“investigation wing”

ReassessmentSection 147Section 14712,584 judgments

The decision most relied on for investigation wing is Sarthak Securities Co. Pvt. Ltd. v. ITO (329 ITR 110), cited in 217 judgments on BharatTax.

Leading authorities on investigation wing

Sarthak Securities Co. Pvt. Ltd. v. ITO

329 ITR 110 · 2010 · High Court

217

citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

ITO, 19(3) (4) Mumbai v. Shamim M Bharwani

69 Taxmann.com 65 · 2016 · Reported

142

citing judgments

Long Term Capital Gains (LTCG) from penny stock transactions are liable to be treated as bogus and added back under Section 68 as unexplained cash credits, especially when evidence suggests the involvement of entry operators providing accommodation entries.

1. Harikishan S. Virmani v. DCIT

394 ITR 146 · 2017 · High Court

citing judgments

Reassessment proceedings under section 147 cannot be initiated by the Assessing Officer based on borrowed satisfaction, vague information from the Investigation Wing, or incorrect jurisdictional facts without independent application of mind. Reopening beyond four years from the end of the relevant assessment year, especially where an original assessment was completed under section 143(3), requires specific conditions relating to the assessee's failure to disclose material facts.

PCIT v. M/s. Kesoram Industries 57

417 ITR 334 · 2019 · High Court

citing judgments

An assessment completed under Section 143(3) cannot be reopened after four years solely based on third-party information or opinions, such as from an Investigation Wing, without the Assessing Officer applying their own independent mind to the material and having new, independent material on record.

ITO v. Purushottam Das Bangur

224 ITR 362 · 1997 · Supreme Court

citing judgments

Information received from the investigation wing constitutes valid 'reason to believe' for initiating reassessment proceedings under Sections 147/148, provided the Assessing Officer applies their mind to the material and does not act mechanically. Prompt issuance of a notice based on such information does not automatically imply a lack of due diligence or borrowed satisfaction.

AGR Investment v. Additional Commissioner

197 Taxmann 177 · 2011 · High Court

citing judgments

A reassessment under Section 147/148 is valid if initiated based on specific, non-vague information, even from an investigation wing, provided the Assessing Officer applies independent mind to form a 'reason to believe' that income has escaped assessment.

56 (Guj.) (para 6) v. Aaspas Multimedia Ltd. v. Dy. CIT

83 Taxmann.com 82 · 2017 · High Court

citing judgments

Information received from the Investigation Wing, identifying the assessee as a beneficiary of accommodation entries through share application from a third party, constitutes valid tangible material and 'reasons to believe' for initiating reassessment proceedings under Section 147 of the Income Tax Act.

Aradhna Estate Pvt. Ltd. v. DCIT

91 Taxmann.com 119 · 2018 · High Court

citing judgments

The Assessing Officer is justified in reopening assessment proceedings based on information received from the Investigation Wing, even when recording findings also rely on documents already on record, provided all procedural requirements for reassessment are met.

Judgments citing investigation wing

Alang Steel Recycling Private Limited, Bhavnagar vs. The Pr. CIT-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1605/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

Section 263Section 37Section 69C

Pr.CIT A.Y: 2018-19 the total income at ₹88,37,215/-. The case was reopened on the basis of information received from the investigation wing alleging that the assessee had availed bogus purchase bills through Shri Gurukamal Singh, proprietor of M/s Preet Enterprise, operating through multiple entities. It was alleged

Sudheer Chirania, Mumbai vs. The Income Tax Officer, Ward - 23(3)(7), Mumbai

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

ITA 5263/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Jan 2026AY 2012-13

Bench: Shri Saktijit Dey & Shri Jagadishassessment Year: 2012-13

For Appellant: Ms. Simran Dhawan & Mr. RaviFor Respondent: Shri Arun Kanti Datta, CIT DR

Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 68Section 69C

capital gains (LTCG). The return was processed under section 143(1). 3. Subsequently, the AO reopened the assessment based on information received from the Investigation Wing alleging that the assessee was a beneficiary of accommodation entries through trading in shares of M/s Tilak Venture Limited, alleged to be a penny ... Income Tax (Appeals) has erred in confirming the additions made by the Assessing Officer, solely based on the generic information received from the investigation wing, not specific to appellant, without carrying out independent enquiries to establish complicity of the appellant or her broker in particular, with the allegations as made

