“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

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

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

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

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

Nawal Basudeo Agarwal, Mumbai vs. National Faceless Appeal Centre (NFAC), Delhi

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

ITA 4419/MUM/2023[2014-15]Status: DisposedITAT Mumbai10 May 2024AY 2014-15

Bench: Shri Pavan Kumar Gadale & Ms Padmavathy S

Section 10(38)Section 143(3)Section 234ASection 271(1)(c)Section 68

demat statements in respect of shares purchase & sale and relied on the various factual aspects of share trends, modus operandi and report of the Investigation Wing ITDA data, BSE data and report 4 ITA. No. 4419/MUM/2023 (A.Y.: 2014-15) Nawal Basudeo Agarwal, Mumbai of the kolkata Investigation Wing, statements recorded ... placed at page 19 of the paper book. We note that the AO has reproduced certain portions of the general report of Investigation Wing of the Income Tax Department. Nowhere from the general report of Investigation Wing is it seen that the assessee has indulged in any nefarious activities

ITO-13(2)(1), Mumbai vs. Sethia Infrastructure Pvt. Ltd, Mumbai

In the result, appeal filed by the revenue is allowed

ITA 2739/MUM/2023[2010-11]Status: DisposedITAT Mumbai10 May 2024AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Rahul Chaudhary, Hon'Bleito-13(2)(1) V. Sethia Infrastructure Pvt. Ltd 701, Central Plaza 147, 1St Floor, Aayakar Bhavan Daftari Road, Malad (East) M. K. Marg, Mumbai Mumbai, Maharashtra -400097 Maharashtra-400020 Pan: Aalcs9354B (Appellant) (Respondent) Assessee Represented By : Jaiprakash Bairaga & Rupa Nanda Department Represented By : Dr. Kishor Dhule

Section 143(2)Section 143(3)Section 68

Tracom Pvt Ltd 73000 10 90 7300000 19 Varadvinayak Properties Pvt Ltd 25000 10 90 2500000 Total 108500000 17. The enquiry conducted by the investigation wing revealed that all the above investor companies are paper concerns. The Assessing Officer also found that in the subsequent financial year the shares

Sachin Kanodia, New Delhi vs. ITO Ward - 42(2), New Delhi

Appeal are dismissed

ITA 9504/DEL/2019[2015-16]Status: DisposedITAT Delhi10 May 2024AY 2015-16

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

Section 142(2)Section 143(2)Section 2Section 68Section 69C

much as addition of Rs 64,90,468/- is made violating principles of natural justice without confronting any investigation wing report relevant extract, statements recorded by investigation wing, etc and without offering cross examination of revenues witness whose statements is extensively relied in impugned orders, which is sufficient to quash ... opportunity is given to the assessee to be confronted with back 4 Sachin Kanodia Vs. ITO material relied extensively in impugned orders like investigation wing report etc and no opportunity to cross examine the revenue's witness was given despite specific written request in this regard made to Ld ΛΟ

Rama Mohan Soma, Anantapur vs. Income Tax Officer, Ward -1, Hindupur

In the result, the appeal of the assessee is allowed

ITA 180/HYD/2024[2012-13]Status: DisposedITAT Hyderabad09 May 2024AY 2012-13

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2012-13 Rama Mohan Soma, Vs. The Income Tax Officer, H.No.12-274-3, Bypass Ward – 1, Road, Kadiri, Anantapur, Hindupur. Andhra Pradesh – 515591. Pan : Aocps8172D (Appellant) (Respondent) Assessee By: Shri G. Srinivasa Rao, C.A. Revenue By: Shri Shakeer Ahamed, Sr.Ar. Date Of Hearing: 02.05.2024 Date Of Pronouncement: 09.05.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2012-13 Arises From Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dt.27.12.2023 Invoking Proceedings Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short, “The Act”). 2. The Grounds Raised By The Assessee Read As Under :

For Appellant: Shri G. Srinivasa Rao, C.AFor Respondent: Shri Shakeer Ahamed, Sr.AR

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 156Section 254Section 69B

that the learned assessing officer without supplying the copies of the reasons recorded for reopening the assessment, satisfaction note and material collected from the investigation wing, has passed the order u/s. 143(3) r.w.s 147 which is against the principle of natural justice and hence the impugned order is liable

