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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

Kamlesh Gupta, New Delhi vs. DCIT, Central Circle- 1, New Delhi

In the result, Revenue’s appeals are dismissed, whereas

ITA 627/DEL/2018[2010-11]Status: DisposedITAT Delhi23 Jan 2023AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2009-10 With Assessment Year: 2011-12 With Assessment Year: 2012-13 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2015-16 Acit, Vs. Sh. Kamlesh Gupta, Central Circle-1, C-4, Maharani Bagh, New Delhi New Ashram, New Delhi Pan :Abcpg9838M (Appellant) (Respondent) With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12

Section 132Section 139Section 153A

company, namely, M/s. Waberten Ltd. incorporated in British Virgin Islands (BVI), FT and TR reference was sent to the competent authorities of BVI by Investigation Wing. From the information and copies of relevant documents received from the competent authorities of BVI, it was found that M/s. Waberton Ltd. was incorporated ... declaring total income of Rs.47,57,130/-. As discussed earlier, with reference to FT & TR reference sent to the competent authorities of BVI by Investigation Wing, information was received indicating that the assessee is a shareholder of M/s. Waberton Ltd. Following the 17 | P a g e approach adopted

Kamlesh Gupta, New Delhi vs. DCIT, Central Circle- 1, New Delhi

In the result, Revenue’s appeals are dismissed, whereas

ITA 626/DEL/2018[2009-10]Status: DisposedITAT Delhi23 Jan 2023AY 2009-10

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2009-10 With Assessment Year: 2011-12 With Assessment Year: 2012-13 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2015-16 Acit, Vs. Sh. Kamlesh Gupta, Central Circle-1, C-4, Maharani Bagh, New Delhi New Ashram, New Delhi Pan :Abcpg9838M (Appellant) (Respondent) With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12

Section 132Section 139Section 153A

company, namely, M/s. Waberten Ltd. incorporated in British Virgin Islands (BVI), FT and TR reference was sent to the competent authorities of BVI by Investigation Wing. From the information and copies of relevant documents received from the competent authorities of BVI, it was found that M/s. Waberton Ltd. was incorporated ... declaring total income of Rs.47,57,130/-. As discussed earlier, with reference to FT & TR reference sent to the competent authorities of BVI by Investigation Wing, information was received indicating that the assessee is a shareholder of M/s. Waberton Ltd. Following the 17 | P a g e approach adopted

Krc Gems Pvt. Ltd., Delhi vs. ACIT, Central Circle- 25, New Delhi

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

ITA 6757/DEL/2017[2012-13]Status: DisposedITAT Delhi23 Jan 2023AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: Shri Anil Jain, CAFor Respondent: Shri B.S. Ananad, Sr.DR
Section 133ASection 143(3)Section 147Section 148Section 68

operation under Section 133A of the Act was carried out at the business premises of M/s. KRC Gems Pvt. Ltd. on 19.12.2013 by the Investigation Wing of the Income Tax Department. In the course of survey operation, an amount of Rs.90 lakh introduced in the garb of share capital/share premium ... Diamonds is a sister concern of the assessee-company and the survey under Section 133A were carried out on both the concerns by the Investigation Wing simultaneously. The ld. counsel submitted that in the identical facts while the legal issue of jurisdiction was decided against the assessee but however

Income Tax Officer, Ward 2(3)(7), Surat vs. Shri Anil Pukhraj Jain, Surat

In the result the ground No

ITA 89/SRT/2017[2008-09]Status: DisposedITAT Surat23 Jan 2023AY 2008-09

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.89/Srt/2017 िनधा"रण वष"/Assessment Year: (2008-09) (Physical Court Hearing) Income Tax Officer, Ward-2(3)(7), Anil Pukhraj Jain, Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206-2Nd Floor, Tulsi Building, Bhavan, Adajan, Surat-395009 Vs. Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. (Appellant) (Respondent)/ "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q ""या"ेप सं Cross Objection No.10/Srt/2021 (A/O Ita No.89/Srt/2017) िनधा"रण वष"/Assessment Year: (2008-09) Anil Pukhraj Jain, Income Tax Officer, Ward-2(3)(7), Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206- 2Nd Floor, Tulsi Building, Vs. Bhavan, Adajan, Surat-395009 Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. Appellant/Co-Objector (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q िनधा"रती क" ओर से /Assessee By Shri Sapnesh R. Sheth, Ca राज"व क" ओर से /Respondent By Shri Ashok B. Koli, Cit-Dr सुनवाई क" तारीख/Date Of Hearing 23/12/2022 उ"ोषणा क" तारीख/Date Of Pronouncement 23/ 01/2023

