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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

M/S. Nova Infratech Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5364/DEL/2014[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

Thus, it is clear that aforesaid documents so quoted in the assessment order has not been issued/recorded by the Assessing officer but by the Investigation wing of the department. As such, it is clear that the assessing officer has made no application of the mind nor any investigation or enquiry ... ever conducted by lower authorities. The orders so passed arc merely copy and paste of observations of the Investigation wing in the appraisal report. Thus, reliance is placed on the following judgments on the proposition that, when no investigation has been carried out by the learned Assessing Officer

Smt. Shobha Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5362/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2021AY 2009-10

Bench: Shri G.S.Pannu & Shri Kul Bharat

Thus, it is clear that aforesaid documents so quoted in the assessment order has not been issued/recorded by the Assessing officer but by the Investigation wing of the department. As such, it is clear that the assessing officer has made no application of the mind nor any investigation or enquiry ... ever conducted by lower authorities. The orders so passed arc merely copy and paste of observations of the Investigation wing in the appraisal report. Thus, reliance is placed on the following judgments on the proposition that, when no investigation has been carried out by the learned Assessing Officer

Smt. Puja Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5361/DEL/2014[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

Thus, it is clear that aforesaid documents so quoted in the assessment order has not been issued/recorded by the Assessing officer but by the Investigation wing of the department. As such, it is clear that the assessing officer has made no application of the mind nor any investigation or enquiry ... ever conducted by lower authorities. The orders so passed arc merely copy and paste of observations of the Investigation wing in the appraisal report. Thus, reliance is placed on the following judgments on the proposition that, when no investigation has been carried out by the learned Assessing Officer

Smt. Puja Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5360/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2021AY 2009-10

Bench: Shri G.S.Pannu & Shri Kul Bharat

Thus, it is clear that aforesaid documents so quoted in the assessment order has not been issued/recorded by the Assessing officer but by the Investigation wing of the department. As such, it is clear that the assessing officer has made no application of the mind nor any investigation or enquiry ... ever conducted by lower authorities. The orders so passed arc merely copy and paste of observations of the Investigation wing in the appraisal report. Thus, reliance is placed on the following judgments on the proposition that, when no investigation has been carried out by the learned Assessing Officer

Sh. Kapil Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5315/DEL/2014[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

Thus, it is clear that aforesaid documents so quoted in the assessment order has not been issued/recorded by the Assessing officer but by the Investigation wing of the department. As such, it is clear that the assessing officer has made no application of the mind nor any investigation or enquiry ... ever conducted by lower authorities. The orders so passed arc merely copy and paste of observations of the Investigation wing in the appraisal report. Thus, reliance is placed on the following judgments on the proposition that, when no investigation has been carried out by the learned Assessing Officer

Sh. Kapil Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5314/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2021AY 2009-10

Bench: Shri G.S.Pannu & Shri Kul Bharat

Thus, it is clear that aforesaid documents so quoted in the assessment order has not been issued/recorded by the Assessing officer but by the Investigation wing of the department. As such, it is clear that the assessing officer has made no application of the mind nor any investigation or enquiry ... ever conducted by lower authorities. The orders so passed arc merely copy and paste of observations of the Investigation wing in the appraisal report. Thus, reliance is placed on the following judgments on the proposition that, when no investigation has been carried out by the learned Assessing Officer

Smt. Aarti Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5313/DEL/2014[2010-11]Status: DisposedITAT Delhi30 Sept 2021AY 2010-11

Bench: Shri G.S.Pannu & Shri Kul Bharat

Thus, it is clear that aforesaid documents so quoted in the assessment order has not been issued/recorded by the Assessing officer but by the Investigation wing of the department. As such, it is clear that the assessing officer has made no application of the mind nor any investigation or enquiry ... ever conducted by lower authorities. The orders so passed arc merely copy and paste of observations of the Investigation wing in the appraisal report. Thus, reliance is placed on the following judgments on the proposition that, when no investigation has been carried out by the learned Assessing Officer

Smt. Aarti Sekhri, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5312/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2021AY 2009-10

