“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

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

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

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.

Aradhna Estate Pvt. Ltd. v. DCIT

91 Taxmann.com 119 · 2018 · High Court

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, Central Circle 7(1), Mumbai vs. Supreme Holdings & Hospitality (India) Limited, Mumbai

In the result, all the appeals of the Revenue and Cross Objections by the assessee are dismissed

ITA 3977/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 131Section 131(1)Section 132(1)Section 153ASection 68

Letter of Credit without any credentials at the time of Bill Discounting or for any other purpose, but nowhere there is any finding of investigation wing or any material found or statement during the search, that some unaccounted money has been given by the assessee company to accommodate any loan

Ruby Singh, Delhi vs. DCIT, Central Circle-8, Delhi

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

ITA 4772/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Jan 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2017-18 Ms. Ruby Singh, Vs. Deputy Commissioner Of R-543, New Rajendra Nagar, Income Tax, New Delhi: 1100 60 Central Circle 8, Pan No. Anaps3827J New Delhi (Appellant) (Respondent)

For Appellant: Shri Mahir Aggarwal, AdvFor Respondent: Shri Om Prakash, Sr. DR

Section 133ASection 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 271ASection 274Section 68

that the assessee is a sole proprietor of M/s. Moonage Films. Survey under Section 133A of the Act was conducted on 11.09.2020 by the Investigation Wing in the case of M/s. SLG Commodities Pvt. Ltd., Kirti India Hospitality Pvt. Ltd. and Maan Promoters Pvt. Ltd. through Principal Officer Shri Kirtiman

Assistant Commissioner of Income Tax, Delhi vs. Triveni Impex Private Limited, Delhi

The appeal of the revenue is dismissed

ITA 2681/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit Vs. Triveni Impex Private Room No. 192A, First Limited, 581/5, Floor, Cr Building, Ito Katraishwarbhawan New Delhi – 110002 Khari Baoli, Delhi – 110006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabct2170N Appellant .. Respondent

For Appellant: Sh. Ved Jain, AdvFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr

Section 143(3)Section 68

selected for scrutiny and assessee’s receipt from certain parties were found to be in the form of accommodation entries with regard to which investigation wing report was also available with the Assessing Officer and thus, the receipt of Rs.5,49,00,000/-from these parties were examined ... parties namely (Balaji enterprises: Rs. Rs.3,52,30,000/-and Maruti enterprise :2,65,00,000). However, it is stated that the investigation wing has conducted the detailed enquiry with respect to the abovementioned parties and come to the conclusion that such concerns are sham parties and incorporated by Shri

DCIT, New Delhi vs. Sh. Ramesh Sharma, New Delhi

In the result, the appeal of the Revenue is dismissed in the aforesaid manner

ITA 6881/DEL/2014[2010-11]Status: DisposedITAT Delhi23 Jan 2026AY 2010-11

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Salil Agarwal, Sr. Adv. &For Respondent: Ms. Monika Singh, CIT(DR)

Section 132Section 143(2)Section 153A

carrying on this business as a proprietor in the name of Sharma Construction. A search and seizure operation u/s. 132 was conducted by the Investigation Wing of the Department in M/s Raus Infra Group of cases on 15.06.2011 and since the assessee was a member of this group, his premises

Khojema Bohra, Indore vs. Income Tax Officer, NFAC, Delhi

In the result, the grounds raised on this issue stands "Dismissed"

ITA 812/IND/2024[2014-2015]Status: DisposedITAT Indore22 Jan 2026AY 2014-2015

Bench: Shri B.M. Biyani & Shri Paresh M Joshikhojema Bohra

Section 115BSection 147Section 250Section 253Section 271(1)(c)Section 68

existing as per the records of registrar of companies, the credit worthiness of the company to give such amount was not satisfactorily proved. The Investigation Wing after conducting necessary enquiries concluded that the appellant has been mentioned as one of the beneficiaries. (vi) The legal precedents relied upon are equally ... said that the assessee has established the identity of the parties. It has further been observed that the report of the investigation wing cannot conclusively prove that the assessee's own monies were brought back in the form of share application money. As noted in the earlier paragraph

Deputy Commissioner of Income Tax, Central Cirlce-1(4), Chennai vs. Ramanathan Viswanathan, Chennai

ITA 1597/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 139Section 142(1)Section 153ASection 153CSection 250

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Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai vs. Ramanathan Viswanathan, Chennai

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

ITA 1556/CHNY/2025[2016]Status: DisposedITAT Chennai22 Jan 2026

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

dated 23.04.2016 from No.10/97C, Ayyampalayam, Thottakurichi Post, Karur ANN/PA/MK/S dated 23.04.2016 from No. 10/97C, Ayyampalayam Thottakurichi Post, Karur ANN/ST/SS/ED/S-1 & dated 12.05.2016 at Income Tax Investigation Wing, No. 46, N.H. Road, Nungambakkam, Chennai 600 (d) Date of seizure of such material 034. (e) particulars of relevant panchanama

