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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

Shri Pannalal Hastimal Gulecha, Mumbai vs. The ITO, Ward-23(2)(7), Mumbai

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

ITA 2228/MUM/2023[2012-13]Status: DisposedITAT Mumbai19 Apr 2024AY 2012-13
Section 10(38)Section 143(3)Section 147Section 148Section 68

confirmed the addition on same reasoning. Smt. Pawanben Pannalal Gulecha 9 Before us, ld. Counsel submitted that the findings and report of the Investigation wing and observation of the ld. AO are general observations without any specific reference to the transaction of the assessee or anything directly adverse against ... penny stock used for providing accommodation entry. 13. Though the case of the assessee has been reopened based on information received from Investigation wing that a search and seizure action was conducted in the case of Shri Shirish Chandrakant Shah on 09/04/2013 wherein it was found that he was controlling

Ganesh Shankar Pujare, Sindhudurg vs. Income Tax Officer, Ward, Kudal

In the result appeal filed by the assessee stands allowed for the statistical purposes

ITA 40/PUN/2024[2014-15]Status: DisposedITAT Pune18 Apr 2024AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.40/Pun/2024 िनधा"रण वष" / Assessment Year: 2014-15 Ganesh Shankar Pujare, Vs. Ito, Ward, Kudal. Bidyewadi, At Post Kalmath, Taluka Kankavli, Sindhudurg- 416602. Pan : Anipp5657R Appellant Respondent Assessee By Shri Tanzil R. Padvekar : Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 17.04.2024 Date Of Pronouncement : 18.04.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Is Filed By The Assessee Assailing The Order Dated 08.11.2023 Passed By Ld Cit(A) [‘Nfac’] For The Assessment Year 2014-15. 2. The Appellant Raised The Following Grounds Of Appeal :- “I. Legality & Validity Of Reassessment Proceeding; 1. On The Facts & In Law, The Re-Assessment Proceeding Initiated By The Ld. Assessing Officer Under Section 147 Of The Act Is Bad In Law As The Same Is Based On Suspicious & Incorrect Information. Hence, As The Formation Of Belief Is Based On Incorrect, Suspicious & Vague Facts Same Is Unsus Tainable In Eye Of Law. 2. On The Facts & In Law, There Is Serious Jurisdictional Requirement In The Reasons Recorded By The Assessing Officer As He

For Respondent: Shri Ramnath P. Murkunde
Section 143(3)Section 147Section 148Section 151

orders were passed u/s 143(3) on 30-11-2016 raising NIL Demand. Thereafter on receipt of the information from the Investigation Wing of the Department that the assessee had received credit entries in the form of cash deposits as well as cash credits amounting to Rs.22

Kodali Suresh Babu, Labbipet vs. Income Tax Officer Ward (International Taxation), Vijayawada

In the result, appeal of the assessee is allowed

ITA 231/VIZ/2022[2016-17]Status: DisposedITAT Visakhapatnam18 Apr 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T. (It). A. No.231/Viz/2022 (निर्धारण वर्ा/ Assessment Year : 2016-17) Kodali Suresh Babu, Vs. Income Tax Officer, Labbipet. Ward (International Taxation), Pan: Atwpk 8835 C Vijayawada. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessee By : Sri Gvn Hari, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Aparna Villuri, Sr. Ar सुिवधईकीतधरीख/ Date Of Hearing : 26/03/2024 घोर्णधकीतधरीख/Date Of : 18/04/2024 Pronouncement O R D E R Per S. Balakrishnan:

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 147Section 148Section 69

associated entities on 25/10/2017 and during the search operation the agreement of sale deed dated 6/1/2016 was seized by the Investigation Wing. Further, Sri Muppavarapu Maheswara Reddy, Managing Director, deposed in his sworn statement that the assessee intended to 3 purchase plots for which he gave an advance ... assessee has not clearly 4 explained the monetary transactions worth Rs. 7,89,85,000/- and based on the information transmitted by the Investigation Wing and with respect to the material available on record, the Ld. AO initiated proceedings U/s. 147 of the Act with the prior approval

