“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

M/S Jet Airways (India) Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle, 5(2), Mumbai

In the result, the appeals for AY 2012-13 to AY 2015-16 are allowed for statistical purposes

ITA 2200/MUM/2022[2014-15]Status: DisposedITAT Mumbai14 Dec 2023AY 2014-15

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Appellant: Shri Anuj Kisnadwala, ARFor Respondent: Shri Vachashpati Tripathi,CIT-DR

Section 115JSection 133ASection 142(1)Section 143(2)Section 143(3)Section 144Section 148Section 30

Airways (India) Ltd. 3. A survey under section 133A of the Act was conducted in the case of the assessee on 19.09.2018 by Investigation Wing, Mumbai. Based on the survey report the Assessing Officer (AO) reopened the assessment by issue of notice under section 148 of the Act. In response

Riya Buildtech Pvt Ltd, New Delhi vs. ACIT Circle-21(2), New Delhi

In the result the appeal of the assessee in ITA No

ITA 5904/DEL/2019[2011-12]Status: DisposedITAT Delhi14 Dec 2023AY 2011-12

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Kapil Goel, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(1)Section 147Section 148

order passed by Ld AO u/s 147/143(3) without appreciating that rubber stamp; reasons in present case are based on unconfronted appraisal report; of investigation wing and are without independent application of mind; 1.2 That on the facts and in the circumstances of the case ... order passed by Ld AO u/s 147/143(3) without appreciating that material referred in reasons has not been confronted to assessee namely report of investigation wing Ahmedabad, broker surveyed /s133A. statement of broker surveyed and material found from survey and connection of that broker with the assessee, lack of which

Income Tax Officer, Ward-2(3)(6), Surat, Anavil Business Centre vs. Sunilkumar, Devratna Apartment

In the result the ground No

ITA 539/SRT/2023[2008-2009]Status: DisposedITAT Surat14 Dec 2023AY 2008-2009

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.539/Srt/2023 Assessment Year: (2008-09) (Physical Hearing) The Ito, Vs. Sunilkumar Parasmal Jain, Ward-2(3)(6), 503, Gokul Apartment, Devidas Surat Pipla Sheri, Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abypj2281P (Appellant) (Respondent) Appellant By Shri Ashish Pophare, Cit-Dr None Respondent By 29/11/2023 Date Of Hearing Date Of Pronouncement 14/12/2023

Section 147

various documentary evidences furnished by assessee. The ld. CIT-DR for the Revenue supported the order of AO. The ld. CIT-DR submits that Investigation Wing, Mumbai made a search on Bhanwarlal Jain Group. During the search and after search, the Investigation Wing made a thorough investigation and concluded that ... made any comment on the documentary evidence furnished by assessee. The AO solely relied upon the statement of third party and the report of Investigation Wing. The report of wing and the statement of Bhanwarlal Jain were not provided to the assessee. The AO has not disputed the sales

Assistant Commissioner of Income Tax, Circle-1, Dibrugarh vs. Santosh Bamalwa, Dibrugarh

In the result, appeal of the revenue is dismissed and the cross- objection filed by the assessee is allowed

ITA 104/GTY/2023[2012-13]Status: HeardITAT Guwahati13 Dec 2023AY 2012-13

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 104/Gty/2023 Assessment Year: 2012-13 Assistant Commissioner Of Income Smt. Santosh Bamalwa Tax, Circle-1, Dibrugarh Vs Ground Floor Mahalaya Road C/O A.K. Varma Dibrugarh - 786001 [Pan: Aedpb9900P] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) C.O. No. 34/Gty/2023 Assessment Year: 2012-13 Smt. Santosh Bamalwa Assistant Commissioner Of Income Tax, Circle-1, Dibrugarh Vs Ground Floor Mahalaya Road C/O A.K. Varma Dibrugarh - 786001 [Pan: Aedpb9900P] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.K. Tulsiyan, Advocate Revenue By : Shri Arun Bhowmick, Jcit, D/R सुनवाई क" तारीख/Date Of Hearing : 01/11/2023 घोषणा क" तारीख /Date Of Pronouncement: 13/12/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Filed By The Revenue & The Cross-Objection Filed By The Assessee Are Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Central, North-East Region, Guwahati (Hereinafter The “Ld. Cit(A)”) Dt. 14/07/2023, Passed U/S