Atul Agarwal, New Dev Puri, Bhatipura, Meerut vs. Income Tax Officer, Meerut

In the result, appeal of the assessee in ITA No

ITA 3756/DEL/2025[2018-19]Status: DisposedITAT Delhi16 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Animesh Vashisth, AdvFor Respondent: Shri Sumer Singh Meena, CIT- DR

Section 147Section 148Section 153ASection 153CSection 44A

44AD of the Income-tax Act, 1961 [the Act, for short] @ 8%. On the basis of information received from Investigation wing that during search and seizure operation in the case of Alankrit group, evidence was recovered that assessee had received unaccounted cash of Rs 1,60,11,223/- and made

Horizon Buildmart Pvt Ltd, Gurgaon vs. ACIT, Circle-2, Faridabad

In the result, the appeal of the Assessee is partly allowed

ITA 1250/DEL/2025[2011-12]Status: DisposedITAT Delhi16 Jan 2026AY 2011-12

Bench: Shri Sudhir Kumar & Shri Manish Agarwalhorizon Buildmart Pvt. Ltd., Asst. Cit, C-131, Ground Floor, Block-C, Central Circle-Ii, Sushant Shopping Arcade, Vs. Faridabad, Sushant Lok-1, Haryana-121001. Gurgaon-122002. Pan-Aacch4582P (Appellant) (Respondent) Shri S.S. Nagar, Ca Assessee By Department By Ms. Amisha S. Gupta, Cit Dr Date Of Hearing 03/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon (‘Ld. Cit(A)’ In Short) Dated 27.01.2025 In Appeal No.10581/Cit(A) Ggn-3/2018-19 For Assessment Year 2011-12 Arising Out Of The Order Passed U/S 147 R.W.S 144 Of The Income Tax Act, 1961 (‘The Act’ For Short) Dated 28.12.2018. 2. Brief Facts Of The Case Are That Assessee Is Private Limited Company Engaged In The Business Of Real Estate. The Assessee Filed Its Return Of Income On 30.09.2011 Declaring A Loss Of Rs.54,833/-. The Ao Had Information That Assessee Received Loan Horizon Buildmart Pvt. Ltd. Vs. Acit

Section 143(2)Section 147Section 148Section 153C

reasons recorded, which are available at PB pages 15 to 19, it could be seen that AO simply reproduced the information received from Investigation Wing, Faridabad and had not applied his mind to find out the real nature of transaction. He drew our attention to the facts that ... revealed that assessee was major beneficiary of accommodation entry operations carried on by 'J' and ‘N’ - Assessing Officer, also received information from investigation wing that assessee had purchased penny scrips- Assessing Officer, based on information issued reopening notice and thereafter made additions under section 68 - Tribunal held that Assessing Officer

Assistant Commissioner of Income Tax, New Delhi vs. Jalco Financial Services Private Limited, New Delhi

The appeal is dismissed

ITA 4209/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveenc Chandraacit, Vs. Jalco Financial Services Room No. 316A, C.R. Private Limited Building, I.P. Estate, K-7B, Ground Floor, New Delhi – 110002 Kalkaji, New Delhi – 110019 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaacj2791E Appellant .. Respondent

For Appellant: Sh. MayankPatawari, AdvFor Respondent: Sh. Om Prakash, Sr. DR

Section 143(1)Section 143(3)Section 15HSection 37Section 37(1)Section 68

that the appellant was also found to be one of the beneficiaries of accommodation entries as per the list provided by the Investigation Wing. The AO acknowledges the response filed by M/s FairlinkCommotradePvt. Ltd.(‘FCPL”) towards P a g e | 9 Jalco Financial Services Pvt. Ltd.(AY: 2017-18) notice ... However, the AO did not accept the credits as explained for want of ITR and by relying on the information so provided by the investigation wing. 4.2.5 The appellant, on the other hand, submitted that it had received the impugned amount from FCPL on behalf of M/s Pioneer Deal Trade

