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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

The Deputy Commissioner of Income Tax, Central Circle-1, Mangaluru vs. Shri. M A Siddique, Mangalore

In the result, all the appeals of the Revenue are dismissed in limine as not admitted

ITA 726/BANG/2020[2014-15]Status: DisposedITAT Bangalore09 Dec 2021AY 2014-15

Bench: Shri B.R Baskaran & Shri Beena Pillai

For Appellant: Smt. Sheethal, AdvocateFor Respondent: Shri Pradeep Kumar, CIT (DR)

appellate orders were received on 20-11-2019 and no appeals filed within the prescribed period. The fact of prosecution launched by the Investigation Wing against the assessee, was inadvertently missed the attention of the Assessing Officer to incorporate while submitting the scrutiny report dated 18.10.2019. In view ... above, the orders of the CIT(A) was accepted due to low tax effect. 4. Since the prosecution launched by the Investigation Wing is still pending before the JMFC Court, Mangalore, this case is covered under the exception as provided in Para 10(f) of CBDT Circular in F.No 279/Misc/142/2007-

The Deputy Commissioner of Income Tax, Central Circle-1, Mangaluru vs. Shri M A Siddique, Mangalore

In the result, all the appeals of the Revenue are dismissed in limine as not admitted

ITA 725/BANG/2020[2013-14]Status: DisposedITAT Bangalore09 Dec 2021AY 2013-14

Bench: Shri B.R Baskaran & Shri Beena Pillai

For Appellant: Smt. Sheethal, AdvocateFor Respondent: Shri Pradeep Kumar, CIT (DR)

appellate orders were received on 20-11-2019 and no appeals filed within the prescribed period. The fact of prosecution launched by the Investigation Wing against the assessee, was inadvertently missed the attention of the Assessing Officer to incorporate while submitting the scrutiny report dated 18.10.2019. In view ... above, the orders of the CIT(A) was accepted due to low tax effect. 4. Since the prosecution launched by the Investigation Wing is still pending before the JMFC Court, Mangalore, this case is covered under the exception as provided in Para 10(f) of CBDT Circular in F.No 279/Misc/142/2007-

Principal Commissioner of Income Tax 1 Kolkata vs. M/S Apeejay Shipping Ltd

In the result, these appeals are allowed and the substantial

ITA/26/2021HC Calcutta08 Dec 2021

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

hierarchy of authorities in the Income Tax Investigation department. It is submitted that in the Income Tax department more particularly in the investigation wing, the top most authority is the CBDT through its Member Investigation, followed by the Principal Director General of Income Tax (Investigation), Director General of Income

The Deputy Commissioner of Income Tax, Central Circle-1, Mangaluru vs. Shri. M A Siddique, Mangalore

In the result, all the appeals of the Revenue are dismissed in limine as not admitted

ITA 730/BANG/2020[2016-17]Status: DisposedITAT Bangalore08 Dec 2021AY 2016-17

Bench: Shri B.R Baskaran & Shri Beena Pillai

For Appellant: Smt. Sheethal, AdvocateFor Respondent: Shri Pradeep Kumar, CIT (DR)

appellate orders were received on 20-11-2019 and no appeals filed within the prescribed period. The fact of prosecution launched by the Investigation Wing against the assessee, was inadvertently missed the attention of the Assessing Officer to incorporate while submitting the scrutiny report dated 18.10.2019. In view ... above, the orders of the CIT(A) was accepted due to low tax effect. 4. Since the prosecution launched by the Investigation Wing is still pending before the JMFC Court, Mangalore, this case is covered under the exception as provided in Para 10(f) of CBDT Circular in F.No 279/Misc/142/2007-

The Deputy Commissioner of Income Tax, Central Circle-1, Mangaluru vs. Shri. M A Siddique, Mangalore

In the result, all the appeals of the Revenue are dismissed in limine as not admitted

ITA 729/BANG/2020[2015-16]Status: DisposedITAT Bangalore08 Dec 2021AY 2015-16

Bench: Shri B.R Baskaran & Shri Beena Pillai

For Appellant: Smt. Sheethal, AdvocateFor Respondent: Shri Pradeep Kumar, CIT (DR)

appellate orders were received on 20-11-2019 and no appeals filed within the prescribed period. The fact of prosecution launched by the Investigation Wing against the assessee, was inadvertently missed the attention of the Assessing Officer to incorporate while submitting the scrutiny report dated 18.10.2019. In view ... above, the orders of the CIT(A) was accepted due to low tax effect. 4. Since the prosecution launched by the Investigation Wing is still pending before the JMFC Court, Mangalore, this case is covered under the exception as provided in Para 10(f) of CBDT Circular in F.No 279/Misc/142/2007-

