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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

Ami Deepak Shah, Mumbai vs. National Faceless Appeal, Delhi

In the result, all the six appeals filed by the assessee are allowed as indicated above for statistical purposes

ITA 2629/MUM/2023[2011-12]Status: DisposedITAT Mumbai20 Nov 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Rajiv Khandelwal &For Respondent: Shri Manoj Kumar Sinha, DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 80I

return was processed under Section 143(1) of the Income-tax Act, 1961 (the Act). 05. Subsequently, information was received from DDIT, Investigation Wing, Unit 4(4), Mumbai, vide letter dated 4th March, 2016, wherein information received from Dy. Director of Central Excise, Mumbai shows that M/s Amardip Design being

Ami Deepak Shah, Mumbai vs. National Faceless Appeal, Delhi

In the result, all the six appeals filed by the assessee are allowed as indicated above for statistical purposes

ITA 2627/MUM/2023[2012-13]Status: DisposedITAT Mumbai20 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Rajiv Khandelwal &For Respondent: Shri Manoj Kumar Sinha, DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 80I

return was processed under Section 143(1) of the Income-tax Act, 1961 (the Act). 05. Subsequently, information was received from DDIT, Investigation Wing, Unit 4(4), Mumbai, vide letter dated 4th March, 2016, wherein information received from Dy. Director of Central Excise, Mumbai shows that M/s Amardip Design being

Sajjan Kedia, Mumbai vs. ITO Ward 30(3)(2), Mumbai

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

ITA 2557/MUM/2023[2014-15]Status: DisposedITAT Mumbai20 Nov 2023AY 2014-15

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Appellant: Shri Joginder Singh, Sr. DR
Section 131Section 68Section 69C

during the course of assessment made addition towards sale of shares under section 68 for the reason that the scrip has been identified by Investigation Wing of the Department to be one of the scrip used for obtaining bogus LTCG. The ld. CIT(A) had issued notices on 8 occasions ... also contended in the grounds before the CIT(A) that the AO has made the addition merely based on the findings of the Investigation Wing and that the report did not impute the assessee and that the AO failed to make further enquires. 8. In our considered view the contentions

Atul Shamji Bharani, Mumbai vs. DCIT CC- 4(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 2021/MUM/2023[2012-13]Status: DisposedITAT Mumbai20 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Vinod Kumar Bindal a/wFor Respondent: Shri Ajay Chandra
Section 10(38)Section 132Section 143(1)Section 143(2)Section 143(3)Section 153ASection 250Section 68Section 69C

order passed under section 143(3) read with section 153A of the Act, we find that the AO placed reliance upon the report of Investigation Wing, Kolkata wherein the scrip, i.e. M/s DB International Stock Brokers Ltd was found to be used for providing bogus accommodation entry of long term ... related persons. It is evident from the record that the information relied upon by the AO is pursuant to the investigation by the Investigation Wing, Kolkata, which is much prior to the date of search, i.e. 06/10/2017, in the present case and the same cannot definitely be called

Erstwhile Achiever'S International, New Delhi vs. ITO Ward 34(5), New Delhi

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

ITA 2063/DEL/2023[2012-13]Status: DisposedITAT Delhi20 Nov 2023AY 2012-13

Bench: Sh. Shamim Yahya & Shri Kul Bharaterstwhile Achiever’S Vs. Ito International, 28, Malka Ward – 34(5) Ganj Road, Jawahar Nagar, New Delhi New Delhi-110 007 Pan No. Aakfa 9671 P (Appellant) (Respondent) Assessee By -None Revenue By Shri Vivek Kumar Upadhyay, Sr. D.R. Date Of Hearing: 16.11.2023 Date Of Pronouncement: 20.11.2023

Section 144Section 147

justified in confirming the initiation of the firm's reassessment proceedings by the Ld. AO, based on the report of the Investigation Wing, New Delhi, without conducting an independent enquiry before recording satisfaction and the reasons to believe that income had escaped assessment and also on the basis of permission

Rajkumar Goyal, Indore vs. The Pr. CIT-2, Indore

In the result, appeal of the assesse is dismissed

ITA 438/IND/2019[2014-15]Status: DisposedITAT Indore20 Nov 2023AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniraj Kumar Goyal Pr. Cit-2 42, Narmda Marg Barwaha Indore Vs. Khargone (Appellant / Assessee) (Revenue) Pan: Ackpg 1896N Assessee By Shri Ram Gilda, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 27.09.2023 Date Of Pronouncement 20.11.2023

Section 133ASection 139(1)Section 143(3)Section 263

provisions of the Act. He has further submitted that the AO has also not considered survey report and material sent by the investigation wing Khargone while passing assessment order. No inquiry was conducted by the AO in the light of the survey report and therefore, the order ... request made after filing this appeal before the Tribunal. Therefore, the said letter of the AO giving details of the report of the Investigation Wing Nagpur received by the AO would not epso facto lead to the conclusion that the said report was considered by the AO while passing

