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“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

Karishma Jain, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1, Guwahati

In the result, the all the appeals of the assessees are allowed

ITA 309/GTY/2019[2016-17]Status: DisposedITAT Guwahati18 Dec 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar Karnani
Section 132Section 143(2)Section 153ASection 153D

dispute essentially emanates from a search and seizure operation which was conducted on 18.11.2016 under Section 132 of the Act by the Investigation Wing in Nayyar Group of cases, including the residential premises of the assessee. The said operation was followed by a survey operation under Section 133A

Karishma Jain, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1, Guwahati

In the result, the all the appeals of the assessees are allowed

ITA 308/GTY/2019[2015-16]Status: DisposedITAT Guwahati18 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar Karnani
Section 132Section 143(2)Section 153ASection 153D

dispute essentially emanates from a search and seizure operation which was conducted on 18.11.2016 under Section 132 of the Act by the Investigation Wing in Nayyar Group of cases, including the residential premises of the assessee. The said operation was followed by a survey operation under Section 133A

Reshmi Jain, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1, Guwahati

In the result, the all the appeals of the assessees are allowed

ITA 307/GTY/2019[2016-17]Status: DisposedITAT Guwahati18 Dec 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar Karnani
Section 132Section 143(2)Section 153ASection 153D

dispute essentially emanates from a search and seizure operation which was conducted on 18.11.2016 under Section 132 of the Act by the Investigation Wing in Nayyar Group of cases, including the residential premises of the assessee. The said operation was followed by a survey operation under Section 133A

Reshmi Jain, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1, Guwahati

In the result, the all the appeals of the assessees are allowed

ITA 306/GTY/2019[2015-16]Status: DisposedITAT Guwahati18 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar Karnani
Section 132Section 143(2)Section 153ASection 153D

dispute essentially emanates from a search and seizure operation which was conducted on 18.11.2016 under Section 132 of the Act by the Investigation Wing in Nayyar Group of cases, including the residential premises of the assessee. The said operation was followed by a survey operation under Section 133A

Belong Tracom Private Limited, Kolkata vs. Income Tax Officer, Ward-2(1), Dibrugahr

In the result, the appeal of the assessee is allowed

ITA 254/GTY/2019[2011-12]Status: DisposedITAT Guwahati18 Dec 2025AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shrimanomohan Das, Jm Belong Tracom Private Limited Income Tax Officer, Ward 2(1) 3, Mullick Street, Kolkata- C.R. Building, Mancotta Road, Vs. 700007, West Bengal Dibrugarh-786008, Assam (Appellant) (Respondent) Pan No. Aaecb0435D Assessee By : Shri Miraj D Shah, Ar Revenue By : Shri Kausik Ray, Dr Date Of Hearing: 18.09.2025 Date Of Pronouncement: 18.12.2025

For Appellant: Shri Miraj D Shah, ARFor Respondent: Shri Kausik Ray, DR
Section 143(1)Section 143(3)Section 147Section 148Section 68

after recording reasons to believe which are extracted below:- "Investigation was made in the case of M/s Hector Dealers Pvt Ltd by Investigation wing, Kolkata wherein it was discovered that the company M/s Hector Dealers Pvt Ltd which is a shell company and its Director Shri Chandresh. Kumar Jain being ... required to verify.” 2.1. A perusal of the above reason reveals that the ld. AO has simply extracted the information received from the investigation wing and has not recorded his own reasons to believe or objective satisfaction to reopen the assessment. In our view there is no satisfaction recorded

Sushil Mitruka, Siliguri vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 2178/KOL/2025[2014-2015]Status: DisposedITAT Kolkata18 Dec 2025AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

total income of ₹11,10,020/- u/s 139(1) of the Act. Thereafter, the ld. AO on the basis of information received from DDIT, investigation, Wing Siliguri, reopened the assessment u/s 147 of the Act by issuing notice u/s 148 of the Act on 31.03.2021. The assessee complied with ... invalid reopening of assessment. 2.3. After hearing the rival contentions and perusing the materials available on record, we find that the ld. DDIT (Investigation) Wing, vide letter dated 30.11.2019, informed the ld. AO that assessee has entered into some suspicious transactions by forwarding the report

