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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

Singhvi Lickmi Chand, Ambur vs. DCIT Central Circle 3(3), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 647/CHNY/2025[2019-20]Status: DisposedITAT Chennai05 Dec 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT
Section 153ASection 69A

assessee ITA Nos.643 to 647/Chny/2025 & ITA Nos.968 to 971/Chny/2025 Shri Singhvi Lickmi Chand :- 12 -: himself had earlier furnished peak cash credit workings before the Investigation Wing, accepting that only the peak balance represents the income component. Considering the continuous and repeated pattern of cash deposits followed by immediate transfers

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 646/CHNY/2025[2018-19]Status: DisposedITAT Chennai05 Dec 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT
Section 153ASection 69A

assessee ITA Nos.643 to 647/Chny/2025 & ITA Nos.968 to 971/Chny/2025 Shri Singhvi Lickmi Chand :- 12 -: himself had earlier furnished peak cash credit workings before the Investigation Wing, accepting that only the peak balance represents the income component. Considering the continuous and repeated pattern of cash deposits followed by immediate transfers

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 645/CHNY/2025[2017-18]Status: DisposedITAT Chennai05 Dec 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT
Section 153ASection 69A

assessee ITA Nos.643 to 647/Chny/2025 & ITA Nos.968 to 971/Chny/2025 Shri Singhvi Lickmi Chand :- 12 -: himself had earlier furnished peak cash credit workings before the Investigation Wing, accepting that only the peak balance represents the income component. Considering the continuous and repeated pattern of cash deposits followed by immediate transfers

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle.3(2), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 644/CHNY/2025[2016-17]Status: DisposedITAT Chennai05 Dec 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT
Section 153ASection 69A

assessee ITA Nos.643 to 647/Chny/2025 & ITA Nos.968 to 971/Chny/2025 Shri Singhvi Lickmi Chand :- 12 -: himself had earlier furnished peak cash credit workings before the Investigation Wing, accepting that only the peak balance represents the income component. Considering the continuous and repeated pattern of cash deposits followed by immediate transfers

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 643/CHNY/2025[2015-16]Status: DisposedITAT Chennai05 Dec 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT
Section 153ASection 69A

assessee ITA Nos.643 to 647/Chny/2025 & ITA Nos.968 to 971/Chny/2025 Shri Singhvi Lickmi Chand :- 12 -: himself had earlier furnished peak cash credit workings before the Investigation Wing, accepting that only the peak balance represents the income component. Considering the continuous and repeated pattern of cash deposits followed by immediate transfers

Shankeshwar Exim LLP, Mumbai vs. ITO - 19(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 5117/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Dec 2025AY 2018-19

Bench: Smt. Beena Pillai, Jm & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 148Section 250Section 69C

Gems) and Bhanwarlal Gurjar (Prop.-Nakoda International)as accommodation entry, merely en assumptions and presumptions, and by relying on the general information received from Investigation Wing, without appreciating that these are genuine sale transactions, done during the regular course of business, duly recorded in the books of accounts as well ... erred in conforming the action of the Ld. AO in making a perverse assessment by merely relying on the information from Investigation Wing, without proper application of mind, following principles of natural justice, making any independent enquiries and collating requisite evidences, and in thereby lending the assessment untenable

DCIT - 19(1), Mumbai, Piramal Chambers vs. Dishant Deepak Shah, Mumbai

In the result, appeal of the revenue is dismissed

ITA 4281/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Dec 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17

For Appellant: Shri Satyaprakash Singh
Section 10(38)Section 68Section 69C

based on analysis of information received from was based on analysis of information received from was based on analysis of information received from investigation Wing Kolkata that the assessee has ente investigation Wing Kolkata that the assessee has ente investigation Wing Kolkata that the assessee has entered into penny stock