R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1324/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Jan 2026AY 2017-18

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 139Section 142(1)Section 153ASection 153CSection 250

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R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1323/CHNY/2025[2016-17]Status: DisposedITAT Chennai22 Jan 2026AY 2016-17

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 139Section 142(1)Section 153ASection 153CSection 250

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R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1322/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 139Section 142(1)Section 153ASection 153CSection 250

{"clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI\nBEE ABY T. VARKEY, JUDICIAL MEMBER AND SHRI S.R.RAGHUNATHA

Mrs. Jigna Hiren Rambhia, Mumbai vs. ITO Ward 27(1)(5), Mumbai

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

ITA 5033/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Jan 2026AY 2014-15

Bench: Shri Sandeep Gosain, () & Shri Bijayananda Pruseth

Section 10(38)Section 250Section 391Section 68

shares of scrip of M/s SRK Industries Ltd. 4. However, the same was denied by the revenue authorities on the premise that the investigation wing of ITA No. 5033/Mum/2025; Jigna Hiren Rambhia, Mumbai Kolkata had examined the entire issue relating to the transactions in “penny stock” and provision of accommodation ... entries for availing exemption u/s 10(38) of the Act. During the course of survey, the investigation wing on the basis of evidences and after analysing financial statement of M/s. SRK Industries ltd., and after recording the statement of entry providers, concluded that the assessee is also

Arvind Bhaguji Kangane, Mumbai vs. Dy. Commissioner of Income Tax, Circle-27(1), Mumbai

In the result, ground no. 2 and 3 of appeal are

ITA 4158/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Jan 2026AY 2016-17

Bench: Shri Pawan Singh & Ms. Padmavathy S(Physical Hearing) Arvind Bhanguji Kangane Dcit, Circle – 27(1), Mumbai Shreyas Building, 11Th Road, Plot No. 4Th Floor, Tower No. 6, Vashi Vs 553, Flat No. 901, 9Th Floor, Opp. Railway Station Building, Navi Heritage Pride Building, Chembur, Mumbai – 400703. Mumbai – 400026. [Pan: Afypk1856R] Appellant / Assessee Respondent / Revenue

Section 10(38)Section 143(1)Section 144BSection 147Section 148Section 151ASection 254(1)Section 68

India(SEBI) against the broker of assessee. STT was paid at the time of sale. The assessing officer simply relied upon the information from Investigation Wing without giving any finding on various evidence or bringing adverse material on record against the evidence furnished by assessee. 7. The ld. AR further ... brought sufficient material on record that scrip on the sale of which the assessee has shown long term capital gain were penny scrip. The Investigation Wing carried out full-fledged investigation against such penny scrip company, Sanasa Tech Fab Ltd. is one of the penny scrip companies. Such penny scrip

Advanced Computers and Mobiles India Private Limited, Mumbai vs. DCIT Circle 1(1)(1), Mumbai

In the result, the ground No

ITA 3212/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jan 2026AY 2018-19

Bench: Shri Pawan Singh & Ms. Padmavathy S(Physical Hearing) Advanced Computers & Mobiles Dcit, Circle – 1(1)(1), Mumbai Room No. 533, 5Th Floor, India Private Limited Vs Unit No. 9, Ground Floor, Aayakarbhavan, M.K. Road, Yusuf Building, Flora Fountain, Fort, Mumbai – 400020. Mumbai – 400001. [Pan: Aamca5425A] Appellant / Assessee Respondent / Revenue

Section 139(4)Section 147Section 148Section 148ASection 151ASection 254(1)

NidhiRoadlines. On further verification, it was found that NidhiRoadlines was non-existent or belonging non- commercial vehicle category. The assessing officer also recorded that Investigation Wing of Income Tax Department carried out analysis and found that assessee issued bogus invoices to 199 parties aggregating of Rs. 1505.24 crores

Babulal Mulchand Varma, Mumbai vs. ACIT Central Circle-4(3), Mumbai

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

ITA 3150/MUM/2025[2009-10]Status: DisposedITAT Mumbai22 Jan 2026AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Respondent: Mr. Ajay R. Singh &

Section 143(3)Section 153CSection 69

hereinafter referred to as tax Act, 1961 (hereinafter referred to as “the Act”) was conducted by the Investig “the Act”) was conducted by the Investigation Wing of the Income ation Wing of the Income- tax Department on 06.03.2018 in the case of the SSS (Satyam, tax Department

Babulal Mulchand Varma, Mumbai vs. ACIT, Central Circle-4(3), Mumbai

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

ITA 3148/MUM/2025[2010-11]Status: DisposedITAT Mumbai22 Jan 2026AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Respondent: Mr. Ajay R. Singh &