Section 143(3)

total unverifiable purchase of Rs. 17,41,74,472/- without appreciating the fact that a search and seizure action was carried out by the Investigation Wing, Mumbai in the case of Sh. Pravin Kumar Jain and Gautam Kumar Jain and other Groups of Mumbai on 01.10.2013 which resulted in collection ... Investigation ITA 89/SRT/2017 & CO. 10/SRT/2021/AY.2008-09 Anil Pukhraj Jain 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 Bhanwarlal Jain Group and his associates including his sons were indulging in managing about 70 benami concerns

Ashok Kirtilal Bhansali, Mumbai vs. The Asst Commisiioner of Income Tax 19(3), Mumbai

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

ITA 1815/MUM/2022[2011-12]Status: DisposedITAT Mumbai20 Jan 2023AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri N.K. MohnotFor Respondent: Shri S. Anbuselvam
Section 143(1)Section 143(3)Section 147Section 148Section 250

record that only the purchases from M/s Krishna Diam have been disputed by the Revenue on the basis of information received from the Investigation Wing. However, the sales made by the assessee have not been disputed by the Revenue. We find that the Co-ordinate Bench of the Tribunal

DCIT, CC - 7 (2), Mumbai vs. Atul Umakant Rege, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 1546/MUM/2019[2011-12]Status: DisposedITAT Mumbai20 Jan 2023AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Anil SatheFor Respondent: Shri S. Anbuselvam
Section 143(1)Section 143(3)Section 147Section 148Section 154Section 250

year under consideration. Accordingly, the assessee booked a loss of Rs.1,59,77,636/-. The AO on the basis of statement recorded by the Investigation Wing of certain persons, who alleged that the aforesaid companies were mere penny stock companies, treated the entire loss of Rs.2 ... account of capital loss but a regular trading loss The Assessing Officer has merely relied upon the information received from Kolkata Investigation Wing and did not do any investigation nor did he bring any adverse information on record to show that the assessee has contrived the losses On the contrary

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 586/COCH/2022[2018-2019]Status: DisposedITAT Cochin20 Jan 2023AY 2018-2019

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR
Section 143(3)Section 144Section 153ASection 245C(1)

complete violation of principles of natural justice by placing reliance on purported statements of third parties recorded by the Investigation Wing behind the back of the Assessee without – (i) providing copies of the purported statements to the Appellant, ITA Nos.580 to 586/Coch/2022 (ii) independently examining such third parties in course ... assessee and no opportunity of cross-examination was ever provided to the assessee. These statements were pre-existing statements recorded by the investigation wing and could not be the sole basis of assessment. For the same, Ld. ITA Nos.580 to 586/Coch/2022 AR has relied on the decision

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 585/COCH/2022[2017-2018]Status: DisposedITAT Cochin20 Jan 2023AY 2017-2018

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR
Section 143(3)Section 144Section 153ASection 245C(1)

complete violation of principles of natural justice by placing reliance on purported statements of third parties recorded by the Investigation Wing behind the back of the Assessee without – (i) providing copies of the purported statements to the Appellant, ITA Nos.580 to 586/Coch/2022 (ii) independently examining such third parties in course ... assessee and no opportunity of cross-examination was ever provided to the assessee. These statements were pre-existing statements recorded by the investigation wing and could not be the sole basis of assessment. For the same, Ld. ITA Nos.580 to 586/Coch/2022 AR has relied on the decision

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 584/COCH/2022[2016-2017]Status: DisposedITAT Cochin20 Jan 2023AY 2016-2017

