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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

ACIT, Circle-1(2), Surat vs. Lypsa Gems, Surat

In the result, grounds of appeal raised by Revenue are partly allowed

ITA 446/SRT/2019[2012-13]Status: DisposedITAT Surat13 May 2022AY 2012-13

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) A.C.I.T. M/S Lypsa Gems, Circle-1(2), Plot No. 230, Special Economic Vs. Surat. Zone, Sachin, Surat-394230. Pan : Aaefl 0483 G Appellant Respondednt

Section 10ASection 254(1)Section 69C

Lypsa Gems various bogus concerns including Kothari & Company, Little Diam, Jewel Diam and Rahul Export. The assessing officer was having such information as the investigation wing of revenue made a search action on Rajendra Jain Group. The assessee has shown purchases from Kothari & Company, Little Diam, Jewel Diam and Rahul ... income of assessee. The assessee filed its reply dated 30/03/2015 and stated that the alleged statement of Bhanwarlal Jain recorded by the Investigation Wing are general and self-contradictory. It relates to accommodation entries of purchase, loans and advances to various parties and not specific

DCIT vs. M/S Fiza Developers & Infrastructer Pvt. Ltd

In the result, the appeals of the revenue are allowed for statistical purposes and the COs of the assessee are dismissed

ITA 986/BANG/2013[2008-09]Status: DisposedITAT Bangalore13 May 2022AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri V. Chandrashekar &For Respondent: Shri Dilip, Standing Counsel for Dept
Section 131

conducted enquiry with PPL wherein they confirmed the completion of the project. It has also been brought on record by the AO that Investigation Wing conducted investigation in the post search proceedings and called the asse to produce books of accounts, vouchers, etc. for examination. However, the assessee

Flex Art Foil Ltd, Mumbai vs. DCIT-CC--4(2), Mumbai

In the result, the appeals of the assessee stand dismissed

ITA 5847/MUM/2019[2011-12]Status: DisposedITAT Mumbai12 May 2022AY 2011-12

Bench: Shri Vikas Awasthy & Shri Amarjit Singh

For Appellant: NoneFor Respondent: Achal Sharma
Section 132Section 132(1)Section 143(3)Section 153ASection 36(1)(iii)Section 69C

facts and circumstances of the case as well as in law, the Learned CIT(A) has erred in confirming the action of the investigation wing in initiating search and seizure action against the appellant, which is bad, illegal, void and is without jurisdiction as the same was merely on suspicion

Flex Art Foil Limited, Mumbai vs. DCIT Dd-4(2), Mumbai

In the result, the appeals of the assessee stand dismissed

ITA 5846/MUM/2019[2010-11]Status: DisposedITAT Mumbai12 May 2022AY 2010-11

Bench: Shri Vikas Awasthy & Shri Amarjit Singh

For Appellant: NoneFor Respondent: Achal Sharma
Section 132Section 132(1)Section 143(3)Section 153ASection 36(1)(iii)Section 69C

facts and circumstances of the case as well as in law, the Learned CIT(A) has erred in confirming the action of the investigation wing in initiating search and seizure action against the appellant, which is bad, illegal, void and is without jurisdiction as the same was merely on suspicion

Deputy Commissioner of Income Tax 3(2)(2), Mumbai vs. Phulchand Exports Private Limited, Mumbai

In the result, appeal filed by the revenue and cross objection filed by the assessee are dismissed

ITA 7214/MUM/2017[2008-09]Status: DisposedITAT Mumbai12 May 2022AY 2008-09

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Shankarlal JainFor Respondent: Shri Sandeep Raj
Section 147

Court of Bombay in VAMAN INTERNATIONAL LTD 107CCH 300 (BOM) confirmed deletion as made by ITAT of addition based on Vat Department information through Investigation Wing. Tribunal held that Assessing Officer could not bring on record any material evidence to show that the purchases were bogus. Mere reliance

Deputy Commissioner of Income Tax 3(2)(2), Mumbai vs. Phulchand Exports Private Limited, Mumbai

In the result, appeal filed by the revenue and cross objection filed by the assessee are dismissed