Section 143(3)Section 153CSection 69

Vikas Chandra HUF, Aligarh vs. ITO Ward-4(1)(1), Aligarh

In the result, the appeal of the assessee is allowed

ITA 450/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshvikas Chandra Huf, Vs. Cit(Appeals), D-117, Ramesh Vihar, Nfac, Delhi Ramghar Road, Aligarh Up (Appellant) (Respondent) Pan: Aakjv9476N Assessee By : Shri Pankaj Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Pankaj Garg, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 139(1)Section 147Section 148Section 148ASection 151

declaring total income of Rs. 34,590/-. Based on the information received from the investigation wing, the ld AO reopened the assessment of the assessee u/s 147 of the Act vide issuance of notice u/s 148 of the Act on 28.3.2024. The reasons recorded for reopening the assessment together with

Ruby Jain, Agra vs. Income Tax Officer, Ward 1(1)(3), Agra

In the result, the questions referred to us are answered as follows :

ITA 128/AGR/2025[2015-16]Status: DisposedITAT Agra21 Jan 2026AY 2015-16

Bench: Shri M. Balaganeshruby Jain, Vs. Income Tax Officer, 1/78A, Kale Ka Tall, Delhi Ward-1(1)(3), Gate, Agra Agra (Appellant) (Respondent) Pan: Aevpj4936P Assessee By : Shri K. K. Jain, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri K. K. Jain, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 10(38)Section 143(3)Section 68Section 69C

statement evidencing the payment for purchase and sale of shares before the ld AO. 4. The ld AO merely placed reliance on the Kolkata Investigation Wing Report, which investigated 84 scrips by categorizing the same as penny stock where the price of shares were artificially rigged abnormally in connivance with ... loss to various persons by converting their unaccounted income into accounted income. Admittedly, HPC Biosciences Ltd was one of the scrip investigated by Kolkata Investigation Wing. Based on this investigation report, the ld Assessing Officer concluded that the sale proceeds received by the assessee on sale of 2800 shares

Virendra Kumar Namdev, Indore vs. CIT(A), National Faceless Appeal Centre (NFAC)

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

ITA 254/IND/2025[2013-14]Status: DisposedITAT Indore21 Jan 2026AY 2013-14

Bench: Shri Siddhartha Nautiyal (Judicial Member), Shri B.M. Biyani (Accountant Member)

For Appellant: Shri Pranay Goyal, C.AFor Respondent: Shri Ashish Porwal, Sr. D.R

Section 144BSection 147

Subsequently, on the basis of an enquiry conducted by the I.TA No. 254/IND/2025 A.Y. 2013-14 3 Virendra Kumar Namdev Vs. CIT(A) Investigation Wing, DDIT (Inv.), Indore, in the case of M/s Shree Vardhman Traders, the Assessing Officer observed that the assessee had facilitated large bank transactions of that ... Fibers and had duly participated in the assessment proceedings initiated under section 147 of the Act pursuant to an enquiry conducted by the Investigation Wing in the case of Shree Vardhman Traders. The assessee has submitted that during the assessment proceedings, the assessee responded to notices issued under sections

Vimal Alloys Private Limited, Mandi Gobindgarh, Punjab vs. Jao the Deputy Commissioner of Income Tax Circle, Patiala, Punjab

ITA 890/CHANDI/2025[2016-2017]Status: DisposedITAT Chandigarh21 Jan 2026AY 2016-2017

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Vipen Sethi, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 143(1)Section 147Section 148Section 151Section 69A

Subsequently, the assessment was reopened by issuance of notice under section 148 of the Act. The reopening was based on information received from the Investigation Wing in consequence to a search conducted on World Window Group, including Futuristic Metal Trading Pvt. Ltd., a concern alleged to be engaged ... cogent evidence. 5.2 The Ld. CIT(A) further held that the reopening was valid as it was based on tangible material received from the Investigation Wing and that the Assessing Officer had valid jurisdiction over the assessee. 6. Aggrieved by the said order, the assessee is in appeal before

Vikramkumar Kishanlal Mehta, Mahisagar vs. The DCIT, Anand Circle, Anand

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

ITA 313/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad21 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.313/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Vikramkumar Kishanlal The Dcit बनाम/ Mehta Anand Circle V/S. C/O. Mahesh Masala Gruh Anand – 388 001 Udhyog 21, Gidc Estate Balasinor Mahisagar – 388 255 "थायी लेखा सं./Pan: Aqhpm 9958 I (अपीलाथ)/ Appellant) (*+ यथ)/ Respondent) Assessee By : Shri Dhinal Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 18/12/2025 घोषणा की तारीख /Date Of Pronouncement: 21/01/2026 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 05/02/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2018-2019. 2. The Assessee, In This Appeal, Has Taken The Following Grounds Of Appeal: Vikramkumar Kishanlal Mehta Vs. Dcit Asst. Year : 2017-19

For Appellant: Shri Dhinal Shah, ARFor Respondent: Shri Sher Singh, CIT-DR

Section 115BSection 147Section 148Section 148ASection 250Section 68Section 69

therefore, has submitted that the re-opening of the assessment has been made by the AO on the basis of borrowed satisfaction of the Investigation Wing (IW). He has submitted that the information received from the IW was factually wrong and, therefore, the reopening of the assessment without correlating