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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

Asstt Commissioner of Income Tax-4 (2) (1), Mumbai vs. S P Jain Securities Pvt Ltd, Fort

In the result, the appeal by the Revenue is dismissed

ITA 606/MUM/2024[2011-12]Status: DisposedITAT Mumbai21 Aug 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Bhavya SundeshaFor Respondent: Shri Surendra Meena, Sr. DR
Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 14ASection 250Section 68

huge business loss is suspicious and detailed investigation of this issue was undertaken. The AO by placing reliance upon the findings of the Investigation Wing concluded that the sale value derived by the assessee amounting to Rs. 12,75,483 from trading in shares of KCL Infra Projects Limited ... during the year under consideration. Thus, we agree with the findings of the learned CIT(A) that the observations of the Investigation Wing may be correct, however, the same cannot be applied to the present case. Further, considering the fact that the assessee has a returned income

Champion Builder Pvt. Ltd., Kolkata vs. ITO, Ward-1(3), Gurgaon

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

ITA 462/DEL/2024[2015-16]Status: DisposedITAT Delhi21 Aug 2024AY 2015-16

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.462 & 463/Del/2024 िनधा"रणवष"/Assessment Years: 2015-16 & 2016-17

Section 144BSection 147Section 148Section 68

with him. It is the submission of the Ld. DR that even if AO from perusal of an extensive report from I.T.A.Nos.462 & 463/Del/2024 Investigation Wing culls out information or entries specify to the assessee is an evidentiary exercise in the form of application of mind on the part ... income chargeable to tax had escaped assessment. The reasons which have been recorded to reopen the case of the assessee are based upon the Investigation Wing report and without any further enquiry made or independent opinion formed. The reasons recorded are incomplete and vague with non specific information, no information

Ravinder Baweja, Delhi vs. ACIT, Central Circle-27, New Delhi

In the result, these appeals are allowed as indicated above for

ITA 1731/DEL/2022[2017-18]Status: DisposedITAT Delhi21 Aug 2024AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Rikky Dua, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 143Section 143(2)Section 143(3)Section 144Section 148Section 151Section 250(6)

erred both in law and on facts in upholding the finding of AO whereby he has made Addition on the information received from investigation wing. It is submitted a power to reopen would vest in the Assessing Officer only if, there is tangible material in his possession for coming ... where the Notice u/s 148 was issued without any enquiry by the Assessing officer as he acted mechanically on the report of investigation wing. Moreover higher authorities also accorded their approval in haste without applying their mind u/s 151. 7. The appellant craves leave to add, alter, amend or vary

Ravinder Baweja, New Delhi vs. ACIT Central Circle-27 Jhandewalan Extn, Nes Delhi, Delhi

In the result, these appeals are allowed as indicated above for

ITA 1730/DEL/2022[2012-13]Status: DisposedITAT Delhi21 Aug 2024AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Rikky Dua, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 143Section 143(2)Section 143(3)Section 144Section 148Section 151Section 250(6)

erred both in law and on facts in upholding the finding of AO whereby he has made Addition on the information received from investigation wing. It is submitted a power to reopen would vest in the Assessing Officer only if, there is tangible material in his possession for coming ... where the Notice u/s 148 was issued without any enquiry by the Assessing officer as he acted mechanically on the report of investigation wing. Moreover higher authorities also accorded their approval in haste without applying their mind u/s 151. 7. The appellant craves leave to add, alter, amend or vary

Ravinder Baweja, New Delhi vs. ITO Ward 36(2), New Delhi

In the result, these appeals are allowed as indicated above for

ITA 2254/DEL/2019[2015-16]Status: DisposedITAT Delhi21 Aug 2024AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Rikky Dua, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 143Section 143(2)Section 143(3)Section 144Section 148Section 151Section 250(6)

erred both in law and on facts in upholding the finding of AO whereby he has made Addition on the information received from investigation wing. It is submitted a power to reopen would vest in the Assessing Officer only if, there is tangible material in his possession for coming ... where the Notice u/s 148 was issued without any enquiry by the Assessing officer as he acted mechanically on the report of investigation wing. Moreover higher authorities also accorded their approval in haste without applying their mind u/s 151. 7. The appellant craves leave to add, alter, amend or vary

Income Tax Officer, Ward-1(3), Ludhiana vs. Shree Balaji Processors, Ludhiana

In the result, appeal of the Revenue is dismissed whereas, the 29

ITA 499/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh20 Aug 2024AY 2017-18

