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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

DCIT, New Delhi vs. M/S Pilot Industries Ltd., New Delhi

In the result, all the five appeals filed by the learned assessing officer are dismissed

ITA 3259/DEL/2016[2007-08]Status: DisposedITAT Delhi19 Aug 2021AY 2007-08

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel, CAFor Respondent: Shri H. K. Choudhary, CIT DR
Section 132

automobile and inverter industries. 5. Search and seizure operation u/s 132 of The Income Tax Act 1961 [The Act] was conducted by the investigation wing of the Department on 26th of April 2010 in ‘pilot group of cases’. The assessee company’s business premise at New Delhi was also covered

DCIT, New Delhi vs. M/S Pilot Industries Ltd., New Delhi

In the result, all the five appeals filed by the learned assessing officer are dismissed

ITA 3258/DEL/2016[2006-07]Status: DisposedITAT Delhi19 Aug 2021AY 2006-07

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel, CAFor Respondent: Shri H. K. Choudhary, CIT DR
Section 132

automobile and inverter industries. 5. Search and seizure operation u/s 132 of The Income Tax Act 1961 [The Act] was conducted by the investigation wing of the Department on 26th of April 2010 in ‘pilot group of cases’. The assessee company’s business premise at New Delhi was also covered

DCIT, New Delhi vs. M/S Pilot Industries Ltd., New Delhi

In the result, all the five appeals filed by the learned assessing officer are dismissed

ITA 3257/DEL/2016[2005-06]Status: DisposedITAT Delhi19 Aug 2021AY 2005-06

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel, CAFor Respondent: Shri H. K. Choudhary, CIT DR
Section 132

automobile and inverter industries. 5. Search and seizure operation u/s 132 of The Income Tax Act 1961 [The Act] was conducted by the investigation wing of the Department on 26th of April 2010 in ‘pilot group of cases’. The assessee company’s business premise at New Delhi was also covered

Vithaldas and Company (Sicne Dissolve), Hyd, Hyderabad vs. DCIT, Circle-6(1), Hyderabad

Appeals are partly allowed in above terms

ITA 757/HYD/2017[2009-10]Status: DisposedITAT Hyderabad18 Aug 2021AY 2009-10

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri Vinay Kumar Kabra, ARFor Respondent: Smt. M.Narmada, DR
Section 143(3)Section 147Section 148

three instant appeals are in a very narrow compress. The assessing authority(ies) herein had received information from the department’s Investigation Wing, Mumbai that the assessee had sourced its purchases involving varying sums (supra) from M/s.Bhanwarlal Jain group concerns namely M/s.Prime Star in these three assessment years. And that ... Assessing Officer’s as well as the CIT(A)’s respective detailed discussions justifying the impugned re-opening(s) based on the Investigation Wing, Mumbai’s information pinpointing the specific inputs in search proceedings including :- 4 -: ITA Nos. 755, 756 & 757/Hyd/2017 M/s.Bhanwarlal Jain group authorised persons statement(s) to have

Vithaldas and Company (Sicne Dissolve), Hyd, Hyderabad vs. DCIT, Circle-6(1), Hyderabad

Appeals are partly allowed in above terms

ITA 756/HYD/2017[2008-09]Status: DisposedITAT Hyderabad18 Aug 2021AY 2008-09

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri Vinay Kumar Kabra, ARFor Respondent: Smt. M.Narmada, DR
Section 143(3)Section 147Section 148

three instant appeals are in a very narrow compress. The assessing authority(ies) herein had received information from the department’s Investigation Wing, Mumbai that the assessee had sourced its purchases involving varying sums (supra) from M/s.Bhanwarlal Jain group concerns namely M/s.Prime Star in these three assessment years. And that ... Assessing Officer’s as well as the CIT(A)’s respective detailed discussions justifying the impugned re-opening(s) based on the Investigation Wing, Mumbai’s information pinpointing the specific inputs in search proceedings including :- 4 -: ITA Nos. 755, 756 & 757/Hyd/2017 M/s.Bhanwarlal Jain group authorised persons statement(s) to have

