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“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

DCIT, Circle - 19(1), Delhi vs. Ramayna Ispat Pvt. Ltd., Delhi

In the result, the appeal of the assessee and Revenue are dismissed

ITA 4147/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalramayna Ispat Private Limited, Dcit, A-48, 1St Floor, Wazirpur Circle-19(1), Industrial Area, Delhi-110052. Vs. New Delhi. Pan-Aaccr7382R (Appellant) (Respondent) Dcit, Ramayna Ispat Private Limited, A-48, 1St Floor, Wazirpur Circle-19(1), New Delhi. Vs. Industrial Area, Delhi-110052. Pan-Aaccr7382R (Appellant) (Respondent) Assessee By Shri Maneesh Upneja, Ca, Shri Baldev Raj, Ca & Ms. Sanju Kumari, Adv. Department By Shri Khitesh Gupta, Sr. Dr Date Of Hearing 27/11/2025 Date Of Pronouncement 27/11/2025 O R D E R Per Manish Agarwal, Am: These Cross Appeals Are Filed By The Assessee & Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Ld. Cit(A)] Dated 11.07.2024 U/S 250 Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2018-19. Ramayna Ispat Pvt. Ltd. Vs. Ito 2. Brief Facts Of The Case Are That The Assessee Is A Private Ltd. Company Engaged In The Business Of Manufacturing, Processing, Forging, Casting Mixing Of Various Kinds Of Steel, Carbon Settle, Mild Steel, Stainless Steel, High Speed Steel & Bright Steel Etc. The Return Of Income Was Revised On 28.10.2018 At An Income Of Rs.1,00,96,587/-. The Case Of The Assessee Was Reopened U/S 148 For The Reason That Assessee Has Taken Accommodation Entries Of Bogus Purchases & After Considering The Submissions Made, Ao Had Made The Addition Of Rs.5,78,99,593/- U/S 69C Of The Act Towards Unexplained Expenditure On Account Of Bogus Purchase & Further Invoked The Provisions Of Section 115Bbe Of The Act. The Ao Further Made An Addition Of Rs.3,14,795/- By Estimating The Net Profit Declared By The Assessee. Besides This Further Disallowance Of Rs.9,37,608/- Was Made Out Of Freight Expenses And, Accordingly, The Total Income Of The Assessee Was Assessed At Rs.6,87,83,788/-.

Section 115BSection 147Section 148Section 250Section 690Section 69C

implementation of mind by the Ld. AO and only Ramayna Ispat Pvt. Ltd. vs. ITO on the basis of information as received from the Investigation Wing. c. Based upon a mechanical approval from the superior authorities. d. Based upon the documents/information which was un-earth during the course of search ... such cases: 1) Principal Commissioner of Income-tax vs. Deepak Banwarilal Agarwal reported at [2024] 161 taxmann.com 601 (Gujarat) Where AO received information from Investigation Wing that assessee had obtained non-genuine purchase bills from a group which was engaged in business of issuing non-genuine purchase bills, unsecured loans

Oracle Granito Limited, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

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

ITA 2432/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad27 Jan 2026AY 2019-20

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.2432/Ahd/2025 िनधा"रण वष" /Assessment Year : 2019-20 Oracle Granito Limited The Dcit, Circle-3(1)(1) बनाम/ 206, Dev Arc, 2Nd Floor Ambawadi V/S. Nr. Fun Republic Ahmedabad- 38015 Opp. Big Bazar S.G. Highway Road Ahmedabad- 380 015 "थायी लेखा सं./Pan: Aaaco 6238 P (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Aseem L. Thakkar, Ar Revenue By : Shri Rohit Aasudani, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 19/01/2026 घोषणा की तारीख /Date Of Pronouncement: 27/01/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 10/10/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2019-2020. 2. The Assessee, In This Appeal, Is Aggrieved By The Action Of The Ld.Cit(A) In Confirming The Addition Made By The Assessing Officer (Ao) Of Oracle Granito Ltd. Vs. Dcit Asst. Year : 2019-20

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Rohit Aasudani, Sr.DR
Section 147Section 250

that, in this case, the entire addition has been made/confirmed by the lower authorities merely based on uncorroborated information received by the AO from Investigation Wing (IW). He has submitted that even the assessee has not been provided with any details showing the alleged transactions, the date of transactions

