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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

Sarvesh Mercantile Pvt. Ltd., Mumbai vs. DCIT, CC 2(1), Mumbai

In the result, the three appeals filed by the assessee are In the result, the three appeals filed by the assessee are allowed partly for statistical allowed partly for statistical purposes

ITA 7162/MUM/2019[2015-16]Status: DisposedITAT Mumbai27 Jul 2022AY 2015-16

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2014-15 M/S Sarvesh Mercantile Pvt. Ltd., Dy. Cit Central Circle-2(4), 2Nd Floor, Johari Mansion, 259, Mumbai. Kalbadevi Road, Vs. Mumbai-400 002. Pan No. Aaics 1651 C Appellant Respondent Assessment Year: 2013-14 & Assessment Year: 2015-16 Sarvesh Mercantile Pvt. Ltd., Dcit Cc-2(1), 2Nd Floor, Johri Mansion, 259, 9Th Floor, New Pratiksha Bhavan, Kalbadevi Road, Kalbadevi, Vs. M.K. Road, Mumbai-400 002. Mumbai-400020. Pan No. Aaics 1651 C Appellant Respondent

For Appellant: NoneFor Respondent: Mrs. Neelam Shukla, CIT-DR
Section 68

section 133A of the Income Tax Act Income Tax Act, 1961 (in short ‘the Act’) was carried out by was carried out by the Investigation Wing Investigation Wing of the Income-tax Department ax Department Mumbai on19.03.2015 alongwith 19.03.2015 alongwith search action at the premises of the search action ... survey action from the Based on the information received of survey action from the Based on the information received of survey action from the Investigation Wing, Mumbai, the , Mumbai, the Assessing Officer Assessing Officer reopened the assessment after recording reasons to believe that income escape nt after recording reasons

DCIT Circle- 15(3)(1), Mumbai vs. M/S Sanjivaini Parenteral Ltd., M

In the result, all the three appeals of the learned assessing officer are partly allowed

ITA 4154/MUM/2019[2011-12]Status: DisposedITAT Mumbai27 Jul 2022AY 2011-12

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

For Appellant: Shri Mehul Shah, ARFor Respondent: Shri Hemant Kumar Chimanlal
Section 143(3)Section 147Section 69C

issued to M/s. Hercules Chem and M/s. Odyssey Chemicals to verify the sales made by the assessee company to them. However, the Inspector of Investigation Wing reported that the address of M/s. Hercules Chem and M/s. Odyssey Chemicals was incomplete and the said parties could not be traced. Thus

DCIT, Circle-15(3)(1), Mumbai vs. M/S- Sanjivani Parenteral Ltd., Mumbai

In the result, all the three appeals of the learned assessing officer are partly allowed

ITA 4153/MUM/2019[2009-10]Status: DisposedITAT Mumbai27 Jul 2022AY 2009-10

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

For Appellant: Shri Mehul Shah, ARFor Respondent: Shri Hemant Kumar Chimanlal
Section 143(3)Section 147Section 69C

issued to M/s. Hercules Chem and M/s. Odyssey Chemicals to verify the sales made by the assessee company to them. However, the Inspector of Investigation Wing reported that the address of M/s. Hercules Chem and M/s. Odyssey Chemicals was incomplete and the said parties could not be traced. Thus

DCIT, C-15(3)(1), Mumbai vs. Sanjivani Parenteral Ltd., Mumbai

In the result, all the three appeals of the learned assessing officer are partly allowed

ITA 4152/MUM/2019[2010-11]Status: DisposedITAT Mumbai27 Jul 2022AY 2010-11

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

For Appellant: Shri Mehul Shah, ARFor Respondent: Shri Hemant Kumar Chimanlal
Section 143(3)Section 147Section 69C

issued to M/s. Hercules Chem and M/s. Odyssey Chemicals to verify the sales made by the assessee company to them. However, the Inspector of Investigation Wing reported that the address of M/s. Hercules Chem and M/s. Odyssey Chemicals was incomplete and the said parties could not be traced. Thus