DCIT, Central Circle-4(3), Kolkata vs. Raja Shelters Private Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1760/KOL/2025[2022-23]Status: DisposedITAT Kolkata18 Dec 2025AY 2022-23
Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 68

Shri Salasar Suppliers Pvt. Ltd.\n5.2 The ld. AR also submits that the statement of Sri Girdhari Lal\nGoenka recorded by the Investigation Wing in the course of search and\nthe same was retracted. His submission is that the summons u/s 133(6)\nwere issued to all the loan creditors

Sushil Mitruka, Darjeeling vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 1631/KOL/2025[2016-2017]Status: DisposedITAT Kolkata18 Dec 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

total income of ₹11,10,020/- u/s 139(1) of the Act. Thereafter, the ld. AO on the basis of information received from DDIT, investigation, Wing Siliguri, reopened the assessment u/s 147 of the Act by issuing notice u/s 148 of the Act on 31.03.2021. The assessee complied with ... invalid reopening of assessment. 2.3. After hearing the rival contentions and perusing the materials available on record, we find that the ld. DDIT (Investigation) Wing, vide letter dated 30.11.2019, informed the ld. AO that assessee has entered into some suspicious transactions by forwarding the report

Sushil Mitruka, Darjeeling vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals\nof the assessee are allowed

ITA 1630/KOL/2025[2015-2016]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-2016

Bench: Shri Rajesh Kumar, Am\Nand\Nshri Pradip Kumar Choubey, Jm\Nita Nos.2178, 1630 & 1631/Kol/2025\N(Assessment Years: 2014-15, 2015-16 & 2016-17)\Nsushil Mitruka\Ng208, City Centre, Office Block,\Np.O. Matigara, Siliguri,\Ndarjeeling, Siliguri-734010,\Nwest Bengal\N(Appellant)\Nvs.\Ndcit, Circle 1,\Naaykar Bhawan, Matigara,\Nsiliguri-734004,\Nwest Bengal\N(Respondent)\Npan No. Accpa9340F\Nita No. 1613/Kol/2025\N(Assessment Years: 2017-18)\Ndcit, Circle 1,\Naaykar Bhawan, Matigara,\Nsiliguri-734004,\Nwest Bengal\N(Appellant)\Nvs.\Nsushil Mitruka\Ng208, City Centre, Office Block,\Np.O. Matigara, Siliguri,\Ndarjeeling, Siliguri-734010,\Nwest Bengal\N(Respondent)\Nassessee By\Nshri Sk Tulsian, Ar\Nrevenue By\Nshri S.B. Chakraborthy, Dr\Ndate Of Hearing:\N03.12.2025\Ndate Of Pronouncement:\N18.12.2025\Norder\Nper Rajesh Kumar, Am:\Nthese Appeals Preferred By The Assessee & Revenue Against\Nthe Orders Of The National Faceless Appeal Centre, Delhi (Hereinafter\Nreferred To As The “Ld. Cit(A)”] Dated 28.08.2025, 27.05.2025 For A.Y.\N2014-15, 2015-16, 2016-17 & 2017-18. Since The Appeals Are Relating\Nto Same Assessee & Involves Commons Issues, Therefore All These\Nappeals Are Decided By This Consolidated Order For The Sake Of Brevity.\Npage 2\Nita Nos.2178,1630,1630 & 1631/Kol/2025\Nsushil Mitruka; Ays 2014-15, 15-16, 16-17 & 17-18\Nfirst Of All We Shall Take Ita No. 2178/Kol/2025 A.Y. 214-15 For\Nadjudication.\Nα.Υ. 2014-15\Nita No. 2178/Kol/2025\N2.\Nthe Issue Raised In Ground No.1 Is Against The Order Of Ld. Cit (A)\Nupholding The Reopening Of Assessment, Which Was Based Upon\Nborrowed Satisfaction Without Examining The Records & Without\Napplication Of Mind & Accordingly, The Reopening Of Assessment Bas\Nbad In Law.\N2.