ITO, New Delhi vs. M/S. S. Systems Pvt. Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 3190/DEL/2016[2007-08]Status: DisposedITAT Delhi08 Dec 2021AY 2007-08

Bench: Sh. Anil Chaturvedi & Sh. Amit Shukla(Through Video Conferencing) Ito Vs. M/S S. System Pvt. Ltd. Ward – 22(1), House No. 5, Block A-31, New Delhi Main Shastri Gali, Maujpur, Pan : Aaics 0471 J New Delhi-110 053 (Appellant) (Respondent) Assessee By Shri Sanjay Mehra, C.A. Revenue By Shri Kumar Pranav, Sr. D.R. Date Of Hearing: 22.11.2021 Date Of Pronouncement: 08.12.2021 Order Per Anil Chaturvedi, Am:

Section 144Section 147Section 148Section 151(2)

section 147 of the Act and to issue notice under section 148 of the Act only on the basis of information received from the Investigation Wing without applying independent mind which is necessary condition for invoking the provisions of Section 147 and 148 of the Act. He further submitted that ... further noted that AO had proceeded to initiate proceedings under section 148 of the Act only on the basis of information received from the Investigation Wing of the Department and there is nothing on record to demonstrate that AO while framing the belief has complied with the mandate section

Rakesh Kumar Khanna HUF, Panchkula vs. ITO, W-3, Panchkula

The appeal of the assessee stands allowed

ITA 892/CHANDI/2019[2009-10]Status: DisposedITAT Chandigarh07 Dec 2021AY 2009-10

Bench: Shri N.K. Saini & Shri Sanjay Garg

For Appellant: Shri Nalin Kumar Nohria, CAFor Respondent: Sh. Ashok Khanna, Addl. CIT
Section 143(3)Section 147Section 148Section 151(1)

through the record. It is evident on the file that in this case the Assessing officer on the basis of the report of the Investigation Wing recorded the reasons that the assessee had manipulated the profits in share transactions by shifting client code through his broker. However, we find that ... been mentioned, wherein, the assessee allegedly shifted the client code to manipulate profits / losses. The Assessing officer simply relied on the report of the Investigation Wing, which was a general report without co-relating with the same to the assessment record. The assessee was never supplied the reasons recorded

Ramesh Chand Investment & Leasing Pvt. Ltd., New Delhi vs. ACIT, Circle- 21(2), New Delhi

ITA 6009/DEL/2017[2004-05]Status: DisposedITAT Delhi07 Dec 2021AY 2004-05

Bench: Smt. Diva Singh & Shri R.K. Pandaassessment Year: 2004-05 Ramesh Chand Investment & Vs. Acit, Leasing Pvt. Ltd., Circle-21(2), 69/2A, Najafgarh Road Industrial New Delhi. Area, New Delhi. Pan:Aaccr3585Q (Appellant) (Respondent) Assessee By : None Revenue By : Shri Anilgandhi, Sr. Dr Date Of Hearing : 06.12.2021 Date Of Pronouncement : 07.12.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 1St March,2013 Of The Cit(A)-18, New Delhi, Relating To Assessment Year 2004-05. 2. None Appeared On Behalf Of The Assessee At The Time Of Hearing. No Application For Adjournment Of Hearing Has Been Filed. A Perusal Of The Order Sheet Entries Shows That No One Was Appearing On The Previous Occasions. Although Notices Have Been Sent By The Registry Through Rpad, Every Time The Same Was Returned By The Postal Authorities With The Remark ‘No Such Person In The Address.’ The Assessee Has Also Not Taken Any Step To Intimate The Change Of Address, If Any. Under These Circumstances, We Deem It Proper To Decide The Appeal On The Basis Of The Material Available On Record & After Hearing The Ld. Dr.