D V Properties Pvt. Ltd, Surat vs. Dy. Commissioner of Income Tax, CC-1(1)(1), Surat

ITA 519/SRT/2023[2015-16]Status: DisposedITAT Surat20 Nov 2023AY 2015-16

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.519/Srt/2023 (Ay 2015-16) (Hearing In Physical Court) D.V. Properties Pvt, Ltd. Deputy Commissioner Of 748-749 Golden Plaza Market, Income Tax, Circle-1(1)(1) Vs Ring Road, Surat-395002 Surat, Aaykar Bhavan, Nr. Pan No. Aaacd 8392 B Majura Gate, Opp. New Civil Hospital, Surat-395001 अपीलाथ"/Appellant ""थ" /Respondent

Section 133(6)Section 143(2)Section 143(3)Section 254(1)Section 69C

company” as per information available with the Department. The Assessing Officer recorded the modus operandi of entry provider and the statement recorded by the Investigation Wing against such entry provider. The Assessing Office also extracted the statement of Shri Manohar Lal Nanglia, who was allegedly controlling lender and other companies ... companies managed and controlled by said Manohar Lal Nanglia. The Assessing Officer after recording such modus operandi and part of investigation carried out by Investigation Wing issued detailed show cause notice as to why such unsecured loan should not be treated as accommodation entry and commission @ 2% of such entry

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 718/MUM/2021[2016-17]Status: DisposedITAT Mumbai17 Nov 2023AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

books of accounts of the assessee and merely the sole reliance on the statement of third party as well as the report of investigation wing without making any further enquiry and issuing any summons and also without affording any opportunity of cross examination to the assessee of those parties

Mohan Thankurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 713/MUM/2021[2015-16]Status: DisposedITAT Mumbai17 Nov 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

books of accounts of the assessee and merely the sole reliance on the statement of third party as well as the report of investigation wing without making any further enquiry and issuing any summons and also without affording any opportunity of cross examination to the assessee of those parties

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 712/MUM/2021[2013-14]Status: DisposedITAT Mumbai17 Nov 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

books of accounts of the assessee and merely the sole reliance on the statement of third party as well as the report of investigation wing without making any further enquiry and issuing any summons and also without affording any opportunity of cross examination to the assessee of those parties

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 711/MUM/2021[2012-13]Status: DisposedITAT Mumbai17 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

books of accounts of the assessee and merely the sole reliance on the statement of third party as well as the report of investigation wing without making any further enquiry and issuing any summons and also without affording any opportunity of cross examination to the assessee of those parties

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 710/MUM/2021[2011-12]Status: DisposedITAT Mumbai17 Nov 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

books of accounts of the assessee and merely the sole reliance on the statement of third party as well as the report of investigation wing without making any further enquiry and issuing any summons and also without affording any opportunity of cross examination to the assessee of those parties

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 709/MUM/2021[2014-15]Status: DisposedITAT Mumbai17 Nov 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

books of accounts of the assessee and merely the sole reliance on the statement of third party as well as the report of investigation wing without making any further enquiry and issuing any summons and also without affording any opportunity of cross examination to the assessee of those parties

Mohan Gurnani, Navi Mumbai vs. DCIT Central Cirle - 5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 2089/MUM/2021[2010-11]Status: DisposedITAT Mumbai17 Nov 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

books of accounts of the assessee and merely the sole reliance on the statement of third party as well as the report of investigation wing without making any further enquiry and issuing any summons and also without affording any opportunity of cross examination to the assessee of those parties

ACIT, Circle-8(2), New Delhi vs. Ecocat India Pvt. Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 8521/DEL/2019[2014-15]Status: DisposedITAT Delhi17 Nov 2023AY 2014-15

Bench: Shri Challa Nagendra Prasada N D Shri M. Balaganesh

For Appellant: Shri R.K. Raghvan, Adv.; &
Section 115JSection 143(3)Section 35Section 37(1)Section 6Section 68

relevant documents before the Assessing Officer to prove the identity, creditworthiness and genuineness of the transaction. The Assessing Officer also issued commission to DDIT (Investigation Wing) Kolkata to verify the identity, creditworthiness and genuineness of the creditor company. The loan creditor M/s. B. D. Vanijya Udyog Pvt. Ltd., submitted relevant ... papers before the DDIT (Investigation Wing) Kolkata and this fact was also brought to the notice of the Assessing Officer by the assessee and submitted that it has received loan from M/s. B. D. Vanijya Udyog Pvt. Ltd. and said company has produced all the relevant documents to prove