Zia Rathi, Delhi vs. Income Tax Officer Ward-44(3), Delhi

In the result, appeal filed by the assessee is allowed

ITA 1881/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwalmrs. Zia Rathi, Income Tax Officer, 274, Dda Flats, Sector-1A, Ward-44(3), Dwarka Nasirpur, Vs. Delhi. New Delhi-110045. Pan-Bsvpr9218M (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv. Shri Somil Agarwal, Adv. Shri Saksham Agarwal, Ca & Shri Deepesh Garg, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 04/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax, National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 27.02.2024 In Appeal No. Cit(A), Delhi- 15/11146/2019-20 Arising Out Of The Order Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’ For Short) For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is Sole Proprietor Of M/S Veezee Traders Engaged In The Business Of Trading Of Pvc Coated Imported Fabric. The Zia Rathi Vs. Ito

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 234BSection 68

amount only. 2. Ld. AO has mentioned in para 2.4 at page number 5 of the assessment order that assessee was also examined by Investigation Wing of the Department wherein it has been found that assesse had stopped the business in mid of Oct 2016 and she failed to demonstrate ... accumulated cash in hand just before demonetization. PB 430-431 is the copy of assessee’s reply dated 06.07.2018 submitting the above facts before Investigation Wing, Unit-7. 3. Ld. AO has mentioned in para 2.5 at page number 6 of the assessment order that assessee has no explanation

Bg Steel Private Limited, Bhiwadi vs. Income Tax Officer, Delhi

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

ITA 6255/DEL/2025[2012-13]Status: DisposedITAT Delhi14 Jan 2026AY 2012-13

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Vishu Arora, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 133(6)Section 143(1)Section 148Section 234BSection 250Section 6Section 68

income of Rs. 38,34,130/- and the case was processed u/s 143(1) of the Act. Subsequently, on receipt of information from the Investigation Wing, regarding the share application money and share premium received by the assessee from certain paper/shell companies, the case was re-opened and a notice

Naresh Arora, Gurgaon vs. DCIT, Central Circle-31, Delhi

In the result, both the appeals filed by the assessees are allowed

ITA 3144/DEL/2025[2021-22]Status: DisposedITAT Delhi14 Jan 2026AY 2021-22

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumararti Garg, Vs. Dcit, Central Circle 31, A – 19, Guru Ram Dass Nagar, Delhi. Laxmi Nagar, Delhi – 110 092. (Pan : Akupg4398A) Naresh Arora, Vs. Dcit, Central Circle 31, A-061, 6Th Floor, Spaze Privy, Delhi. Sector 72, Sohna Road, Gurgaon – 122 001 (Haryana). (Pan : Aacpa3657P) (Appellant) (Respondent) Assessee By : Shri Saubhagya Agarwal, Advocate Shri Vaibhav Srivastava, Advocate Revenue By : Shri Dayainder Singh Sidhu, Cit Dr Date Of Hearing : 29.10.2025 Date Of Order : 14.01.2026

For Appellant: Shri Saubhagya Agarwal, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CIT DR

Section 65BSection 69Section 69C

seizure operation leading to recovery of the mobile of Praveen Kumar Jain on 07.01.2021, the master copy and working copy were analysed by the investigation wing and how the same reached in the hands of the AO so as to have enabled the AO to take out and retrieve

Arit Garg, Delhi vs. DCIT, Central Circle-31, Delhi

In the result, both the appeals filed by the assessees are allowed

ITA 3143/DEL/2025[2021-22]Status: DisposedITAT Delhi14 Jan 2026AY 2021-22

For Appellant: Shri Saubhagya Agarwal, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CIT DR

Section 65BSection 69Section 69C

R.N. Khemka Enterprises (P) Ltd., Delhi vs. ITO, Ward- 20(3), New Delhi

In the result, assessee’s appeal is allowed

ITA 6016/DEL/2018[2007-08]Status: DisposedITAT Delhi14 Jan 2026AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shuklaassessment Year: 2007-08

Section 133(6)Section 139Section 143(3)Section 147Section 148Section 151

referred the annexures and relevant pages in the last column, we find that the data mentioned has been reproduced from the Investigation Wing information and as such no discussion is forthcoming in the reasons recorded as to what was actually revealed from the seized annexures and referred pages. Had there ... been independent verification based on the contended information of the Investigation Wing, there had been proper discussion between the finding of examination of those annexures referred in page 258 being part of the reasons recorded by the Ld. AO. In the absence of examination of any such seized material

Deputy Commissioner of Income Tax, Indore vs. Ferro Concrete Con India Pvt. Ltd., Indore