For Appellant: NoneFor Respondent: Shri AnilGandhi, Sr. DR
Section 143(2)Section 144Section 147Section 148

147/148 has been done by the AO after recording of reasons as per law showing “reason to believe”, based on information received from the Investigation Wing, and after approval of competent authority. In this connection reference is also placed on the following judicial pronouncements. In CIT v. India Terminal Connector ... assessee under section 68, as per the assessment order, the same has been done on the basis of: • Information received from the Investigation Wing of the Department that the appellant Company was one of the beneficiaries and had taken bogus accommodation entries. • The appellant did not prove the creditworthiness

Intime Realty Pvt. Ltd., Mumbai vs. DCIT- CC 3(4), Mumbai

In the result, appeal of the assessee in ITA No

ITA 6357/MUM/2019[2010-11]Status: DisposedITAT Mumbai06 Dec 2021AY 2010-11
Section 133ASection 139Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 151(1)

Addl.CIT & Anr.(Del) (333 ITR 146)  Shalimar Buildcon (P) Ltd. Vs ITO ITAT Jaipur (136 TTJ 701) wherein it was held that information from investigation Wing ' notice u/s. 148 issued on the basis of such letter'.” 7 M/s. Intime Realty P. Ltd., 5.3. We find that the reopening ... Shalimar Buildcon 136 TTJ 701 wherein it was held that the notice u/s.148 of the Act could be issued based on information from Investigation Wing about tainted transactions carried out by the assessee. 5.11. We find that all the aforesaid case laws referred by the ld. DR did not address

Vijayshree Food Products P.Ltd, New Delhi vs. ACIT, Central Circle-30, New Delhi

In the result, both these appeals are partly allowed

ITA 587/DEL/2019[2014-15]Status: DisposedITAT Delhi06 Dec 2021AY 2014-15

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2014-15 Vijayshree Food Products P. Ltd., Vs. Acit, C/O Ravi Gupta, Advocate, Central Circle-30, E-6A, Kailash Colony, New Delhi. New Delhi. Pan: Aaccv4721C (Appellant) (Respondent) Assessee By : Shri P.C. Yadav, Advocate Revenue By : Shri Prakash Dubey, Sr.Dr Date Of Hearing : 09.09.2021 Date Of Pronouncement : 06.12.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28Th December, 2018 Of The Cit(A)-30, New Delhi, Relating To Assessment Year 2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company Engaged In The Business Of Manufacturing & Export Of Tobacco Products. It Filed Its Return Of Income On 30Th September, 2014 Declaring The Loss Of Rs.18,78,467/-. The Return Was Processed U/S 143(1) Of The Act On 26Th November, 2014 At The Returned Income. Subsequently, The Ao Reopened The Assessment As Per The Provisions Of Section 147 Of The Act By Recording The Following Reasons:-

For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Shri Prakash Dubey, Sr.DR
Section 131Section 131(1)(d)Section 132Section 132(4)Section 143(1)Section 147Section 148Section 68

various Kuber Group of companies, enquiries were conducted by issuing commission u/s 131(1)(d) of the Act and information was gathered from the Investigation Wing, Kolkata. As per the information received, M/s Binapani 5 Merchandise Pvt. Ltd. is one of the many paper/jamakharchi companies used in providing accommodation entries ... following date chart:- DATE EVENT Remarks 09.12.2013 Statement of one Vikash Aggarwal was Copy of the statement is at recorded by Calcuta investigation wing Page no-52 of the PB 30.09.2014 Return of Income for the impugned year Admitted fact declaring loss was filed by assessee 09.10.2014 A search

Shri. Inderjit Singh, Jalandhar vs. Income Tax Officer Ward-2(2), Jalandhar

In the result, appeal filed by the Assessee is allowed for statistical purpose

ITA 321/ASR/2019[2010-11]Status: DisposedITAT Amritsar03 Dec 2021AY 2010-11

Bench: Shri Mahavir Prasad & Shri Manish Boarad)

For Appellant: Shri P. N. Arora, AdvFor Respondent: Shri Inderjit Singh, CIT/DR
Section 147Section 148

case for scrutiny for assessment year 2010-11 was selected u/s. 147 of the Act on the basis of information received from the Investigation Wing (sale of immovable properties worth Rs. 1,68,00,000/- and after recording the satisfaction, Ld. A.O. issued notice to the assessee but none appeared ... assessee, Ld. A.O. made addition of Rs. 1,68,00,000/- on the basis of information and documents were forwarded by the Investigation Wing of the department. 4. Thereafter, assesee preferred first statutory appeal before the Ld. CIT(A) and during the proceedings before the lower authorities, assessee