Vithaldas and Company (Sicne Dissolve), Hyd, Hyderabad vs. DCIT, Circle-6(1), Hyderabad

Appeals are partly allowed in above terms

ITA 755/HYD/2017[2007-08]Status: DisposedITAT Hyderabad18 Aug 2021AY 2007-08

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri Vinay Kumar Kabra, ARFor Respondent: Smt. M.Narmada, DR
Section 143(3)Section 147Section 148

three instant appeals are in a very narrow compress. The assessing authority(ies) herein had received information from the department’s Investigation Wing, Mumbai that the assessee had sourced its purchases involving varying sums (supra) from M/s.Bhanwarlal Jain group concerns namely M/s.Prime Star in these three assessment years. And that ... Assessing Officer’s as well as the CIT(A)’s respective detailed discussions justifying the impugned re-opening(s) based on the Investigation Wing, Mumbai’s information pinpointing the specific inputs in search proceedings including :- 4 -: ITA Nos. 755, 756 & 757/Hyd/2017 M/s.Bhanwarlal Jain group authorised persons statement(s) to have

ACIT, CC - 1 (2), Chennai vs. M/S. Studio Green, Chennai

In the result, the appeal of the Revenue is dismissed and the Cross

ITA 2427/CHNY/2019[2011-12]Status: DisposedITAT Chennai18 Aug 2021AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.2427/Chny/2019 िनधा"रण वष"/Assessment Year: 2011-12 & C.O. No. 99/Chny/2019 [In I.T.A. No. 2427/Chny/2019] The Assistant Commissioner Of M/S. Studio Green, Income Tax, Central Circle 1(2), Vs. Old No. 13, New No. 6, Ii Floor, Investigation Wing, Room No. 311, 6, Thanikachalam Road, No. 46, Mg Road, Chennai. T. Nagar, Chennai 600 017. [Pan: Absfs6433Q] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri S. Bharath, Cit : ""थ" की ओर से/Respondent By Shri V. Vivek Rajan, C.A. : सुनवाई की तारीख/ Date Of Hearing 18.08.2021 : घोषणा की तारीख /Date Of Pronouncement : 18.08.2021 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 26.06.2019 Relevant To The Assessment Year 2011-12. 2. The Only Issue Involved In The Appeal Of The Revenue Is Relating To Whether The Second Proviso Section 40(A)(Ia) Of The Income Tax Act, 1961 [“Act” In Short] Applies Retrospectively Or Only Prospective From The Date Of 2

Section 194CSection 194JSection 201Section 40

2427/Chny/2019] The Assistant Commissioner of M/s. Studio Green, Income Tax, Central Circle 1(2), Vs. Old No. 13, New No. 6, II Floor, Investigation Wing, Room No. 311, 6, Thanikachalam Road, No. 46, MG Road, Chennai. T. Nagar, Chennai 600 017. [PAN: ABSFS6433Q] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की

Sheikh Kutbuddin Habib, Coimbatore vs. ACIT, Coimbatore

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

ITA 264/CHNY/2017[2011-12]Status: DisposedITAT Chennai18 Aug 2021AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 263 & 264/Chny/2017 िनधा"रण वष" / Assessment Years: 2010-11 & 2011-12

For Appellant: Shri K. Raghu, CAFor Respondent: Shri G. Suresh Periasamy, JCIT
Section 131Section 139(1)Section 143(3)Section 147Section 148Section 271(1)(c)Section 274

case are that the assessee is an individual engaged in real estate business, was not filing his income tax returns regularly. The Investigation Wing of Income-Tax Department conducted enquiry on the basis of suspicious transaction report generated by the system about huge investments made by the assessee in real ... filing belated return had also expired but no return was filed till that date. It was only after the enquiries conducted by the Investigation Wing and impounding of certain documents evidencing income, the appellant had no choice but to file returns of income for the last four years

Sheikh Kutbuddin Habib, Coimbatore vs. ACIT, Coimbatore

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

ITA 263/CHNY/2017[2010-11]Status: DisposedITAT Chennai18 Aug 2021AY 2010-11

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 263 & 264/Chny/2017 िनधा"रण वष" / Assessment Years: 2010-11 & 2011-12