Sarika Dugar, Kolkata vs. ITO, Kolkata

In the result, appeal of the assessee is partly allowed

ITA 363/KOL/2023[2013-14]Status: DisposedITAT Kolkata16 Nov 2023AY 2013-14

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Ble

For Appellant: Shri Chirag Desai, Office staff on behalf of Miraj D. Shah, A/RFor Respondent: Shri B.K. Singh, JCIT, Sr. D/R
Section 10(38)Section 143(3)Section 148Section 250Section 271(1)(c)Section 275Section 275(1)(c)

claimed the said exemption. Now, post filing of income tax return, there were certain information available with the Income tax department through its investigation wing along with information received through SEBI about few companies which were indulged in providing accommodation entries and were said to be penny stock companies. Such

The Hamlet, Bangalore vs. The Income-Tax Officer-Ward-6(2)(4), Bangalore

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

ITA 70/BANG/2023[2012-13]Status: DisposedITAT Bangalore16 Nov 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2012-13 M/S. The Hamlet, No. 11, Kemwell House, The Income Tax Tumkur Road, Officer, Yeshwanthpur, Ward – 6(2)(4), Bangalore – 560 022. Bangalore. Vs. Pan: Aaaft6690D Appellant Respondent Assessee By : Shri H.N. Kincha, Ca : Shri D.K. Mishra, Cit - Revenue By Dr Date Of Hearing : 24-08-2023 Date Of Pronouncement : 16-11-2023 Order Per Beena Pillaipresent Appeal Arises Out Of The Order Dated 27.12.2022 Passed By The Nfac, Delhi For A.Y. 2012-13 On Following Grounds Of Appeal: “1. The Learned Commissioner Of Income Tax (Appeals) Has Erred In Passing The Appellate Order In The Manner Passed. The Appellate Order As Passed Is Bad In Law & Is Liable To Be Quashed. 2. In Any Case, The Learned Commissioner Of Income Tax (Appeals) Has Erred In Confirming The Assessment Order Passed By The Learned Assessing Officer. On The Facts & Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeals) Should Have Quashed, The Order Passed By Assessing Officer Or Atleast Should Have Deleted The Additions Made By The Assessing Officer.

For Appellant: Shri H.N. Kincha, CA
Section 133(6)Section 148Section 234BSection 68

Kemwell Biopharma Pvt. Ltd. for an amount of Rs 3 crores approximately. It is further recorded in the reasons for reopening that, the DDIT, Investigation Wing informed the Ld.AO regarding M/s. Newedge Realtors Pvt. Ltd. to be a shell company and engaged in providing accommodation entries in the form ... 2513/Bang/2018 Page 15 of 52 M/s. The Hamlet, Bangalore 3.8. The Ld. DR on the contrary submitted that, there was material received from the investigation wing to form a reasonable belief and that there was live link between the information received and the sale transaction between the assessee

The Assistant Commissioner of Income Tax, Central Circle, Rajkot vs. Smt. Urmilaben Kishorbhai Viramgama, Rajkot

ITA 66/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

brief facts leading to this case it this that a survey was carried out at the premises of M/s. Raghuvir Group by the Investigation Wing, Vadodara on 27.12.2018. During the course of survey proceeding, certain documents were found and impounded from the said office premises at Ahmedabad out of with ... assessment on surmises and conjecture basis. ITA Nos. 22/Rjt/2021 & 12 Ors. (Smt. Bhavnaben B. Rangani & Ors. - 16 - During the course of Survey Proceedings, the Investigation Wing has found the MOU i.e. Agreement of Sale Page 55 to 60 of the Annexure -1 amounting to Rs.38,00,00,000/- which

Maulesh D. Ukani, Rajkot-Gujarat vs. The Asstt. Commr. of Income Tax, Cir-1(1), Rajkot-Gujarat

ITA 46/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

brief facts leading to this case it this that a survey was carried out at the premises of M/s. Raghuvir Group by the Investigation Wing, Vadodara on 27.12.2018. During the course of survey proceeding, certain documents were found and impounded from the said office premises at Ahmedabad out of with ... assessment on surmises and conjecture basis. ITA Nos. 22/Rjt/2021 & 12 Ors. (Smt. Bhavnaben B. Rangani & Ors. - 16 - During the course of Survey Proceedings, the Investigation Wing has found the MOU i.e. Agreement of Sale Page 55 to 60 of the Annexure -1 amounting to Rs.38,00,00,000/- which

The Asstt. Commr. of Income Tax, Cen. Cir-1, Rajkot-Gujarat vs. Maulesh D. Ukani, Rajkot-Gujarat

ITA 44/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

brief facts leading to this case it this that a survey was carried out at the premises of M/s. Raghuvir Group by the Investigation Wing, Vadodara on 27.12.2018. During the course of survey proceeding, certain documents were found and impounded from the said office premises at Ahmedabad out of with ... assessment on surmises and conjecture basis. ITA Nos. 22/Rjt/2021 & 12 Ors. (Smt. Bhavnaben B. Rangani & Ors. - 16 - During the course of Survey Proceedings, the Investigation Wing has found the MOU i.e. Agreement of Sale Page 55 to 60 of the Annexure -1 amounting to Rs.38,00,00,000/- which