ACIT Central Circle 2(4), Chennai vs. Kannan Dhanasekar, Chennai

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

ITA 1467/CHNY/2018[2012-13]Status: DisposedITAT Chennai02 Dec 2021AY 2012-13

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.1467/Chny/2018 िनधा"रण वष"/Assessment Year: 2012-13 The Assistant Commissioner Of Shri Kannan Dhanasekar, Income Tax, Central Circle 2(4), Vs. No. 66, Dr. Rajendra Prasad Road, Investigation Wing, Chrompet, Chennai 600 044. Chennai – 34. [Pan: Aebpd2267D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri D. V. Subba Rao, Addl. Cit : ""थ" की ओर से/Respondent By Shri T. Vasudevan, Advocate : सुनवाई की तारीख/ Date Of Hearing 02.12.2021 : घोषणा की तारीख /Date Of Pronouncement : 02.12.2021 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 31.01.2018 Relevant To The Assessment Year 2012-13. 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 Cbdt

/Assessment Year: 2012-13 The Assistant Commissioner of Shri Kannan Dhanasekar, Income Tax, Central Circle 2(4), Vs. No. 66, Dr. Rajendra Prasad Road, Investigation Wing, Chrompet, Chennai 600 044. Chennai – 34. [PAN: AEBPD2267D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by Shri D. V. Subba Rao, Addl

Principal Commissioner of Income Tax, Central-1, Kolkata vs. Tanuj Holdings Pvt. Ltd

In the result, the connected application for stay IA

ITA/30/2020HC Calcutta01 Dec 2021

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 10(38)Section 143(3)Section 260ASection 68

Learned Tribunal has committed substantial error in law when the Learned Tribunal failed to give evidence to investigations made by the Assessing Officer, Investigation wing of the Income Tax Department as well as SEBI an astronomical rise in pricy of shares of companies which have no net worth

Mehta Finstock P. Ltd., Mumbai vs. Pr. CIT -4, Mumbai

Accordingly, grounds raised by the assessee are allowed

ITA 774/MUM/2021[2012-13]Status: DisposedITAT Mumbai30 Nov 2021AY 2012-13

Bench: Shri S. Rifaur Rahman () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 Mehta Finstock Pvt. Ltd., Pr. Cit-4, 903, Lodha Supremus Dr. E Moses Vs. Aayakar Bhavan, M.K. Road, Road, Worli Naka, Mumbai-400020. Mumbai-400018. Pan No. Aacck 2231 L Appellant Respondent

For Appellant: Mr. Rajiv Khandelwal, ARFor Respondent: Mr. Sunil Jha, CIT-DR
Section 143Section 143(3)Section 147Section 148Section 263

assessment order which was passed by assessing officer by invoking the provisions of section 147 of the Act based on the information received from investigation wing of the Department in order to verify the investments made by the assessee in shares, according to the Department it is classified under penny

M/S. Adihemshree Financial, I, Nao vs. Pr. CIT - 19, Mumbai

In the result, appeal of the assessee is allowed

ITA 326/MUM/2021[2015-16]Status: DisposedITAT Mumbai30 Nov 2021AY 2015-16
Section 263

Pearl Electric Ltd., and Pine Animations Ltd. totaling to Rs.4,26,63,518. The ld. AO heavily placed reliance on the findings of Investigation Wing of Kolkata Income Tax department, and even reproduced the financials of those three companies apart from statement recorded from various entry operators and explaining ... assessee on the aforesaid four scrips ought to have been disallowed by the ld. AO in view of the findings of Kolkata Investigation Wing of Income Tax department. The ld. PCIT stated that since the assessment order was completed without making necessary enquiries and verification in respect of aforesaid four

Dy CIT, CC--1(2), Mumbai vs. M/S Mahendra Brothers Exports P. Ltd., Mumbai

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

ITA 127/MUM/2021[2010-11]Status: DisposedITAT Mumbai29 Nov 2021AY 2010-11
Section 143(3)

post search investigation proceedings. The assessee had also produced the copy of the Jangad (Memo of Neelam Exports) evidencing the same before the DDIT Investigation Wing. The ld. AO however, observed that the goods if at all received from third parties had to be registered in the some register ... even at that point in time, no register showing the entry of stock received from third party (i.e. Neelam Exports) was shown to the Investigation wing. The ld. AO observed that the copy of Jangad of M/s. Neelam Exports was not found at the time of search on 08/08/2011