Sarvesh Mercantile P.Ltd, Mumbai vs. DCIT 2(4), Mumbai

In the result, the three appeals filed by the assessee are In the result, the three appeals filed by the assessee are allowed partly for statistical allowed partly for statistical purposes

ITA 4634/MUM/2018[2014-15]Status: DisposedITAT Mumbai27 Jul 2022AY 2014-15

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2014-15 M/S Sarvesh Mercantile Pvt. Ltd., Dy. Cit Central Circle-2(4), 2Nd Floor, Johari Mansion, 259, Mumbai. Kalbadevi Road, Vs. Mumbai-400 002. Pan No. Aaics 1651 C Appellant Respondent Assessment Year: 2013-14 & Assessment Year: 2015-16 Sarvesh Mercantile Pvt. Ltd., Dcit Cc-2(1), 2Nd Floor, Johri Mansion, 259, 9Th Floor, New Pratiksha Bhavan, Kalbadevi Road, Kalbadevi, Vs. M.K. Road, Mumbai-400 002. Mumbai-400020. Pan No. Aaics 1651 C Appellant Respondent

For Appellant: NoneFor Respondent: Mrs. Neelam Shukla, CIT-DR
Section 68

section 133A of the Income Tax Act Income Tax Act, 1961 (in short ‘the Act’) was carried out by was carried out by the Investigation Wing Investigation Wing of the Income-tax Department ax Department Mumbai on19.03.2015 alongwith 19.03.2015 alongwith search action at the premises of the search action ... survey action from the Based on the information received of survey action from the Based on the information received of survey action from the Investigation Wing, Mumbai, the , Mumbai, the Assessing Officer Assessing Officer reopened the assessment after recording reasons to believe that income escape nt after recording reasons

Mukesh Adlakha, New Delhi vs. ITO Ward - 62(1), New Delhi

In the result, the appeal is partly allowed

ITA 9755/DEL/2019[2011-12]Status: DisposedITAT Delhi27 Jul 2022AY 2011-12

Bench: Shri Saktijit Deyassessment Year: 2011-12 Sh. Mukesh Adlakha, Vs. Income Tax Officer, Ae-43, Tagore Garden, Ward -62(1), New Delhi New Delhi Pan :Aahpa3621L (Appellant) (Respondent)

Section 147Section 148Section 151Section 250

filed his return of income on 29.09.2011 declaring income of Rs.9,19,919/-. It is evident, subsequently, the Assessing Officer received information from the Investigation Wing, Ghaziabad, that the assesse has taken 3 accommodation entry of Rs.2,06,016/- indicating that certain supplies amounting to Rs. 2,06,016/- made ... assessment under section 147 of the Act. 6. Before us, learned counsel for the assessee submitted that merely based on information received from the Investigation Wing, the Assessing Officer has reopened the assessment mechanically without proper application of mind. He submitted, before initiating proceeding under section

Ramniwas Choyal, Surat vs. ACIT CC -1(3), Mumbai

In the result, appeals of the assessees are allowed

ITA 360/MUM/2022[2015-16]Status: DisposedITAT Mumbai26 Jul 2022AY 2015-16

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Mahalaxmi Gems Pvt. Ltd., V. Acit – Cc – 1(3) 316, Pancharatna Pratishtha Bhavan Opera House, Mumbai -400004 Mumbai - 400020 Pan: Aabcm8875H (Appellant) (Respondent) Shri Mahavir M. Jain V. Acit – Cc – 1(3) 11, Shakti Chamber M.K. Road, Churchgate Rughnathpura Main Road Mumbai - 400020 Surat, Gujarat-395003 Pan: Ahnpj4936G (Appellant) (Respondent) Ramniwas Choyal V. Acit – Cc – 1(3) 11, Shakti Chamber Pratishtha Bhavan Rughnathpura Main Road Mumbai - 400020 Surat, Gujarat-395003 Pan: Aknpc1507H (Appellant) (Respondent)

