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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

Shri Kushal R Jain, Surat vs. ITO-3(3)(3), Surat

In the result, appeals filed by the assessee in ITA Nos

ITA 215/SRT/2020[2007-08]Status: DisposedITAT Surat29 Mar 2022AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos. 420 & 504 /Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) Shri Gautam Chunilal Jain, Vs. The Ito, Ward-2(3)(7), Prop. Of M/S Sai Star, 286, Laxmi Surat. Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. (Assessee) (Revenue) The Ito, Ward-2(3)(7), Vs. Shri Gautam Chunilal Jain, Surat. Prop. Of M/S Sai Star, 286, Laxmi Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abhpl0577D (Revenue) (Assessee) आयकरअपीलसं./Ita Nos. 215/Srt/2020 & 575/Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) Shri Kushal R. Jain, The Ito, Ward-3(3)(3), Vs. Prop. M/S Kunal Gems, C/O. Surat. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. (Assessee) (Revenue) The Ito, Ward-3(3)(3), Vs. Shri Kushal R. Jain, Surat. Prop. M/S Kunal Gems, C/O. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Advpj6155B (Revenue) (Assessee) Assessee By Shri Himanshu Gandhi, Ca Shri H. P. Meena, Cit(Dr) Respondent By Date Of Hearing 21/03/2022 Date Of Pronouncement 29/03/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Cross Appeals Filed By The Assessees & Revenue, Pertaining To Assessment Year (Ay) 2007-08, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Surat [In Ita. 420 & 504, 575/Srt/2019 & 215/Srt/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain Short “The Ld. Cit(A)”] Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 132(4)Section 143(3)

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 ... made any comment on the documentary evidence furnished by assessee. The AO solely relied upon the statement of third party and the report of Investigation Wing. The report of wing and the statement of Bhanwarlal Jain were not provided to the assessee. The AO has not disputed the sales

ITO, Ward-3(3)(3), Surat vs. Kushal R Jain, Surat

In the result, appeals filed by the assessee in ITA Nos

ITA 575/SRT/2019[2007-08]Status: DisposedITAT Surat29 Mar 2022AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos. 420 & 504 /Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) Shri Gautam Chunilal Jain, Vs. The Ito, Ward-2(3)(7), Prop. Of M/S Sai Star, 286, Laxmi Surat. Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. (Assessee) (Revenue) The Ito, Ward-2(3)(7), Vs. Shri Gautam Chunilal Jain, Surat. Prop. Of M/S Sai Star, 286, Laxmi Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abhpl0577D (Revenue) (Assessee) आयकरअपीलसं./Ita Nos. 215/Srt/2020 & 575/Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) Shri Kushal R. Jain, The Ito, Ward-3(3)(3), Vs. Prop. M/S Kunal Gems, C/O. Surat. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. (Assessee) (Revenue) The Ito, Ward-3(3)(3), Vs. Shri Kushal R. Jain, Surat. Prop. M/S Kunal Gems, C/O. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Advpj6155B (Revenue) (Assessee) Assessee By Shri Himanshu Gandhi, Ca Shri H. P. Meena, Cit(Dr) Respondent By Date Of Hearing 21/03/2022 Date Of Pronouncement 29/03/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Cross Appeals Filed By The Assessees & Revenue, Pertaining To Assessment Year (Ay) 2007-08, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Surat [In Ita. 420 & 504, 575/Srt/2019 & 215/Srt/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain Short “The Ld. Cit(A)”] Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 132(4)Section 143(3)

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 ... made any comment on the documentary evidence furnished by assessee. The AO solely relied upon the statement of third party and the report of Investigation Wing. The report of wing and the statement of Bhanwarlal Jain were not provided to the assessee. The AO has not disputed the sales

