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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

Rajesh Lakhamshi Nisar, Mumbai vs. ITO Ward 32(3)(1), Mumbai

In the result, the appeal filed by assessee is allowed for statistical purposes

ITA 1773/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Jan 2024AY 2014-15

Bench: Shri Pavan Kumar Gadalerajesh Lakhmshi Nisar, Vs. Ito-Ward 32(3)(1), 1404, Rite Galaxy, Kautilya Bhavan, Sodawala Lane, Bkc,Bandra(E), Borivali (W), Mumbai-400051. Mumbai- 400092. Pan/Gir No. : Adnpn2986L Appellant .. Respondent Appellant By : Shri.Ajay R. Singh & Shri.Akshay Pawar.Ar Respondent By : Ms. Shakuntala.N.Shet.Dr Date Of Hearing 02.11.2023 Date Of Pronouncement 22.01.2024 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The National Faceless Appeal Centre (Nfac)/Cit(A), Delhi Passed U/Sec143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri.Ajay R. Singh and Shri.Akshay Pawar.ARFor Respondent: Ms. Shakuntala.N.Shet.DR

Rajesh Lakhamshi Nisar, Mumbai. consideration of Rs. 45,30,950/-.Whereas the AO has dealt on the information of the investigation wing ITBA data, BSE data and investigation wing report and has called for the purchase confirmation, sale contract notes, bank statement and demat Account Statement in respect of shares ... purchase and sale transactions. The A.O has relied on the various facts, modus operandi and the report of the Kolkata investigation wing and statements recorded and has doubted the earning of Long Term Capital Gains (LTCG). The A.O also relied on the statement of the persons recorded u/sec

DCIT, CC-5(1), Mumbai vs. Hetal N. Shah (Leagal Heir of the Assessee Shri Nitin Rajmal Shah), Mumbai

In the result, we admit the appeal of the AO as it has been replaced by bringing the legal heir of deceased assessee on record but dismissed the appeal on the merits of the addition

ITA 1080/MUM/2023[2012-13]Status: DisposedITAT Mumbai22 Jan 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Hetal Nitin Shah Dcit Legal Heir Of Nitin Rajmal Central Circle 5(1) Room No.1928, 19 Th Floor, Shah Air India Building, 301, Chandramani, Vs. Nariman Point, Hanuman Road, Mumbai-400 021 Vile Parle(E), Mumbai-400 057 (Appellant) (Respondent) Pan No. Aadps5476M Assessee By : Shri Jaiprakash Bairagra, Ar Revenue By : Shri Ashok Kumar Ambastha, Dr Date Of Hearing: 16.11.2023 Date Of Pronouncement : 22.01.2024

For Appellant: Shri Jaiprakash Bairagra, ARFor Respondent: Shri Ashok Kumar Ambastha
Section 131Section 132Section 133ASection 143Section 143(3)Section 68

group companies have obtained accommodation entries as well as bogus purchase. Information was also received from the DGIT, Nitin Rajmal Shah; A.Y. 2012-13 Investigation Wing, Mumbai on 12th March, 2015, that assessee has taken a loan from Arihant Exports of ₹1 crore and Karnavat Impex ... loans have been repaid by account payee cheques. Assessee also requested LD AO to provide information received from Nitin Rajmal Shah; A.Y. 2012-13 Investigation Wing and to ask the parties to make available for cross-examination. 08. The learned AO considered the submission of the assessee and rejected

Rakesh Bansal, New Delhi vs. ACIT, Central Circle-16, New Delhi

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

ITA 1685/DEL/2023[2014-15]Status: DisposedITAT Delhi22 Jan 2024AY 2014-15

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri P.N. Barnwal, CIT-DR
Section 234ASection 234BSection 234DSection 69Section 69A

Collaboration Agreement dated 10.07.2013 between Smt. Vijay Gupta and Smt. Suman Bala Aggarwal and the assessee was found. The assessee was summoned by the Investigation Wing and statement was recorded in which the assessee denied any payment of cash to Smt. Vijay Gupta. Similarly, when Smt. Vijay Gupta was examined

DCIT, CC-3(3), Kolkata vs. Tulsyan and Sons Pvt. Ltd., Kolkata

In the result, the appeal of the revenue is dismissed

ITA 812/KOL/2023[2011-12]Status: DisposedITAT Kolkata18 Jan 2024AY 2011-12

Bench: Dr. Manish Borad & Shri Sonjoy Sarma]