Appeal is allowed for statistical purpose

ITA 111/IND/2025[2019-20]Status: DisposedITAT Indore13 Jan 2026AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri B.M. Biyaniassessment Year:2019-20 Deputy Commissioner Of Ferro Concrete Con India Income-Tax Pvt. Ltd., बनाम/ 3/5/7B, Bhagirathpura Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aaacf2726K Revenueby Shri Ashish Porwal, Sr. Dr Assessee By Shri Venus Rawka, Ar Date Of Hearing 17.12.2025 Date Of Pronouncement 13.01.2026

Section 115BSection 139Section 143(2)Section 147Section 148Section 69

concerned, it is clear that reopening of assessment of Appellant was done merely on the basis of information received from the Investigation Wing after carrying out the search and seizure operation in the case of Bansal Group. It is observed that A.O has concluded the re-assessment proceedings by making

Simatajvar Yusufkhan Khan, Vadodara vs. Income Tax Officer, Ward-3(1)(5), Vadodara

In the result, all four appeals filed by the assessee are dismissed

ITA 243/AHD/2022[2014-15]Status: DisposedITAT Ahmedabad13 Jan 2026AY 2014-15

Bench: Us Is The Same, Arising In The Backdrop Of Identical Set Of Facts, Therefore, All The Appeals Were Taken Up Together For Hearing & Are Being Disposed Of Vide This Common & Consolidated Order.

For Appellant: Ms. Kaushani Shah, ARFor Respondent: Shri Abhijit, Sr.DR

Section 147Section 148Section 148(2)Section 250Section 56(2)(vii)

Majid Shaikh (purchaser) for a land bearing Survey Nos. 506, 507 and 508 at Village Abhwa, Tal. Choryasi, District Surat. The report of the Investigation Wing of the department revealed that as per the MOU the entire deal was of Rs.151 Crores. Accordingly, the AO formed reason to believe that ... crores as a cost of acquisition by the ultimate owners. The AO may look into this aspect also, and refer the matter to the Investigation Wing for further inquiries, if it is deemed fit. Hence, it is concluded that the appellant has received the amounts due to the disputes between

Simatajvar Yusufkhan Khan, Vadodara vs. Income Tax Officer, Ward-3(1)(5), Vadodara

In the result, all four appeals filed by the assessee are dismissed

ITA 242/AHD/2022[2013-14]Status: DisposedITAT Ahmedabad13 Jan 2026AY 2013-14

Bench: Us Is The Same, Arising In The Backdrop Of Identical Set Of Facts, Therefore, All The Appeals Were Taken Up Together For Hearing & Are Being Disposed Of Vide This Common & Consolidated Order.

For Appellant: Ms. Kaushani Shah, ARFor Respondent: Shri Abhijit, Sr.DR

Section 147Section 148Section 148(2)Section 250Section 56(2)(vii)

Simatajvar Yusufkhan Khan, Vadodara vs. Income Tax Officer, Ward-3(1(5), Vadodara

In the result, all four appeals filed by the assessee are dismissed

ITA 241/AHD/2022[2010-11]Status: DisposedITAT Ahmedabad13 Jan 2026AY 2010-11

Bench: Us Is The Same, Arising In The Backdrop Of Identical Set Of Facts, Therefore, All The Appeals Were Taken Up Together For Hearing & Are Being Disposed Of Vide This Common & Consolidated Order.

For Appellant: Ms. Kaushani Shah, ARFor Respondent: Shri Abhijit, Sr.DR

Section 147Section 148Section 148(2)Section 250Section 56(2)(vii)

Simatajvar Yusufkhan Khan, Vadodara vs. Income Tax Officer, Ward- 3(1(5, Vadodara

In the result, all four appeals filed by the assessee are dismissed

ITA 240/AHD/2022[2009-10]Status: DisposedITAT Ahmedabad13 Jan 2026AY 2009-10

Bench: Us Is The Same, Arising In The Backdrop Of Identical Set Of Facts, Therefore, All The Appeals Were Taken Up Together For Hearing & Are Being Disposed Of Vide This Common & Consolidated Order.

