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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

Dy. Commissioner of Income Tax, Mumbai vs. Ashok Jasraj Jain, Mumbai

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

ITA 3839/MUM/2024[2011-12]Status: DisposedITAT Mumbai14 Oct 2024AY 2011-12

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL, ‘A’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 132Section 143(1)Section 143(3)Section 147Section 148

153A vide order dated 26/03/2014 declaring total income at Rs.49,06,660/- after making certain additions / disallowance. Later on, an information was received from Investigation Wing vide letter dated 16/03/2018 that assessee had purchased property for Rs.3,44,27,000/- in F.Y.2010-11 and had shown gross total income of Rs.29 ... passed on 26.03.2014 determining total income at Rs 49,06,660/- making certain addition/disallowances. Information has been received from Investigation Wing, Mumbai that the assessee SHRI ASHOK JASRAJ JAIN has purchased property of Rs 3,44,27,000/- in FY 2010-11. On perusal of the ROI 4 ITA No.3839/Mum

Sandesh Projects Pvt. Ltd, Mumbai vs. ITO 11(1)(3), Mumbai

In the result appeal of the assessee is partly allowed

ITA 1734/MUM/2024[2010-11]Status: DisposedITAT Mumbai14 Oct 2024AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

Section 133Section 142Section 143Section 147Section 148Section 68

orders of the learned lower authorities and submitted that the case of the assessee was reopened based on the information received by the investigation wing that during the course of search in case of one accommodation entry provider, the above 2 investor companies were found to be entities operated ... filed its return of income which was accepted as it is. Subsequently on account of information received by the learned assessing officer from Investigation Wing that based on the search operation carried out by the income tax Department on an accommodation entry provider, the name of two companies were found

Dinesh Prabhudas Hingoo, Jogeshwari (W), Mumbai vs. ACIT Circle-31(1), Mumbai

In the result, the appeal filed by the Assessee stands allowed

ITA 667/MUM/2024[2011-12]Status: DisposedITAT Mumbai11 Oct 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2011-12

For Appellant: Shri Ravindra Poojari, A.RFor Respondent: Shri H.M. Bhatt, Sr. D.R
Section 10(38)Section 131Section 143(1)Section 148Section 250

Subsequently, the AO received that information vide letter dated 23.03.2018 from the Dy. Director of Income Tax (Investigation Wing-8(3)], Mumbai, that M/s. Nivyah Infrastructure and Telecom Services Ltd. (in short “M/s. Nivyah”) is a penny stock listed on BSE with scrip code (531588) and has been used ... quashed. 6. On the contrary, the Ld. D.R. refuted the claim of the Assessee and submitted that may be in the information received from investigation wing the name of the scrip has been mentioned as “M/s. Nivyah” but it is a fact that erstwhile name of M/s. Nivyah

DCIT 41(4)(1), Room No, Kautilya Bhawan, G Block, Bkc, Mumbai vs. Dinesh Prabhudas Hingoo, Jogeshwari(W), Mumbai

In the result, the appeal filed by the Assessee stands allowed

ITA 1348/MUM/2024[2011-12]Status: DisposedITAT Mumbai11 Oct 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2011-12

For Appellant: Shri Ravindra Poojari, A.RFor Respondent: Shri H.M. Bhatt, Sr. D.R
Section 10(38)Section 131Section 143(1)Section 148Section 250

Subsequently, the AO received that information vide letter dated 23.03.2018 from the Dy. Director of Income Tax (Investigation Wing-8(3)], Mumbai, that M/s. Nivyah Infrastructure and Telecom Services Ltd. (in short “M/s. Nivyah”) is a penny stock listed on BSE with scrip code (531588) and has been used ... quashed. 6. On the contrary, the Ld. D.R. refuted the claim of the Assessee and submitted that may be in the information received from investigation wing the name of the scrip has been mentioned as “M/s. Nivyah” but it is a fact that erstwhile name of M/s. Nivyah