Ramotar Choudhari HUF, Kolkata vs. PCIT 5 Kolkata, Kolkata

In the result, the appeal of the assessee stands allowed

ITA 1336/KOL/2023[2013-14]Status: DisposedITAT Kolkata09 May 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.1336/Kol/2023 Assessment Year : 2013-14 Ramotar Choudhari Huf.……..…………............…...……………....Appellant 7Th Floor, R.N 25 Fortuna Tower, 23A N.S. Road, Kolkata-1. [Pan: Aanhr9093K] Vs. Pcit-5, Kolkata………….…...............................................…..…..... Respondent Appearances By: Shri S. K. Pransukha, Fca, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 06, 2024 Date Of Pronouncing The Order : May 09, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Revision Order Dated 18.10.2023 Of The Principal Commissioner Of Income Tax, Kolkata [Hereinafter Referred To As ‘Pr. Cit’] Passed U/S 263 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In This Appeal Has Agitated Against The Action Of The Pr. Cit In Exercising His Revision Jurisdiction U/S 263 Of The Act & Thereby Directing The Assessing Officer To Frame The Assessment Afresh. 2. The Brief Facts Of The Case Are That The Assessee Filed Return Of Income For The Year Under Consideration Declaring Total Income Of Rs.2,55,970/- On 21.01.2014. Thereafter, An Information Was Received By The Assessing Officer From Investigation Wing That The Assessee Has

Section 10(38)Section 142(1)Section 147Section 263

year under consideration declaring total income of Rs.2,55,970/- on 21.01.2014. Thereafter, an information was received by the Assessing Officer from Investigation Wing that the assessee has I.T.A. No.1336/Kol/2023 Assessment Year : 2013-14 Ramotar Choudhari HUF received accommodation entry in the form of bogus long term capital gain through ... issued show cause on 22.03.2022 wherein the detailed modus operandi has been mentioned by the A.O. based on the investigation conducted by the Investigation Wing of the Department wherein the entry operator Praveen Agarwal has confirmed that M/s Blue Print Securities Ltd. was controlled by him and the said company

Namokar Builders Pvt. Ltd., Kolkata vs. D.C.I.T., Central Circle -2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 762/KOL/2022[2013-2014]Status: DisposedITAT Kolkata09 May 2024AY 2013-2014

Bench: Shri Rajpal Yadav & Shri Rajesh Kumar, Am]

Section 131Section 133ASection 143(1)Section 143(3)

manner . The also noted that these two shares appeared in the list of penny stocks comprising 84 companies as brought out by SEBI and Investigation Wing of the Income Tax Department after conducting detailed enquiries and investigations. The AO noted that the price of shares were at its peak when ... This right has not been taken away by any express provision of the Income Tax Act.” 32. In respect of the report of the Investigation Wing of the Department, the appellant pointed out the said report nowhere states the name of the appellant or the transaction of the appellant

Dy. Commissioner of Income Tax -5(2)(1), Mumbai vs. Imi Alloys Private Limited, Mumbai

In the result, appeals of the Revenue are dismissed

ITA 4367/MUM/2023[2009-10]Status: DisposedITAT Mumbai09 May 2024AY 2009-10

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 271(1)(c)

gross profit of alleged bogus purchases. Here, in this case the assessments were completed u/s.147 on the basis of information received from the Investigation Wing of the department in respect of purchases made from suspected hawala dealers as declared by the Sales Tax department. The ld. AO has completed

Dy Commissioner of Income Tax -5(2)(1), Mumbai vs. Imi Alloys Private Limited, Mumbai

In the result, appeals of the Revenue are dismissed

ITA 4366/MUM/2023[2010-11]Status: DisposedITAT Mumbai09 May 2024AY 2010-11

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 271(1)(c)

Dy. Commissioner of Income Tax -5(2)(1), Mumbai vs. Imi Alloys Private Limited, Mumbai

In the result, appeals of the Revenue are dismissed

ITA 4365/MUM/2023[2011-12]Status: DisposedITAT Mumbai09 May 2024AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 271(1)(c)

DCIT, Faridabad vs. M/S. Vsb Investment Pvt. Ltd., Faridabad

In the result, the cross objection of the Assessee is allowed whereas the Revenue appeal is dismissed

ITA 467/DEL/2016[2006-07]Status: DisposedITAT Delhi09 May 2024AY 2006-07

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

For Appellant: Shri Amit Sharma, AdvFor Respondent: Shri Vivek Kumar Upadhyay, Sr.DR

Section 143(3)Section 147Section 148Section 68

speaking order, but he has erred in holding that proceedings u/s. 147 were valid in law simply because the information was received from investigation wing but without considering that the genesis of the information was vague, far fetched unreliable, and based on a wild guess in as much as undisclosed ... Basant Marketing is engaged in the business of providing accommodation entries. There is also no mention of any independent inquiries conducted by the Investigation Wing of the Income Tax Department at Bombay or Kolkata or by the AO, on M/s Basant Marketing to establish, or even indicate that M/s Basant

Pooja Rohan Shah, Ahmedabad vs. The Pr. CIT-1, Ahmedabad

In the result, the appeal filed by assessee is dismissed

ITA 130/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad08 May 2024AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2015-16 Pooja Rohan Shah, The Pr. Cit-1 401 Samutkarsh Residency, Vs Ahmedabad 19, Shrinivas Society, Nr. Sukhipura, Paldi,Ahmedabad-380007 (Gujarat) Pan: Dxmps8666E