ITA 7213/MUM/2017[2011-12]Status: DisposedITAT Mumbai12 May 2022AY 2011-12

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Shankarlal JainFor Respondent: Shri Sandeep Raj
Section 147

Court of Bombay in VAMAN INTERNATIONAL LTD 107CCH 300 (BOM) confirmed deletion as made by ITAT of addition based on Vat Department information through Investigation Wing. Tribunal held that Assessing Officer could not bring on record any material evidence to show that the purchases were bogus. Mere reliance

Deputy Commissioner of Income Tax 3(2)(2), Mumbai vs. Phulchand Exports Private Limited, Mumbai

In the result, appeal filed by the revenue and cross objection filed by the assessee are dismissed

ITA 7212/MUM/2017[2010-11]Status: DisposedITAT Mumbai12 May 2022AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Shankarlal JainFor Respondent: Shri Sandeep Raj
Section 147

Court of Bombay in VAMAN INTERNATIONAL LTD 107CCH 300 (BOM) confirmed deletion as made by ITAT of addition based on Vat Department information through Investigation Wing. Tribunal held that Assessing Officer could not bring on record any material evidence to show that the purchases were bogus. Mere reliance

Vip Housing and Propertiees, Chennai vs. The Principle Chief Commissioner, Chennai Circle - 2(2)

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

ITA 46/CHNY/2022[2016-17]Status: DisposedITAT Chennai11 May 2022AY 2016-17

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri S. Sundar Raman, CAFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT
Section 143(3)Section 263

appeal filed by assessee has become infructuous. 4. We have heard rival contentions and noticed that the AO i.e., DCIT, Central Circle 2(2), Investigation Wing, Chennai passed order u/s.143(3) r.w.s. 263 of the Act vide order dated 31.03.2022 and no addition on the above subject was made

S.F.Dyes /Firm, Mumbai vs. A.C.Circle 17(1), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 2023/MUM/2021[2013-14]Status: DisposedITAT Mumbai11 May 2022AY 2013-14

Bench: Shri Om Prakash Kant ()And Shri Rahul Chaudhary () Assessment Year: 2013-14 S.F. Dyes/Firm A.C. Circle 17(1), First Floor, Hague Building, 9 Sprott Bandra Kurla Complex Road ,Ballard Estate, Vs. Mumbai-400051. Mumbai-400001. Pan No. Aacfs 5153 J Appellant Respondent

For Appellant: Mr. Shiv Prakash, ARFor Respondent: Mr. Hoshang B. Irani, DR
Section 131Section 143(3)Section 147Section 154Section 271(1)Section 271(1)(c)Section 35(1)(ii)

Officer during the assessment proceedings, in order to verification of payment made by the assessee issued commission u/s 131 of the Act to the Investigation Wing, Kolkata. In the report filed by the Investigation Wing of the Kolkata, it was found that the S.F. Dyes/Firms 4 ‘School of Human Genetics ... case are that the Assessing Officer based his findings on Survey action where bogus donation racket was unearthed and statements given to the Investigation wing that the institute provided accommodation entries for donors to claim bogus deduction u/s 35(1)ii) of the IT Act. The Assessee had withdrawn

Dy. Commissioner of Income Tax, Central Cir.-2, Surat vs. Shri Prabodhchabndra Jayantilal Patel, Surat

In the result, appeals filed by the Revenue ( in ITA nos

ITA 137/SRT/2021[2017-18]Status: DisposedITAT Surat10 May 2022AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.134 To 137/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) (Virtual Court Hearing) The Dcit, Central Circle-2, Vs. Shri Pravinchandra Dahyabhai Umriger, Surat. Bungalow No.01, Opp. Talao Street, Near Govindji Park, Umra, Surat-395007(Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabpu5216D The Dcit, Central Circle-2, Vs. Shri Vasantrai Ambaram Modi, Surat. 504, D/1, Subham Residency, Pal, Surat- 395005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acrpm0852D The Dcit, Central Circle-2, Vs. Shri Shankar Mulchand Uttamani, Surat. 1/3210-11, New Textile Market, Ring Road, Surat-395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahpu9028R The Dcit, Central Circle-2, Vs. Shri Prabodhchandra Jayantilal Patel, Surat. 297, Hari Narar-3, Opp. Brc Gate, Udhna, Surat-394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afvpp7466F (Assessee) (Respondent) Assessee By: Shri Rasesh Shah, Ca Revenue By: Shri Ritesh Mishra, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 02/03/2022 घोषणाक"तार"ख/Date Of Pronouncement : 10/05/2022 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Four Appeals Filed By The Revenue, Pertaining To Assessment Year (Ay) 2017-18, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri Ritesh Mishra, CIT(DR)
Section 143(3)