For Appellant: Shri K. Raghu, CAFor Respondent: Shri G. Suresh Periasamy, JCIT
Section 131Section 139(1)Section 143(3)Section 147Section 148Section 271(1)(c)Section 274

case are that the assessee is an individual engaged in real estate business, was not filing his income tax returns regularly. The Investigation Wing of Income-Tax Department conducted enquiry on the basis of suspicious transaction report generated by the system about huge investments made by the assessee in real ... filing belated return had also expired but no return was filed till that date. It was only after the enquiries conducted by the Investigation Wing and impounding of certain documents evidencing income, the appellant had no choice but to file returns of income for the last four years

Smt. Parminder Kaur, Ludhiana vs. Income Tax Officer, 3(3), Jalandhar

In the result, the appeal is partly allowed

ITA 643/ASR/2017[2009-10]Status: DisposedITAT Amritsar16 Aug 2021AY 2009-10

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

Section 147Section 148

husband had made unaccounted investments of Rs.3,17,47,500/- on the basis of the agreement I.T.A. No. 643/AMR/2017 13 dated 09.05.2008. The investigation wing of the respondent have recorded the statement of the assessee’s husband, wherein he had submitted that he had signed the agreement on 15.08.2008, however

ITO 32 (1)(4), Mumbai vs. M/S Deora Enterprises, Mumbai

In the result, the appeal of Revenue is dismissed

ITA 108/MUM/2020[2010-11]Status: DisposedITAT Mumbai13 Aug 2021AY 2010-11

Bench: Sri Mahavir Singh, Vp & Sri Manoj Kumar Aggarwal, Am आमकय अऩीर िं./ Ita No. 108/Mum/2020 (ननधाायण वर्ा / Assessment Year 2010-11) The Income Tax Officer M/S Deora Enterprises Ward 32(1)(4) 401-402, Narbada Niwas Room No. 706, 7 Th Floor, Kautilya R.C. Patel Road, फनाभ/ Bhavan, Bandra Kurla Complex, Chandavarkar Road, Bandra (East), Mumbai-400 051 Borivali West, Vs. Mumbai-400 092 (अऩीराथी / Appellant) (प्रत्मथी/ Respondent) स्थामी रेखा िं./Pan No. Aaafd1878R अऩीराथी की ओय े/ Appellant By : Shri Bharat Andhle, Cit Dr प्रत्मथी की ओय े/ Respondent By : None ुनवाई की तायीख / Date Of Hearing: 20.07.21 घोर्णा की तायीख / Date Of Pronouncement: 13.08.21

For Appellant: Shri Bharat Andhle, CIT DRFor Respondent: None
Section 143(3)Section 271(1)(c)

Nos.108/Mum/2020 M/s Deora Enterprises; AY 10-11 3. Briefly stated facts are that the AO received information from the investigation wing of the department, who in turn received information Maharashtra Sales Tax Department about the entry provider who are engaged in issuing accommodation bills to various beneficiaries but not supplying

ITO - 4(3)(1), Mumbai vs. Nita Jajoo Ventures Pvt. Ltd., Mumbai

ITA 2890/MUM/2017[2012-13]Status: DisposedITAT Mumbai13 Aug 2021AY 2012-13
Section 143(3)Section 68

find that the ld AO had relied on the information received from the Investigation wing and alleged that the said companies are controlled and operated by Shri Shirish C Shah who has indulged in providing accommodation entries through the said entities without entering into actual transactions. The ld AO therefore

R.N. Khemka Enterprises (P) Ltd., Delhi vs. ITO Ward- 20(3), New Delhi

In the result, the appeal filed by the assessee is

ITA 7244/DEL/2019[2011-12]Status: DisposedITAT Delhi12 Aug 2021AY 2011-12

Bench: Shri R.K. Panda & Ms. Suchitra Kamble[Assessment Year: 2011-12]