For Appellant: Shri Mehul Thakkar, ARFor Respondent: Shri Sudhendu Das, CIT-DR

Section 10(38)Section 143(3)Section 263

persons involved in the syndicate of penny stock accommodation entries, in their respective statements recorded by the Investigation Wing Kolkata, had categorically admitted that the scrip of M/s Suchak Trading Ltd. was utilised for facilitating accommodation entries to the desired beneficiaries. (ii) In this case, at the time of purchase

Deepak Switch Gears Pvt. Ltd., Kolkata vs. PCIT, Asansol

In the result, the appeal of the assessee stands allowed

ITA 809/KOL/2023[2012-13]Status: DisposedITAT Kolkata07 May 2024AY 2012-13

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.809/Kol/2023 Assessment Year: 2012-13 Deepak Switch Gears Pvt. Ltd….…......................…...……………....Appellant 48/6, Suman Villa, 2Nd Floor, 155, Jessore Road, Kolkata-700055. [Pan: Aabcd1131H] Vs. Pcit, Asansol….....….........................................................…..…..... Respondent Appearances By: Shri A. K. Tibrewal, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : April 08, 2024 Date Of Pronouncing The Order : May 07, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Revision Order Dated 30.12.2022 Of The Principal Commissioner Of Income Tax, Kolkata [Hereinafter Referred To As ‘Pr. Cit’] Passed U/S 263 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In This Appeal Has Agitated Against The Action Of The Pr. Cit In Exercising His Revision Jurisdiction U/S 263 Of The Act & Thereby Directing The Assessing Officer To Frame The Assessment Afresh. 2. The Registry Has Pointed Out That The Appeal Is Time-Barred By 158 Days. A Separate Application Of Condonation Of Delay Has Been Filed, Wherein, It Has Been Pleaded That After Receipt Of The Impugned Order Of The Pr. Cit, The Assessee, Through Its Director, Shri Deep Kishan Saraf, Immediately Approached One Shri Pawan Kumar Agarwal, Chartered

Section 253Section 263Section 5

September 2018. The reasons for re-opening of the assessment were that the Assessing Officer received some information from Investigation Wing, Kolkata that the assessee company was beneficiary of accommodation entry received from Swiss Progressive Production (P) Ltd. (hereinafter referred to as "Swiss"). In response to the Notice ... assessment proceedings u/s 147/148 of the Act. It is pertinent to submit that the reassessment proceedings were initiated pursuant to report of the Investigation Wing alleging issue of shares by the assessee company through accommodation entries. 3. The Assessing Company submits that, in such circumstances, the assessment order passed

Sharad Bhaskarrao Gaikwad, Nashik vs. Income Tax Officer, Nashik

In the result, appeal of the assessee is allowed

ITA 918/PUN/2023[2018-19]Status: DisposedITAT Pune06 May 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.918/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Sharad Bhaskarrao The Income Tax Officer, Gaikwad, V Nashik. T No.1, Vanai Apartment, S Gangapur Road, Behind Kulswamini Apartment, Nashik – 422005. Pan: Adspg2339R Appellant / Assessee Respondent / Revenue Miss Abhilasha Sanjay Pawar – Ar Assessee By Revenue By Shri Sourabho Nayak – Addl.Cit Date Of Hearing 14/02/2024 Date Of Pronouncement 06/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Under Section 250 Of The Income Tax Act, 1961 Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Dated 02.05.2023 For A.Y.2018-19 Emanating From Penalty Order Under Section 270A Of The Act, Dated 22.02.2022. The Assessee Has Raised Following Grounds Of Appeal : Sharad Bhaskarrao Gaikwad [A]

Section 133ASection 148Section 250Section 270ASection 270A(9)

persons among them whose Return has been filed by Mr.Kishore Patil(ITP). 2.2 The Assessing Officer(AO) received information from the Investigation Wing of the Income Tax Department. The AO issued notice u/s.148 of the Act. In response to notice u/s.148, assessee filed Revised Return of Income showing Net Total

Income Tax Officer Ward-12(2)(1), Mumbai vs. Hari Steel Industries Limited, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3574/MUM/2023[2016-17]Status: DisposedITAT Mumbai06 May 2024AY 2016-17

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Anil ThakrarFor Respondent: Shri Biswanath Das

Section 144BSection 147Section 148Section 250

assessee filed its return of income on 16.10.2016 declaring a total income of Rs.4,25,280/-. On the basis of information received from the Investigation Wing that the assessee has received funds of Rs.29,82,60,232/- from M/s. Kasturi Commodities Pvt. Ltd, which is an accommodation entry provider ... issued on 31.03.2021 and proceedings u/s 147 of the Act were initiated. As per the information received from the Investigation Wing, M/s. Kasturi Commodities Pvt. Ltd does not have any actual business or financial creditworthiness and is engaged in providing accommodation entry in return of commission which proves that

