← 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

Adesh Kumar Gupta, Delhi vs. Income Tax Officer, Ward 62(1), Delhi

In the result, ground no. 2 & 3 of the appeal is partly

ITA 6930/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Dec 2025AY 2019-20

Bench: Shri Pawan Singh(Physical Hearing) Adesh Kumar Gupta Ito, Ward-62(1), Delhi House No. 6, Sector -11, Pocket-C- Vs Civic Centre, Delhi – 110002. 5, Rohini, Delhi – 110085. [Pan: Aaipg9669H] Appellant / Assessee Respondent / Revenue

Section 145Section 147Section 254(1)Section 69C

Revenue submits that assessing officer made addition on the basis of information which were based on sufficient evidence calculated by Investigation Wing in a search action on Sanjay Jain and his group. The assessee is one of the beneficiary of purchases shown from Sanjay Jain Group. The entity namely Jain ... case of assessee was reopened on the basis of information in the insight portal with assessing officer that search action was carried out by Investigation Wing on 29 premises related to Sanjay Jain and his associate, who were providing bogus transaction. During assessment, the assessing officer noted that the assessee

Bansal Industries, Hansi vs. ITO Ward 1 Hissar, Hissar

In the result, the appeal filed by the assessee for A

ITA 5404/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad

Section 143(2)Section 147Section 148Section 151

outset referring to ground No.1 submitted that in the assessee’s case the assessment was reopened based only on the report of the Investigation Wing on the ground that certain accommodation entries were obtained by the assessee. The Ld. Counsel stated that during the A.Y.2015-16 the assessee had not received/obtained

Bansal Industries, Hansi vs. ITO Ward 1 Hissar, Hissar

In the result, the appeal filed by the assessee for A

ITA 5395/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri C.N. Prasad

Section 143(2)Section 147Section 148Section 151

outset referring to ground No.1 submitted that in the assessee’s case the assessment was reopened based only on the report of the Investigation Wing on the ground that certain accommodation entries were obtained by the assessee. The Ld. Counsel stated that during the A.Y.2015-16 the assessee had not received/obtained

Optus Developers Pvt Ltd, Delhi vs. ACIT, Central Circle-32, New Delhi

The appeals are allowed and

ITA 4385/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Dec 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Sh. KapilGoel, AdvFor Respondent: Sh. Jitender Singh, CIT, DR
Section 132Section 139Section 147Section 148Section 148A

stated to be purported search action on one Sh. Abhishek Kumar Munka with date of search as 17.09.2021 and information received from Kolkata investigation wing. The above order led to issue of impugned jurisdictional notice u/s 148 under the Act dated 30.03.2023. 7. Then if the impugned assessment order dated

Optus Developers Pvt Ltd, Delhi vs. ACIT, Central Circle-32, New Delhi

The appeals are allowed and

ITA 4384/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Sh. KapilGoel, AdvFor Respondent: Sh. Jitender Singh, CIT, DR
Section 132Section 139Section 147Section 148Section 148A

stated to be purported search action on one Sh. Abhishek Kumar Munka with date of search as 17.09.2021 and information received from Kolkata investigation wing. The above order led to issue of impugned jurisdictional notice u/s 148 under the Act dated 30.03.2023. 7. Then if the impugned assessment order dated

Uma Strips Limited, Delhi vs. ACIT, Circle-27(1), Delhi

In the result, appeal of the assessee in ITA No

ITA 2507/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Neeraj Mangla, CAFor Respondent: Ms. Pooja Swaroop, CIT- DR
Section 115BSection 133(6)Section 142(1)Section 143(2)Section 143(3)Section 68

Baba Metals Pvt Ltd ( Rs 31,00,000/-), during the year under consideration. The Assessing Officer, had information from the Investigation Wing that the assessee company was in list of Indian exporters and importers transacting with FIU listed foreign entities suspected to be involved in Hawala transactions. The AO also ... additional evidence which was cryptically accepted by the CIT(A). 14. On the other hand, the ld DR pointed to the report of the Investigation Wing that the lender of the assessee is not genuine. The ld DR submitted that the supporting documents furnished are self serving and the explanation

Vishal Singhal, Ghaziabad vs. ITO, Ward 2(2)(1), Ghaziabad

ITA 4106/DEL/2024[2016-17]Status: DisposedITAT Delhi17 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklamr. Vishal Singhal Vs. Nfac, G-35, B, Patel Nagar Iii, Ward 2(2)(1) Ghaziabad Cgo Complex-Ii, Purani Uttar Pradesh - 201001 Hapur Chungi, Ghaziabad, Uttar Pradesh 201002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Dijps2427H Appellant .. Respondent Appellant By : Sh. Gagan R. Khandelwal, Adv, Sh. Rajiv Khandelwal, Ca, Sh. Jaind Kumar Jaiswal, Adv. Respondent By : Sh. Om Prakash, Sr. Dr Date Of Hearing 15.12.2025 Date Of Pronouncement 17.12.2025