Dskn Jewellers, Delhi vs. ITO Ward-46(3), New Delhi

The appeal is dismissed

ITA 1051/DEL/2021[2011-12]Status: DisposedITAT Delhi18 Apr 2024AY 2011-12

Bench: Shri G. S. Pannu, Vice- & Shri Anubhav Sharmadskn Jewellers Vs. Ito C/O. Mr. Samar Kapoor, Adv. Ward – 46(3) Chamber No.E-523, Karkardooma New Delhi Court, Delhi-32 Pan No. Aahfd 2162 M (Appellant) (Respondent) Assessee By : None Revenue By : Shri Sumesh Swani, Sr. D.R. Date Of Hearing : 24.01.2024 Date Of Pronouncement : 18.04.2024

For Appellant: NoneFor Respondent: Shri Sumesh Swani, Sr. D.R
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 148(1)Section 149(1)(b)Section 151Section 27Section 271(1)(b)

However, the appellant completely disregarded the notices. In the absence of any evidence to DSKN Jewellers vs. ITO 4 controvert the finding of the Investigation Wing, the AO was justified to treat the entire credits in the bank account amounting to Rs. 13,66,90,335/- during

Mkr Trading Pvt Ltd, New Delhi vs. ITO Ward - 16(4), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 9285/DEL/2019[2009-10]Status: DisposedITAT Delhi18 Apr 2024AY 2009-10

Bench: Shri Saktijit Dey & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Ms. Kamaljot Kaur, Sr. DR
Section 120Section 143(1)Section 148Section 151Section 250Section 68

assessee filed revised return of income declaring income of Rs. 2,885/- which was processed u/s 143(1). Subsequently, information was received from Investigation Wing that Shri Vishal Gupta, Chartered Accountant and Shri Jai Prakash Gupta, Chartered Accountants had opened several bank accounts in different branches in Delhi

Pushpa Gupta, Gurgaon vs. ITO Ward -3(3), Gurgaon

In the result, the appeal of the assessee is allowed

ITA 3604/DEL/2019[2015-16]Status: DisposedITAT Delhi18 Apr 2024AY 2015-16

Bench: Shri Shamim Yahyapushpa Gupta, Vs. Ito, Ward 3 (3), Tg-6/8A, Sun City, Sector 54, Gurgaon. Gurgaon (Haryana).

For Appellant: Shri Vijay Singla, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 10(38)Section 115BSection 143(2)Section 68

confirming the above addition despite the fact that the addition is made by the AO relying on the report of the investigation wing without application of his own mind. 9(i) On the facts and circumstances of the case the learned CIT(A) has erred both on facts

Kaushik Pravinchandra Gohel, Bhavnagar vs. The Assessing Officer, Ward-1(2), Bhavnagar

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

ITA 694/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2017-18

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri B. R. Popat, A.RFor Respondent: Shri H. Phani Raju, CIT DR
Section 115BSection 143(2)Section 144Section 147Section 148Section 69Section 69A

before the Bench for it’s consideration. Accordingly, the Department vide letter dated 15.03.2024, submitted before us the information regarding the report of the Investigation Wing and other related documents. 12. On going through the contents of the report of the Investigation Wing made available to us, we observe that ... funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society had roped in various individuals of meagre means to open bank accounts in their names and thereafter, such bank accounts were operated

Kaushik Pravinchandra Gohel, Bhavnagar vs. The Assessing Officer, Ward-1(2), Bhavnagar

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

ITA 693/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2016-17

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri B. R. Popat, A.RFor Respondent: Shri H. Phani Raju, CIT DR
Section 115BSection 143(2)Section 144Section 147Section 148Section 69Section 69A

before the Bench for it’s consideration. Accordingly, the Department vide letter dated 15.03.2024, submitted before us the information regarding the report of the Investigation Wing and other related documents. 12. On going through the contents of the report of the Investigation Wing made available to us, we observe that ... funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society had roped in various individuals of meagre means to open bank accounts in their names and thereafter, such bank accounts were operated

Kaushik Pravinchandra Gohel, Bhavnagar vs. The Assessing Officer, Ward-1(2), Bhavnagar