For Appellant: Shri Suchek AnchaliyaFor Respondent: Shri B.K. Bagchi
Section 132(1)Section 143(1)Section 143(2)Section 143(3)Section 148Section 153A

filed its original return of income on 5.10.2015 declaring total income of Rs 60,380/- Subsequently, the ld. AO received information from the investigation wing of the Income tax department, Mumbai that assessee is one of the concern controlled and managed by Shri Bhanwarlal Jain who used this concern

Mahavir M. Jain, Mumbai vs. ACIT CC -1(3), Mumbai

In the result, appeals of the assessees are allowed

ITA 352/MUM/2022[2015-16]Status: DisposedITAT Mumbai26 Jul 2022AY 2015-16

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Mahalaxmi Gems Pvt. Ltd., V. Acit – Cc – 1(3) 316, Pancharatna Pratishtha Bhavan Opera House, Mumbai -400004 Mumbai - 400020 Pan: Aabcm8875H (Appellant) (Respondent) Shri Mahavir M. Jain V. Acit – Cc – 1(3) 11, Shakti Chamber M.K. Road, Churchgate Rughnathpura Main Road Mumbai - 400020 Surat, Gujarat-395003 Pan: Ahnpj4936G (Appellant) (Respondent) Ramniwas Choyal V. Acit – Cc – 1(3) 11, Shakti Chamber Pratishtha Bhavan Rughnathpura Main Road Mumbai - 400020 Surat, Gujarat-395003 Pan: Aknpc1507H (Appellant) (Respondent)

For Appellant: Shri Suchek AnchaliyaFor Respondent: Shri B.K. Bagchi
Section 132(1)Section 143(1)Section 143(2)Section 143(3)Section 148Section 153A

filed its original return of income on 5.10.2015 declaring total income of Rs 60,380/- Subsequently, the ld. AO received information from the investigation wing of the Income tax department, Mumbai that assessee is one of the concern controlled and managed by Shri Bhanwarlal Jain who used this concern

Mahalaxmi Gems Pvt. Ltd., Mumbai vs. ACIT- CC-1(3), Mumbai

In the result, appeals of the assessees are allowed

ITA 329/MUM/2022[2015-16]Status: DisposedITAT Mumbai26 Jul 2022AY 2015-16

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Mahalaxmi Gems Pvt. Ltd., V. Acit – Cc – 1(3) 316, Pancharatna Pratishtha Bhavan Opera House, Mumbai -400004 Mumbai - 400020 Pan: Aabcm8875H (Appellant) (Respondent) Shri Mahavir M. Jain V. Acit – Cc – 1(3) 11, Shakti Chamber M.K. Road, Churchgate Rughnathpura Main Road Mumbai - 400020 Surat, Gujarat-395003 Pan: Ahnpj4936G (Appellant) (Respondent) Ramniwas Choyal V. Acit – Cc – 1(3) 11, Shakti Chamber Pratishtha Bhavan Rughnathpura Main Road Mumbai - 400020 Surat, Gujarat-395003 Pan: Aknpc1507H (Appellant) (Respondent)

For Appellant: Shri Suchek AnchaliyaFor Respondent: Shri B.K. Bagchi
Section 132(1)Section 143(1)Section 143(2)Section 143(3)Section 148Section 153A

filed its original return of income on 5.10.2015 declaring total income of Rs 60,380/- Subsequently, the ld. AO received information from the investigation wing of the Income tax department, Mumbai that assessee is one of the concern controlled and managed by Shri Bhanwarlal Jain who used this concern

ITO Ward-32(1)(1), Mumbai vs. Sandeep D. Shah, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 101/MUM/2021[2004-05]Status: DisposedITAT Mumbai26 Jul 2022AY 2004-05
Section 144Section 147Section 148Section 68Section 69C

holding only 2 bank accounts in Bank of Baroda that is 1 current account and 1 saving account. With regard to information received from investigations wing for that I state that I have not received any amount from M/s. Mahasagar Securities Pvt. Ltd. The Directors of the company fraudly ... check whether the assessee has actually received any amount from the said M/s. Mahasagar Securities Pvt Ltd and whether the information received from the Investigation Wing is verifiable from the bank account of the party (the appellant). If the information says that the appellant received particular amount from particular party