Section 143(2)Section 148Section 4Section 68

also has given its finding in his order in the following manner: “11. The Assessing Officer perused the information supplied by the investigation wing and having formed the belief that income chargeable to tax had escaped assessment, cannot be stated to have acted mechanically. Further, mere fact that assessee

Naz Shazia, Moradabad vs. ITO Ward 1(1), Moradabad

In the result, the appeal of the assessee is allowed

ITA 1831/DEL/2023[2014-15]Status: DisposedITAT Delhi18 Jan 2024AY 2014-15

Bench: Shri M. Balaganeshnaz Shazia, Vs. Ito, Anwar House, Ground Ward-1(1), Floor, Pandit Nagla Mini Moradabad Bye Pass Road, Moradabad Pan: Bbwps217R Assessee By : Shri V. K. Tulsian, Ca Revenue By: Shri Om Parkash, Sr. Dr Date Of Hearing 15/01/2024 Date Of Pronouncement 18/01/2024

For Appellant: Shri V. K. Tulsian, CAFor Respondent: Shri Om Parkash, Sr. DR
Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 234BSection 69A

duly processed u/s 143(1) of the Act. No scrutiny assessment was framed by the revenue. The ld. AO received information from the Kolkata Investigation Wing stating that they had identified 84 scrips as penny stocks and that the prices had been artificially rigged up by certain entry operators ... entered into transaction of selling scrip of KAILASH AUTO (SCRIP CODE 511357). The total of trade value comes to Rs 39,64,750/- The Investigation Wing, Kolkata has categorized the assessee as "Client Type A-LTCG Mainly Profit" Beneficiary-Client which has only sold penny stock on the exchange without

Atmiben Aliptkumar Doshi, Sabarkantha vs. The Income Tax Officer, Sk Ward-3, Himatnagar

In the result, appeal filed by the assessee is dismissed

ITA 520/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad17 Jan 2024AY 2015-16

Bench: Ms. Suchitra Kambleassessment Year: 2015-16

Section 10(38)Section 142(1)Section 143(1)Section 143(2)Section 250Section 68

transaction and the Assessing Officer has not related any specific information/ material evidence pertaining to the assessee from the report of the Investigation Wing of the Kolkata and as to what documents were in the possession of the Assessing Officer to establish the allegation of bogus LTCG claim ... applicable in assessee‘s case. 7. The Ld. DR submitted that the assessee has not relied on any statement as such in respect of Investigation Wing’s report but has given categorical and independent finding about the assessee’s purchase as the sale of the said scrip was through

Brajesh Narnolia, Jharkhand vs. ITO, WD-1(1), Asansol.

In the result, the appeal of the assessee is dismissed

ITA 799/KOL/2023[2015-16]Status: DisposedITAT Kolkata17 Jan 2024AY 2015-16

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawali.T.A. No. 799/Kol/2023 Assessment Year: 2015-2016 Brajesh Narnolia,…………………………..........Appellant 419, City Center, Luby Circular Road, Dhanbad-826001, Jhankhand [Pan: Aczpn0347G] -Vs.- Income Tax Officer,.................................Respondent Ward-1(1), Asansol, Aayakar Bhawan, Room No. 3, Ground Floor, 116, Vivekananda Sarani, Kanyapur, Asansol-713341, West Bengal Appearances By: Shri S.S. Gupta, A.R., Appeared On Behalf Of The Assessee Shri B.K. Singh, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : January 15, 2024 Date Of Pronouncing The Order : January 17, 2024 O R D E R

Section 10(38)Section 143(2)

lack of adverse comments from stock exchange and officials of company involved in these transactions and no material relating to assessee was found in investigation wing report, additions made by Assessing Officer had rightly been deleted. SLP filed by revenue against impugned order was to be dismissed" In the case

Bhalchandra P. Dalvi, Ghahtkopar, Mumbai vs. ITO, Ward 27 (1) (2), Vashi, Navi Mumbai

