← All Phrases

“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
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.

PCIT v. M/s. Kesoram Industries 57
417 ITR 334 · 2019 · High Court
96
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
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.

Aradhna Estate Pvt. Ltd. v. DCIT
91 Taxmann.com 119 · 2018 · High Court
56
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

Hardayal Milk Products Private Limited, Shikohabad vs. DCIT, Circle-2(2)(1), Firozabad

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

ITA 343/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68

which was reported to have been engaged in providing accommodation entries in lieu of cash. Thus, in view of the information/reports of the Investigation Wing, Kolkata, the Assessing Officer made an addition of ₹18,23,00,000/- as unexplained cash credits under Section 68 of the Act and addition ... tantamount to non-application of mind; (c) that the re-assessment is based solely on borrowed 5 satisfaction solely based on information of Investigation Wing without any independent verification; (d) that the information received from DDIT (Inv)-Unit-3, Kolkata, on 08.03.2019, including statements of third parties (Mahendra Kumar Agarwal

Meena Suresh Raithatha, Mumbai vs. ITO Ward 27(2)(1), Mumbai

ITA 4813/MUM/2025[2022-23]Status: DisposedITAT Mumbai29 Dec 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Deepak KanabarFor Respondent: Assessee by
Section 132Section 132(4)Section 143(3)Section 65BSection 69

above grounds of appeal.” 3. Concisely stated, pursuant to a search action u/s 132 of the Act carried out on 03.12.2021, by the Investigation wing of the department in the case of Sangini Group of builders, Surat. Certain information qua the assessee, to enter into a transaction of purchase ... submitted that the addition was made under preconceived mind set by the Ld. AO placing reliance on the findings and information received from Investigation wing. The assessee tried to explain that the allegation was made under wrong inferences and thus cannot survive. Ld. AR made a written submission in support

Ratori Maa Trading P.Ltd, Delhi vs. ITO, Ward-21(1), New Delhi

In the result, the appeal is dismissed

ITA 4485/DEL/2019[2010-11]Status: DisposedITAT Delhi29 Dec 2025AY 2010-11

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandraratori Maa Trading P. Ltd. Vs Ito M-98, 2Nd Floor, Jagat Ward -21(1) Rampark, Laxmi Nagar, New C. R. Building, New Delhi Delhipan: Aaecr0612A Appellant Respondent Assessee By None Revenue By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 18/12/2025 Date Of Pronouncement 29/12/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-7, New Delhi Dated

Section 143(3)Section 147Section 148Section 151

specific transactions, identifying the parties to the transactions, bank account details etc. typical of entry operators providing accommodation entries. The information conveyed by the investigation wing cast a doubt on the money received from the investing companies. When such detailed information came to the possession of the Assessing Officer

Income-Tax Officer - 12(1)(1), Mumbai vs. Blues It Innovations India Private Limited, Mumbai

In the result, the appeal of the assessee is partly allowed and the

ITA 6465/MUM/2025[2011-12]Status: DisposedITAT Mumbai24 Dec 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 143(3)Section 145(3)Section 234ASection 254(1)Section 69C

reassessment can be made just to make an enquiry or verification b. Reassessment proceeding cannot be initiate merely on the information received from investigation wing. c. Reassessment proceeding cannot be initiated when the LD AO have reason to suspect and not reason to believe 8. On the facts ... purchases shown from Banjara Enterprises, Daksh Enterprises and Karan Enterprises. The Assessing Officer while making addition solely relied upon the information received from investigation wing. During the assessment the assessee provided complete details of purchases to substantiate the purchase which includes invoices of purchases, payment proof through account pay cheque

Blues It Innovations India Private Limited, Mumbai vs. ITO - 12(1)(1), Mumbai

In the result, the appeal of the assessee is partly allowed and the

ITA 6300/MUM/2025[2014-15]Status: DisposedITAT Mumbai24 Dec 2025AY 2014-15

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 143(3)Section 145(3)Section 234ASection 254(1)Section 69C

reassessment can be made just to make an enquiry or verification b. Reassessment proceeding cannot be initiate merely on the information received from investigation wing. c. Reassessment proceeding cannot be initiated when the LD AO have reason to suspect and not reason to believe 8. On the facts ... purchases shown from Banjara Enterprises, Daksh Enterprises and Karan Enterprises. The Assessing Officer while making addition solely relied upon the information received from investigation wing. During the assessment the assessee provided complete details of purchases to substantiate the purchase which includes invoices of purchases, payment proof through account pay cheque