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 499/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 The Ito, Vs. Shree Balaji Processors, बनाम Ward-1(3), Tajpur Road, Ludhiana Opp. Central Jail, Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent & C.O. No. 09/Chd/2024 ( In आयकर अपील सं./ Ita No. 499/Chd/2023) "नधा"रण वष" / Assessment Year : 2017-18 Shree Balaji Processors, Vs. The Ito, बनाम Tajpur Road, Ward-1(3), Opp. Central Jail, Ludhiana Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 26.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.08.2024

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 143(3)Section 145(3)Section 69A

Kolkata branch for whole of the year. 3. There is a huge difference in closing cash in hand which was submitted to the investigation wing vis a vis submitted during the assessment- proceedings. 4. There are no name/PAN/complete address details of the persons with whom the appellant had cash sale ... said submissions deserve to be accepted. xxiv). It is also for kind information that the assessee has filed the detailed reply before the Investigation Wing wherein, the assessee has filed a list of the cash realized from the debtors during the relevant assessment ear and in which, the assessee

Decent Industries P. Ltd., Bhopal vs. ITO-1(2), Bhopal

Appeal is partly allowed

ITA 356/IND/2023[2012-13]Status: DisposedITAT Indore20 Aug 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2012-13 M/S Decent Industries Ito-1(2), Private Ltd, Bhopal 5Th Floor, Corporate Park, बनाम/ Db City Area Hills, Vs. Opp. M.P. Nagar Zone I, Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aaeca6271G Assessee By Ms. Shilpa Gupta & Shri N.K. Gupta Revenue By Shri V.K. Singh, Cit-Dr Date Of Hearing 04.06.2024 Date Of Pronouncement 20.08.2024

Section 133ASection 143(2)Section 147Section 148Section 14ASection 68

declaring a total income of Rs. 80,100/- which was duly assessed. Subsequently, the AO received information from Investigation Wing, Kolkata of Income-tax Department [“Investigation Wing”] that the assessee had allotted preference shares having face value of Rs. 10/- per share at an issue price ... Hind 4,48,100 10/- 990/- 44,81,00,000/ Financial Advisors P - Ltd (AABCJ9501B) Total 66,91,70,000/ - The report of Investigation Wing was based on a survey action u/s 133A carried out in the case of one ‘Shri Anand Sharma, Kolkata’ (entry operator) on 02.07.2013 pursuant

Manohar Lal Chugh, Jaipur vs. ITO, Ward 6(1), Jaipur

In the result, the appeal of the assessee is allowed with no order as to costs

ITA 505/JPR/2023[2011-12]Status: DisposedITAT Jaipur20 Aug 2024AY 2011-12

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sanjay Godha, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 10(38)Section 147Section 68Section 69C

based his addition u/s 68 of the Act on the basis of statement of the entry operator and information received from the Investigation Wing of the Department. However in the statement of entry operator no question was ever put to the entry operator regarding transaction through the companies, through which ... transaction of purchase and sale of the shares in question cannot be held as bogus merely on the basis of Report of the Investigation Wing of the Department in some other cases where some persons were found indulged in providing accommodation entry, and further it cannot be held that

Income Tax Officer Ward 23(2)(6), Mumbai vs. Manisha Narpatkumar Chopra, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 2443/MUM/2023[2015-16]Status: DisposedITAT Mumbai20 Aug 2024AY 2015-16

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran: A.Y : 2015-16

For Appellant: Ms. Ridisha JainFor Respondent: Smt. Mahita Nair, Sr.DR
Section 10(38)Section 131Section 143(1)Section 148

same was processed u/s. 143(1) of the Income Tax Act, 1961 („the Act‟). Subsequently, the AO received information from the Investigation Wing of Kolkatta that certain brokers are involved in manipulating the prices of small companies (called “penny stock”) in order to generate bogus capital gains/losses. It was also ... assessee claimed the same as exempt u/s. 10(38) of the Act. Based on the information so given by the Investigation Wing, the AO took the view that the Long Term Capital Gain declared by the assessee is not genuine one and accordingly reopened the assessment by issuing notice

Aarna Infrazone Pvt. Ltd., Noida vs. Pr, CIT, Noida

In the result, the impugned order is upheld and appeal of the assessee is dismissed

ITA 1208/DEL/2024[2013-14]Status: DisposedITAT Delhi20 Aug 2024AY 2013-14

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

For Appellant: S/Shri S Krishnan, and V. Rajkumar, AdvocatesFor Respondent: Ms. Neha Chaudhary, CIT-DR
Section 132Section 142(1)Section 147Section 263

material or the alleged monies received as advances from M/s Savitri Fashion Crafts. II. Secondly, it should also be seen as to how the Investigation Wing reached the conclusion that cash has exchanged hands between the appellant and M/s Celebration City Projects Pvt Ltd especially in light of that fact