Tejinder Kaur, U.P vs. ACIT, Central Circle-31, Delhi

In the result, appeal of the assessee is allowed

ITA 936/DEL/2024[2021-22]Status: DisposedITAT Delhi11 Oct 2024AY 2021-22

Bench: Pradip Kumar Kedia & Shri Sudhir Pareek

Section 132Section 139(1)Section 143(2)Section 143(3)Section 153CSection 45

AALPK6683J), AYs. 2015-16 to 2021-22. Action under section 132 of the Income Tax Act was conducted in HANS Group of cases by Investigation wing, New Delhi on 06.01.202.ilt has the en brought to the notice of the undersigned by the AO of Sh. Parveen K. Jain

Sarojben Rajkumar Bansal Legal Heir of Late Rajkumar Kakaram Bansal, Bhavnagar vs. The Dy. Commissioner of Income Tax, Circle-1, Bhavnagar

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

ITA 306/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad10 Oct 2024AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.306/Ahd/2024 िनधा"रण वष" /Assessment Year : 2013-14 Sarojben Rajkumar Bansal The Dy.Cit बनाम/ Legal Heir Of Circle-1 V/S. Late Shri Rajkumar Kakaram Bhavnagar – 364 001 Bansal Plot No.1497/B, Opp. Theosophical Lodge Bhavnagar, Gujarat 364 001 "थायी लेखा सं./Pan: Aanpb 1618 G अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Tushar Hemani, Sr. Advocate & Shri Parimalsinh B. Parmar, Ar Revenue By : Shri Prithviraj Meena, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 08/10/2024 घोषणा की तारीख /Date Of Pronouncement: 10/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Shri Prithviraj Meena, CIT-DR
Section 10(38)Section 143(3)Section 147Section 148Section 250Section 250(6)Section 271(1)(c)Section 68

completed on 26.11.2015, accepting the returned income. The assessment was subsequently reopened under section 147 of the Act, based on information received from the Investigation Wing, Ahmedabad. The Investigation Wing conducted a search in the case of Globe Ecologistics Group on 23.01.2015 and found that several individuals, including the assessee

Godavari Multipurpose Articles Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 7(1), Kolkata

In the result, appeal of the assessee isallowed

ITA 1262/KOL/2024[2012-2013]Status: DisposedITAT Kolkata10 Oct 2024AY 2012-2013

Bench: Shri Manish Borad, Accountant Member Shri Sonjoy Sarma (Judicial Member)

Section 143(3)Section 147Section 148Section 250Section 68

tangible material to suggests that escapement of income. He argued that the Ld. CIT(A) had relied merely on the information provided by the Investigation Wings without independent verification or examination by the AO. The Ld. AO during the assessment proceedings proceeded that the reassessment and added ... time of hearing, the Ld. AR stated that the reopening of the assessment order solely based on information received through Investigation Wing and which was without independent inquiry made by the AO in such a situation assessment framed by the AO is not valid and liable to be dismissed

Amit Sajjan Kumar Gupta, Mumbai vs. DCIT 8(2)(1), Mumbai

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

ITA 1378/MUM/2024[2015-16]Status: DisposedITAT Mumbai10 Oct 2024AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalamitsajjankumargupta, Dcit-8(2)(1), 110, Ashirwad, Roomno.624, बनाम/ Ahmedabad Street, Aayakar Bhavan, Vs. Carnac Bunder, M.K.Road, Mumbai-400009. Mumbai-400020. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abrpg2852N (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) Assessee By : Shri Ravikant Pathak.Ar Revenue By : Shri Manoj Kumar Sinha, Sr. Dr सुनवाई की तारीख / Date Of Hearing 08/08/2023 घोषणा की तारीख /Date Of Pronouncement 10/10/2024 आदेश / Order Per Pavan Kumar Gadale - Jm: The Appeal Is Filed By The Assesse Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi / Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal: 1. On The Facts & In The Circumstances Of The Case & In Law, The Learned Cit (A) Nfac, Erred In Confirming Order Made U/S. 143(3) Of The Income Tax Act, 1961 Which Is Bad In Law, Ultra Vires & Without Appreciating The Facts, Submission & Evidences In The Proper Perspective, Without Providing Copies Of Material Used Against The Appellant & Without Providing Opportunity Of Cross Examination, Is Liable To Be Annulled.