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

ITA 692/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2016-17

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri B. R. Popat, A.RFor Respondent: Shri H. Phani Raju, CIT DR
Section 115BSection 143(2)Section 144Section 147Section 148Section 69Section 69A

before the Bench for it’s consideration. Accordingly, the Department vide letter dated 15.03.2024, submitted before us the information regarding the report of the Investigation Wing and other related documents. 12. On going through the contents of the report of the Investigation Wing made available to us, we observe that ... funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society had roped in various individuals of meagre means to open bank accounts in their names and thereafter, such bank accounts were operated

Kaushik Pravinchandra Gohel, Bhavnagar vs. The Assessing Officer, Ward-1(2), Bhavnagar

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

ITA 691/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2015-16

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri B. R. Popat, A.RFor Respondent: Shri H. Phani Raju, CIT DR
Section 115BSection 143(2)Section 144Section 147Section 148Section 69Section 69A

before the Bench for it’s consideration. Accordingly, the Department vide letter dated 15.03.2024, submitted before us the information regarding the report of the Investigation Wing and other related documents. 12. On going through the contents of the report of the Investigation Wing made available to us, we observe that ... funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society had roped in various individuals of meagre means to open bank accounts in their names and thereafter, such bank accounts were operated

Kaushik Pravinchandra Gohel, Bhavnagar vs. The Assessing Officer, Ward-1(2), Bhavnagar

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

ITA 690/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2015-16

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri B. R. Popat, A.RFor Respondent: Shri H. Phani Raju, CIT DR
Section 115BSection 143(2)Section 144Section 147Section 148Section 69Section 69A

before the Bench for it’s consideration. Accordingly, the Department vide letter dated 15.03.2024, submitted before us the information regarding the report of the Investigation Wing and other related documents. 12. On going through the contents of the report of the Investigation Wing made available to us, we observe that ... funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society had roped in various individuals of meagre means to open bank accounts in their names and thereafter, such bank accounts were operated

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 111/CHANDI/2023[2020-21]Status: DisposedITAT Chandigarh15 Apr 2024AY 2020-21

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

whose possession cash amounting to Rs. 35,00,000/- was seized by the Police Authorities and subsequently, the matter was referred to the Investigation Wing, Income Tax Department, Ludhiana. It was further submitted that the preliminary statement of the assessee was recorded by the ITO (Inv.), Jalandhar on 21/12/2019. Subsequently ... assessee by the Police Authorities during the regular checking at Hightech Naka, G.T. Road, Phillaur and the matter was referred to the Investigation Wing, Income Tax Department by SHO, Police Station, Phillaur on 21/12/2019 for ascertaining the source of cash so found in possession of the assessee. Thereafter, preliminary statement

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 110/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh15 Apr 2024AY 2019-20

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

whose possession cash amounting to Rs. 35,00,000/- was seized by the Police Authorities and subsequently, the matter was referred to the Investigation Wing, Income Tax Department, Ludhiana. It was further submitted that the preliminary statement of the assessee was recorded by the ITO (Inv.), Jalandhar on 21/12/2019. Subsequently ... assessee by the Police Authorities during the regular checking at Hightech Naka, G.T. Road, Phillaur and the matter was referred to the Investigation Wing, Income Tax Department by SHO, Police Station, Phillaur on 21/12/2019 for ascertaining the source of cash so found in possession of the assessee. Thereafter, preliminary statement

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 109/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh15 Apr 2024AY 2018-19

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

whose possession cash amounting to Rs. 35,00,000/- was seized by the Police Authorities and subsequently, the matter was referred to the Investigation Wing, Income Tax Department, Ludhiana. It was further submitted that the preliminary statement of the assessee was recorded by the ITO (Inv.), Jalandhar on 21/12/2019. Subsequently ... assessee by the Police Authorities during the regular checking at Hightech Naka, G.T. Road, Phillaur and the matter was referred to the Investigation Wing, Income Tax Department by SHO, Police Station, Phillaur on 21/12/2019 for ascertaining the source of cash so found in possession of the assessee. Thereafter, preliminary statement

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 108/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh15 Apr 2024AY 2017-18