ITO, Ward 2(3)(7), Surat vs. Gautamchand Chunilal Jain, Surat

In the result, appeals filed by the assessee in ITA Nos

ITA 504/SRT/2019[2007-08]Status: DisposedITAT Surat29 Mar 2022AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos. 420 & 504 /Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) Shri Gautam Chunilal Jain, Vs. The Ito, Ward-2(3)(7), Prop. Of M/S Sai Star, 286, Laxmi Surat. Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. (Assessee) (Revenue) The Ito, Ward-2(3)(7), Vs. Shri Gautam Chunilal Jain, Surat. Prop. Of M/S Sai Star, 286, Laxmi Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abhpl0577D (Revenue) (Assessee) आयकरअपीलसं./Ita Nos. 215/Srt/2020 & 575/Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) Shri Kushal R. Jain, The Ito, Ward-3(3)(3), Vs. Prop. M/S Kunal Gems, C/O. Surat. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. (Assessee) (Revenue) The Ito, Ward-3(3)(3), Vs. Shri Kushal R. Jain, Surat. Prop. M/S Kunal Gems, C/O. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Advpj6155B (Revenue) (Assessee) Assessee By Shri Himanshu Gandhi, Ca Shri H. P. Meena, Cit(Dr) Respondent By Date Of Hearing 21/03/2022 Date Of Pronouncement 29/03/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Cross Appeals Filed By The Assessees & Revenue, Pertaining To Assessment Year (Ay) 2007-08, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Surat [In Ita. 420 & 504, 575/Srt/2019 & 215/Srt/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain Short “The Ld. Cit(A)”] Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 132(4)Section 143(3)

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 ... made any comment on the documentary evidence furnished by assessee. The AO solely relied upon the statement of third party and the report of Investigation Wing. The report of wing and the statement of Bhanwarlal Jain were not provided to the assessee. The AO has not disputed the sales

Gautamchand Chunilal Jain, Surat vs. ITO, Ward-2(3)(7), Surat

In the result, appeals filed by the assessee in ITA Nos

ITA 420/SRT/2019[2007-08]Status: DisposedITAT Surat29 Mar 2022AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos. 420 & 504 /Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) Shri Gautam Chunilal Jain, Vs. The Ito, Ward-2(3)(7), Prop. Of M/S Sai Star, 286, Laxmi Surat. Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. (Assessee) (Revenue) The Ito, Ward-2(3)(7), Vs. Shri Gautam Chunilal Jain, Surat. Prop. Of M/S Sai Star, 286, Laxmi Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abhpl0577D (Revenue) (Assessee) आयकरअपीलसं./Ita Nos. 215/Srt/2020 & 575/Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) Shri Kushal R. Jain, The Ito, Ward-3(3)(3), Vs. Prop. M/S Kunal Gems, C/O. Surat. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. (Assessee) (Revenue) The Ito, Ward-3(3)(3), Vs. Shri Kushal R. Jain, Surat. Prop. M/S Kunal Gems, C/O. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Advpj6155B (Revenue) (Assessee) Assessee By Shri Himanshu Gandhi, Ca Shri H. P. Meena, Cit(Dr) Respondent By Date Of Hearing 21/03/2022 Date Of Pronouncement 29/03/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Cross Appeals Filed By The Assessees & Revenue, Pertaining To Assessment Year (Ay) 2007-08, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Surat [In Ita. 420 & 504, 575/Srt/2019 & 215/Srt/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain Short “The Ld. Cit(A)”] Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 132(4)Section 143(3)

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 ... made any comment on the documentary evidence furnished by assessee. The AO solely relied upon the statement of third party and the report of Investigation Wing. The report of wing and the statement of Bhanwarlal Jain were not provided to the assessee. The AO has not disputed the sales

M/S. Borda Brothers, Surat vs. The DCIT., Circle-3(3), Surat

In the result the ground No

ITA 774/SRT/2018[2008-09]Status: DisposedITAT Surat29 Mar 2022AY 2008-09

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.774&765/Srt/2018 (िनधा"रणवष" / Assessment Year: (2008-09) (Virtual Court Hearing) M/S Borda Brothers Dy. Commissioner Of Income 8/9 Saurashtra Diamond B/H Tax, Circle-3(3), Aayakar Geetanjali Cinema, Varachha Bhawan, Majura Gate, Surat- Road,Surat-395006 396009 Vs. Income Tax Officer, Ward- M/S Borda Brothers 3(3)(1), Room No. 418, Aayakar B/8, Panchdev Society, B/H Bhavan, Marjura Gate, Surat- Laxmi Hotel, Varachha 395001 Road,Surat-395006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefb 0796 Q (Appellant ) (Respondent)

For Appellant: Shri Sapnesh R Sheth, C.AFor Respondent: Shri H.P.Meena, CIT-DR
Section 144Section 148