In the result the appeal filed by the assessee is allowed

ITA 2492/MUM/2023[2008-09]Status: DisposedITAT Mumbai17 Jan 2024AY 2008-09

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadalebhalchandra P. Dalvi, Vs. Ito-Ward 27(1)(2), 1, Hemalaya Society, It-Office, Vashi Milind Nagar, Near Railway Station Sungrace English Building, School,Ghatkopar(W), Navimumbai-400705. Mumbai-400084. Pan/Gir No. : Aampd3092P Appellant .. Respondent Appellant By : Shri. Dinesh R.Shah & Shri B.R.Vyas.Ar Respondent By : Shri.Ashokkumarambastha,Sr.Dr Date Of Hearing 21.12.2023 Date Of Pronouncement 17.01.2024 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac) Delhi / Cit(A) Passed U/Sec271D & U/Sec250 Of The Act. 1. The Learned Joint Commissioner Of Income Tax 27(1) Erred In Levying Penalty U/S 271D Amounting To Rupees 24,50,000/- Rupees Twenty Four Lakhs Fifty Thousand As Well As Cit(A) National Faceless Appeal Centre (Nfac) Erred In Confirming The Same. Bhalachandra P. Dalvi.Mumbai. 2.1 The Appellant Has Received Rupees 18,50,000/- Rupees Eighteen Lakhs Fifty Thousand Cash Against Sale Of Flat & Rs.6,00,000/- Amount Raised From Lenders Which Amount Was Less Than Rupees Twenty Thousand Out Of Rupees Six Lakhs, Rupees Four Lakhs Seventy Five Thousand Is Already Taxed As Income & Balance Loans Are Accepted As Genuine & Each Loans Less Than Rs.20,000/- Considering Above Facts & Circumstances No Penalty U/S 271D Can Be Levied & Same Be Deleted.

For Appellant: Shri. Dinesh R.Shah & ShriFor Respondent: Shri.AshokKumarAmbastha,Sr.DR
Section 143(3)Section 147Section 271Section 271D

revised computation of income with the total income of Rs. 3,41,590/-.Whereas the Assessing Officer (AO) has received information from the Investigation Wing, Mumbai that the assessee has made cash deposits of Rs. 26,93,000/- with Bank of Baroda, Ghatkopar (East) branch during period Bhalachandra P. Dalvi.Mumbai

DCIT, CC 5(2), Central Range -5, Mumbai vs. Manubhai Gems Pvt Ltd, Mumbai

In the result, the C.O. of the assessee is rejected

ITA 659/MUM/2023[2019-20]Status: DisposedITAT Mumbai16 Jan 2024AY 2019-20

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Dr. K. Shivaram & Sh. Rahul
Section 115JSection 132Section 143(2)Section 143(3)Section 41(1)Section 69A

details of subsequent sales along with invoice copies. The ld. AR drew our attention to the submissions dated 20.05.2019 and 23.05.2019 submitted before the Investigation Wing wherein the details of the advance received are submitted (page 213 to 237 and pg. 160 to 212 of PB) along with copies

ITO, Ward-20(1), New Delhi vs. Placid Buildwell P.Ltd, New Delhi

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

ITA 6744/DEL/2018[ 2009-10]Status: DisposedITAT Delhi16 Jan 2024

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Prakash Nath Baranwal, CIT- DR
Section 143(3)Section 147Section 148

facts and under the circumstances of the case, the Ld. CIT (A) has erred in law without considering the survey conducted by the Investigation Wing of the department that the share applicant companies are only layering companies having no substantial income/ revenue which may justify source of such huge funds

I.T.O., Ward-43(2), Kolkata vs. Champalal Omprakash, Kolkata

ITA 1546/KOL/2019[2011-12]Status: DisposedITAT Kolkata15 Jan 2024AY 2011-12

Bench: Shri Sanjay Garg, Judical Member & Dr. Manish Boradi.T.A. Nos.1168&1169/Kol/2019 Assessment Years: 2010-11 & 2011-12 Champalal Omprakash......................................................................Appellant 49, Madan Mohan Burman Street, Kolkata-700007. [Pan:Aabfc8279L] Vs. Ito, Ward-43(2), Kolkata................................................................Respondent I.T.A. Nos.1545&1546/Kol/2019 Assessment Years: 2010-11 & 2011-12 Ito, Ward-43(2), Kolkata................................................................ Respondent Vs. Champalal Omprakash..........................................................................Appellant 49, Madan Mohan Burman Street, Kolkata-700007. [Pan:Aabfc8279L] Appearances By: Shri J. P. Khaitan, Sr. Counsel, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 13, 2023 Date Of Pronouncing The Order : January 15, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Are Cross-Appeals Preferred By The Assessee As Well As By The Department Against The Impugned Common Order Dated 19.03.2019 Of The Commissioner Of Income Tax (Appeals)-13, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since Common Issues Involved

Section 131Section 250

purpose of narration of facts. ITA No.1169/Kol/2019 – The brief facts of the case are that an 2. information was received from the Investigation Wing pursuant to a survey and search action carried out in the case of one Shri Sanjiw Kumar Singh who has been found to be involved ... assessment pleading that there was no valid reason for the Assessing Officer to reopen the assessment as that the information provided by the Investigation Wing was vague. However, the Assessing Officer proceeded to frame the assessment without deciding the objections of the assessee against the reopening of the assessment. During