Section 144BSection 147Section 148Section 148(2)

total income of ₹11,10,020/- u/s\n139(1) of the Act. Thereafter, the Ld. AO on the basis of information\nreceived from DDIT, investigation, Wing Siliguri, reopened the\nassessment u/s 147 of the Act by issuing notice u/s 148 of the Act on\n31.03.2021. The assessee complied with ... invalid reopening\nof assessment.\n2. 3. After hearing the rival contentions and perusing the materials\navailable on record, we find that the Ld. DDIT (Investigation) Wing,\nvide letter dated 30.11.2019, informed the Ld. AO that assessee has\nentered into some suspicious transactions by forwarding the report to\nthe

DCIT, Circle-1, Siliguri vs. Sushil Mitruka, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 1613/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Dec 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

total income of ₹11,10,020/- u/s 139(1) of the Act. Thereafter, the ld. AO on the basis of information received from DDIT, investigation, Wing Siliguri, reopened the assessment u/s 147 of the Act by issuing notice u/s 148 of the Act on 31.03.2021. The assessee complied with ... invalid reopening of assessment. 2.3. After hearing the rival contentions and perusing the materials available on record, we find that the ld. DDIT (Investigation) Wing, vide letter dated 30.11.2019, informed the ld. AO that assessee has entered into some suspicious transactions by forwarding the report

DCIT, Central Circle-1(4), Kolkata vs. Educo Ventures Pvt Ltd., Kolkata

Appeal is dismissed

ITA 2144/KOL/2024[2015-16]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-16

Bench: the AO.

Section 133ASection 147Section 250Section 68

addition the AO has stated in the assessment order that the impugned unsecured loans have been taken from the paper/Jamakharchi Companies because as per Investigation Wing data base, the Company M/s Bholenath Commosale Pvt. Ltd. and M/s. Anamika Dealmark Pvt. Ltd. were controlled and managed by entry operator Pranaw Kumar ... found in the survey against the assessee. 5.2.9 Furthermore, the AO has heavily relied on the statement of entry operators and data base of investigation wing, Kolkata in arriving at the conclusion that the above loan creditors were the Jamakharchi/Paper Companies and have been used for giving accommodation entries

DCIT Central Circle 1(4), Kolkata vs. Educo Ventures Pvt Ltd, Kolkata

Appeal is dismissed

ITA 2125/KOL/2024[2014-15]Status: DisposedITAT Kolkata18 Dec 2025AY 2014-15

Bench: the AO.

Section 133ASection 147Section 250Section 68

addition the AO has stated in the assessment order that the impugned unsecured loans have been taken from the paper/Jamakharchi Companies because as per Investigation Wing data base, the Company M/s Bholenath Commosale Pvt. Ltd. and M/s. Anamika Dealmark Pvt. Ltd. were controlled and managed by entry operator Pranaw Kumar ... found in the survey against the assessee. 5.2.9 Furthermore, the AO has heavily relied on the statement of entry operators and data base of investigation wing, Kolkata in arriving at the conclusion that the above loan creditors were the Jamakharchi/Paper Companies and have been used for giving accommodation entries

Educo Ventures Pvt. Ltd., Kolkata vs. D.C.I.T., Central Circle - 1(4), Kolkata

Appeal is dismissed

ITA 2025/KOL/2024[2020-2021]Status: DisposedITAT Kolkata18 Dec 2025AY 2020-2021

Bench: the AO.