For Appellant: Shri Ravikant Pathak.ARFor Respondent: Shri Manoj Kumar Sinha, Sr. DR
Section 143(3)Section 68

purchase, shares split, sale of shares and relied on the various factual aspects of share trends, modus operandi and report of the Kolkata Investigation Wing statements recorded, BSE data and has doubted the earning of long term capital gains on shares. Further the AO has 4 ITA.No.1378/Mum/2024. Amit Sajjan ... quoted by any of such persons nor was any material relating to the assessee found at any place where investigation was done by the Investigation Wing, on a petition for special leave to appeal to the Supreme Court special leave to appeal to the Supreme Court The Supreme Court dismissed

ITO-28.3.1, Navi Mumbai vs. Seema Narendra Bapna, Nerul

In the result both the grounds of appeal are dismissed

ITA 1120/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Oct 2024AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm A.Y.2014-15 Ito,28.3.1, Seema Narendra Bapna, Mumbai Flat No.A 2701, Plot No. R3 B Emerald Bay, Sector Vs. 14 Nerul, Navi Mumbai, Thane 400706

Section 143Section 147Section 148

erred in allowing the assessee’s appeal without appreciating the fact that in this case after receiving a detailed report from the investigation Wing, the AO has brought out the circumstances of evidence is in the assessment order wherein the AO has detected the abnormal price rise in the penny ... revenue A Y : 2014–15 Income Tax Officer Versus Seema Narendra Bapna and in paragraph number five has recorded the findings of the investigation wing where above company is one of the scrips which is identified by the Calcutta investigation directorate being used in providing accommodation entries to the beneficiaries

DCIT Cenral Circle - 8, New Delhi vs. Artline Vinimay Private Limited, New Delhi

In the result, the appeals of the Revenue are dismissed

ITA 722/DEL/2021[2012-13]Status: DisposedITAT Delhi10 Oct 2024AY 2012-13

Bench: Shri Shamim Yahya & Shri Sudhir Kumara.Yr. : 2012-13 Dy. Commissioner Of Artline Vinimay Private Income Tax, Vs. Limited, Central Circle-8, H.No. 8, Ground Floor, New Delhi Todarmal Lane, Bengali Market, New Delhi – 110 001 (Pan: Aacca5237E) (Appellant) (Respondent) Appellant By : Sh. Amit Goel, Ca & Sh. Pranav Yadav, Adv. Respondent By : Sh. N.K. Bansal, Sr. Dr Date Of Hearing : 08.10.2024 Date Of Pronouncement : 10.10.2024 Order

For Appellant: Sh. Amit Goel, CA & Sh. PranavFor Respondent: Sh. N.K. Bansal, Sr. DR
Section 142(1)Section 143(2)Section 147Section 148

return of income on 28.09.2012 declaring total income of Rs. 16,178/-. AO noted that in this case, information was received from the Investigation Wing, Kolkata and as per the information received, on perusal of the bank statement of the assessee company, it was found during the year under consideration ... parties from- whom share application money was received back. He has only relied upon figure of Rs. 2,44,68,000/- given by Investigation Wing, Kolkata. Secondly, in para 7 of the assessment order, the heading given by the Assessing Officer is ‘Addition on account of bogus refund of share

DCIT, Circle-20(1), New Delhi vs. Pragyawan Technologies Private Limited, Delhi

ITA 88/DEL/2020[2016-17]Status: DisposedITAT Delhi10 Oct 2024AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharmaassessment Year: 2016-17 Dcit, Vs Pragyawan Technologies Private Circle-20(1), Limited, Flat No.02, 2Nd Floor, New Delhi. Plot No.70A/31, Guru Nanakpura, Laxmi Nagar, Delhi – 110 092. Pan: Aagcp1209D