Rajesh Khanna, Neelkanth Plywood, Yamunanagar vs. Income Tax Officer, Ward-3, Yamunanagar

In the result, the assessee's appeal in ITA

ITA 62/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh19 Aug 2024AY 2018-19

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Goel, CAFor Respondent: Shri Dharam Vir, JCIT Sr.DR
Section 148Section 69A

violated the principles of natural justice as all evidences and documents on records are completely ignored and assessment is completed on the diktat of Investigation Wing and appropriate cost be imposed on erring officers. (same as above) 3. At the outset, the ld. Counsel for the assessee has stated ... sold by the assessee, i.e., M/s Shiv Shankar Plywood and Veneer, Indore. It was on the basis of the information gathered by the Investigation Wing of the Department in the said search, that the case of the assessee was reopened u/s 148 of the Act, on 30.03.2022. ITA 62, 230/CHD/2024

Income Tax Officer, Yamuna Nagar vs. Rajesh Khanna, Yamuna Nagar

In the result, the assessee's appeal in ITA

ITA 230/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh19 Aug 2024AY 2018-19

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Goel, CAFor Respondent: Shri Dharam Vir, JCIT Sr.DR
Section 148Section 69A

violated the principles of natural justice as all evidences and documents on records are completely ignored and assessment is completed on the diktat of Investigation Wing and appropriate cost be imposed on erring officers. (same as above) 3. At the outset, the ld. Counsel for the assessee has stated ... sold by the assessee, i.e., M/s Shiv Shankar Plywood and Veneer, Indore. It was on the basis of the information gathered by the Investigation Wing of the Department in the said search, that the case of the assessee was reopened u/s 148 of the Act, on 30.03.2022. ITA 62, 230/CHD/2024

Income Tax Officer, Ward-1, Ahmednagar vs. Narendra Sampatlal Bafna, Ahmednagar

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

ITA 688/PUN/2024[2017-18]Status: DisposedITAT Pune19 Aug 2024AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Shri Prasad BhandariFor Respondent: Shri Keyur Patel, CIT
Section 1Section 132Section 132(4)Section 143(3)

which was revised on 22.07.2018 declaring total income at Rs.31,47,670/-. Subsequently, the Assessing Officer on the basis of information received from the Investigation wing that the assessee has taken cash loan of Rs.6,20,00,000/- from various parties through Mr. Sachin Nahar, which is not reflected ... Shri Sachin Nahar during the course of Search and Post Search enquiries in the case of Shri Sachin Nahar by the Investigation Wing and also during the course of the enquiries conducted during the course of Search assessment by the Central Circle 1(1) Pune. Search and Seizure action

Ranjay Developers Private Limited, Mumbai vs. ITO-14(3)(1), Mumbai

In the result, the appeal of the assessee is restored back to the file of the learned Assessing Officer with the direction to the assessee to furnish the necessary details before the Assessing

ITA 308/MUM/2024[2011-12]Status: DisposedITAT Mumbai19 Aug 2024AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shrisunil Kumar Singh, Jm A.Y.2011-12

Section 143Section 143(1)Section 143(2)Section 147Section 148Section 153Section 68

total income of Rs.2,25,430/-. It was processed u/s.143(1) of the Act. 4. Subsequently information was gathered by the Investigation Wing that assessee has taken accommodation entries from certain parties and has shown bogus loan/share premium belonging to Shri Shrish Chandrakant Shah who have been found ... assessment as well as the addition on merits.The learned CIT(A) confirmed the reopening of the assessment holding that there is credible informationfrom the Investigation Wing that Shri Shrish Chandrakant Shah has provided accommodation entry to various parties through various dummy entities. The assessee was also found

Jain Machine Tools, Mumbai vs. Income Tax Officer, Ward 26(1)(7), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2110/MUM/2024[2012-13]Status: DisposedITAT Mumbai19 Aug 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2012-13 Jain Machine Tools, Ito, Ward 26(1)(7), 16, Meghal Industrial Estate, Room 625, 6Th Floor, Kautilya Vs. Devidayal Road, Mulund (West) Bhavan, C-41 To C-43, G Block, Mumbai-400080. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan No. Aacfj 6163 H Appellant Respondent

For Appellant: Ms. Rajeshwari Menon, Sr. DRFor Respondent: Mr. Devendra Jain
Section 143(3)Section 147Section 148

reopening the case were response to notice u/s 148. The reasons for reopening the case were specific and based on information received from the Investigation Wing, specific and based on information received from the Investigation Wing, specific and based on information received from the Investigation Wing, Mumbai, which is also ... recorded by the Assessing Officer is merely based on the in Assessing Officer is merely based on the information from the formation from the Investigation Wing that there is a credit in bank statement in the Investigation Wing that there is a credit in bank statement in the Investigation Wing