Mohil Estates Pvt Ltd, New Delhi vs. ITO Ward 5(4), New Delhi

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

ITA 3397/DEL/2019[2006-07]Status: DisposedITAT Delhi29 Nov 2021AY 2006-07

Bench: Shri R.K. Pandaassessment Year: 2006-07 Mohil Estates Pvt. Ltd., Vs. Ito, 22, Ssi, Industrial Area, Ward-5(4), Iind Floor, Gt Karnal Road, New Delhi. Delhi. Pan: Aaecm5516C (Appellant) (Respondent) Assessee By : None Revenue By : Shri Om Prakash, Sr.Dr Date Of Hearing : 15.11.2021 Date Of Pronouncement : 29.11.2021 Order

For Appellant: NoneFor Respondent: Shri Om Prakash, Sr.DR
Section 133(6)Section 142(1)Section 148Section 68

carried on in the case of Shri Aseem Kumar Gupta and Group of cases (entry operator) and on further inquiries conducted by the Investigation Wing of the Department, it was found that the assessee company is one of the companies who have taken the following accommodation entry:- S. Bank Name ... thereafter, confronted the assessee by writing a letter the contents of which read as under:- “1. That the information has been received from the Investigation Wing that you have taken accommodation entry of Rs.5,00,000/- from M/s Moderate Credit Corp. Ltd. vide cheque no. 797374. In this regards

Ms. Binna Nitin Parikh, Mumbai vs. ACIT Circle-19(1), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2604/MUM/2019[2012-13]Status: DisposedITAT Mumbai26 Nov 2021AY 2012-13

Bench: Shri Mahavir Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blems. Binna Nitin Parikh V. Acit – Circle – 19(1) W1, Sudantta Apartments Room No. 203, 2Nd Floor 10A Mount Pleasant Road Matru Mandir, Tardev Road Malabar Hill, Mumbai - 400006 Mumbai – 400 007 Pan: Aadpp1671P (Appellant) (Respondent) Assessee By : Shri Sunil Hirawat Department By : Shri C.T. Mathews

For Appellant: Shri Sunil HirawatFor Respondent: Shri C.T. Mathews
Section 143(3)Section 147Section 148Section 271(1)(c)Section 35(1)(ii)

given the donation and the Assessing Officer was not able to contradict this fact and he has simply relied on some observations of the Investigation Wing of Kolkata. Nowhere in the said finding of the Investigation Wing of Kolkata, the name of the assessee appears. It is, therefore, submitted that ... explain as to why the claim made by the assessee u/s 35(1)(ii) should not be disallowed in view of findings of the investigation wing. He was also given copies of the statement of the persons recorded by the investigation wing. In response, the representative of the assessee explained

ITO, Ward- 22(4), New Delhi vs. Satvik Logistics Pvt. Ltd., New Delhi

In the result, appeal of the Revenue dismissed

ITA 6306/DEL/2018[2013-14]Status: DisposedITAT Delhi26 Nov 2021AY 2013-14

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

For Appellant: Shri Ashish SachdevaFor Respondent: Shri Bhopal Singh, Sr. DR
Section 143(1)Section 68

assessee has obtained any accommodation entry. No information has been received 11 ITA.No.6306/Del./2018 M/s. Satvik Logistics Pvt. Ltd., New Delhi. from the Investigation Wing or any other Department against the assessee or M/s. Paras Steel Trading Company. He accordingly submitted that the order ... Paras Steel Trading Company which is at Rs.22,65,23,321/-. There is also no allegation either by the A.O. or by Investigation Wing or any other Department against the assessee or M/s. Paras Steel Trading Company that the assessee has obtained any accommodation entry. In this view

Ekkta Buildwell P.Ltd, Nerw Delhi vs. ITO, Ward-8(1), New Delhi

In the result the appeal of the revenue is partly allowed for statistical purposes and the appeal of the assessee is dismissed

ITA 5809/DEL/2018[2010-11]Status: DisposedITAT Delhi26 Nov 2021AY 2010-11

Bench: Shri O. P. Kant & Ms. Suchitra Kambleasstt. Year 2010-11

For Appellant: Shri Amitosh Moitra, CAFor Respondent: Shri Jagdish Singh, Sr.(DR)
Section 143(3)Section 147Section 148Section 68

without any jurisdiction. The Ld. AR further submitted that in the reopening all the reference is that of information of investigation wing. The Ld. AR submitted that the mention of the bank account in the reasons for re-opening was that of personal bank account of the Director ... there is no discrepancy in the reasons. Hence assessee’s appeal is dismissed. It is seen that the information received from investigation wing was part of the re- opening, yet the reopening was based on the records and facts of the assessee’s case. It was observed in the reasons