For Appellant: Shri Vijay Singla, CAFor Respondent: Shri Mandeep Pawar, Sr. DR
Section 131(1)(d)Section 133(6)Section 142(1)Section 143(3)Section 68

placing reliance on only the papers and documents submitted on their behalf, and ignoring the findings of enquiry made by the investigation wing, Kolkata proving that these were just paper companies without having any existence at their given addresses?” 3 “Whether on the facts and in the circumstances ... creditor companies may be intimated to examine the source of funds in their books, without appreciating the report of the Investigation Wing, Kolkata which stated that these were shell companies reflected in the database of entry operators, further evidenced by the fact that these companies did not exist

ACIT, Central Circle-2, Patna vs. Shri Nitesh Kumar, Patna

In the result, the appeal of the revenue is dismissed

ITA 50/PAT/2020[2017-18]Status: DisposedITAT Patna09 Oct 2024AY 2017-18

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey]

Section 115BSection 132ASection 139(4)Section 143(2)Section 143(3)Section 44ASection 69A

bank account, audited financial accounts, books of account before the AO. It was also stated that the documents and records seized by the Investigation Wing were available with the department and all these transactions as shown in the seized documents were found duly reflected in the audited financial accounts

M/S. Star Dealcom Pvt. Ltd., Birbhum vs. I.T.O., Ward - 3(1), Suri, Birbhum

ITA 1415/KOL/2024[2011-2012]Status: DisposedITAT Kolkata09 Oct 2024AY 2011-2012

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 133(6)Section 143(1)Section 147Section 148

Issue raised in ground no. 1 is against the reopening of assessment initiated on the basis of report of investigation wing of the department without any independent application of mind or bringing on record any tangible record in invalid and bad in law and therefore the entire assessment is liable

M/S Gassin Pierre Pvt. Ltd., Kolkata vs. DCIT, Cir. 7(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 112/KOL/2024[2014-15]Status: DisposedITAT Kolkata09 Oct 2024AY 2014-15

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 133ASection 147Section 148Section 148(2)Section 35(1)(ii)

therefore submitted that the case of the assessee was re-opened on the basis of the said information supplied by the investigation wing and could not be said to be without any basis or on borrowed satisfaction. The ld DR therefore prayed that the reopening 5 I.T.A. No.112/Kol/2024 Assessment Year ... reason to believe recorded by the AO did not contain the findings of AO and were at best reproduced the conclusion of the Investigation Wing and that amounted to borrowed satisfaction. The Court has held that since there was no independent application of mind in forming the reasons to believe

Deputy Commissioner of Income Tax, Central Circle-4, Jaipur vs. Sunder Das Sonkiya, Jaipur

In the result, both appeals of the revenue are dismissed

ITA 454/JPR/2024[2013-14]Status: DisposedITAT Jaipur09 Oct 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. R. Sharma, CA &For Respondent: Sh. Anup Singh, Addl.CIT
Section 143(1)Section 143(2)Section 143(3)Section 148

ground of the information received from DCIT, Central Circle- 4, Surat that during the course of search operation carried out by Investigation wing of the department in case of Rajendra Jain group Mumbai on 03.10.2013 it is revealed from documents and evidences found during the searen, it has been gathered ... able to establish the genuineness of the purchase claimed by it or it has failed in discharging this onus. The information received from investigation wing and statement of Shri Rajendra Jain group supplied to the assessee clearly explains the modus operandi of this bogus transaction. The case laws cited

Deputy Commissioner of Income Tax, Central Circle-4, Jaipur vs. Sunder Das Sonkiya, Jaipur

In the result, both appeals of the revenue are dismissed

ITA 453/JPR/2024[2012-13]Status: DisposedITAT Jaipur09 Oct 2024AY 2012-13

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal In Ita No.453/Jp/2024 On The Following Grounds; “(I) Whether On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Is Justified In Deleting The Addition Of Rs.43,33,606/- Without Appreciating The Fact That Assessee Has Shown Bogus Purchase Of Rs 1,73,34,424/- During The Year From A Bogus Concern. 3

