Tax Officer Divesh Ashok Bafna, Ward-20(1)(1), 302, C-Wing, 3Rd Floor, Room No. 303, 3Rd Floor, Vs. Arihant Apartment, Piramal Chamber, Dr. D.B. Marg, Lalbaugh, Parel, Mumbai Central, Mumbai. Mumbai. Pan : Atapb9065D (Appellant) (Respondent)

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri R.R. Makwana, Sr.DR
Section 10(38)Section 131Section 133(6)Section 3Section 68

gains amounting to Rs. 61,02,662/- arising on sale of shares of M/s. Greencrest Financial Services Limited. The AO received information from the Investigation Wing of Kolkata that the shares of certain companies were manipulated to generate bogus long term capital gains. Such kind of shares were termed ... penny stocks‟. The AO noticed that the Investigation Wing has identified shares of M/s. Greencrest Financial Services Ltd., as one of such penny stock shares. Hence, the AO took the view that the long term capital gains declared by the assessee is bogus in nature. 3. In the assessment order

Income Tax Officer, Vashi, Navi Mumbai vs. Mahesh K Shavdia HUF, Mumbai

ITA 2214/MUM/2024[2011]Status: DisposedITAT Mumbai05 Dec 2024

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhanassessment Year : 2011-12 Income Tax Officer, Mahesh K. Shavdia Huf, Room No. 413, 4Th Floor, 27/28, Kailash Niwas No. 2, Tower No. 6, Vs. R.B.Mehta Marg, Vashi Railway Station Ghatkopar (East), Complex, Mumbai Navi Mumbai Pan : Aahhm1877L (Appellant) (Respondent) Assessee By : Shri Sanjay R. Parikh Revenue By : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 08/11/2024 Date Of Pronouncement : 05/12/2024

For Appellant: Shri Sanjay R. ParikhFor Respondent: Shri Krishna Kumar, Sr. DR
Section 132(4)Section 133(6)Section 148Section 69

return of income for the year under consideration declaring a total income of Rs. 8,470/-. Subsequently, the AO received information from the Investigation Wing about the search and seizure action conducted 2 in the business premises of M/s. Nish Developers Pvt. Ltd., and its group. During the course ... related to sale of flats in the project named, “1 Avighna Park” located at Curry Road, Mumbai. As per the information given by the Investigation wing, the assessee has purchased a flat in the above said project and it had paid on money of Rs. 2.41 crores