note that ld Counsel also contended that cross-examination of Shri Manoj C. Patel and Shri Jayantibhai Babariya whose statements were recorded by the Investigation Wing and also by the Assessing Officer, was requested from the Assessing Officer. However, the same has been denied by the Assessing Officer stating that

Dy. Commissioner of Income Tax, Central Cir.-2, Surat vs. Shri Shankar Mulchand Uttamani, Surat

In the result, appeals filed by the Revenue ( in ITA nos

ITA 136/SRT/2021[2017-18]Status: DisposedITAT Surat10 May 2022AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.134 To 137/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) (Virtual Court Hearing) The Dcit, Central Circle-2, Vs. Shri Pravinchandra Dahyabhai Umriger, Surat. Bungalow No.01, Opp. Talao Street, Near Govindji Park, Umra, Surat-395007(Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabpu5216D The Dcit, Central Circle-2, Vs. Shri Vasantrai Ambaram Modi, Surat. 504, D/1, Subham Residency, Pal, Surat- 395005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acrpm0852D The Dcit, Central Circle-2, Vs. Shri Shankar Mulchand Uttamani, Surat. 1/3210-11, New Textile Market, Ring Road, Surat-395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahpu9028R The Dcit, Central Circle-2, Vs. Shri Prabodhchandra Jayantilal Patel, Surat. 297, Hari Narar-3, Opp. Brc Gate, Udhna, Surat-394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afvpp7466F (Assessee) (Respondent) Assessee By: Shri Rasesh Shah, Ca Revenue By: Shri Ritesh Mishra, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 02/03/2022 घोषणाक"तार"ख/Date Of Pronouncement : 10/05/2022 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Four Appeals Filed By The Revenue, Pertaining To Assessment Year (Ay) 2017-18, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri Ritesh Mishra, CIT(DR)
Section 143(3)

note that ld Counsel also contended that cross-examination of Shri Manoj C. Patel and Shri Jayantibhai Babariya whose statements were recorded by the Investigation Wing and also by the Assessing Officer, was requested from the Assessing Officer. However, the same has been denied by the Assessing Officer stating that

Dy. Commissioner of Income Tax, Central Cir.-2, Surat vs. Shri Vasantrai Ambaram Modi, Surat

In the result, appeals filed by the Revenue ( in ITA nos

ITA 135/SRT/2021[2017-18]Status: DisposedITAT Surat10 May 2022AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.134 To 137/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) (Virtual Court Hearing) The Dcit, Central Circle-2, Vs. Shri Pravinchandra Dahyabhai Umriger, Surat. Bungalow No.01, Opp. Talao Street, Near Govindji Park, Umra, Surat-395007(Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabpu5216D The Dcit, Central Circle-2, Vs. Shri Vasantrai Ambaram Modi, Surat. 504, D/1, Subham Residency, Pal, Surat- 395005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acrpm0852D The Dcit, Central Circle-2, Vs. Shri Shankar Mulchand Uttamani, Surat. 1/3210-11, New Textile Market, Ring Road, Surat-395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahpu9028R The Dcit, Central Circle-2, Vs. Shri Prabodhchandra Jayantilal Patel, Surat. 297, Hari Narar-3, Opp. Brc Gate, Udhna, Surat-394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afvpp7466F (Assessee) (Respondent) Assessee By: Shri Rasesh Shah, Ca Revenue By: Shri Ritesh Mishra, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 02/03/2022 घोषणाक"तार"ख/Date Of Pronouncement : 10/05/2022 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Four Appeals Filed By The Revenue, Pertaining To Assessment Year (Ay) 2017-18, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri Ritesh Mishra, CIT(DR)
Section 143(3)

note that ld Counsel also contended that cross-examination of Shri Manoj C. Patel and Shri Jayantibhai Babariya whose statements were recorded by the Investigation Wing and also by the Assessing Officer, was requested from the Assessing Officer. However, the same has been denied by the Assessing Officer stating that