Section 132Section 143(1)Section 143(2)Section 148

ground that information was received from DCIT, Central Circle-4, Surat that during the course of search operation carried out by Investigation Wing of the Deptt. in case of Rajendra Jain group Mumbai on 3-10- 2013 it is revealed from documents and evidences found during the search ... burden casted on him and relied on various judgements. The assessee also stated that it does not know that what enquiries and which connection investigation wing carried on the alleged investigation and on what basis and evidences in the eyes of law it is concluded by department that the said

Banwari Purshottam Bhargav, Andheri West Mumbai vs. ITO 24(1)(3), Piramal Chamber, Mumbai

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

ITA 2182/MUM/2024[2014-15]Status: DisposedITAT Mumbai09 Oct 2024AY 2014-15

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhanassessment Year 2014-15 Banwari Purshottam Bhargav, Income Tax Officer-24(1)(3), Flat No. 202, Panch Amrut, Piramal Chamber, Panch Complex, Off. Yari Road, Vs. Lalbaug, Versova, Andheri West, Mumbai Mumbai Pan : Aabpb7453M (Appellant) (Respondent) Assessee By: Shri Vimal Punmiya, Revenue By: Shri Ashok Kumar Ambastha, Sr.Dr Date Of Hearing : 11/07/2024 Date Of Pronouncement : 09/10/2024

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Ashok Kumar Ambastha, Sr.DR
Section 10(38)Section 131Section 133(6)Section 68Section 69

assessee had purchased shares of M/s. Santoshima Tradelinks Ltd., which was later merged with M/s. Sunrise Asian Ltd. 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 stocks. The AO noticed ... shares for a consideration of Rs.2.47 crores and declared long term capital gains of Rs.2.36 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

Anshu Vashisth, Faridabad vs. ITO Ward 1(1) Faridabad, Faridabad

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

ITA 3761/DEL/2023[2012-2013]Status: DisposedITAT Delhi09 Oct 2024AY 2012-2013

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR KUMAR (Judicial Member)

For Appellant: Shri Deepanshu Singla, CAFor Respondent: Shri B.S. Anand, Sr. DR
Section 148Section 68

Assessment Year 2012-13. 2 2. Briefly stated the facts are, the AO was in possession of an information from the Investigation Wing, Faridabad that the assessee had obtained accommodation entry of bogus sales/purchase from proprietorship firms, namely, M/s Jai Shiv Enterprises, M/s Shiv Shakti Enterprises, M/s P.S Enterprises ... Company, M/s Jagdamba Enterprises & M/s Shivam Trading of Sh. Dalip Kumar during the F.Y. 2011-12. During the course of enquiry made by the Investigation Wing, Faridabad, it was found that Shri Dalip Kumar was engaged in providing accommodation entries through bogus sale bills of his proprietorship firms in lieu

Dolly Ghosh, Bhagalpur vs. ACIT Central Circle 1 Patna, Patna

In the result, the appeal of the assessee is allowed

ITA 182/PAT/2022[2012-13]Status: DisposedITAT Patna08 Oct 2024AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 234ASection 269SSection 269TSection 271DSection 271E

provided to the assessee. But again no compliance made by the assessee. From the ledger of the assessee as provided by Investigation Wing, it was seen that during F.Y. 2011- 12, Smt. Dolly Ghosh took loan in cash of Rs 13,00.000/- on various dates and repaid a total

M/S. Rushabhdev Infra Projects Private Limited, Ahmedabad vs. The ITO, Ward- 3(1)(2), Ahmedabad

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

ITA 1287/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad08 Oct 2024AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2013-14

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

treating entire transaction of genuine labor expense as bogus merely based on information received from Assessment Year: 2013-14 Page 2 of 5 Investigation Wing ignoring submission made and documentary evidences filed. 4. The Ld. CIT(A)- NFAC erred in law and or on facts in confirming the addition ... 15/05/2024. The Assessing Officer made addition treating Construction Labor rendered by M/s. Task Management Services as non-genuine merely based on information received from Investigation Wing of Revenue Department without appreciating submission, explanation and evidences filed in right prospective and summarily adjudicated appeal including Alternative Ground of Appeal No.4