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

whose possession cash amounting to Rs. 35,00,000/- was seized by the Police Authorities and subsequently, the matter was referred to the Investigation Wing, Income Tax Department, Ludhiana. It was further submitted that the preliminary statement of the assessee was recorded by the ITO (Inv.), Jalandhar on 21/12/2019. Subsequently ... assessee by the Police Authorities during the regular checking at Hightech Naka, G.T. Road, Phillaur and the matter was referred to the Investigation Wing, Income Tax Department by SHO, Police Station, Phillaur on 21/12/2019 for ascertaining the source of cash so found in possession of the assessee. Thereafter, preliminary statement

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 107/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh15 Apr 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

whose possession cash amounting to Rs. 35,00,000/- was seized by the Police Authorities and subsequently, the matter was referred to the Investigation Wing, Income Tax Department, Ludhiana. It was further submitted that the preliminary statement of the assessee was recorded by the ITO (Inv.), Jalandhar on 21/12/2019. Subsequently ... assessee by the Police Authorities during the regular checking at Hightech Naka, G.T. Road, Phillaur and the matter was referred to the Investigation Wing, Income Tax Department by SHO, Police Station, Phillaur on 21/12/2019 for ascertaining the source of cash so found in possession of the assessee. Thereafter, preliminary statement

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 106/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh15 Apr 2024AY 2015-16

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

whose possession cash amounting to Rs. 35,00,000/- was seized by the Police Authorities and subsequently, the matter was referred to the Investigation Wing, Income Tax Department, Ludhiana. It was further submitted that the preliminary statement of the assessee was recorded by the ITO (Inv.), Jalandhar on 21/12/2019. Subsequently ... assessee by the Police Authorities during the regular checking at Hightech Naka, G.T. Road, Phillaur and the matter was referred to the Investigation Wing, Income Tax Department by SHO, Police Station, Phillaur on 21/12/2019 for ascertaining the source of cash so found in possession of the assessee. Thereafter, preliminary statement

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 105/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh15 Apr 2024AY 2014-15

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

whose possession cash amounting to Rs. 35,00,000/- was seized by the Police Authorities and subsequently, the matter was referred to the Investigation Wing, Income Tax Department, Ludhiana. It was further submitted that the preliminary statement of the assessee was recorded by the ITO (Inv.), Jalandhar on 21/12/2019. Subsequently ... assessee by the Police Authorities during the regular checking at Hightech Naka, G.T. Road, Phillaur and the matter was referred to the Investigation Wing, Income Tax Department by SHO, Police Station, Phillaur on 21/12/2019 for ascertaining the source of cash so found in possession of the assessee. Thereafter, preliminary statement

Jaya Garg, Indore vs. ACIT NFAC, New Delhi

Appeal is allowed for statistical purpose

ITA 418/IND/2023[2014-15]Status: DisposedITAT Indore15 Apr 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2014-15 Jaya Garg, Acit-Nfac, C-4/5, Shivkripa Colony, New Delhi बनाम/ Sajan Nagar Road, Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Agtpg 4247 L Assessee By Shri Pankaj Shah Ca, Shri Soumya Bumb Ca, Ms. Ayushi Garg Ca & Ms. Anshika Goyal Ca - Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 09.04.2024 Date Of Pronouncement 5.04.2024

Section 143(2)Section 144BSection 147Section 148Section 149Section 68

proceeding u/s 147. Ld. AR submitted that the AO’s approach clearly shows that he just proceeded, acted and executed the information received from Investigation Wing and without application of his own mind. Ld. AR strongly contended that such an approach is clearly illegal, unsustainable and deserves to be quashed ... hereby clarified that office of investigation has sufficient material on record and on the basis of the said material and information received from the investigation Wing, proceedings u/s 147 has been initiated as per law and notice has been issued u/s 148 of the Income- tax Act, 1961, which

Rohit Vinat Gupta, Mumbai vs. ACIT CC 3(2), Mumbai

Accordingly, ground no. 4 is dismissed

ITA 3718/MUM/2023[2018-19]Status: DisposedITAT Mumbai12 Apr 2024AY 2018-19
For Appellant: Shri Mani & Prateek JainFor Respondent: Smt Sanyogita Nagpal (CIT- DR)
Section 132Section 69A

assessment order, the AO has observed that the said valuation report was never brought to the notice of the search officials or investigation wing post search. Having considered the facts, I agree with the AO that the said valuation was never mentioned by the assessee before the search officials