Nandkishore Telefilms & Media Private Limited, Mumbai vs. Circle 7(2)(2), Mumbai

In the result appeal of the revenue is dismissed

ITA 2563/MUM/2025[2013-14]Status: DisposedITAT Mumbai05 Dec 2025AY 2013-14
Section 132(4)Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 68

against addition of Rs 50 Lakhs u/s 68 on account\nof unexplained cash-creditors, being Unsecured Loans Lenders. The AO received\nthe information from Investigation Wing that an S & S operation was conducted\nin the case of one Shri Vipul Bhatt, an entry-operator. In his statement recorded\nu/s

Sunny Vijay Lakhani, Mumbai vs. ACIT, 28(3), Mumbai

In the result all the three appeals of the assessee are In the result all the three appeals of the assessee are In the result all the three appeals of the assessee are allowed for statistical purposes

ITA 6950/MUM/2024[2016-17]Status: DisposedITAT Mumbai05 Dec 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Ms. Kavitha Kaushik, (SR DR)For Respondent: Ms. Ritika Aggarwal
Section 68

reliance upon some untested and uncorroborated report of reliance upon some untested and uncorroborated report of reliance upon some untested and uncorroborated report of investigation wing where the Appellant is not even named. investigation wing where the Appellant is not even named. investigation wing where the Appellant is not even ... Officer also relied upon statements recorded by the Officer also relied upon statements recorded by the Officer also relied upon statements recorded by the Investigation Wing—inter alia of Shri Anuj Agrawal Investigation Wing inter alia of Shri Anuj Agrawal (13.03.2015) (13.03.2015) (13.03.2015) and and and Shri Shri Shri Devesh

Sunny Vijay Lakhani, Mumbai vs. ACIT, 28(3), Mumbai

In the result all the three appeals of the assessee are In the result all the three appeals of the assessee are In the result all the three appeals of the assessee are allowed for statistical purposes

ITA 6948/MUM/2024[2015-16]Status: DisposedITAT Mumbai05 Dec 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Ms. Kavitha Kaushik, (SR DR)For Respondent: Ms. Ritika Aggarwal
Section 68

reliance upon some untested and uncorroborated report of reliance upon some untested and uncorroborated report of reliance upon some untested and uncorroborated report of investigation wing where the Appellant is not even named. investigation wing where the Appellant is not even named. investigation wing where the Appellant is not even ... Officer also relied upon statements recorded by the Officer also relied upon statements recorded by the Officer also relied upon statements recorded by the Investigation Wing—inter alia of Shri Anuj Agrawal Investigation Wing inter alia of Shri Anuj Agrawal (13.03.2015) (13.03.2015) (13.03.2015) and and and Shri Shri Shri Devesh

Sunny Vijay Lakhani, Mumbai vs. ACIT 28(3), Mumbai

In the result all the three appeals of the assessee are In the result all the three appeals of the assessee are In the result all the three appeals of the assessee are allowed for statistical purposes

ITA 6947/MUM/2024[2014-15]Status: DisposedITAT Mumbai05 Dec 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Ms. Kavitha Kaushik, (SR DR)For Respondent: Ms. Ritika Aggarwal
Section 68

reliance upon some untested and uncorroborated report of reliance upon some untested and uncorroborated report of reliance upon some untested and uncorroborated report of investigation wing where the Appellant is not even named. investigation wing where the Appellant is not even named. investigation wing where the Appellant is not even ... Officer also relied upon statements recorded by the Officer also relied upon statements recorded by the Officer also relied upon statements recorded by the Investigation Wing—inter alia of Shri Anuj Agrawal Investigation Wing inter alia of Shri Anuj Agrawal (13.03.2015) (13.03.2015) (13.03.2015) and and and Shri Shri Shri Devesh

M/S Frozen Iron and Steel Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, CC-25, Delhi