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR
Section 143(3)Section 144Section 153ASection 245C(1)

complete violation of principles of natural justice by placing reliance on purported statements of third parties recorded by the Investigation Wing behind the back of the Assessee without – (i) providing copies of the purported statements to the Appellant, ITA Nos.580 to 586/Coch/2022 (ii) independently examining such third parties in course ... assessee and no opportunity of cross-examination was ever provided to the assessee. These statements were pre-existing statements recorded by the investigation wing and could not be the sole basis of assessment. For the same, Ld. ITA Nos.580 to 586/Coch/2022 AR has relied on the decision

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 583/COCH/2022[2015-2016]Status: DisposedITAT Cochin20 Jan 2023AY 2015-2016

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR
Section 143(3)Section 144Section 153ASection 245C(1)

complete violation of principles of natural justice by placing reliance on purported statements of third parties recorded by the Investigation Wing behind the back of the Assessee without – (i) providing copies of the purported statements to the Appellant, ITA Nos.580 to 586/Coch/2022 (ii) independently examining such third parties in course ... assessee and no opportunity of cross-examination was ever provided to the assessee. These statements were pre-existing statements recorded by the investigation wing and could not be the sole basis of assessment. For the same, Ld. ITA Nos.580 to 586/Coch/2022 AR has relied on the decision

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 582/COCH/2022[2014-2015]Status: DisposedITAT Cochin20 Jan 2023AY 2014-2015

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR
Section 143(3)Section 144Section 153ASection 245C(1)

complete violation of principles of natural justice by placing reliance on purported statements of third parties recorded by the Investigation Wing behind the back of the Assessee without – (i) providing copies of the purported statements to the Appellant, ITA Nos.580 to 586/Coch/2022 (ii) independently examining such third parties in course ... assessee and no opportunity of cross-examination was ever provided to the assessee. These statements were pre-existing statements recorded by the investigation wing and could not be the sole basis of assessment. For the same, Ld. ITA Nos.580 to 586/Coch/2022 AR has relied on the decision

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 581/COCH/2022[2013-2014]Status: DisposedITAT Cochin20 Jan 2023AY 2013-2014

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR
Section 143(3)Section 144Section 153ASection 245C(1)

complete violation of principles of natural justice by placing reliance on purported statements of third parties recorded by the Investigation Wing behind the back of the Assessee without – (i) providing copies of the purported statements to the Appellant, ITA Nos.580 to 586/Coch/2022 (ii) independently examining such third parties in course ... assessee and no opportunity of cross-examination was ever provided to the assessee. These statements were pre-existing statements recorded by the investigation wing and could not be the sole basis of assessment. For the same, Ld. ITA Nos.580 to 586/Coch/2022 AR has relied on the decision

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 580/COCH/2022[2012-2013]Status: DisposedITAT Cochin20 Jan 2023AY 2012-2013

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR
Section 143(3)Section 144Section 153ASection 245C(1)

complete violation of principles of natural justice by placing reliance on purported statements of third parties recorded by the Investigation Wing behind the back of the Assessee without – (i) providing copies of the purported statements to the Appellant, ITA Nos.580 to 586/Coch/2022 (ii) independently examining such third parties in course ... assessee and no opportunity of cross-examination was ever provided to the assessee. These statements were pre-existing statements recorded by the investigation wing and could not be the sole basis of assessment. For the same, Ld. ITA Nos.580 to 586/Coch/2022 AR has relied on the decision

M/S Manthan Inc, Mumbai vs. Income Tax Circle, 19(2), Mumbai

In the result, both the appeals of the assessee are dismissed

ITA 2664/MUM/2022[2014-2015]Status: DisposedITAT Mumbai19 Jan 2023AY 2014-2015

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14 & Assessment Year: 2014-15 M/S Manthan Inc, Acit Cir. 19(2), Rani Bldg., V.P. Road, Tardeo, Vs. Mumbai-400 004. Mumbai. Pan No. Aakfm 6011 D Appellant Respondent : Assessee By Mr. Dilip Diwan, Ar Revenue By : Smt. Mahita Nair, Dr : Date Of Hearing 12/01/2023 : Date Of Pronouncement 19/01/2023