For Appellant: Ms. Kaushani Shah, ARFor Respondent: Shri Abhijit, Sr.DR

Section 147Section 148Section 148(2)Section 250Section 56(2)(vii)

Nezone Tubes Limited, Kolkata vs. DCIT, Circle 1(1), Kolkata

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

ITA 180/KOL/2025[2015-16]Status: DisposedITAT Kolkata13 Jan 2026AY 2015-16

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 144BSection 147Section 148ASection 149(1)Section 250Section 251(1)(a)Section 68

returned income of the assessee at ₹8,75,36,420/-. The assessment was reopened on the basis of information received from the Investigation Wing that a sum of ₹42,61,133/- was received from Ambika Ispat Udyog as accommodation entry without delivering any goods. During the course of the reassessment ... returned income of the assessee. Subsequently, the case of the appellant company was reopened on 31.03.2018 on the basis of information received from the investigation wing that a sum of Rs. 42,61,133/- received from Ambika Ispat Udyog as accommodation entry without delivered any goods. The assessing officer passed

Nezone Tubes Limited, Kolkata vs. DCIT, Circle 1(1), Kolkata

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

ITA 179/KOL/2025[2011-12]Status: DisposedITAT Kolkata13 Jan 2026AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 144BSection 147Section 148ASection 149(1)Section 250Section 251(1)(a)Section 68

M/S. Sagun Sales Pvt. Ltd., Kolkata vs. I.T.O., Ward - 4(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 1194/KOL/2024[2011-2012]Status: DisposedITAT Kolkata13 Jan 2026AY 2011-2012

Bench: Shri George Mathan

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Abhijit Adhikary, Sr. DR

Section 147Section 148

submissions. Admittedly, as it is noticed that there is no independent enquiry in regard to the information received by the AO from the ITO (Investigation Wing) and as no clear live link has been shown between the said information on the assessee, respectfully following the decision

M/S. Aryan Share and Stock Brockers Limited, Chennai vs. ITO, Corp Ward-1, Chennai

In the result, Appeal filed by the assessee is allowed

ITA 2115/CHNY/2025[2014-15]Status: DisposedITAT Chennai13 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No. 2115/Chny/2025 "नधा"रण वष"/Assessment Year: 2014-15 M/S Aryan Share & Stock Brokers V. Ito Corp Ward-1, Limited., Itd, M G Road, No. 07, 07Th Cross Street, Nungambakkam, 2Nd Floor, Shreeji Metropolis, Chennai-600034 Aminjikarai, Chennai-600030 Tamil Nadu Tamil Nadu [Pan:Aadca 1233 H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Assessee By : Mr. Y Sridhar, Ca ""यथ" क" ओर से /Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 10.11.2025 घोषणा क" तार"ख /Date Of Pronouncement : 13.01.2026

For Appellant: Mr. Y Sridhar, CAFor Respondent: Ms. Anitha, Addl.CIT

Section 147Section 69A

section 147 of the Income Tax Act. 4. The Id CIT (A) ought to have appreciated the fact that mere information received from investigation wing cannot constitute valid reasons for initiating reassessment proceedings in the absence of anything to show that the AO had independently applied his mind to arrive ... 30/9/2014 admitting a total income of Rs. 10,81,390/-.The case was reopened u/s 147 based on the information received from the Investigation Wing, Mumbai, that the appellant has incurred fictitious loss in Equity/Derivative trading in the shares of M/s Looks Health Services Ltd and the assessment was completed

Abhishek Jayketu Joshi, Mumbai vs. Ac Cir-42(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5775/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Jan 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarabhishek Jayketu Joshi Ac Cir-42(2)(1), C-73, Venus Society, R. G. Kautilya Bhavan, Thadani Marg, Worli Sea Vs. Mumbai-400 051 Face, Mumbai-400 018 Pan/Gir No. Ackpj8583H (Applicant) (Respondent) Assessee By Shri M. M. Golvala, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 13.01.2026

Section 132Section 132(4)Section 139(1)Section 139(5)Section 143(1)Section 144BSection 147Section 148Section 148ASection 250

Subsequently, the Jurisdictional Assessing Officer received information through the Risk Management Strategy of the Board, based on inputs from the Investigation Wing, pursuant to search and seizure operations under section 132 conducted in the case of certain Registered Unrecognized Political Parties (RUPPs). As per the said information, some political parties ... returned to donors after deducting commission. The Assessing Officer observed that the assessee’s name appeared in the list of beneficiaries identified by the Investigation Wing. The Assessing Officer rejected the assessee’s request for cross-examination of the persons whose statements were relied upon, holding that such cross- examination