Surpreet Singh Suri, New Delhi vs. DCIT Central Circle-6, New Delhi

The appeal is allowed and the issue on merit is

ITA 1118/DEL/2023[2014-15]Status: DisposedITAT Delhi06 May 2024AY 2014-15

Bench: Dr. B.R.R. Kumar & Shri Anubhav Sharma[Assessment Year: 2014-15

Section 143(3)Section 153ASection 154Section 250

record. 3. On hearing both the sides, it comes up that a search and seizure operation was carried on Three C group by the Investigation Wing, on 29.10.2013 and thereupon return by the assessee was filed in pursuance of proceedings initiated u/s 153A of the Act. The assessment order dated

ITO, W-6(5), Mohali vs. Smt. Gurdev Kaur, Kharar

In the result, the appeal of the Revenue is dismissed

ITA 1448/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh03 May 2024AY 2010-11

Bench: Disposal Of Appeal.”

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR

Section 143(2)Section 144Section 148

found a n y other source of income in the hands o f the assessee and relied upon the report o f investigation wing. The AO also did not even try to apply her mind to find out the real source o f deposit o f Rs. 2J5.80.000/- dated

Ajmer Singh, Mohali vs. ITO, W-6(5), Mohal

In the result, the appeal of the Revenue is dismissed

ITA 1439/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh03 May 2024AY 2011-12

Bench: Disposal Of Appeal.”

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR

Section 143(2)Section 144Section 148

Ajmer Singh, Mohali vs. ITO, W-6(5), Mohal

In the result, the appeal of the Revenue is dismissed

ITA 1438/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh03 May 2024AY 2010-11

Bench: Disposal Of Appeal.”

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR

Section 143(2)Section 144Section 148

ITO, WD. 1(2)(2), Race Course Circle, Vadodara vs. Neetaben Snehalkumar Patel, Race Course Circle, Vadodara

In the result, the appeal preferred by the Revenue is allowed

ITA 247/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad03 May 2024AY 2014-15

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 247/Ahd/2024 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15) िनधा"रण वष"

For Respondent: Shri Sunil Talati, A.R

Section 10(38)Section 68

Rs.5,56,630/-. The case was selected for scrutiny on the ground “suspicious transaction relating to long term capital gain on shares (inputs from Investigation Wing)”. In the course of assessment, the AO made enquiries in this regard and the relevant facts which emerge from the assessment order ... made the disallowance on mere suspicion and without any specific material against the assessee. The reliance placed by the AO on the report of Investigation Wing, Kolkata was misplaced. The Ld. AR further submitted that identical addition was made in the case of Late Shri Mihir P. Panchal, which

M D Diesel Spares, Howrah vs. ITO, Ward-47, Kolkata

In the result, the appeal of the assessee stands allowed

ITA 1430/KOL/2023[2012-2013]Status: DisposedITAT Kolkata03 May 2024AY 2012-2013

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A No.1430/Kol/2023 Assessment Year: 2012-13 M D Diesel Spares………..………………………… ........................……Appellant 7/12, Kings Road, Howrah-711101. [Pan: Aakfm7649F] Vs. Ito, Ward-47(2), Kolkata..................…................…........……...…..…..Respondent Appearances By: Shri A. K. Tibrewal & Saurabh Gupta, Ar, Appeared On Behalf Of The Appellant. Shri Prabir Gupta Choudhury, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 26, 2024 Date Of Pronouncing The Order : May 03, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 28.10.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Addition Of Rs.18,85,520/- Made By The Assessing Officer U/S 69C Of The Act On Account Of Bogus Purchases. 3. The Brief Facts Of The Case Are That The Assessee Firm Is Involved In The Business Of Spare Parts Of The Machinery. The Assessee Firm For The Year Under Consideration Filed Its Return Of Income Declaring A Total Income Of Rs.45,150/-. The Said Return Was Processed U/S 143(1) Of The

Section 143(1)Section 147Section 250Section 271(1)(c)Section 69C

I.T.A No.1430/Kol/2023 Assessment year: 2012-13 M D Diesel Spares Act. Thereafter, information was received by the Assessing Officer from the Investigation Wing that one Shri Sanjiw Kumar Singh was involved in providing bogus bills to various parties. That the assessee was also one of the beneficiaries of bogus bills ... I.T.A No.1430/Kol/2023 Assessment year: 2012-13 M D Diesel Spares year under consideration, the Assessing Officer, solely relying on the report of the investigation wing, made the impugned addition of the purchases made from the aforementioned two parties invoking the provisions of section 69C of the Act. The ld. counsel