For Appellant: Sh. Gagan R. Khandelwal, AdvFor Respondent: Sh. Om Prakash, Sr. DR
Section 10(38)Section 131(1)(d)Section 147Section 148Section 68Section 69C

recognised stock exchange (the BSE). (d) Pre-arranged transaction (e) Commission under section 131(1)(d) was sent by Assessing Office to the Investigation Wing, Delhi and Kolkata. The Assessing Officer P a g e | 4 Mr. Vishal Singhal (AY:2016-17) states that reports from the respective Wings have

Gian Gupta, New Delhi vs. ACIT, Circle- 33(1), New Delhi

In the result, this appeal is allowed

ITA 1307/DEL/2024[2011-12]Status: DisposedITAT Delhi17 Dec 2025AY 2011-12

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.1307/Del/2024 िनधा"रणवष"/Assessment Year: 2011-12 बनाम Gian Gupta, Acit, Kh. No. 389/2/2-415, Vs. Circle 33(1), Civic Centre, Ford Service Centre, Nh-8, Rangpuri, Minto Road, New Delhi. New Delhi. Pan No.Aaapg7797G अपीलाथ" Appellant ""यथ"/Respondent

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

original assessment was done u/s 143(3) of the Act on 28.03.2014. Thereafter, ostensibly on account of some allegedly incriminating information received from the Investigation Wing, the Ld. AO issued a notice u/s 148 of the Act dated 28.03.2018. Since the wording of the reasons recorded has considerable bearing ... section 143(3) of the Act. 6. That the notice under section 148 of the Act is issued only on the basis of the investigation wing report without any independent application of mind by the Assessing officer. There is no independent application of mind. Hence, the proceeding is illegal

Gayathri Global Resources Private Limited, Jamshedpur vs. ITO Ward (1), Jamshedpur

In the result, both the appeals are allowed for statistical purposes

ITA 96/RAN/2025[2014-15]Status: DisposedITAT Ranchi16 Dec 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.456/Ran/2024 Assessment Year: 2013-14 Gayatri Global Pvt. Ltd …………….…….…............................……….……Appellant 153, Kamani Centre, Bistupur, Jharkhand-831001. [Pan: Aadcg3732B] Vs. Nfac, New Delhi…….....………...….…..….........……........……...…..…..Respondent I.T.A. No.96/Ran/2025 Assessment Year: 2014-15 Gayatri Global Pvt. Ltd …………….…….…............................……….……Appellant 153, Kamani Centre, Bistupur, Jharkhand-831001. [Pan: Aadcg3732B] Vs. Nfac, New Delhi…….....………...….…..….........……........……...…..…..Respondent Appearances By: Shri Manish Agarwal, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : December 16, 2025 Order Per Sonjoy Sarma: These Two Appeals Are Filed By The Assessee For The Assessment Years 2013–14 & 2014–15. Since The Issues Involved, The Assessment Proceedings & The Additions Made Are Common & On Identical Issues, Both The Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order. For The Sake Of Convenience, We First Take Up

Section 115BSection 144Section 147Section 148Section 68

I.T.A. No.456/Ran/2024 Gayatri Global Pvt. Ltd section 148 of the Income-tax Act, 1961 was issued on the basis of information received from the Investigation Wing alleging that the assessee had received share application money amounting to ₹37,44,600. During the reassessment proceedings, the Assessing Officer issued notices calling

Gayatri Global Private Limited, Jamshedpur vs. National Faceless Assessment Centre, New Delhi

In the result, both the appeals are allowed for statistical purposes

ITA 456/RAN/2024[2013-14]Status: DisposedITAT Ranchi16 Dec 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.456/Ran/2024 Assessment Year: 2013-14 Gayatri Global Pvt. Ltd …………….…….…............................……….……Appellant 153, Kamani Centre, Bistupur, Jharkhand-831001. [Pan: Aadcg3732B] Vs. Nfac, New Delhi…….....………...….…..….........……........……...…..…..Respondent I.T.A. No.96/Ran/2025 Assessment Year: 2014-15 Gayatri Global Pvt. Ltd …………….…….…............................……….……Appellant 153, Kamani Centre, Bistupur, Jharkhand-831001. [Pan: Aadcg3732B] Vs. Nfac, New Delhi…….....………...….…..….........……........……...…..…..Respondent Appearances By: Shri Manish Agarwal, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : December 16, 2025 Order Per Sonjoy Sarma: These Two Appeals Are Filed By The Assessee For The Assessment Years 2013–14 & 2014–15. Since The Issues Involved, The Assessment Proceedings & The Additions Made Are Common & On Identical Issues, Both The Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order. For The Sake Of Convenience, We First Take Up