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Arun Bhowmick, JCIT, D/R

Section 132Section 143(2)Section 153ASection 68

Assessing Officer was also aware. He has not possessed any material. Therefore, he tried to collect the material by issuing a commission to the Investigation Wing, Kolkata and apprising them that basically during the course of search, nothing has unearthed. Therefore, DIT Investigation should again call the persons

Jai Shankar Srivastava, Gurgaon vs. DCIT, Central Circle- 18, New Delhi

ITA 7114/DEL/2017[2014-15]Status: DisposedITAT Delhi13 Dec 2023AY 2014-15

Bench: Sh. N. K. Billaiya & Sh. C.N. Prasadassessment Year: 2014-15 Jai Shankar Srivastava, Vs. Dcit Central Circle – 18 D-153, Pinnacle, Dlf New Delhi Phase-5, Gurgaon Haryana 122002 Pan No.Apqps0001J (Appellant) (Respondent) Appellant By None Respondent By Sh. Rohit Garg, Cit Dr Date Of Hearing: 13/12/2023 Date Of Pronouncement: 13/12/2023 Order Per N. K. Billaiya, Am:

Section 132Section 132(1)Section 132(1)(a)Section 143(2)Section 153(1)(a)Section 153ASection 2(24)(iv)Section 2(31)Section 2(45)Section 28

Because CIT (A) has stated that the search and seizure actions which was conducted as per the Information collected by the Investigation wing and that to after due process carried out which hold diversion of money fraudulent from NSEL is liable for tax as it is an Income ... view of Law and facts that Session Court of MPID has observed in its order on the plea of Dy Director of Income Tax (Investigation wing) that it is almost undisputed that the amount is transferred from the account of NSEL and therefore it is apparently and basically the money

Vilson Roofing Products Private Limited, Kolhapur vs. The Assistant Commissioner of Income Tax, Central Circle, Kolhapur

The appeal of the assessee is DISMISSED

ITA 956/PUN/2023[2009-10]Status: DisposedITAT Pune12 Dec 2023AY 2009-10

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 956/Pun/2023 निर्धारण वर्ा / Assessment Year : 2009-10 Vilson Roofing Products Pvt. Ltd., 1St Lane, Opp. Prataprao Jagdale Hall, Rajarampuri, Kolhapur, Pin – 416 008 . . . . . . . अपऩलधथी / Appellant Pan: Aaccv0661M

For Appellant: Mr Sharad Vaze [‘Ld. AR’]For Respondent: Mr M G Jasnani [‘Ld. DR’]

Section 143(3)Section 147Section 148Section 250Section 253(1)(a)Section 68

facts of the case are that; 2.1 Assessee Company filed its return of income [in short ‘ITR’] declaring NIL total income. Upon information from investigating wing that assessee is ultimate beneficiary of cash transaction arising to it in the form of share subscription, Ld. AO after recording reasons & obtaining prior ... Avirat Star Homes Venture (P.) Ltd. [2019] 102 taxmann.com 60 (Bombay), Hon‟ble Bombay High Court has held- Where information was received from investigation wing about certain companies that were involved in giving accommodation entries of various natures to several beneficiaries and assessee was one of them, information supplied

Deepak Nagori, Hyderabad vs. Income Tax Officer, Ward-8(3), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 1713/HYD/2018[2012-13]Status: DisposedITAT Hyderabad12 Dec 2023AY 2012-13