In the result, the Appeal of the Assessee is partly allowed for

ITA 3065/DEL/2025[2012-13]Status: DisposedITAT Delhi05 Dec 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Frozen Iron & Steel Vs Deputy Commissioner Of Private Limited. Nb-426, 4Th Income Tax, Central Circle- Floor, Nbc Complex, Plot No. 25, Jhandewalan Extension, 43, Sector-11, Cbd Belapur, New Delhi Navi Mumbai, Maharashtra Pan:Aabcf439Q Appellant Respondent Assessee By Sh. Ashwani Kumar, Ca & Sh. Ankur Agarwal, Ca Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 05/12/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeal)-29, New Delhi (‘Ld. Cit(A)’ For Short) Order Dated 24/03/2025 For Assessment Year 2012-13. 2. Brief Facts Of The Case Are That, An Assessment Order Came To Be Passed On 14/12/2019 Under Section 143(3)/147 Of The Income Tax Act

Section 142(1)Section 143(3)Section 147Section 148Section 68

substantiating proof are submitted alongwith its submission. On the other hand, AO had in his possession the specific information forwarded by investigation wing after conducting detailed enquiries on the basis of which the appellant company was found to be beneficiary of availing accommodation entries. AO has replied to the objections ... raised by the appellant stating as under:- ‘In this regard Para wise reply is as under: 3 (i). The Investigation Wing Kolkata has established that cash was deposited in the accounts of M/s ShardaVanijya Private Limited and then transferred M/s Parmeshwar Merchandise Private Limited. Therefrom the funds were transferred

Deputy Commissioner of Income Tax, Ghaziabad vs. Mahalaxmi Light House, Hapur

ITA 3514/DEL/2024[2018-19]Status: DisposedITAT Delhi05 Dec 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Deputy Commissioner Of Vs. Mahalakshmi Light House, Income Tax 285, Avas Vikas Vihar, Room No. 201, First Floor, Hapur, Uttar Pradesh Cgo Complex, Hapurchungi, Pan: Aatfm3627N Ghaziabad, Uttar Pradesh Appellant Respondent

Section 148Section 148ASection 69

facts to treat that bogus expenses of Rs.68,78,020/- and bogus GST of Rs.3.43,898/ as genuine, contrary to the findings of the Investigation wing of the department. The Investigation Wing conducted a search and seizure action on KK Spun Group and gave detailed findings with regard to bogus

Hydrise Foods Private Limited, Uttar Pradesh, India vs. Deputy Commissioner of Income Tax, Central Circle, Agra, Uttar Pradesh, India

In the result, both the appeals of the assessee are allowed

ITA 87/AGR/2024[2018-19]Status: DisposedITAT Agra04 Dec 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing)

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT DR
Section 132(1)Section 143(3)Section 153ASection 153D

Central Range, the ld. Addl. CIT is involved in the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing and is involved with the ld. AO from time to time while issuing various questionnaires to the assessee. The ld. Addl. CIT in Central ... Addl. CIT is involved with the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing, still, the ld. Addl.CIT, while granting the approval u/s 153D has to independently apply his mind dehors the conclusions drawn either by the Investigation Wing in the appraisal

Hydrise Foods Private Limited, Noida, Uttar Pradesh, India vs. Deputy Commissioner of Income Tax, Central Circle, Agra, Uttar Pradesh, India

In the result, both the appeals of the assessee are allowed

ITA 86/AGR/2024[2017-18]Status: DisposedITAT Agra04 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing)

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT DR
Section 132(1)Section 143(3)Section 153ASection 153D

Central Range, the ld. Addl. CIT is involved in the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing and is involved with the ld. AO from time to time while issuing various questionnaires to the assessee. The ld. Addl. CIT in Central ... Addl. CIT is involved with the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing, still, the ld. Addl.CIT, while granting the approval u/s 153D has to independently apply his mind dehors the conclusions drawn either by the Investigation Wing in the appraisal

Mamta Patel, Raipur vs. ACIT, Circle-1(1), Raipur

In the result, appeal of the assessee is allowed

ITA 684/RPR/2025[2020-21]Status: DisposedITAT Raipur04 Dec 2025AY 2020-21

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.684/Rpr/2025 "नधा"रण वष" /Assessment Year : 2020-21 Mamta Patel E-802, Wallfort Height, Bhatagaon, Raipur-492 015 (C.G.) Pan: Ahrpp8532E