Dy. Commissioner of Income Tax, Central Cir., 2, Surat vs. Shri Pravinchandra Dahyabhai Umriger, Surat

In the result, appeals filed by the Revenue ( in ITA nos

ITA 134/SRT/2021[2017-18]Status: DisposedITAT Surat10 May 2022AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.134 To 137/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) (Virtual Court Hearing) The Dcit, Central Circle-2, Vs. Shri Pravinchandra Dahyabhai Umriger, Surat. Bungalow No.01, Opp. Talao Street, Near Govindji Park, Umra, Surat-395007(Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabpu5216D The Dcit, Central Circle-2, Vs. Shri Vasantrai Ambaram Modi, Surat. 504, D/1, Subham Residency, Pal, Surat- 395005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acrpm0852D The Dcit, Central Circle-2, Vs. Shri Shankar Mulchand Uttamani, Surat. 1/3210-11, New Textile Market, Ring Road, Surat-395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahpu9028R The Dcit, Central Circle-2, Vs. Shri Prabodhchandra Jayantilal Patel, Surat. 297, Hari Narar-3, Opp. Brc Gate, Udhna, Surat-394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afvpp7466F (Assessee) (Respondent) Assessee By: Shri Rasesh Shah, Ca Revenue By: Shri Ritesh Mishra, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 02/03/2022 घोषणाक"तार"ख/Date Of Pronouncement : 10/05/2022 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Four Appeals Filed By The Revenue, Pertaining To Assessment Year (Ay) 2017-18, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri Ritesh Mishra, CIT(DR)
Section 143(3)

note that ld Counsel also contended that cross-examination of Shri Manoj C. Patel and Shri Jayantibhai Babariya whose statements were recorded by the Investigation Wing and also by the Assessing Officer, was requested from the Assessing Officer. However, the same has been denied by the Assessing Officer stating that

The Income Tax Officer, Ward-2(3)(7), Surat vs. Shri Jitendra Kumar Pukhraj Ranka, Surat

In the result, appeal filed by the Revenue is dismissed

ITA 291/SRT/2019[2008-09]Status: DisposedITAT Surat10 May 2022AY 2008-09

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.291/Srt/2019 ("नधा"रणवष" / Assessment Years: (2008-09) (Virtual Court Hearing) The Ito, Ward-2(3)(7), Vs. Jitendra Pukhraj Ranka, Surat. Prop Of M/S P Jitendra & Co., 304/A, Sumangal Appt., Jadda Khadi, Mahidharpura, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abhpj0571F (Assessee) (Respondent) Assessee By : Shri Prakash Jhunjhunwala, Ca Revenue By : Shri H. P. Meena, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 16/02/2022 घोषणाक"तार"ख/Date Of Pronouncement : 10/05/2022 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Appeal Filed By The Revenue, Pertaining To Assessment Year (Ay) 2008-09, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Surat [In Short “The Ld. Cit(A)”] In Appeal No. Cit(A)-I/11694/2018-19 Dated 27.03.2019, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer Under Section 143 R.W.S. 147 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Dated 23.03.2016. 2. Grounds Of Appeal Raised By The Revenue Are As Follows: “(I) On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Quashing Reopened Assessment Proceedings For Ay 2008-09. (Ii) On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Failed To Appreciate Decision Of Larger Bench Of Hon'Ble Gujarat High Court In The Case Of A.L.A Firm Vs Cit, 189 (1991) Itr 285, Whereas The Hon'Ble High Court Has Held That The Jurisdiction Of The Ito To Reassess Income Arises If He Has Reassessed Based On Specific & Relevant Information Coming Into His