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarassessment Year:2012-13 Shri Deepak Nagori Vs. Income Tax Officer Hyderabad Ward 8(3) Hyderabad (Appellant) (Respondent) Pan:Abspn3300M Assessee By: None Revenue By: Shri K. Madhusudan, Cit(Dr) Date Of Hearing: 07/12/2023 Date Of Pronouncement: 12/12/2023 Order Per Laliet Kumar, J.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.05.2018 Of The Learned Cit (A)-2, Hyderabad Relating To A.Y.2012-13. 2. The Grounds Raised By The Assessee Reads As Under: “1. That The Appellant Is An Individual & Filed His Income Tax Return (Tr) For Fy 2011-12 By Declaring Income Of Rs.5,82,686/-. The Itr Includes Long Term Capital Gains Of Rs.23,08,721/- & Claimed Exemption Under Section 10(38) Of It Act 1961. Notices Issued Under Section 148 & Notice Under Section 142(1) Of The Income Tax Act, 1961. The Ld. Ao Passed The Assessment Order Under Section 143(3) R.W.S. 147 Of The I.T Act, 1961 & The Same Was Upheld By Ld. Cit(A).

For Appellant: NoneFor Respondent: Shri K. Madhusudan, CIT(DR)

Section 10(38)Section 142(1)Section 143(3)Section 148Section 69

time to time submitted the information called for. 5. In this regard, the Assessing Officer gave a background of investigation carried out by the investigation wing of the department. The Directorate of Investigation, Kolkata carried out a country wide investigation to unearth the organized racket of generating bogus entries

Ramnik Sushil Chaudhry, Mumbai vs. Assistant .CIT Circle (3), Thane

The appeals are allowed

ITA 2820/MUM/2023[2010-11]Status: DisposedITAT Mumbai12 Dec 2023AY 2010-11

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri Dinesh R ShahFor Respondent: Smt Mahita Nair

Section 144Section 148Section 271(1)(c)Section 274

Rs.16,17,750/-. Both these cases were reopened under Section 148 of the said Act, on the basis of the information received from Investigation Wing, Mumbai, that the assessee was a beneficiary of certain accommodation entries. 3. The Assessing Officer passed re-assessment order under Section 144 r.w.s

A.S.Motiwala Jewellers Private Limited, Mumbai vs. ITO 12(2)(1), Mumbai

In the result, both the appeals are, accordingly, disposed of

ITA 2773/MUM/2023[2013-14]Status: DisposedITAT Mumbai12 Dec 2023AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. No.2773/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2013-14) As Motiwala Jewellers Pvt. बिधम/ Ito-12(2)(1) Ltd. Aayakar Bhavan, Vs. (Formerly Known As Ghazi Mumbai-400020. Gems & Jewellers Pvt. Ltd) 40 Rebello Road Bandra West, Mumbai-400050. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaecg8165B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Nishit Gandhi/Ms Madhuri Tambe Revenue By: Shri Ashok Kumar Ambastha (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 04/12/2023 घोषणा की तारीख /Date Of Pronouncement: 12/12/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/(Nfac), Delhi Dated 14.06.2023 For The Assessment Year 2013-14. 2. At The Outset, The Ld. Ar Of The Assessee, Assails The Action Of The Ld. Cit(A) Sustaining The Addition On Merits, To The Tune Of Rs.59,53,440/- U/S 69C Of The Income Tax Act, 1961 (Hereinafter “The Act”). In Other Words, Assessee Assails The Action Of Ld Cit(A) Upholding The Action Of Ao, Wherein He Disallowed The Entire Purchases Of Diamonds Made From M/S. Mohit Enterprises (Alleged Concern Of Shri Bhanwarlal Jain Group).