I.T.O., Ward-43(2), Kolkata vs. Champalal Omprakash, Kolkata

ITA 1545/KOL/2019[2010-11]Status: DisposedITAT Kolkata15 Jan 2024AY 2010-11

Bench: Shri Sanjay Garg, Judical Member & Dr. Manish Boradi.T.A. Nos.1168&1169/Kol/2019 Assessment Years: 2010-11 & 2011-12 Champalal Omprakash......................................................................Appellant 49, Madan Mohan Burman Street, Kolkata-700007. [Pan:Aabfc8279L] Vs. Ito, Ward-43(2), Kolkata................................................................Respondent I.T.A. Nos.1545&1546/Kol/2019 Assessment Years: 2010-11 & 2011-12 Ito, Ward-43(2), Kolkata................................................................ Respondent Vs. Champalal Omprakash..........................................................................Appellant 49, Madan Mohan Burman Street, Kolkata-700007. [Pan:Aabfc8279L] Appearances By: Shri J. P. Khaitan, Sr. Counsel, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 13, 2023 Date Of Pronouncing The Order : January 15, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Are Cross-Appeals Preferred By The Assessee As Well As By The Department Against The Impugned Common Order Dated 19.03.2019 Of The Commissioner Of Income Tax (Appeals)-13, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since Common Issues Involved

Section 131Section 250

purpose of narration of facts. ITA No.1169/Kol/2019 – The brief facts of the case are that an 2. information was received from the Investigation Wing pursuant to a survey and search action carried out in the case of one Shri Sanjiw Kumar Singh who has been found to be involved ... assessment pleading that there was no valid reason for the Assessing Officer to reopen the assessment as that the information provided by the Investigation Wing was vague. However, the Assessing Officer proceeded to frame the assessment without deciding the objections of the assessee against the reopening of the assessment. During

Champalal Omprakash, Kolkata vs. I.T.O., Ward-43(2), Kolkata

ITA 1169/KOL/2019[2011-12]Status: DisposedITAT Kolkata15 Jan 2024AY 2011-12

Bench: Shri Sanjay Garg, Judical Member & Dr. Manish Boradi.T.A. Nos.1168&1169/Kol/2019 Assessment Years: 2010-11 & 2011-12 Champalal Omprakash......................................................................Appellant 49, Madan Mohan Burman Street, Kolkata-700007. [Pan:Aabfc8279L] Vs. Ito, Ward-43(2), Kolkata................................................................Respondent I.T.A. Nos.1545&1546/Kol/2019 Assessment Years: 2010-11 & 2011-12 Ito, Ward-43(2), Kolkata................................................................ Respondent Vs. Champalal Omprakash..........................................................................Appellant 49, Madan Mohan Burman Street, Kolkata-700007. [Pan:Aabfc8279L] Appearances By: Shri J. P. Khaitan, Sr. Counsel, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 13, 2023 Date Of Pronouncing The Order : January 15, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Are Cross-Appeals Preferred By The Assessee As Well As By The Department Against The Impugned Common Order Dated 19.03.2019 Of The Commissioner Of Income Tax (Appeals)-13, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since Common Issues Involved

Section 131Section 250

purpose of narration of facts. ITA No.1169/Kol/2019 – The brief facts of the case are that an 2. information was received from the Investigation Wing pursuant to a survey and search action carried out in the case of one Shri Sanjiw Kumar Singh who has been found to be involved ... assessment pleading that there was no valid reason for the Assessing Officer to reopen the assessment as that the information provided by the Investigation Wing was vague. However, the Assessing Officer proceeded to frame the assessment without deciding the objections of the assessee against the reopening of the assessment. During

Champalal Omprakash, Kolkata vs. I.T.O., Ward-43(2), Kolkata

ITA 1168/KOL/2019[2010-11]Status: DisposedITAT Kolkata15 Jan 2024AY 2010-11

Bench: Shri Sanjay Garg, Judical Member & Dr. Manish Boradi.T.A. Nos.1168&1169/Kol/2019 Assessment Years: 2010-11 & 2011-12 Champalal Omprakash......................................................................Appellant 49, Madan Mohan Burman Street, Kolkata-700007. [Pan:Aabfc8279L] Vs. Ito, Ward-43(2), Kolkata................................................................Respondent I.T.A. Nos.1545&1546/Kol/2019 Assessment Years: 2010-11 & 2011-12 Ito, Ward-43(2), Kolkata................................................................ Respondent Vs. Champalal Omprakash..........................................................................Appellant 49, Madan Mohan Burman Street, Kolkata-700007. [Pan:Aabfc8279L] Appearances By: Shri J. P. Khaitan, Sr. Counsel, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 13, 2023 Date Of Pronouncing The Order : January 15, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Are Cross-Appeals Preferred By The Assessee As Well As By The Department Against The Impugned Common Order Dated 19.03.2019 Of The Commissioner Of Income Tax (Appeals)-13, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since Common Issues Involved