For Respondent: Assessee by Mr. Dilip Diwan, AR
Section 143(3)Section 147Section 148Section 35A

Manthan Inc ITA Nos. 2663 & 2664/M/2022 6.1 The Assessing Officer Assessing Officer subsequently received information from received information from the Investigation Wing the Investigation Wingof the Income-tax Department tax Department that M/s Navjeevan Charitable Trust was engaged in issuing bogus entry of Navjeevan Charitable Trust was engaged in issuing

M/S Manthan Inc, Mumbai vs. Income Tax Circle, 19(2) Mumbai, Mumbai

In the result, both the appeals of the assessee are dismissed

ITA 2663/MUM/2022[2013-2014]Status: DisposedITAT Mumbai19 Jan 2023AY 2013-2014

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14 & Assessment Year: 2014-15 M/S Manthan Inc, Acit Cir. 19(2), Rani Bldg., V.P. Road, Tardeo, Vs. Mumbai-400 004. Mumbai. Pan No. Aakfm 6011 D Appellant Respondent : Assessee By Mr. Dilip Diwan, Ar Revenue By : Smt. Mahita Nair, Dr : Date Of Hearing 12/01/2023 : Date Of Pronouncement 19/01/2023

For Respondent: Assessee by Mr. Dilip Diwan, AR
Section 143(3)Section 147Section 148Section 35A

Manthan Inc ITA Nos. 2663 & 2664/M/2022 6.1 The Assessing Officer Assessing Officer subsequently received information from received information from the Investigation Wing the Investigation Wingof the Income-tax Department tax Department that M/s Navjeevan Charitable Trust was engaged in issuing bogus entry of Navjeevan Charitable Trust was engaged in issuing

Pankaj Jain, Mumbai vs. DCIT CC 1 (1), Mumbai

In the result, appeals in the case of Shri Pravin Kumar Jain and Shri

ITA 4977/MUM/2019[2008-09]Status: FixedITAT Mumbai19 Jan 2023AY 2008-09

Bench: Shri Kuldip Singh () & Shri Rifaur Rahman (

Section 145Section 153ASection 250Section 80C

Rs.1,00,000/-. 8. We have also perused the impugned order passed by Ld.CIT(A). From the search and seizure operation conducted by the Investigation Wing of the Revenue Department and assessment proceedings carried out by the Assessing Officer it is proved on record that the assessees were directors / partners ... employees 12 Pravin Kumar Jain / Pankaj Jain / Casper Enterprises Pvt Ltd ITAs7191 to 7197/M/2021 ITAs 4977 to 498/Mum/2019& ITA 2498/Mum/2019 recorded during search by Investigation Wing that no genuine business was being carried out by the group concerns in question. 12. The Ld.DR for the Revenue minutely explained the modus

Casper Enterprises Pvt Ltd., Mumbai vs. DCIT CC 1(1), Mumbai

In the result, appeals in the case of Shri Pravin Kumar Jain and Shri

ITA 2498/MUM/2019[2008-09]Status: DisposedITAT Mumbai19 Jan 2023AY 2008-09

Bench: Shri Kuldip Singh () & Shri Rifaur Rahman (

Section 145Section 153ASection 250Section 80C

Rs.1,00,000/-. 8. We have also perused the impugned order passed by Ld.CIT(A). From the search and seizure operation conducted by the Investigation Wing of the Revenue Department and assessment proceedings carried out by the Assessing Officer it is proved on record that the assessees were directors / partners ... employees 12 Pravin Kumar Jain / Pankaj Jain / Casper Enterprises Pvt Ltd ITAs7191 to 7197/M/2021 ITAs 4977 to 498/Mum/2019& ITA 2498/Mum/2019 recorded during search by Investigation Wing that no genuine business was being carried out by the group concerns in question. 12. The Ld.DR for the Revenue minutely explained the modus