Section 115BSection 144Section 147Section 148Section 68

I.T.A. No.456/Ran/2024 Gayatri Global Pvt. Ltd section 148 of the Income-tax Act, 1961 was issued on the basis of information received from the Investigation Wing alleging that the assessee had received share application money amounting to ₹37,44,600. During the reassessment proceedings, the Assessing Officer issued notices calling

Deputy Commissioner of Income Tax Circle 2 1 1 Ahmedabad, Ahmedabad vs. Sunali Biren Shah, Ahmedabad

In the result, the appeal filed by the Department is dismissed the Cross

ITA 1726/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Kamal Deep Singh, Sr. DRFor Respondent: Shri Kamal Deep Singh, Sr. DR
Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 271(1)(c)

return was processed under section 143(1) of the Income-tax Act, 1961 (“the Act”). Subsequently, based on information received from the Investigation Wing alleging misuse of the National Multi Commodity Exchange (NMCE) platform and systematic tax evasion by certain clients/members through booking of fictitious profits and losses, reassessment proceedings ... income on 30.04.2018 declaring total income of ₹3,52,080/-. 4.1 During the reassessment proceedings, the Assessing Officer relied upon information received from the Investigation Wing and also obtained details from NMCE by issuing a notice under section 133(6) of the Act. On the basis of the reply received

Vijaykumar Ukabhai Patel, Mehsana vs. Income Tax Office, Ward 1, Mehsana

The appeal of the assessee is allowed for statistical purposes

ITA 1712/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Abhijit, Sr. DR
Section 144Section 147Section 148Section 69A

claiming exempt income of ₹37,16,666/- on account of sale of agricultural land. Subsequently, based on information received from the Investigation Wing pursuant to a search action conducted in the case of VEE GEE Group, reassessment proceedings were initiated. The Assessing Officer initiated reassessment proceedings and during the reassessment

Rakeshkumar Mahendrakumar Shah, Ahmedabad vs. The ACIT, Central Circle-1(3), Ahmedabad

The appeal of the assessee stand dismissed, and the order of the CIT(Appeals) is hereby affirmed in toto

ITA 1724/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Urvashi Sodhan, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 132Section 132(4)Section 139(1)Section 143(1)Section 143(3)Section 28Section 69A

reiterating similar claims was filed during assessment. The Assessing Officer rejected both affidavits as afterthoughts, noting that the assessee never complained before the Investigation Wing, provided no evidence of having applied for copies of statements, and himself admitted in the affidavit that he had “no memory” of what was recorded

ACIT Central Circle 1(3), Ahmedabad vs. Rakeshkumar Mahendrakumar Shah, Ahmedabad

The appeal of the assessee stand dismissed, and the order of the CIT(Appeals) is hereby affirmed in toto

ITA 1713/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Urvashi Sodhan, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 132Section 132(4)Section 139(1)Section 143(1)Section 143(3)Section 28Section 69A

reiterating similar claims was filed during assessment. The Assessing Officer rejected both affidavits as afterthoughts, noting that the assessee never complained before the Investigation Wing, provided no evidence of having applied for copies of statements, and himself admitted in the affidavit that he had “no memory” of what was recorded

Manish Gupta, Gurgaon vs. ITO Ward 2(4), Gurgaon

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

ITA 7269/DEL/2025[2012-13]Status: DisposedITAT Delhi16 Dec 2025AY 2012-13

Bench: Shri Vikas Awasthyआअसं.7269/धिल्ली/2025 (नि.व. 2012-13) Manish Gupta, H-101, Surya Vihar Complex, Near Kapashera Border, Gurgaon, Haryana 122016 ...... अपीलार्थी/Appellant Pan: Amppg-7521-B बिाम Vs. Income Tax Officer, Ward-2(4), ..... प्रनिवादी/Respondent Gurgaon, Haryana 122016 अपीलार्थी द्वारा/Appellant By : Shri Chandresh Gupta & Ms. Manisha Lahoti Chartered Accountants प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 16/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against An Ex-Parte Order Of Joint/Additional Commissioner Of Income Tax (Appeals), Agra [In Short ‘The Cit(A)’] Dated 12.09.2025, For The Assessment Year 2012-13. 2. Shri Chandresh Gupta, Appearing On Behalf Of The Assessee Submits That The Assessment Was Reopened On The Basis Of Information Received From The Investigation Wing Alleging Investment In Immovable Property Amounting To Rs. 80,86,553/-. In Reassessment Proceedings, The Assessee Explained Source Of Investment. The Ao Accepted Source Of Entire Investments Except Rs.15,00,000/-. The Assessing Officer (Ao) Held That An Amount Of Rs.15,00,000/- Stated To Be Sale