Section 131Section 250

purpose of narration of facts. ITA No.1169/Kol/2019 – The brief facts of the case are that an 2. information was received from the Investigation Wing pursuant to a survey and search action carried out in the case of one Shri Sanjiw Kumar Singh who has been found to be involved ... assessment pleading that there was no valid reason for the Assessing Officer to reopen the assessment as that the information provided by the Investigation Wing was vague. However, the Assessing Officer proceeded to frame the assessment without deciding the objections of the assessee against the reopening of the assessment. During

Assistant Commissioner of Income Tax (Central)-1, Indore vs. Shri Ritesh Jain, Indore

ITA 794/IND/2018[2010-11]Status: DisposedITAT Indore12 Jan 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani & It(Ss)Ano.14/Ind/2022 (Assesssment Year 2011-12

Section 139Section 143(2)Section 147Section 148

assessment u/s 147 is contrary to law in the absence of any incriminating material to form reason to believe, as per the report of Investigation Wing & AO relied on, which only directs the AO to examine the details and after this examination only to determine whether there could ... legal grounds and on merits. 10. That the Id. CIT(A) has erred in law in treating the vague and general information of investigation wing and of the AO of the searched party M/s Jain Brothers as sacrosanct without examination with reference to the seized material and the facts

DCIT, CC- 19, New Delhi vs. Sharp Mint Ltd., New Delhi

In the result, all the appeals filed by the Revenue are dismissed

ITA 1093/DEL/2021[2017-18]Status: DisposedITAT Delhi12 Jan 2024AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 133ASection 153ASection 37

that a search & seizure and survey operation under section 132/133A of the Income-tax Act, 1961 (for short 'the Act') was conducted by the Investigation Wing of the Department on 07.04.2017 in Sharp Group of cases. The assessee’s premise was also covered under section

DCIT, CC- 19, New Delhi vs. Sharp Mint Ltd., New Delhi

In the result, all the appeals filed by the Revenue are dismissed

ITA 1092/DEL/2021[2016-17]Status: DisposedITAT Delhi12 Jan 2024AY 2016-17

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 133ASection 153ASection 37

that a search & seizure and survey operation under section 132/133A of the Income-tax Act, 1961 (for short 'the Act') was conducted by the Investigation Wing of the Department on 07.04.2017 in Sharp Group of cases. The assessee’s premise was also covered under section

DCIT, CC- 19, New Delhi vs. Sharp Mint Ltd., New Delhi

In the result, all the appeals filed by the Revenue are dismissed

ITA 1091/DEL/2021[2015-16]Status: DisposedITAT Delhi12 Jan 2024AY 2015-16

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 133ASection 153ASection 37

that a search & seizure and survey operation under section 132/133A of the Income-tax Act, 1961 (for short 'the Act') was conducted by the Investigation Wing of the Department on 07.04.2017 in Sharp Group of cases. The assessee’s premise was also covered under section

DCIT, CC- 19, New Delhi vs. Sharp Mint Ltd., New Delhi

In the result, all the appeals filed by the Revenue are dismissed

ITA 1090/DEL/2021[2014-15]Status: DisposedITAT Delhi12 Jan 2024AY 2014-15

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 133ASection 153ASection 37

that a search & seizure and survey operation under section 132/133A of the Income-tax Act, 1961 (for short 'the Act') was conducted by the Investigation Wing of the Department on 07.04.2017 in Sharp Group of cases. The assessee’s premise was also covered under section

DCIT, CC- 19, New Delhi vs. Sharp Mint Ltd., New Delhi

In the result, all the appeals filed by the Revenue are dismissed

ITA 1089/DEL/2021[2013-14]Status: DisposedITAT Delhi12 Jan 2024AY 2013-14

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 133ASection 153ASection 37

that a search & seizure and survey operation under section 132/133A of the Income-tax Act, 1961 (for short 'the Act') was conducted by the Investigation Wing of the Department on 07.04.2017 in Sharp Group of cases. The assessee’s premise was also covered under section