Arvindkumar Soni, Surat vs. ITO, WD-2(3)(7), Surat

In the result the ground No

ITA 165/SRT/2021[2009-10]Status: DisposedITAT Surat25 Jul 2022AY 2009-10

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.460/Srt/2019 Assessment Year: (2009-10) (Physical Court Hearing) The Ito, Ward-2(3)(7), Vs. Arvind Soni, Surat. Prop. Of M/S. Balajee Diamond, B-3, 701, Nakshara Platinum, Opp. Mathura Nagari, Palanpur Gam, Surat - 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bfmps0796F (Revenue)/(Appellant) (Assessee)/(Respondent) आयकर अपील सं./Ita No.165/Srt/2021 Assessment Year: (2009-10) (Physical Court Hearing) Arvindkumar Soni, Vs. The Ito, Ward-2(3)(7), B-3, 701, Nakshara Platinum, Surat. Opp. Mathura Nagari, Planpur Gam, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bfmps0796F (Appellant) (Respondent) Cross Objection. No.14/Srt/2021 [Arising Out Of Ita No. 460/Srt/2019 Assessment Year: (2009-10) (Physical Court Hearing) The Ito, Ward-2(3)(7), Vs. Arvind Soni, Surat. Prop. Of M/S. Balajee Diamond, B-3, 701, Nakshara Platinum, Opp. Mathura Nagari, Palanpur Gam, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bfmps0796F (Appellant) (Respondent) Shri Prakash G. Jhunjhunwala, Ca With Assessee By Shri Anand R. Chourasia, Ca Respondent By Shri H. P. Meena, Cit(Dr) Date Of Hearing 01/07/2022 25/07/2022 Date Of Pronouncement

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

Revenue argued that Assessing Officer has recorded valid reasons for reopening the assessee’s case, based on the information received from Investigation Wing. To support his arguments, Ld. DR relied on the judgment of Hon'ble Gujarat High Court in the case of Peass International Engineering (P.) Ltd.,76 taxmann.com ... reasons recorded by the Assessing Officer and noted that these reasons were recorded by the Assessing Officer, based on the information received from the investigation wing. The Assessing Officer has been taken information received from the investigation wing as a lead to come to a conclusion that income

ITO, Ward-2(3)(8), Surat vs. M/S. Sparsh Impex, Surat

In the result, assessee’s appeal is dismissed

ITA 60/SRT/2020[2014-15]Status: DisposedITAT Surat25 Jul 2022AY 2014-15

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअ पीलसं./Ita Nos.27&60/Srt/2020 (िनधा"रणवष" / Assessment Year: (2014-15) (Virtual Court Hearing) M/S Sparsh Impex Income Tax Officer, Ward- 2(3)(8), Room No. 407, 4Th Floor, 302, Nishit Diamond Complex, Gujar Fallia, Mahidharpura, Surat- Anavil Business Centre, Hazira 395001 Road, Adajan, Surat-395009 Vs. Income Tax Officer, Ward-2(3)(8), M/S Sparsh Impex Room No. 407, 4Th Floor, Anavil 302, Nishit Diamond Complex, Business Centre, Hazira Road, Gujar Fallia, Mahidharpura, Adajan, Surat-395009 Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Achfs 7559 M (Appellant ) (Respondent)

For Appellant: Shri Himanshu Gandhi, C.AFor Respondent: Shri H.P.Meena, CIT-DR
Section 143(2)Section 143(3)

negative from 26.06.2006 onwards and no sale is possible in absence of purchases. The AO relied on the statement of Bhanwarlal Jain recorded by Investigation Wing against, copy of purchase bill, copy of bank statement, showing payment, day to day stock register, incoming and outgoing diamonds and daily stock tally ... also observed that there is no denying circumstances under which statement were made by Bhanwarlal Jain and the elaborate modus-operandi unearthed by Investigation Wing, Mumbai, which has created sufficient suspicion regarding the purchase made by the assessee. The said parties are assessed with Central Circle, Mumbai where they