Luvkesh Textile Industries Pvt Ltd, Mumbai vs. DCIT Circle 4(2)(1), Mumbai

In the result the both the appeals are allowed for statistical purposes

ITA 6054/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarluvkesh Textile Industries Pvt. Deputy Commissioner Ltd. Of Income Tax Circle 201, Maxheal House, Swami 4(2)(1) Vs. Ayyappa Mandir Marg, Bangur Aayakar Bhavan, Nagar, Goregaon West, Maharishi Karve Road, Mumbai - 400104 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Deputy Commissioner Of Lukesh Textile Industries Income Tax Circle Private Limited 4(2)(1) Vs. 21/22 A Chunawal Ind Estate, 640 Aayakar Bhavan, Condivita Lane, Andheri East, Maharishi Karve Road, Mumbai - 400020 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Present For: Assessee By : Shri A. L. Sharma, Ar Revenue By : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 04.12.2025 Date Of Pronouncement : 27.01.2026 आदेश / O R D E R Per Prabhash Shankar [A.M.] :- The Instant Appeals Have Been Preferred By Both The Assessee & The Revenue Which Emanate From The Appellate Order Passed By The Ld. Cit(A)/National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As “Cit(A)”] With Regard To The Assessment Order Passed Under Luvkesh Textile Industries Pvt. Ltd. Section 147 R.W.S. 144 Of The Income Tax Act 1961, (In Short ‘The Act’) Dated 22.03.2024 A.Y. 2018-19. 2. The Revenue Has Raised Following Grounds Of Appeal :

For Appellant: Shri A. L. Sharma, ARFor Respondent: Shri Surendra Mohan, Sr. DR
Section 131Section 147Section 69C

World Design Studio Pvt. Ltd., M/s One World Sourcing, and M/s Tissori India Fabrics Pvt. Ltd. As per the information received from the Investigation wing of the Department, M/s. One World Group entities were Luvkesh Textile Industries Pvt. Ltd. involved in bogus purchase and bogus sales transactions wherein no actual ... assessee. Such action on the part of the ld.CIT(A) is not appreciated. He failed to take due cognizance of the findings of the Investigation wing and also the admission of the key person of indulging in accommodation entry activity and the assessee company was found to be the beneficiary

DCIT-421, Mumbai vs. Lukesh Textile Industries Private Limited, Mumbai

In the result the both the appeals are allowed for statistical purposes

ITA 5924/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarluvkesh Textile Industries Pvt. Deputy Commissioner Ltd. Of Income Tax Circle 201, Maxheal House, Swami 4(2)(1) Vs. Ayyappa Mandir Marg, Bangur Aayakar Bhavan, Nagar, Goregaon West, Maharishi Karve Road, Mumbai - 400104 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Deputy Commissioner Of Lukesh Textile Industries Income Tax Circle Private Limited 4(2)(1) Vs. 21/22 A Chunawal Ind Estate, 640 Aayakar Bhavan, Condivita Lane, Andheri East, Maharishi Karve Road, Mumbai - 400020 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Present For: Assessee By : Shri A. L. Sharma, Ar Revenue By : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 04.12.2025 Date Of Pronouncement : 27.01.2026 आदेश / O R D E R Per Prabhash Shankar [A.M.] :- The Instant Appeals Have Been Preferred By Both The Assessee & The Revenue Which Emanate From The Appellate Order Passed By The Ld. Cit(A)/National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As “Cit(A)”] With Regard To The Assessment Order Passed Under Luvkesh Textile Industries Pvt. Ltd. Section 147 R.W.S. 144 Of The Income Tax Act 1961, (In Short ‘The Act’) Dated 22.03.2024 A.Y. 2018-19. 2. The Revenue Has Raised Following Grounds Of Appeal :

For Appellant: Shri A. L. Sharma, ARFor Respondent: Shri Surendra Mohan, Sr. DR
Section 131Section 147Section 69C

World Design Studio Pvt. Ltd., M/s One World Sourcing, and M/s Tissori India Fabrics Pvt. Ltd. As per the information received from the Investigation wing of the Department, M/s. One World Group entities were Luvkesh Textile Industries Pvt. Ltd. involved in bogus purchase and bogus sales transactions wherein no actual ... assessee. Such action on the part of the ld.CIT(A) is not appreciated. He failed to take due cognizance of the findings of the Investigation wing and also the admission of the key person of indulging in accommodation entry activity and the assessee company was found to be the beneficiary