For Appellant: Mrs. Dimple Warylani, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 132(4)Section 69

return of income for the Assessment Year (AY) 2020-21 declaring a total income of Rs.17,32,640/-. Subsequently, information was received from the Investigation Wing of the department concerning a search and seizure action carried out in the case of the Wallfort Group on 03.11.2023. During the search proceedings

Sumitra Surendra Gadodia, Mumbai vs. ITO 31(3)(4), Bandra, Mumbai

ITA 4519/MUM/2025[2014-15]Status: DisposedITAT Mumbai04 Dec 2025AY 2014-15
Section 10(26)Section 10(38)Section 143(2)Section 44ASection 68

Resorts Limited, the assessee claimed capital\ngains of Rs.81,72,626/- to be exempt u/s 10(26), the Ld.AO.\n2. 3. Based upon the Investigation Wing's report the Ld.AO\nobserved that there is no co-relation in the price rise of KDJ\nHolidayscapes Resorts Limited. The Ld.AO dealt with ... various facts\nof transactions, allotment of shares, payment of premium one\nallotment of shares, price trend on stock exchange, the report of\nKolkata Investigation Wing and the statement of the persons. The\nLd.AO based on these documents, doubted the earnings of long-\nterm capital gain on sale of shares

Principal Commissioner of Income Tax 2 Kolkata vs. M/S Royal Touch Fablon Private Limited

The appeal is dismissed

ITAT/132/2025HC Calcutta03 Dec 2025

Bench: HON'BLE JUSTICE RAJARSHI BHARADWAJ,HON'BLE JUSTICE UDAY KUMAR

Section 143(2)Section 147Section 148Section 68

quashing the reassessment order without considering the fact that the reopening was made on the basis of specific and credible information from the investigation wing of the department ? b) WHETHER in facts and in the circumstances of the case the Ld. Income Tax Appellate Tribunal was not justified

Manju Gems, Surat vs. The Income-Tax, Ward 3(3)(1), Surat.

In the result, the appeal of the assessee is allowed

ITA 217/SRT/2025[2018-19]Status: DisposedITAT Surat03 Dec 2025AY 2018-19

Bench: Shri Diesh Mohan Sinha & Shri Bijayananda Pruseth

For Appellant: Shri Rajesh C Shah, CAFor Respondent: Shri Ajay Uke, Ld. Sr. DR
Section 143(2)Section 147Section 148Section 690Section 69C

Income Tax Act 1961 dated 21/03/2023 which was received by the assessee on 22/03/2023. The AO relied on the report of the Investigation wing which has stated that the purchase transaction with Blooming Star Diamond P. Ltd and Glorious Diamond P. Ltd are bogus. Further the AO has written ... record. The learned AO without seeing my reply has made his mind for the addition of the amount as per the report of the investigation wing. In spite of the fact that in the reply to show cause has been proved that both the parties i.e Blooming Star Diamond

Palak Alloys Pvt. Ltd., Rajganj vs. DCIT, Circle 3(1), Siliguri

In the result, the appeal of the assessee is allowed

ITA 2104/KOL/2025[2019-2020]Status: HeardITAT Kolkata03 Dec 2025AY 2019-2020

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Palak Alloys Pvt. Ltd. C/O Subash Agarwal & Dcit, Circle 3(1) Associates, Advocates, Siddha Aayakar Bhawan, Gibson,1, Gibson Lane, Suite Matigara, Paribahan Nagar, Vs. 213, 2Nd Floor, Kolkata-700069, Siliguri-734101, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aaecp8679B Assessee By : Shri Siddharth Agrawal, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 18.11.2025 Date Of Pronouncement: 03.12.2025

For Appellant: Shri Siddharth Agrawal, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 131Section 147Section 148Section 148ASection 68Section 69CSection 69c

doing this they have also availed and utilized input tax credit (ITC) against fake invoices issued by others. The learned AO noted that the investigation wing issued summon u/s 131 of the Act to M/s Ultra Trade Mart but the same was not complied with. Thereafter, the AO issued show