Section 133ASection 147Section 250Section 68

addition the AO has stated in the assessment order that the impugned unsecured loans have been taken from the paper/Jamakharchi Companies because as per Investigation Wing data base, the Company M/s Bholenath Commosale Pvt. Ltd. and M/s. Anamika Dealmark Pvt. Ltd. were controlled and managed by entry operator Pranaw Kumar ... found in the survey against the assessee. 5.2.9 Furthermore, the AO has heavily relied on the statement of entry operators and data base of investigation wing, Kolkata in arriving at the conclusion that the above loan creditors were the Jamakharchi/Paper Companies and have been used for giving accommodation entries

Educo Ventures Pvt. Ltd., Kolkata vs. D.C.I.T., Central Circle - 1(4), Kolkata

Appeal is dismissed

ITA 2024/KOL/2024[2015-2016]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-2016

Bench: the AO.

Section 133ASection 147Section 250Section 68

addition the AO has stated in the assessment order that the impugned unsecured loans have been taken from the paper/Jamakharchi Companies because as per Investigation Wing data base, the Company M/s Bholenath Commosale Pvt. Ltd. and M/s. Anamika Dealmark Pvt. Ltd. were controlled and managed by entry operator Pranaw Kumar ... found in the survey against the assessee. 5.2.9 Furthermore, the AO has heavily relied on the statement of entry operators and data base of investigation wing, Kolkata in arriving at the conclusion that the above loan creditors were the Jamakharchi/Paper Companies and have been used for giving accommodation entries

Alpesh K. Ajmera HUF, Mumbai vs. Income Tax Officer Ward 18(1)(1), Mumbai

In the result, the appeal filed by the assessee stands\nallowed

ITA 4041/MUM/2025[2011-12]Status: DisposedITAT Mumbai18 Dec 2025AY 2011-12
Section 132Section 68Section 69

Ajmera HUF Mumbai.\npurchase and sale of the shares. The Assessing Officer\nexamined the material and also took note of the findings of\nthe Investigation Wing, Ahmedabad, which allegedly\nrevealed a penny stock accommodation entry mechanism\nin respect of the scrip Prraneta Industries Ltd.\n5.\nThereafter AO concluded that there ... represented prearranged\naccommodation entry, treating the sale proceeds as\n‘unexplained cash credit' u/s 68 of the Act. Whereas Ld.\nAR specifically submitted that investigation Wing\",\n\"Findings in the case of Assessee\", \"Share Purchase/Sale\nAnalysis\", the Ld. AO has explained the Modus Operandi of\nthe Unscrupulous Operators, who were

Ramchandra Kadava Sharma, Mumbai vs. Income Tax Officer, Mumbai

ITA 4360/MUM/2024[2010-11]Status: DisposedITAT Mumbai18 Dec 2025AY 2010-11

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

For Appellant: Mr. Jay Bhansali, ARFor Respondent: Assessee by
Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250(6)Section 69C

material available on record. Going through the factum of case, we find that the AO has received certain information from Sales Tax Department thorough Investigation wing according to which certain purchases were made by the assessee amounting to Rs. 35,82,062/- from alleged bogus parties, who are involved

Principal Commissioner Of Income Tax Central Kanpur vs. Rajan Rajesh Kumar

The Appeal stands dismissed without being admitted

ITA/12/2024HC Uttarakhand17 Dec 2025

Bench: This Court Being Aggrieved By The Judgment & Order Dated 08.02.2024, Whereby The Appellate Tribunal Was Pleased To Allow The Appeal Of The Respondent. 3.

For Appellant: Mr. Hari Mohan Bhatia, learned counsel
Section 133ASection 151

SIDCUL and was holding the post of M.D., and was having close nexus with Shri Amit Sharma, the assessee surveyed. During enquiries conducted by Investigation Wing, it is found that Shri R. Rajesh Kumar was residing in the house owned by Shri Amit Sharma. He was also person responsible

Assistant Commissioner of Income Tax, Central Circle, Jamshedpur vs. Benko Traders Private Limited, Kolkata