For Appellant: Shri Chandresh Gupta & Ms. Manisha LahotiFor Respondent: Shri Manoj Kumar, Sr. DR
Section 69A

Shri Chandresh Gupta, appearing on behalf of the assessee submits that the assessment was reopened on the basis of information received from the Investigation Wing alleging investment in immovable property amounting to Rs. 80,86,553/-. In reassessment proceedings, the assessee explained source of investment. The AO accepted source

DCIT, Delhi vs. Sephan Lubricants Private Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 7255/DEL/2025[2020-21]Status: DisposedITAT Delhi16 Dec 2025AY 2020-21

Bench: Shri Vikas Awasthyआअसं.7255/धिल्ली/2025 (नि.व. 2020-21) Deputy Commissioner Of Income Tax, ...... अपीलार्थी/Appellant 348, Ara Centre, E2, Jhandewalan, New Delhi 110055 बिाम Vs. Sephan Lubricants P. Ltd., M-10, Sec-5, Bawana Industrial Area, New Delhi ...... प्रनिवादी/Respondent Pan: Aaocs-1829-E अपीलार्थी द्वारा/Appellant By : Shri Manoj Kumar, Sr. Dr प्रधििािीद्वारा/Respondent By : Shri Ankit Kumar, Advocate सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 16/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-29, Delhi [In Short ‘The Cit(A)’] Dated 18.07.2025, For The Assessment Year 2020-21. 2. The Appeal Is Time Barred By 12 Days. The Revenue Has Filed An Application Citing Reasons Causing Delay In Filing Of Appeal. After Perusal Of The Same, I Am Satisfied That Delay In Filing Of Appeal Is Not Intentional, The Delay Has Been Caused For The Reasons Stated In Petition Which Appears To Be Bonafide. Thus, Delay Of 12 Days In Filing Of Appeal Is Condoned & Appeal Is Admitted For Decision On Merits.

For Appellant: Shri Manoj Kumar, Sr. DRFor Respondent: Shri Ankit Kumar, Advocate
Section 132Section 147Section 68Section 69C

return of income for the assessment year under consideration on 05.02.2021 declaring total income of Rs.1,40,080/-. Information was received from the Investigation Wing pursuant to search conducted u/s. 132 of the Income Tax Act,1961(hereinafter referred to as ‘the Act’) on Galaxy Group and alleged entry operators

Damandeep Kaur, Mohali vs. Assistant Commissioner of Income Tax (Central Circle-2), Chandigarh

In the result, all appeals of the assessee are allowed

ITA 902/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh15 Dec 2025AY 2020-21
Section 10(3)Section 153ASection 245D(4)

treated as a resident for the\nrelevant years. In our view, this fact has been independently verified and\naccepted by the Black Money Investigation Wing and the FRRO, whose findings\nare binding and consistent with the statutory framework of Section 6. The finding\nof the FRRO and Black Money Investigation

Damandeep Kaur, Mohali vs. Assistant Commissioner of Income Tax (Central Circle-2), Chandigarh

In the result, all appeals of the assessee are allowed

ITA 901/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh15 Dec 2025AY 2019-20
Section 10(3)Section 153ASection 245D(4)

treated as a resident for the\nrelevant years. In our view, this fact has been independently verified and\naccepted by the Black Money Investigation Wing and the FRRO, whose findings\nare binding and consistent with the statutory framework of Section 6. The finding\nof the FRRO and Black Money Investigation

Damandeep Kaur, Mohali vs. Assistant Commissioner of Income Tax (Central Circle-2), Chandigarh

In the result, all appeals of the assessee are allowed

ITA 900/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh15 Dec 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

treated as a resident for the relevant years. In our view, this fact has been independently verified and accepted by the Black Money Investigation Wing and the FRRO, whose findings are binding and consistent with the statutory framework of Section 6. The finding of the FRRO and Black Money Investigation

Damandeep Kaur, Mohali vs. Assistant Commissioner of Income Tax (Central Circle-2), Chandigarh

In the result, all appeals of the assessee are allowed

ITA 899/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh15 Dec 2025AY 2016-17
For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

treated as a resident for the\nrelevant years. In our view, this fact has been independently verified and\naccepted by the Black Money Investigation Wing and the FRRO, whose findings\nare binding and consistent with the statutory framework of Section 6. The finding\nof the FRRO and Black Money Investigation