For Appellant: Shri Prakash Jhunjhunwala, CAFor Respondent: Shri H. P. Meena, CIT(DR)
Section 132Section 143Section 147Section 148

activity of Shri Pravin Kumar Jain and his associates is concern, which have been noted by the AO in the reasons i.e. report of Investigation wing is concern the same information was also before the AO during the original assessment proceeding u/s 143(3) r.w.s. | 153A

ACIT 12(2)(1), Mumbai vs. M/S Fame Engineering India Pvt Ltd., Mumbai

In the result, both the appeal of the assessee as well as Revenue are dismissed

ITA 3978/MUM/2019[2009-10]Status: DisposedITAT Mumbai10 May 2022AY 2009-10

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2009-10 Fame Engineering Pvt. Ltd., Ito-12(2)(1), D-31, Star Apartment, S.V. Aayakar Bhavan, Road, Borivali (West), Vs. Mumbai-400020. Mumbai-400092. Pan No. Aaaca 9948 E Appellant Respondent Assessment Year: 2009-10 Asst. Commissioner Of Income M/S Fame Engineering India Pvt. Ltd., Tax-12(2)(1), 31, Star Apartment, S.V. Road, Borivali Room No. 128E, 1St Floor, Vs. West, Aayakar Bhavan, Churchgate, Mumbai-400092. Mumbai-400020. Pan No. Aaaca 9948 E Appellant Respondent Assessee By : None Revenue By : Mr. S.N. Kabra, Dr Date Of Hearing : 13/04/2022 Date Of Pronouncement : 10/05/2022

For Appellant: NoneFor Respondent: Mr. S.N. Kabra, DR
Section 143(3)Section 147Section 68

loan of ₹1,00,00,000/- from M/s KPH Metals, which was founded to be paper company in the enquiry conducted by the Investigation Wing of the Income Tax Department at Vadodara. The Assessing Officer commenced reassessment proceeding and after considering the submission of the assessee M/s Fame Engineering India

Fame Engineering Pvt. Ltd., Mumbai vs. ITO 12 (2)(1), Mumbai

In the result, both the appeal of the assessee as well as Revenue are dismissed

ITA 2570/MUM/2019[2009-10]Status: DisposedITAT Mumbai10 May 2022AY 2009-10

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2009-10 Fame Engineering Pvt. Ltd., Ito-12(2)(1), D-31, Star Apartment, S.V. Aayakar Bhavan, Road, Borivali (West), Vs. Mumbai-400020. Mumbai-400092. Pan No. Aaaca 9948 E Appellant Respondent Assessment Year: 2009-10 Asst. Commissioner Of Income M/S Fame Engineering India Pvt. Ltd., Tax-12(2)(1), 31, Star Apartment, S.V. Road, Borivali Room No. 128E, 1St Floor, Vs. West, Aayakar Bhavan, Churchgate, Mumbai-400092. Mumbai-400020. Pan No. Aaaca 9948 E Appellant Respondent Assessee By : None Revenue By : Mr. S.N. Kabra, Dr Date Of Hearing : 13/04/2022 Date Of Pronouncement : 10/05/2022

For Appellant: NoneFor Respondent: Mr. S.N. Kabra, DR
Section 143(3)Section 147Section 68

loan of ₹1,00,00,000/- from M/s KPH Metals, which was founded to be paper company in the enquiry conducted by the Investigation Wing of the Income Tax Department at Vadodara. The Assessing Officer commenced reassessment proceeding and after considering the submission of the assessee M/s Fame Engineering India

DCIT, Circle- 8, Rewari vs. Shree Balaji Grit & Rolling Pvt. Ltd., Rewari

In the result, the appeal of the Department is allowed for statistical

ITA 3807/DEL/2017[2013-14]Status: DisposedITAT Delhi10 May 2022AY 2013-14

Bench: Shri Anil Chaturvedi & Shri Yogesh Kumar U.S.Assessment Year: 2013-14

Section 143(1)Section 143(2)Section 250(6)Section 36(1)(iii)Section 68

companies at sr no 3 & 4 to conduct enquiry and furnish the report. Reports dt 26.02.2016 & 29.02.2016 were received from the Investigation wing wherein the share applicants were reported as lacking in identity, creditworthiness & genuineness and same are also enclosed as part of the order. Regarding Telic Finvest ... share applicants worth Rs. 4.5 crores. Beside the same, the addition has been made by the Assessing Officer based on the Report of the Investigation wing and other materials. But the learned CIT (Appeals) has neither discussed the said facts and nor even mentioned regarding the full exercise and investigation