Blues It Innovations India Private Limited, Mumbai vs. ITO -12(1)(1), Mumbai

In the result, the appeal of the assessee is partly allowed and the

ITA 6299/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Dec 2025AY 2013-14

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 143(3)Section 145(3)Section 234ASection 254(1)Section 69C

reassessment can be made just to make an enquiry or verification b. Reassessment proceeding cannot be initiate merely on the information received from investigation wing. c. Reassessment proceeding cannot be initiated when the LD AO have reason to suspect and not reason to believe 8. On the facts ... purchases shown from Banjara Enterprises, Daksh Enterprises and Karan Enterprises. The Assessing Officer while making addition solely relied upon the information received from investigation wing. During the assessment the assessee provided complete details of purchases to substantiate the purchase which includes invoices of purchases, payment proof through account pay cheque

Blues It Innovations India Private Limited, Mumbai vs. ITO - 12(1)(1), Mumbai

In the result, the appeal of the assessee is partly allowed and the

ITA 6298/MUM/2025[2012-13]Status: DisposedITAT Mumbai24 Dec 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 143(3)Section 145(3)Section 234ASection 254(1)Section 69C

reassessment can be made just to make an enquiry or verification b. Reassessment proceeding cannot be initiate merely on the information received from investigation wing. c. Reassessment proceeding cannot be initiated when the LD AO have reason to suspect and not reason to believe 8. On the facts ... purchases shown from Banjara Enterprises, Daksh Enterprises and Karan Enterprises. The Assessing Officer while making addition solely relied upon the information received from investigation wing. During the assessment the assessee provided complete details of purchases to substantiate the purchase which includes invoices of purchases, payment proof through account pay cheque

Blues It Innovations India Private Limited, Mumbai vs. ITO - 12(1)(1), Mumbai

In the result, the appeal of the assessee is partly allowed and the

ITA 6297/MUM/2025[2011-12]Status: DisposedITAT Mumbai24 Dec 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 143(3)Section 145(3)Section 234ASection 254(1)Section 69C

reassessment can be made just to make an enquiry or verification b. Reassessment proceeding cannot be initiate merely on the information received from investigation wing. c. Reassessment proceeding cannot be initiated when the LD AO have reason to suspect and not reason to believe 8. On the facts ... purchases shown from Banjara Enterprises, Daksh Enterprises and Karan Enterprises. The Assessing Officer while making addition solely relied upon the information received from investigation wing. During the assessment the assessee provided complete details of purchases to substantiate the purchase which includes invoices of purchases, payment proof through account pay cheque

Sindhumati Ramavtar Pathak, Borivali Mumbai vs. Asst Commissioner of Income Tax 32 3 Mumbai Presently Dy C I T Circle 42 3 1 Mumbai, Mumbai

In the result, Assessee’s appeal is allowed

ITA 4914/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Dec 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Prabhash Shankar (Am) Sindhumati Ramavtar Pathak Acit-32(3) 4, Shree Bhalchandra Kripa Presently Cit, Circle Building, Daulat Nagar Road Vs. 42(3)(1) No. 3, Borivali East Kautilya Bhavan Bkc, Mumbai-400 066. Mumbai-51. Pan : Agbpp5972D Appellant Respondent

For Appellant: Shri Jitendra Singh, Ld. ADVFor Respondent: Ms. Kavitha Kaushik, Ld. DR
Section 10(38)Section 250Section 68Section 69C

Assessee about shares and penny stock companies. (x) Financial analysis of the penny stock companies. (xi) Analysis of transaction and end finding of the investigation wing. 4. The Assessee being aggrieved, challenged the said addition by filling first appeal before the Ld. Commissioner, who though affirmed the addition ... Investigation, Kolkata and the mode of acquisition of the shares by the Assessee and unusual rise in the prices of share, findings of the investigation wing at Mumbai, analysis of transactions, failure of the Assessee to discharge his onus, ignorance of the Assessee about shares and penny stock companies, financial

M/S Adrem India (P) Ltd., South Delh vs. Sh. Anshul, DCIT, Central Circle-20, Delhi

In the result, the appeal of the assessee is accordingly allowed in above terms for statistical purposes