Bench: Shri G.S.Pannu & Shri Kul Bharat

Thus, it is clear that aforesaid documents so quoted in the assessment order has not been issued/recorded by the Assessing officer but by the Investigation wing of the department. As such, it is clear that the assessing officer has made no application of the mind nor any investigation or enquiry ... ever conducted by lower authorities. The orders so passed arc merely copy and paste of observations of the Investigation wing in the appraisal report. Thus, reliance is placed on the following judgments on the proposition that, when no investigation has been carried out by the learned Assessing Officer

Jt. CIT (OSD), CC-7(1), Mumbai vs. M/S Hillview Impex Pvt. Ltd, Mumbai

The appeal of the revenue is dismissed

ITA 774/MUM/2019[2014-15]Status: DisposedITAT Mumbai29 Sept 2021AY 2014-15

Bench: Shri S.Rifuar Rahman () & Shri Ravish Sood () Jt. Commissioner Of Income Tax M/S Hillview Impex Pvt. Ltd. (Osd), Central Circle-7(1) Vs. 118/120, 3Rd Floor, Ashok R. No. 676B, 6Th Floor, Aayakar House, Opp. Khara Kuwa, Bhavan, M.K. Road, Zaveri Bazar, Mumbai – 400 020 Mumbai – 400 002 Pan No. Aacch2338F (Revenue) (Assessee) Assessee By : Shri Vivek Shah, A.R Revenue By : Shri Gurbinder Singh, D.R Date Of Hearing : 12/08/2021 Date Of Pronouncement : 29/09/2021

For Appellant: Shri Vivek Shah, A.RFor Respondent: Shri Gurbinder Singh, D.R
Section 143(2)Section 143(3)Section 68

Business Loss : Rs. 3,86,56,040/- After exhaustively referring to the findings of the Investigation wing and the modus operandi that was adopted by the operators for facilitating booking of accommodation entries in the form of LTCG/STCL, the A.O concluded that the business loss that was booked ... this issue was undertaken. Various tools available were examined including FTD data, B5E data, (none/control website, taxmann, court rulings, internet as well as investigation wing report and findings of the SEBI”. The Ld. Assessing Officer erred in appreciating the facts and submissions made by the Assessee Company and passed

Mega Management Servises P.Ltd, Mumbai vs. DCIT CC-6(4), Mumbai

In the result, appeal is partly allowed for statistical purposes

ITA 4913/MUM/2018[2009-10]Status: DisposedITAT Mumbai29 Sept 2021AY 2009-10

Bench: Shri Saktijit Dey () & Shri Rajesh Kumar ()

Section 115BSection 133ASection 143(1)Section 147

return of income filed by the assessee was processed under section 143(1) of the Act. Subsequently, the assessing officer received information from the Investigation Wing that in course of a survey conducted under section 133A of the Act in case of M/s Nina Concrete Systems ... unsecured loan provided by the assessee is in the nature of accommodation entry. He submitted, merely relying upon the information received from the Investigation Wing the assessing officer reopened the assessment. Thus, he submitted, the reopening of assessment since is based on borrowed satisfaction, is invalid. He submitted, in course

Income Tax Officer, Ward - 3(2)(3), Bangalore vs. Sri Made Gowda Thibbe Gowda, Bangalore

In the result, the appeal of the revenue is dismissed and CO of the assessee is partly allowed

ITA 910/BANG/2019[2008-09]Status: DisposedITAT Bangalore29 Sept 2021AY 2008-09

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2008-09

For Appellant: Shri H. Guruswamy, ITP & Shri Ravi Kiran, CAFor Respondent: Shri Priyadarshi Mishra, Jt. CIT(DR)(ITAT), Bengaluru
Section 131Section 148

facts of the case. 2. The Ld.CIT(A) erred in stating that the Assessing officer has relied upon only the Information received from the Investigation wing without any supporting material to establish the fact that the advance of Rs.2,55,00,000/- was in the nature of Commission/Brokerage or facilitation ... dismissed since the Ld. CIT(A) was justified to hold that the AO did not have any information except information received from the Investigation Wing. 3. The Ground No.3 of the Revenue's Appeal is liable to be dismissed since the statement recorded