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

The Income Tax Officer, Ward-3(3)(1), Surat vs. M/S. Borda Brothers, Surat

In the result the ground No

ITA 765/SRT/2018[2008-09]Status: DisposedITAT Surat29 Mar 2022AY 2008-09

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.774&765/Srt/2018 (िनधा"रणवष" / Assessment Year: (2008-09) (Virtual Court Hearing) M/S Borda Brothers Dy. Commissioner Of Income 8/9 Saurashtra Diamond B/H Tax, Circle-3(3), Aayakar Geetanjali Cinema, Varachha Bhawan, Majura Gate, Surat- Road,Surat-395006 396009 Vs. Income Tax Officer, Ward- M/S Borda Brothers 3(3)(1), Room No. 418, Aayakar B/8, Panchdev Society, B/H Bhavan, Marjura Gate, Surat- Laxmi Hotel, Varachha 395001 Road,Surat-395006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefb 0796 Q (Appellant ) (Respondent)

For Appellant: Shri Sapnesh R Sheth, C.AFor Respondent: Shri H.P.Meena, CIT-DR
Section 144Section 148

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

Shri Manish Agarwal, Surat vs. The ITO, Ward-3(1)(5), Surat

In the result, assessee’s the appeals in ITA No

ITA 256/SRT/2017[2008-09]Status: DisposedITAT Surat29 Mar 2022AY 2008-09

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.206 & 256/Srt/2017 (िनधा"रणवष" / Assessment Year: (2008-09) (Virtual Court Hearing) Income Tax Officer, Ward- Manish Agarwal 3(1)(5)Room No. 115, 1St Floor, 204, Vaibhav Chambers, Anavil Business Centre, Hajira Raghunathpura, Main Road, Road, Opp. Star Bazar, Adajan, Surat-395003 Surat-395009 Vs. Income Tax Officer, Ward- Manish Agarwal 3(1)(5), Aayakar Bhawan, 204, Vaibhav Chambers, Majura Gate, Surat Raghunathpura, Main Road,Surat-395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afwpa 2629 A (Appellant ) (Respondent)

For Appellant: Shri Suchek Anchalia, C.AFor Respondent: Shri H.P.Meena, CIT-DR
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

Shri Ramprakash V. Vijayvergiya, Surat vs. The ITO, Ward-3(1)(5), Surat

In the result, assessee’s the appeals in ITA No

ITA 253/SRT/2017[2008-09]Status: DisposedITAT Surat29 Mar 2022AY 2008-09

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.206 & 256/Srt/2017 (िनधा"रणवष" / Assessment Year: (2008-09) (Virtual Court Hearing) Income Tax Officer, Ward- Manish Agarwal 3(1)(5)Room No. 115, 1St Floor, 204, Vaibhav Chambers, Anavil Business Centre, Hajira Raghunathpura, Main Road, Road, Opp. Star Bazar, Adajan, Surat-395003 Surat-395009 Vs. Income Tax Officer, Ward- Manish Agarwal 3(1)(5), Aayakar Bhawan, 204, Vaibhav Chambers, Majura Gate, Surat Raghunathpura, Main Road,Surat-395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afwpa 2629 A (Appellant ) (Respondent)

For Appellant: Shri Suchek Anchalia, C.AFor Respondent: Shri H.P.Meena, CIT-DR
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

The ITO, Ward-3(1)(5), Surat vs. Shri Manish Agarwal, Surat

In the result, assessee’s the appeals in ITA No

ITA 206/SRT/2017[2008-09]Status: DisposedITAT Surat29 Mar 2022AY 2008-09

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.206 & 256/Srt/2017 (िनधा"रणवष" / Assessment Year: (2008-09) (Virtual Court Hearing) Income Tax Officer, Ward- Manish Agarwal 3(1)(5)Room No. 115, 1St Floor, 204, Vaibhav Chambers, Anavil Business Centre, Hajira Raghunathpura, Main Road, Road, Opp. Star Bazar, Adajan, Surat-395003 Surat-395009 Vs. Income Tax Officer, Ward- Manish Agarwal 3(1)(5), Aayakar Bhawan, 204, Vaibhav Chambers, Majura Gate, Surat Raghunathpura, Main Road,Surat-395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afwpa 2629 A (Appellant ) (Respondent)

For Appellant: Shri Suchek Anchalia, C.AFor Respondent: Shri H.P.Meena, CIT-DR
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