Sparsh Impex, Surat vs. ITO, Ward-2(3)(8), Surat

In the result, assessee’s appeal is dismissed

ITA 27/SRT/2020[2014-15]Status: DisposedITAT Surat25 Jul 2022AY 2014-15

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअ पीलसं./Ita Nos.27&60/Srt/2020 (िनधा"रणवष" / Assessment Year: (2014-15) (Virtual Court Hearing) M/S Sparsh Impex Income Tax Officer, Ward- 2(3)(8), Room No. 407, 4Th Floor, 302, Nishit Diamond Complex, Gujar Fallia, Mahidharpura, Surat- Anavil Business Centre, Hazira 395001 Road, Adajan, Surat-395009 Vs. Income Tax Officer, Ward-2(3)(8), M/S Sparsh Impex Room No. 407, 4Th Floor, Anavil 302, Nishit Diamond Complex, Business Centre, Hazira Road, Gujar Fallia, Mahidharpura, Adajan, Surat-395009 Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Achfs 7559 M (Appellant ) (Respondent)

For Appellant: Shri Himanshu Gandhi, C.AFor Respondent: Shri H.P.Meena, CIT-DR
Section 143(2)Section 143(3)

negative from 26.06.2006 onwards and no sale is possible in absence of purchases. The AO relied on the statement of Bhanwarlal Jain recorded by Investigation Wing against, copy of purchase bill, copy of bank statement, showing payment, day to day stock register, incoming and outgoing diamonds and daily stock tally ... also observed that there is no denying circumstances under which statement were made by Bhanwarlal Jain and the elaborate modus-operandi unearthed by Investigation Wing, Mumbai, which has created sufficient suspicion regarding the purchase made by the assessee. The said parties are assessed with Central Circle, Mumbai where they

ITO, Ward-3(3)(5), Surat vs. Vimalchand Manikchand Jain, Surat

In the result, the grounds of appeal raised by the revenue are partly allowed and the grounds raised in Cross Objection by assessee are dismissed

ITA 119/SRT/2020[2013-14]Status: DisposedITAT Surat25 Jul 2022AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 147Section 148Section 254(1)

assessee filed his return of income for AY.2011-12 on 30/09/2011 declaring total income of Rs.1,88,880/-. Subsequently, on receipt of information from Investigation Wing, Mumbai the case of assessee was reopened under section 147. The assessing officer received information that a search action was carried out on Rajendra Jain ... providing bogus entries of sale purchase of diamond, Long Term Capital Gain (LTCG) and loss etc. The statement of Rajendra Jain was recorded by Investigation Wing under section 132 of the Income Tax Act, 1961 (in short, the Act). The said Rajendra Jain confirmed that he is managing various bogus

ITO, Ward-3(3)(5), Surat vs. Vimalchand Manikchand Jain, Surat

In the result, the grounds of appeal raised by the revenue are partly allowed and the grounds raised in Cross Objection by assessee are dismissed

ITA 118/SRT/2020[2012-13]Status: DisposedITAT Surat25 Jul 2022AY 2012-13

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 147Section 148Section 254(1)

assessee filed his return of income for AY.2011-12 on 30/09/2011 declaring total income of Rs.1,88,880/-. Subsequently, on receipt of information from Investigation Wing, Mumbai the case of assessee was reopened under section 147. The assessing officer received information that a search action was carried out on Rajendra Jain ... providing bogus entries of sale purchase of diamond, Long Term Capital Gain (LTCG) and loss etc. The statement of Rajendra Jain was recorded by Investigation Wing under section 132 of the Income Tax Act, 1961 (in short, the Act). The said Rajendra Jain confirmed that he is managing various bogus

ITO, Ward-3(3)(5), Surat vs. Vimalchand Manikchand Jain, Surat

In the result, the grounds of appeal raised by the revenue are partly allowed and the grounds raised in Cross Objection by assessee are dismissed