For Appellant: Shri Nishit Gandhi/Ms MadhuriFor Respondent: Shri Ashok Kumar Ambastha (Sr

Section 147Section 148Section 69C

assessment, we are not discussing about the action of re-opening the assessment. According to the AO, he received information that from the Investigation Wing, Mumbai that Shri Bhanwarlal Jain (known entry operator) was managing and controlling M/s. Mohit Enterprises from which concern, the assessee has shown to have transacted/purchased

Kishansing Pahadsingh Parmar (HUF), Malad (West) vs. The Income Tax Officer-30 (2) (1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2440/MUM/2023[2011-12]Status: DisposedITAT Mumbai12 Dec 2023AY 2011-12

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.2440/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2011-12) Kishansing Pahadsingh बिधम/ Ito-30(2)(1) Parmar (Huf) C-13 Pratyakshakar Vs. Flat No.801, Shreenath Bhavan, Bandra Kurla Apartment A-Wing, J.P. Complex, Bandra East, Cross Lane, Himanshurai Mumbai-400051. Road, Malad (West), Mumbai-400064. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aadhk9023N (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Rajendra Kumar Jain/Shri Kunal Lunawat Revenue By: Shri S. N. Kabra (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 30/11/2023 घोषणा की तारीख /Date Of Pronouncement: 12/12/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Trust Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/(Nfac), Delhi Dated 28.04.2023 For The Assessment Year 2011-12. 2. The Main Grievance Of The Assessee Is Against The Action Of The Ld. Cit(A) Confirming The Action Of The Ao Making An Addition Of Rs.29,77,009/- & Rs.89,310/- U/S 69C Of The Income Tax Act, 1961 (Hereinafter “The Act”).

For Appellant: Shri Rajendra Kumar Jain/ShriFor Respondent: Shri S. N. Kabra (Sr. AR)

Section 10(38)Section 69C

According to the AO/Ld. CIT(A), the aforesaid transaction was suspicious and bogus which fact according to him, was revealed from the report of Investigation Wing of Directorate of Investigation Kolkata, which held that shares of M/s. Comfort Intech was a penny-stock. The AO in the assessment order ... bank statement showing receipt of sales etc. Though the AO did not find any infirmity in the aforesaid documents but he relied upon the Investigation Wing Report to draw adverse inference against the transaction made by assessee in respect of scrip of M/s. Comfort Intech Ltd which was also branded

Sanjay Basudeo Agarwal, Mumbai vs. Income Tax Officer 25(1)(1), Bandra Kurla Complex

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

ITA 2398/MUM/2023[2014-15]Status: DisposedITAT Mumbai12 Dec 2023AY 2014-15

Bench: Shri Pavan Kumar Gadalesanjay Basudeo Agarwal, Vs Ito, Ward - 25(1)(1), 1601, Kanchan Ganga, Kautilya Bhawan, J.P Road, Manishnagar, G- Block,Bkc, Andheri (W), Bandra Kurla Complex, Mumbai-400053. Mumbai-400051. Pan/Gir No. : Aabpa1748E Appellant .. Respondent

For Appellant: Shri Vimal Punmiya.ARFor Respondent: Shri.UjjawalkumarChavhanSr.DR

Section 10(38)Section 143(3)Section 234ASection 271(1)(c)Section 68Section 69

demat account, statements in respect of shares purchase and relied on the various factual aspects of share trends, modus operandi and report of the Investigation Wing ITDA data, BSE data and report of the kolkata Investigation Wing, statements recorded U/sec131 of the Act and has doubted the earning of long ... 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

DCIT RG 8(2), Mumbai vs. Proctor & Gamble Hygiene & Health Care Ltd, Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 2446/MUM/2013[2008-09]Status: DisposedITAT Mumbai12 Dec 2023AY 2008-09

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite

Section 143(2)Section 143(3)

shifted its Vicks Vaporub Unit located at Honda to Kundiam during the financial year 2003-04. Further, as per the enquiries conducted by the Investigation Wing of the Department, the Assessing Officer got to know that some of the assets were left behind. Since the aforesaid assets worth ... found acceptable on the basis of detailed factual analysis and concrete evidence and spot survey in industrial undertaking located at Goa by the investigation wing Belgaum which had established beyond doubt that the assessee’s claim of deduction u/s 80IB for its manufacturing of ultra whisper E-line was factually

Procter & Gamble Hygine & Health Care Ltd, Mumbai vs. Addl CIT Cir 8(2), Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 1735/MUM/2013[2008-09]Status: DisposedITAT Mumbai12 Dec 2023AY 2008-09