ITA 5246/DEL/2024[2022-23]Status: DisposedITAT Delhi24 Dec 2025AY 2022-23

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwal

Section 132Section 250Section 28

Chawla. During the search and seizure operation under section 132 of the Act conducted on the assessee company on 9th February, 2022 by the Investigation Wing, Delhi, a hand-written note was found and seized from E-40, South City-1, Block E, Sector-40, Gurugram Haryana. The Contents

Jastej Gorowara, Bhopal vs. Commissioner of Income-Tax (Appeals), Delhi

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

ITA 277/IND/2025[2015-16]Status: DisposedITAT Indore23 Dec 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR
Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

assessment by issuing notice under section 148 of the Income-tax Act, 1961 (“the Act”). The reopening was based on information received from the Investigation Wing that the assessee had purchased an immovable property worth ₹2,40,40,000/- through open auction from UCO Bank and that part

Jastej Gorowara, Bhopal vs. CIT(A), Delhi

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

ITA 276/IND/2025[2011-12]Status: DisposedITAT Indore23 Dec 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR
Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

assessment by issuing notice under section 148 of the Income-tax Act, 1961 (“the Act”). The reopening was based on information received from the Investigation Wing that the assessee had purchased an immovable property worth ₹2,40,40,000/- through open auction from UCO Bank and that part

Khazana Stores Pvt. Ltd., Ahmedabad vs. The ITO, Ward-2(1)(1), Ahmedabad

ITA 1506/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Makarand Vasant Mahadeokarआयकर अपील सं/Ita No. 1506/Ahd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Khazana Stores Pvt. Ltd. The Ito Gf 2 Commerce House 2 बनाम/ Ward 2(1)(1) Judges Bunglow Road, V/S. Ahmedabad 380 015 Bodakdev, Ahmedabad 380 054 स्थायी लेखा सं./Pan: Aaack 7880 R (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) Assessee By: Shri S.N. Divatia & Shri Samir Vora, Ars Revenue By : Shri Kalpesh Rupavatia, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 30/09/2025 घोषणा की तारीख / Date Of Pronouncement: 23/12/2025 आदेश/Order Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As 'Cit(A)'] Dated 07/07/2025 For Assessment Year (Ay) 2017-18. 2. The Assessee, In This Appeal Has Taken The Following Grounds Of Appeal:

For Appellant: Shri S.N. Divatia &For Respondent: Shri Kalpesh Rupavatia, Sr. DR
Section 143(1)Section 147Section 148Section 250Section 69A

directed to go through the same and take necessary action to tax the unaccounted income, unearthed during the course of investigation carried investigation Wing(s) and Other Sources such as Central Circle(s). Other AO(s) and Other Agency(s). As such, the assessment of the assessee is being reopened ... opening of the assessment was bad in law. 6. The Ld. DR, on the other hand, has submitted that there was information from the Investigation Wing that there were huge cash deposits in the bank account of the assessee and, therefore, the AO had rightly formed the belief of escapement

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 427/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

possession of the undersigned earlier. The said information/scheme of tax evasion could be unearthed only after investigation was done by Investigation Wing Ahmedabad after carrying out search and seizure operations in the case of Dishman Group. Although, during the course of assessment proceedings, the assessee submitted, P&L account, Balance ... that it could not be detected by the AO and could be detected only after search was conducted and investigation was carried out by Investigation Wing. It can be reasonably concluded that there is failure on the part of assessee to disclose fully and truly all necessary facts during

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby\nallowed

ITA 426/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2015-16
For Appellant: \nShri S.N. Soparkar, Sr.AdvocateFor Respondent: \nShri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

possession of the\nundersigned earlier. The said information/scheme of tax evasion could be unearthed\nonly after investigation was done by Investigation Wing Ahmedabad after carrying\nout search and seizure operations in the case of Dishman Group. Although, during\nthe course of assessment proceedings, the assessee submitted, P&L account,\nBalance ... that it\ncould not be detected by the AO and could be detected only after search was\nconducted and investigation was carried out by Investigation Wing. It can be\nreasonably concluded that there is failure on the part of assessee to disclose\nfully and truly all necessary facts during