Praveen Kumar Jain, Mumbai vs. DCIT, CC -1(1), Mumbai

In the result, appeals in the case of Shri Pravin Kumar Jain and Shri

ITA 7191/MUM/2018[2008-09]Status: FixedITAT Mumbai19 Jan 2023AY 2008-09

Bench: Shri Kuldip Singh () & Shri Rifaur Rahman (

Section 145Section 153ASection 250Section 80C

Rs.1,00,000/-. 8. We have also perused the impugned order passed by Ld.CIT(A). From the search and seizure operation conducted by the Investigation Wing of the Revenue Department and assessment proceedings carried out by the Assessing Officer it is proved on record that the assessees were directors / partners ... employees 12 Pravin Kumar Jain / Pankaj Jain / Casper Enterprises Pvt Ltd ITAs7191 to 7197/M/2021 ITAs 4977 to 498/Mum/2019& ITA 2498/Mum/2019 recorded during search by Investigation Wing that no genuine business was being carried out by the group concerns in question. 12. The Ld.DR for the Revenue minutely explained the modus

DCIT, CC Gzbd, Ghaziabad vs. Yugank Goyal, Ghaziabad

ITA 1808/DEL/2021[2015-16]Status: DisposedITAT Delhi19 Jan 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Narendra Kumar Billaiyaassessment Year: 2018-19 Anil Bala Goyal, Dy. Commissioner Of Income- 6/204, Tikonia, Tax, Central Circle, Belanganj, Agra 282004 Vs. Ghaziabad 201002 Pan Aappb5034N (Appellant) (Respondent) Assessment Year: 2018-19 Maanya Goyal, Dy. Commissioner Of Income- 6/204, Tikonia, Tax, Central Circle, Belanganj, Agra 282004 Vs. Ghaziabad 201002 Pan Blxps7985K (Appellant) (Respondent) Assessment Year: 2015-16 Yugank Goyal, Dy. Commissioner Of Income- 6/204, Tikonia, Tax, Central Circle, Belanganj, Agra 282004 Vs. Ghaziabad 201002 Pan Ahhpg4073H (Appellant) (Respondent)

For Appellant: Shri Sushil Kumar

rather ignored this important piece of 23 ITA.Nos.1533 to 1536/Del./2021 ITA Nos. 1807 & 1808/Del./2021 evidence gathered by the Directorate of Investigation Wing. We are not in agreement with the contention of the Ld. CIT DR that the A.O. cannot referred the DVO report suo motto ... that the Ld. CIT(A) has properly considered the entire facts and circumstances of the case including valuation report called by the Directorate of Investigation Wing and thereafter restricted the addition to Rs. 9.02 lac taking the difference between the value shown by the assessee and his co-purchaser

DCIT CC, Gzbd vs. Bankey Behari Goyal, Agra

ITA 1807/DEL/2021[2017-2018]Status: DisposedITAT Delhi19 Jan 2023AY 2017-2018

Bench: Shri Chandra Mohan Garg & Shri Narendra Kumar Billaiyaassessment Year: 2018-19 Anil Bala Goyal, Dy. Commissioner Of Income- 6/204, Tikonia, Tax, Central Circle, Belanganj, Agra 282004 Vs. Ghaziabad 201002 Pan Aappb5034N (Appellant) (Respondent) Assessment Year: 2018-19 Maanya Goyal, Dy. Commissioner Of Income- 6/204, Tikonia, Tax, Central Circle, Belanganj, Agra 282004 Vs. Ghaziabad 201002 Pan Blxps7985K (Appellant) (Respondent) Assessment Year: 2015-16 Yugank Goyal, Dy. Commissioner Of Income- 6/204, Tikonia, Tax, Central Circle, Belanganj, Agra 282004 Vs. Ghaziabad 201002 Pan Ahhpg4073H (Appellant) (Respondent)

For Appellant: Shri Sushil Kumar

rather ignored this important piece of 23 ITA.Nos.1533 to 1536/Del./2021 ITA Nos. 1807 & 1808/Del./2021 evidence gathered by the Directorate of Investigation Wing. We are not in agreement with the contention of the Ld. CIT DR that the A.O. cannot referred the DVO report suo motto ... that the Ld. CIT(A) has properly considered the entire facts and circumstances of the case including valuation report called by the Directorate of Investigation Wing and thereafter restricted the addition to Rs. 9.02 lac taking the difference between the value shown by the assessee and his co-purchaser