Ankur Aggarwal, New Delhi vs. ITO Ward - 40(1), New Delhi

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

ITA 124/DEL/2020[2015-16]Status: DisposedITAT Delhi29 Sept 2021AY 2015-16

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri K. A. Manu, Sr. D.R
Section 10Section 10(38)Section 143(2)Section 68

claimed exemption under Section 10(38) of the Act. 04. The ld. Assessing Officer referred to the investigation report of the Director, Investigation Wing to un-earth organized racket generating bogus entries with long term capital gain, which is exempt from tax. In the case of M/s. Goldline Finvest International ... parties based on whose statement the addition has been made. In para No. 5.3 he noted that the finding of the case of the Investigation Wing further corroborated the independent findings of the ld. Assessing Officer and, therefore, the Assessing Officer was not allowed to the appellant the opportunities

Dove Consultants Pvt Ltd, New Delhi vs. DCIT Circle-7(1), New Delhi

The appeal of the assessee stands allowed

ITA 1197/DEL/2019[2009-10]Status: DisposedITAT Delhi29 Sept 2021AY 2009-10

Bench: Shri Anil Chaturvedi & Shri Sanjay Garg

For Appellant: Sh. Kapil Goel, AdvFor Respondent: Sh. Maninder Kaur, Sr. DR
Section 147Section 148Section 4Section 69

erred in sustaining the order passed by Ld AO u/s 147/143(3) without appreciating that no back material like, investigation wing report details vis a vis assessee, and statements etc if any recorded by investigation wing, was lawfully confronted to assessee thus invalidating entire reopening and even cross examination request ... without appreciating that it was specifically pointed out to Ld CIT-A vide ground no 6 of appeal that assessee fully cooperated with investigation wing in summon proceedings and filed necessary details which plea has not been objectively considered, without which entire addition is bad and deserves to be deleted

Mahendra H. Shah, Mumbai vs. ITO - Ward- 4 (1)(3), Mumbai

ITA 6892/MUM/2018[2012-13]Status: DisposedITAT Mumbai27 Sept 2021AY 2012-13

Bench: Shri C.N. Prasad, Hon’Bleshri Mahendra H. Shah V. Income Tax Officer – 4(1)(3) 6Th Floor, Aayakar Bhavan C/O. The Presscopper Industries M.K. Road, Mumbai - 400020 175, Kika Street Mumbai – 400004 Pan: Aafps0929R (Appellant) (Respondent)

For Appellant: Vimal PunmiyaFor Respondent: Smita Verma
Section 132(4)Section 133(4)Section 143(1)Section 143(2)Section 68

discredit the evidences and the explanation given by the assessee company and cannot rely only on statement of third parties recorded by the investigation wing. e. In another landmark judgment of Hon'ble Gujarat High Court in the case of Varshahen S Patel vs. ITO,[2015] 64 taxmann.com 179 (Gujarat ... received from Josh 14 Shri Mahendra H. Shah Trading Company Pvt. Ltd. and Viraj Mercantile Put. Ltd on the basis of information received from Investigation Wing which revealed that the assessee is beneficiary of bogus accommodation entries provided by ShriPraveenkumar Jain through his bogus companies.................. The AO has brought

M/S Diam International, Surat vs. The Income Tax Officer, Ward-2(3)(7), Surat

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

ITA 475/SRT/2018[2010-11]Status: DisposedITAT Surat24 Sept 2021AY 2010-11

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) M/S Diam International, Income Tax Officer 202-B, Krishna Apartment, Ward-2(3)(7), Room No. Vs Kansara Sheri, 414, Anavil Centre, Hazira Mahidharpura, Surat Road, Adajan, Surat- Pan : Aaofm 4432 A 395001 Assessee / Appellant Revenue /Respondent

Section 132Section 147Section 148Section 254(1)

information that a search and seizure action under section 132 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the Investigation Wing, Mumbai was carried out on 03.10.2013 on Shri Bhanwarlal Jain group. During the search action a lot of incriminating material pertaining of providing ... find that the assessing officer made 100% disallowance of the purchases shown from Rare Diamonds Private Limited by making reliance on the report of investigation wing Mumbai. The ld CIT(A) confirmed the action of assessing officer under section 147 as well as on making addition of bogus purchases

ITO 27(1)(4), Mumbai vs. Shri. Dilip G Kachhara, Mumbai

Accordingly, the impugned order is upheld and appeal by the Revenue is dismissed, sans merit