ITO, Ward-1(3)(7), Surat vs. Shri Krunal Chandrakant Parmar, Surat

In the result, the grounds of appeal raised by the revenue are dismissed

ITA 177/SRT/2020[2011-12]Status: DisposedITAT Surat09 May 2022AY 2011-12

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) I.T.O. Shri Krunal Chandrakant Parmar, Ward-1(3)(7), 152, Dipmala Near Kesarba School, Vs. Surat. B/H Ram Nagar, Rander Road, Palanpur Patiya, Surat. Pan : Aoopp 9749 R Appellant Respondednt

Section 133(6)Section 148Section 254(1)

individual and no return of income was filed by the assessee for the assessment year (A.Y.) 2011-12. The Assessing Officer received information form investigation wing of revenue that the assesse has deposited cash of Rs. 19,22,925/- in bank account maintained with City Cooperative Bank ... assessee failed to prove that transaction in script of CCL Inter Ltd. is genuine. The Assessing Officer on the basis of information form investigation wing, made addition of Rs. 17,03,063/- and further added 1% of commission thereby made total addition of Rs. 17,20,093/-. 5. Aggrieved

ACIT Central Circle 2(1), Chennai vs. Cavinkare Pvt. Ltd., Chennai

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

ITA 1075/CHNY/2018[2004-05]Status: DisposedITAT Chennai06 May 2022AY 2004-05

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.1075/Chny/2018 िनधा"रण वष"/Assessment Year: 2004-05 The Assistant Commissioner Of Vs. M/S. Cavinkare Pvt. Ltd., Income Tax, Central Circle 2(1), No. 12, Cenotaph Road, Investigation Wing, Teynampet, Chennai 600 018. Chennai – 600 034. [Pan: Aaacb3754B] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri Ar V Sreenivasan, Addl. Cit : ""थ" की ओर से/Respondent By Shri T. Banusekar, C.A. : सुनवाई की तारीख/ Date Of Hearing 28.04.2022 : घोषणा की तारीख /Date Of Pronouncement : 06.05.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 18.12.2017 Relevant To The Assessment Year 2004-05. 2. When The Appeal Was Taken Up For Hearing, The Ld. Counsel For The Assessee Has Submitted That The Tax Effect In The Appeal Filed By The Revenue Is Less Than The Monetary Limit Of ₹.50,00,000/- Fixed By The Cbdt To File An Appeal By The Revenue Before The Tribunal As Per The 2

वष"/Assessment Year: 2004-05 The Assistant Commissioner of Vs. M/s. Cavinkare Pvt. Ltd., Income Tax, Central Circle 2(1), No. 12, Cenotaph Road, Investigation Wing, Teynampet, Chennai 600 018. Chennai – 600 034. [PAN: AAACB3754B] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by Shri AR V Sreenivasan, Addl

ITO (It)2(1)(1), Mumbai vs. Shri. Pravin Ambalal Dabi, Mumbai

In the result, appeal by the Revenue is allowed for statistical purpose

ITA 6289/MUM/2019[2014-15]Status: DisposedITAT Mumbai06 May 2022AY 2014-15

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Milind Chavan, Sr. DR
Section 131Section 143(3)Section 147Section 148Section 250Section 69

issued on 15/09/2016 in order to verify certain transactions in shares entered into by the assessee as intimated by the investigation wing. The said summons was received by cousin of the assessee. As, no one attended to the summons, the Assessing Officer issued notice under section ... present case, the assessee had not filed return of income and in order to verify the transactions as intimated by the investigation wing, the summons was issued. However, the same was also not attended by the assessee, and reassessment proceeding under section 148 of the Act was initiated. The Assessing