Smt Chandradevi Gautamchand Jain, Mumbai vs. The Income Tax Officer-30(1)(2), Mumbai

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

ITA 1104/MUM/2024[2015-16]Status: DisposedITAT Mumbai19 Aug 2024AY 2015-16

Bench: Shri Anikesh Banerjee & Shri Gagan Goyalsmt. Chandra Devi Gautam Chand Jain, Flat No. 1401, Bldg. 5, Raheja Classique Co-Op. Hsg. Soc. Ltd. Behind Infinity Mall, New Link Road, Andheri West, Mumbai-400 053 Pan: Aekpc6743G ..... Appellant Vs. Ito-30(1) (2) Room No. 505, C-505, Pratyaksh Kar Bhavan, Bandra Kurla Complex, Bandra East, Mumbai- 400 051 ..... Respondent

For Appellant: Shri Sanjay Parikh, Ld. ARFor Respondent: Shri H. M. Bhatt, Ld. DR
Section 143(3)Section 250Section 68

Lacs were taken from M/s. NCL Research Financial Services and M/s. Tanya Vincom Pvt. Ltd. respectively. These two companies were under investigation by the investigation wing, Kolkata for various financial irregularities carried out with an intention to convert unaccounted income into accounted one without paying legitimate taxes thereon

DCIT-191, Mumbai vs. Bhavin P Mehta, Mumbai

In the result, the appeal of the revenue is partly allowed for statistical purposes

ITA 4689/MUM/2023[2012]Status: DisposedITAT Mumbai19 Aug 2024

Bench: Shri Om Prakash Kant, Am & Shri Sunil Kumar Singh, Jm

For Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 132Section 132(4)Section 143

short ‘the Act’). Thereafter, an information was 4 ITA No. 4689/Mum/2023- Bhavin P Mehta received by the Assessing Officer from the Investigation Wing of Income Tax, Mumbai that the assessee received accommodation entries of bogus purchases from the concerns controlled and managed by Shri Bhanwarlal Jain as found out during

Kishore Hargovind Patel (HUF), Mumbai vs. Income Tax Officer-Ward 25(2)(5), Mumbai

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

ITA 4631/MUM/2023[2012-13]Status: DisposedITAT Mumbai19 Aug 2024AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2012-13

For Appellant: Shri Prakash Jotwani, A.RFor Respondent: Shri P.D. Chougule, (Addl. CIT) Sr. DR
Section 10(38)Section 131Section 147Section 148Section 250Section 68

ultimately by considering the mode of acquisition of the, sale of shares and unusual rise in the price, findings of the investigation wing, analysis of the transactions, failure of the Assessee to discharge its onus, ignorance of the Assessee about shares and penny stock companies, financial analysis of penny stock ... aggrieved, challenged the said addition before the Ld. Commissioner, who on the similar footing and mainly focusing on the investigation carried out by the investigation wing at Kolkata and by considering that the Assessee was found unaware of the financial position and business activities of the company and fundamentals also

Aadesh Commodities Pvt Ltd, Mumbai vs. National Faceless Assessment Centre, Delhi, Mumbai

In the result, the appeal by the assessee is allowed

ITA 3959/MUM/2023[2013-14]Status: DisposedITAT Mumbai19 Aug 2024AY 2013-14

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri Jay BhansaliFor Respondent: Shri Harmesh Lal
Section 115BSection 143(2)Section 147Section 151Section 250Section 68

also been received from Dy. Director of Income-tax (Investigation), Unit 8(2), Mumbai vide email dated 07/07/2019. As per this information, the investigation wing of the income tax department conducted enquiries in the scrip of penny stock, M/s ACI Infocom-Ltd-and-found that the scrip ... Year.” 4. The AO vide order dated 30/09/2021 passed under section 147 read with section 144B of the Act after placing reliance upon the Investigation Wing’s report concluded that during the year under consideration, the assessee earned profit from trading in penny stocks ofNYSSA Corporation

Nalapad Properties, Bangalore vs. The Deputy Commissioner of Incomer Tax, Central Circle-2(3), Bangalore

ITA 1297/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Aug 2024AY 2017-18
For Appellant: Sri H. Guruswamy, ITP &For Respondent: Shri Kiran D., D.R
Section 139(9)Section 143(2)Section 153CSection 250Section 45

percent share of undivided land was transferred in lieu of 50 percent of the built-up area receivable by the assessee. The Investigation wing of the Department has conducted a Search u/s 132 of the Act on 02-11-2017 in the case of the Developer M/s. Brigade Enterprises