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 425/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

possession of the undersigned earlier. The said information/scheme of tax evasion could be unearthed only after investigation was done by Investigation Wing Ahmedabad after carrying out search and seizure operations in the case of Dishman Group. Although, during the course of assessment proceedings, the assessee submitted, P&L account, Balance ... that it could not be detected by the AO and could be detected only after search was conducted and investigation was carried out by Investigation Wing. It can be reasonably concluded that there is failure on the part of assessee to disclose fully and truly all necessary facts during

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 424/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

possession of the undersigned earlier. The said information/scheme of tax evasion could be unearthed only after investigation was done by Investigation Wing Ahmedabad after carrying out search and seizure operations in the case of Dishman Group. Although, during the course of assessment proceedings, the assessee submitted, P&L account, Balance ... that it could not be detected by the AO and could be detected only after search was conducted and investigation was carried out by Investigation Wing. It can be reasonably concluded that there is failure on the part of assessee to disclose fully and truly all necessary facts during

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. Siddheshwari Vyapaar Private Limited, Kolkata

In the result, appeal of the revenue is dismissed

ITA 2280/KOL/2025[2012-13]Status: DisposedITAT Kolkata23 Dec 2025AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.2280/Kol/2025 (निर्धारणवर्ा/Assessment Years :2012-2013) Dcit, Central Circle-1(2), Vs Siddheshwarivyapaar Pvt Ltd Kolkata 2Nd Floor, 159, Ravindra Sarani Kolkata-700007 Pan No. :Aancs 2337 J (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) रधजस्वकीओरसे /Revenue By : Shri Sanat Kumar Raha, Cit-Dr निर्धाररतीकीओरसे /Assessee By : Shrisoumitra Choudhury & Rainak Jain, Advocates सुनवाई की तारीख / Date Of Hearing : 09/12/2025 घोषणा की तारीख/Date Of Pronouncement : 23.12.2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Revenueagainst The Order Passed By The Ld. Cit(A), Kolkata-20, Dated 06.05.2025For The Assessment Year2012-2013. 2. The Appeal Of The Revenue Is Barred By 69 Days. Considering The Submissions Of The Ld. Cit-Dr & Looking To The Facts Of The Case, We Condone The Delay Of 69 Days In Filing The Present Appeal By The Revenue & The Appeal Is Admitted For Hearing. 3. The Only Issue Raised In This Appeal Is Against The Order Of The Ld. Cit(A) In Deleting The Addition Of Rs.6,82,00,000/- Made U/S.68 Of The Act On Account Of Unexplained Cash Credits Received From Shell Entities In The Guise Of Share Capital.

For Appellant: ShriSoumitra Choudhury and Rainak Jain, AdvocatesFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 131Section 133(6)Section 143(2)Section 143(3)Section 148Section 68

satisfaction are invalid in the eyes of law. In the present case, the only allegation was that the fund trail, as indicated by the Investigation Wing. showed that the appellant was a beneficiary of funds routed through a proprietorship concern and M/s Runicha Merchants Ltd. However, upon verification ... findings, the reasons recorded by the AO for reopening the assessment appear to be vague, incomplete, and based solely on the report from the Investigation Wing without apy independent verification or application of mind. The lack of specific details, coupled with the absence of a clear basis for the "reason

Mahak Doshi Legal Heir of Late Aditya Doshi, Kolkata vs. I.T.O., Ward - 2(1), Kolkata

Appeal of the assessee is allowed

ITA 2075/KOL/2025[2011-2012]Status: DisposedITAT Kolkata23 Dec 2025AY 2011-2012

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 147Section 148Section 250

order of Ld. CIT(A) upholding the assessment wherein the AO made reopening the assessment on the basis of information received from the Investigation Wing without any tangible material or applying his own mind that income of the assessee has escaped assessment. 3. After hearing the rival contention and perusing

Dcti 19 1 Mumbai, Mumbai vs. D Manish and Company, Mumbai

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is allowed

ITA 5875/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Dec 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 147Section 148Section 69C

Subsequently, the assessment was reopened by issuance of notice under section 148 dated 13 March 2019 on the basis of information received from the Investigation Wing pursuant to a search and seizure action carried out on 3 October 2013 in the case of the Bhanwarlal Jain Group, who were allegedly ... Total 8,47,61,242 5. In the assessment order, the Assessing Officer has largely reproduced the information received from the Investigation Wing and the statements recorded during the course of search proceedings in the case of third parties. However, despite the assessee having filed detailed replies 4 D Manish