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite

Section 143(2)Section 143(3)

Addl CIT RG 8(2), Mumbai vs. Proctor & Gamble Hyginene & Health Care Ltd, Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 3566/MUM/2012[2007-08]Status: DisposedITAT Mumbai12 Dec 2023AY 2007-08

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite

Section 143(2)Section 143(3)

Procter & Gamble Hygiene & Health Care Ltd, Mumbai vs. Addl CIT Cir 8(2), Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 3518/MUM/2012[2007-08]Status: DisposedITAT Mumbai12 Dec 2023AY 2007-08

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite

Section 143(2)Section 143(3)

Procter & Gamble Hygiene & Health Care Ltd., Mumbai vs. Addl.C.I.T. Cir. 8(2), Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 2277/MUM/2012[2006-07]Status: DisposedITAT Mumbai12 Dec 2023AY 2006-07

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite

Section 143(2)Section 143(3)

Addl CIT RG 8(2), Mumbai vs. Proctor & Gamble Hygiene & Health Care Ltd, Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 2167/MUM/2012[2006-07]Status: DisposedITAT Mumbai12 Dec 2023AY 2006-07

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite

Section 143(2)Section 143(3)

Chandra Pal, New Delhi vs. ACIT, Central Circle-II, Noida

In the result, appeal of the assessee is allowed

ITA 981/DEL/2023[2020-21]Status: DisposedITAT Delhi12 Dec 2023AY 2020-21

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2020-21 Chandra Pal Vs. Acit, C-8/8787, Central Circle-11, Vasant Kunj, Noida, 2Nd Floor, Arto New Delhi – 110 070 Complex, Sector-33, Pan Ainpp1209K Noida Uttar Pradesh 201301 (Appellant) (Respondent)

For Appellant: Shri Harish Choudhary, CAFor Respondent: Shri T. James Singson, CIT-DR

Section 132Section 132(4)Section 153ASection 250Section 69C

Hence, liable to be deleted. 2. That having regards to the facts and circumstance to the case the alleged investigation carried out by the investigation wing of the Income Tax Department were carried out at the back of the appellant and Ld CIT(A) has neither brought any material, statement

Nitin A. Shah, Mumbai vs. ITO, 19(2)(4), Mumbai

ITA 667/MUM/2023[ 2007-08]Status: DisposedITAT Mumbai11 Dec 2023

For Appellant: Shri Tushar NagoriFor Respondent: Shri S.K. Jain

Section 143(3)Section 147Section 148Section 68

From the above facts, it is clear that the Assessing Officer had reopened the assessment on the basis of specific information received from Investigation Wing, Mumbai to the effect that the assessee had taken accommodation entries in nature of unsecured loan of Rs.49,83,000/-. This was sufficient reason

Daksha Bharadwaj, New Delhi vs. ACIT, Central Circle-6, New Delhi

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

ITA 7747/DEL/2018[2014-15]Status: DisposedITAT Delhi11 Dec 2023AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Anubhav Sharmaassessment Year: 2014-15 Daksha Bharadwaj, Vs Acit, C-58, Defence Colony, Central Circle-6, New Delhi – 110 024. New Delhi. Pan: Afgpb6995N (Appellant) (Respondent) Assessee By : Shri Satyen Sethi & Shri A.T. Panda, Advocates Revenue By : Shri T. James Singson, Cit, Dr Date Of Hearing : 13.09.2023 Date Of Pronouncement : 11.12.2023

For Appellant: Shri Satyen Sethi &For Respondent: Shri T. James Singson, CIT, DR

Section 132Section 143(3)Section 153CSection 243ASection 271

this ground is that admittedly, the search and seizure operation u/s 132 of the Act was carried out on Three C Group by the Investigation Wing on 29.10.2013 and one Shri Vidur Bhardwaj, who is son of the assessee/appellant was one of the persons covered in the search on this