ITA 117/SRT/2020[2011-12]Status: DisposedITAT Surat25 Jul 2022AY 2011-12

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 147Section 148Section 254(1)

assessee filed his return of income for AY.2011-12 on 30/09/2011 declaring total income of Rs.1,88,880/-. Subsequently, on receipt of information from Investigation Wing, Mumbai the case of assessee was reopened under section 147. The assessing officer received information that a search action was carried out on Rajendra Jain ... providing bogus entries of sale purchase of diamond, Long Term Capital Gain (LTCG) and loss etc. The statement of Rajendra Jain was recorded by Investigation Wing under section 132 of the Income Tax Act, 1961 (in short, the Act). The said Rajendra Jain confirmed that he is managing various bogus

ITO, Ward-2(3)(7), Surat vs. Arvind Soni, Surat

In the result the ground No

ITA 460/SRT/2019[2009-10]Status: DisposedITAT Surat25 Jul 2022AY 2009-10

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.460/Srt/2019 Assessment Year: (2009-10) (Physical Court Hearing) The Ito, Ward-2(3)(7), Vs. Arvind Soni, Surat. Prop. Of M/S. Balajee Diamond, B-3, 701, Nakshara Platinum, Opp. Mathura Nagari, Palanpur Gam, Surat - 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bfmps0796F (Revenue)/(Appellant) (Assessee)/(Respondent) आयकर अपील सं./Ita No.165/Srt/2021 Assessment Year: (2009-10) (Physical Court Hearing) Arvindkumar Soni, Vs. The Ito, Ward-2(3)(7), B-3, 701, Nakshara Platinum, Surat. Opp. Mathura Nagari, Planpur Gam, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bfmps0796F (Appellant) (Respondent) Cross Objection. No.14/Srt/2021 [Arising Out Of Ita No. 460/Srt/2019 Assessment Year: (2009-10) (Physical Court Hearing) The Ito, Ward-2(3)(7), Vs. Arvind Soni, Surat. Prop. Of M/S. Balajee Diamond, B-3, 701, Nakshara Platinum, Opp. Mathura Nagari, Palanpur Gam, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bfmps0796F (Appellant) (Respondent) Shri Prakash G. Jhunjhunwala, Ca With Assessee By Shri Anand R. Chourasia, Ca Respondent By Shri H. P. Meena, Cit(Dr) Date Of Hearing 01/07/2022 25/07/2022 Date Of Pronouncement

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

Revenue argued that Assessing Officer has recorded valid reasons for reopening the assessee’s case, based on the information received from Investigation Wing. To support his arguments, Ld. DR relied on the judgment of Hon'ble Gujarat High Court in the case of Peass International Engineering (P.) Ltd.,76 taxmann.com ... reasons recorded by the Assessing Officer and noted that these reasons were recorded by the Assessing Officer, based on the information received from the investigation wing. The Assessing Officer has been taken information received from the investigation wing as a lead to come to a conclusion that income

ITO, Ward-2(3)(8), Surat vs. Mukesh Babulal Parlecha, Surat

In the result, appeals filed by the assessees (ITA Nos

ITA 267/SRT/2019[2014-15]Status: DisposedITAT Surat25 Jul 2022AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.225 & 226/Srt/2019 Assessment Years: (2013-14 To 2014-15) (Virtual Court Hearing) Mukesh Babulal Parlechav, Vs. The Ito, Ward-2(3)(8), 201, Panchratna Appartment, Dalgiya Surat. Mohalla, Mahidharpura, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apopp4334F (Appellant) (Respondent) आयकर अपील सं./Ita Nos.266 & 267/Srt/2019 Assessment Years: (2013-14 To 2014-15) (Virtual Court Hearing) The Ito, Ward-2(3)(8), Vs. Mukesh Babulal Parlechav, Surat. 201, Panchratna Appartment, Dalgiya Mohalla, Mahidharpura, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apopp4334F (Appellant) (Respondent) Assessee By Shri Mehul Shah, Ca Respondent By Shri H. P. Meena, Cit(Dr) & Shri Vinod Kumar, Sr. Dr Date Of Hearing 08/07/2022 Date Of Pronouncement 25/07/2022

Section 143(3)