In the result, the appeal filed by the Revenue is dismissed

ITA 436/RAN/2024[2015]Status: DisposedITAT Ranchi17 Dec 2025

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.436/Ran/2024 Assessment Year: 2015-16 Acit, Cc, Jamshedpur…………….…….…............................……….……Appellant Vs. Benko Traders Pvt. Ltd....………...….…..….........……........……...…..…..Respondent 119, 4Th Floor, Block D, White House, Park Stree, Wb – 700016. [Pan: Aabcb1888R] Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 07, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-3, Patna For The Assessment Year 2015–16 Dated 25.09.2024 Passed U/S 250 Of The Income Tax Act (The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Under Section 139 Of The Act Declaring A Total Income As Nil. The Return Was Processed Under Section 143(1). Subsequently, The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Was Completed On 28.11.2017 Determining The Total Income At ₹9,88,28,406. Based On Information Received From The Investigation Wing, Mumbai, Relating To Alleged Use Of Stock Exchange Platform (Bse/Nse) For Generating Fictitious Long-Term/Short-Term Capital Gains Through Certain Scripts & Alleged Accommodation Entries, The Assessing Officer Recorded Reasons Under Section 147 Of The Act. A Notice Under Section 148 Was Issued The Assessee Filed Its Return Declaring The Same Income

Section 139Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69C

assessment under section 143(3) was completed on 28.11.2017 determining the total income at ₹9,88,28,406. Based on information received from the Investigation Wing, Mumbai, relating to alleged use of stock exchange platform (BSE/NSE) for generating fictitious long-term/short-term capital gains through certain scripts and alleged accommodation

Indira Bai Jindal, Khargone vs. Income Tax Officer, NFAC

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

ITA 134/IND/2025[2013-14]Status: DisposedITAT Indore17 Dec 2025AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: None (Written request)For Respondent: Shri Ashish Porwal, Sr. DR
Section 142(1)Section 144BSection 147Section 148Section 271(1)(c)Section 271F

that the assessee, Smt. Indra Bai Jindal, filed her return of income for the relevant assessment year. Subsequently, based on information received from the Investigation Wing showing that the assessee was a beneficiary of accommodation entries, the Assessing Officer initiated reassessment proceedings by issuing notice under section ... observed that the notice under section 148 was duly issued and served, that the reopening was based on tangible material received from the Investigation Wing, and Indira Bai Jindal vs. ITO A.Y. 2013-14 that the Assessing Officer had formed a bona fide belief of escapement of income. Relying upon

Income Tax Officer/Ward-19(2)(2), Mumbai vs. Kruti Sandeep Shah, Mumbai

In the result, the appeal of the Revenue is disposed off in light of aforesaid directions

ITA 1968/MUM/2025[2009-10]Status: DisposedITAT Mumbai17 Dec 2025AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2009-10 Income Tax Officer, Kruti Sandeep Shah, Ward-19(2)(2), 117, Navyug Nagar Forjet Hill 503, 5Th Floor, Vs. Road, Piramal Chambers, Mumbai-400007. Parel, [Pan: Aapps4121F] Mumbai-400012. (Appellant) (Respondent) For Assessee : Shri Sandeep Shah For Revenue : Shri Kiran K. Chhatrapati, Sr.Dr Date Of Hearing : 16-12-2025 Date Of Pronouncement : 17-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 23-01-2025, Pertaining To Assessment Year (Ay) 2009-10. 2. Briefly The Facts Of The Case Are That The Assessee Filed Her Return Of Income U/S. 139(1) Of The Income Tax Act, 1961 („The Act‟) On 26-09-2009, Declaring Total Income Of Rs. 4,04,880/-. The Return Was Processed U/S. 143(1) Of The Act. Subsequently, The Ao Was In Receipt Of Information From The Investigation Wing That The Assessee Has Obtained Accommodation

For Appellant: Shri Sandeep ShahFor Respondent: Shri Kiran K. Chhatrapati, Sr.DR
Section 139(1)Section 142(1)Section 143(1)Section 144Section 145(3)Section 148

return was processed u/s. 143(1) of the Act. Subsequently, the AO was in receipt of information from the Investigation Wing that the assessee has obtained accommodation 2 entries in the form of bogus purchase bills to the tune of Rs. 34,20,545/- from various hawala parties as detailed