ITA 494/MUM/2020[2009-10]Status: DisposedITAT Mumbai24 Sept 2021AY 2009-10

Bench: Shri Vikas Awasthyआअसं. 494/मुं/2020 (िन.व.2009-10) Ito-27(1)(4), Room No. 409, 4Th Floor, Tower No.6, Vashi Railway Station Complex, Vashi, Navi Mumbai-400703. ...... अपीलाथ" /Appellant बनाम Vs. Dilip G. Kachhara, Bhairav Enterprises, 1, Kanta Smruti, Near Hotel Airways, Lbs Marg, Ghatkopar (W), Mumbai-400086. Pan: Aabpk2046H ..... "ितवाद"/Respondent अपीलाथ" "ारा/ Appellant By : Sh. Sanjay J. Sethi "ितवाद" "ारा/Respondent By : None सुनवाई क" ितिथ/ Date Of Hearing : 01/07/2021 घोषणा क" ितिथ/ Date Of Pronouncement : 24/09/2021 आदेश/ Order Per Vikas Awasthy, J.M: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-24, Mumbai [Hereinafter Referred To As ‘The Cit(A)’] ' Dated 23.10.2019 For The Assessment Year (Ay) 2009-10. 2. The Brief Facts Of The Case As Emanating From Records Are: The Assessee Is Engaged In Trading Of Building Material. On The Basis Of Information Received

For Appellant: Sh. Sanjay J. SethiFor Respondent: None
Section 142(1)Section 143(3)Section 144Section 147Section 148

assessee is engaged in trading of building material. On the basis of information received आअसं. 494/मुं/2020 (िन.व.2009-10) from Investigation wing of the Department, the assessment for AY 2009-10 in the case of assessee was re-opened. As per the information received, the assessee

Shri Krishna Jewels Pvt. Ltd., New Delhi vs. DCIT, Central Circle- 25, New Delhi

In the result, the appeal of the assessee is partly

ITA 6758/DEL/2017[2013-14]Status: FixedITAT Delhi24 Sept 2021AY 2013-14

Bench: Shri R.K.Panda & Shri Vijay Pal Raoassessment Year : 2013-14

Section 271(1)(c)

Thereafter, a survey operation u/s 133A of the Act was carried out at the business premises of the assessee on 19.12.2013 by the Investigation Wing-1(1) of the Department. A survey was 8 | P a g e also conducted in case of 3 other companies of this group including ... under consideration. Therefore, it is not voluntarily surrender made by the assessee but the surrender was made because of the enquiry conducted by the Investigation Wing during survey proceedings. 14. We have considered the rival submission as well as the material available on record. The assessee has not disputed

ACIT-19(3), Mumbai vs. M/S Vijay Jewellers, Mumbai

Appeal of the Revenue is dismissed

ITA 6167/MUM/2019[2009-10]Status: DisposedITAT Mumbai23 Sept 2021AY 2009-10

Bench: Shri Vikas Awasthyआअसं. 6167/मुं/2019 (िन.व.2009-10) Acit-19(3), Room No. 206, 2Nd Floor, Matru Mandir, Tardeo Road, Mumbai-400007. ...... अपीलाथ" /Appellant बनाम Vs. M/S Vijay Jewellers 67, Kundamal Hosue, Hughes Road,Mumbai-400007. Pan: Aaafv3730A ..... "ितवाद"/Respondent अपीलाथ" "ारा/ Appellant By : Sh. Sanjay J. Sethi "ितवाद" "ारा/Respondent By : Sh. Devang Divecha सुनवाई क" ितिथ/ Date Of Hearing : 29/06/2021 घोषणा क" ितिथ/ Date Of Pronouncement : 23/09/2021 आदेश/ Order Per Vikas Awasthy, J.M: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-29, Mumbai [Hereinafter Referred To As ‘The Cit(A)’] Dated 16.07.2019 For The Assessment Year (Ay) 2009-10. 2. The Brief Facts Of The Case As Emanating From Records Are: The Assessee Is A Trader In Gold & Diamond Jewellery. The Assessment For Ay 2009-10 In The Case Of Assessee Was Re-Opened On The Ground That The Assessee Has Obtained