Gautam Jain Group. The Assessing Officer was in possession of information that a search and seizure action has been carried out by the investigation Wing, Mumbai on the Gautam Jain Group which was indulged in providing of accommodation entries in the form of unsecured loans, bogus purchases/sales to the interested ... various documentary evidences furnished by assessee. The ld. CIT-DR for the Revenue supported the order of AO. The ld. CIT-DR submits that Investigation Wing, Mumbai made a search on Bhanwarlal Jain Group. During the search and after search, the Investigation Wing made a thorough investigation and concluded that

ITO, Ward-2(3)(8), Surat vs. Mukesh Babulal Parlecha, Surat

In the result, appeals filed by the assessees (ITA Nos

ITA 266/SRT/2019[2013-14]Status: DisposedITAT Surat25 Jul 2022AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.225 & 226/Srt/2019 Assessment Years: (2013-14 To 2014-15) (Virtual Court Hearing) Mukesh Babulal Parlechav, Vs. The Ito, Ward-2(3)(8), 201, Panchratna Appartment, Dalgiya Surat. Mohalla, Mahidharpura, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apopp4334F (Appellant) (Respondent) आयकर अपील सं./Ita Nos.266 & 267/Srt/2019 Assessment Years: (2013-14 To 2014-15) (Virtual Court Hearing) The Ito, Ward-2(3)(8), Vs. Mukesh Babulal Parlechav, Surat. 201, Panchratna Appartment, Dalgiya Mohalla, Mahidharpura, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apopp4334F (Appellant) (Respondent) Assessee By Shri Mehul Shah, Ca Respondent By Shri H. P. Meena, Cit(Dr) & Shri Vinod Kumar, Sr. Dr Date Of Hearing 08/07/2022 Date Of Pronouncement 25/07/2022

Section 143(3)

Gautam Jain Group. The Assessing Officer was in possession of information that a search and seizure action has been carried out by the investigation Wing, Mumbai on the Gautam Jain Group which was indulged in providing of accommodation entries in the form of unsecured loans, bogus purchases/sales to the interested ... various documentary evidences furnished by assessee. The ld. CIT-DR for the Revenue supported the order of AO. The ld. CIT-DR submits that Investigation Wing, Mumbai made a search on Bhanwarlal Jain Group. During the search and after search, the Investigation Wing made a thorough investigation and concluded that

Mukesh Babulal Parlecha, Surat vs. ITO, Ward-2(3)(8), Surat

In the result, appeals filed by the assessees (ITA Nos

ITA 226/SRT/2019[2014-15]Status: DisposedITAT Surat25 Jul 2022AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.225 & 226/Srt/2019 Assessment Years: (2013-14 To 2014-15) (Virtual Court Hearing) Mukesh Babulal Parlechav, Vs. The Ito, Ward-2(3)(8), 201, Panchratna Appartment, Dalgiya Surat. Mohalla, Mahidharpura, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apopp4334F (Appellant) (Respondent) आयकर अपील सं./Ita Nos.266 & 267/Srt/2019 Assessment Years: (2013-14 To 2014-15) (Virtual Court Hearing) The Ito, Ward-2(3)(8), Vs. Mukesh Babulal Parlechav, Surat. 201, Panchratna Appartment, Dalgiya Mohalla, Mahidharpura, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apopp4334F (Appellant) (Respondent) Assessee By Shri Mehul Shah, Ca Respondent By Shri H. P. Meena, Cit(Dr) & Shri Vinod Kumar, Sr. Dr Date Of Hearing 08/07/2022 Date Of Pronouncement 25/07/2022

Section 143(3)

Gautam Jain Group. The Assessing Officer was in possession of information that a search and seizure action has been carried out by the investigation Wing, Mumbai on the Gautam Jain Group which was indulged in providing of accommodation entries in the form of unsecured loans, bogus purchases/sales to the interested ... various documentary evidences furnished by assessee. The ld. CIT-DR for the Revenue supported the order of AO. The ld. CIT-DR submits that Investigation Wing, Mumbai made a search on Bhanwarlal Jain Group. During the search and after search, the Investigation Wing made a thorough investigation and concluded that