For Appellant: Sh. Sanjay J. SethiFor Respondent: Sh. Devang Divecha
Section 143(3)Section 147

reasons for re-opening reveals that the assessment in the case of assessee was re-opened on the basis of information received from Investigation Wing of Income Tax Department. The Tribunal in the case of ITO vs. Amarchand P. Shah आअसं. 6167/मुं/2019 (िन.व.2009-10) reported ... CBDT Circular (supra). It is an internal wing of the Income Tax Department, therefore, any addition on the basis of information received from the Investigation Wing of the Department would not be covered by exception provided in para-10(e) of the CBDT Circular (supra). Since, the appeal by Revenue

ITO, Ward-2(3)(7), Surat vs. Dipakkumar S. Mehta, Surat

In the result, the appeal of the Revenue in (ITA No

ITA 1503/AHD/2017[2007-08]Status: DisposedITAT Surat22 Sept 2021AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.1503/Ahd/2017 ("नधा"रणवष" / Assessment Years: (2007-08) (Virtual Court Hearing) The Ito, Ward-2(3)(7), Vs. Shri Dipakkumar S. Mehta, Surat. Prop. Of Seema Impex, 401, 6/1582, Kumbhar Sheri, Mahidharpura, Surat-395009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afapm8151K (Revenue) (Assessee) आयकरअपीलसं./Ita No.1461/Ahd/2017 ("नधा"रणवष" / Assessment Years: (2007-08) (Virtual Court Hearing) Shri Deepak S. Mehta, Vs. The Ito, Ward-2(3)(7), C/O. 302, Nishit Diamond Complex, Surat. Gujjar Falia, Mahidharpura, Surat-395009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afapm8151K (Assessee) (Revenue)

For Appellant: Shri Himashu Gandhi, CAFor Respondent: Shri O.P. Vaishnav, CIT(DR)
Section 142(1)Section 143(2)Section 143(3)Section 148Section 151

perused the submission of the AR and considered verbal arguments. It is seen from the records that the AO has received report from the Investigation Wing, Mumbai, which indicated that the assessee was beneficiary of accommodation entry operators. The said accommodation entry operator has admitted before the Investigation Wing that ... further seen that the Id assessing officer has not made any independent enquiries of his own. He has just relied on the report of Investigation Wing, Mumbai, The Hon'ble Supreme Court in the case of Andaman Timber Mart (281CTR 241) has categorically held that "not furnishing the copy material

Deepak S. Mehta, Surat vs. ITO, Ward-2(3)(7), Surat

In the result, the appeal of the Revenue in (ITA No

ITA 1461/AHD/2017[2007-08]Status: DisposedITAT Surat22 Sept 2021AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.1503/Ahd/2017 ("नधा"रणवष" / Assessment Years: (2007-08) (Virtual Court Hearing) The Ito, Ward-2(3)(7), Vs. Shri Dipakkumar S. Mehta, Surat. Prop. Of Seema Impex, 401, 6/1582, Kumbhar Sheri, Mahidharpura, Surat-395009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afapm8151K (Revenue) (Assessee) आयकरअपीलसं./Ita No.1461/Ahd/2017 ("नधा"रणवष" / Assessment Years: (2007-08) (Virtual Court Hearing) Shri Deepak S. Mehta, Vs. The Ito, Ward-2(3)(7), C/O. 302, Nishit Diamond Complex, Surat. Gujjar Falia, Mahidharpura, Surat-395009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afapm8151K (Assessee) (Revenue)

For Appellant: Shri Himashu Gandhi, CAFor Respondent: Shri O.P. Vaishnav, CIT(DR)
Section 142(1)Section 143(2)Section 143(3)Section 148Section 151

perused the submission of the AR and considered verbal arguments. It is seen from the records that the AO has received report from the Investigation Wing, Mumbai, which indicated that the assessee was beneficiary of accommodation entry operators. The said accommodation entry operator has admitted before the Investigation Wing that ... further seen that the Id assessing officer has not made any independent enquiries of his own. He has just relied on the report of Investigation Wing, Mumbai, The Hon'ble Supreme Court in the case of Andaman Timber Mart (281CTR 241) has categorically held that "not furnishing the copy material