Section 131Section 139Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 68

invoking the provisions of section 68 of the Act. 5. The AO further noted that as per the other information received from the Investigation Wing, the assessee has taken accommodation entries of Rs.50 lakhs from M/s. Ashish Capital Services (P) Ltd. on 15.05.2010. This company is controlled by Shri Surender ... that the reassessment proceedings were made without applying independent mind by the AO and the reopening was merely based on the report of the Investigation Wing. It was also argued that the reasons recorded do not contain the name of the so called entry provider, the important details in form

Jansampark Advertising & Marketing P.Ltd, Delhi vs. ITO, Ward-4(2) (Now Ward-13(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 3132/DEL/2018[2004-05]Status: DisposedITAT Delhi12 Aug 2021AY 2004-05

Bench: Shri N.K.Billaiya & Shri K.Narasimha Chary

Section 143(3)Section 148Section 68

assessee filed the return of income on 1/11/2004 declaring an income of Rs.3,180/-; that claiming to have received specific information from investigation wing of the Department, learned Assessing Officer recorded reasons that the assessee company had indulged in receiving accommodation entries and the total amount of payment received ... found by the Ld. CIT(A) as available at page 30 of the assessment record, read as under:- "Information has been received from the Investigation Wing of IT Department, New Delhi regarding beneficiaries and operators of accommodation entries in Delhi. In the said information, it has been inter alia reported

Shri. Bhanwarlal H Chandak, Mumbai vs. ITO 35(1)(2), Mumbai

ITA 4815/MUM/2019[2014-15]Status: DisposedITAT Mumbai10 Aug 2021AY 2014-15

Bench: Shri Vikas Awasthyआअसं. 4815/मुं/2019 (िन.व.2014-15) Shri Bhanwarlal H. Chandak, Ito-35(1)(2), Room No. 904, 9Th Floor, 9-A, Giri Apartment, J.B. Nagar, Andheri (East), C-41 To C-43, G Block, बनाम Mumbai-400059 Kautilya Bhavan, Bkc, /Vs. Bandra (E), Mumbai-400051. (अपीलाथ" /Appellant) ("ितवाद" /Respondent) Pan No. Aavpc9789M अपीलाथ" "ारा/ Appellant By : Sh. Kumar U. Kale, Advocate "ितवाद" "ारा/Respondent By : Sh. Sanjay J. Sethi सुनवाई क" ितिथ/ Date Of Hearing : 03/06/2021 घोषणा क" ितिथ/ Date Of Pronouncement : 10/08/2021 आदेश/ Order Per Vikas Awasthy, J.M: This Appeal By Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-46, Mumbai [Hereinafter Referred To As ‘The Cit(A)’] Dated 01.05.2019 For The Assessment Years (Ay) 2014-15. 2. Shri Kumar U. Kale Appearing On Behalf Of The Assessee Submitted That The Solitary Ground Raised By The Assessee In Appeal Is Against The Disallowance Of Rs. 1,25,000/- Claimed By The Assessee/Appellant As Deduction Under Section 80Gga Of The Income Tax Act, 1961 [Hereinafter Referred To As ‘The Act’]. The Ld. Counsel Narrating Facts Of The Case Submitted That, The Assessee Had Made

For Appellant: Sh. Kumar U. Kale, AdvocateFor Respondent: Sh. Sanjay J. Sethi
Section 143(3)Section 147Section 35ASection 80G

prayed for dismissing the appeal of assessee. The ld. Departmental Representative (DR) submitted that search and survey operation was carried out by the Investigation Wing on Navjeevan Charitable Trust. During search operation, it was found that the Trust had accepted donations and returned the amount to donors in cash after

Benco Finance & Investment P.Ltd, Mumbai vs. DCIT Cen Cir 40, Mumbai

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 2092/MUM/2017[2006-07]Status: DisposedITAT Mumbai10 Aug 2021AY 2006-07

Bench: Shri M.Balaganesh () & Shri Ravish Sood () Benco Finance & Investment Dy. Cit, Central Circle-40 Private Limited; 205, Sujata Vs. (Now Dcit, Central Circle -7(2), Mumbai) Room No. 656, 6Th Floor, Chambers, 2Nd Floor, 1/3 Aaykar Bhawan, M.K Road, Abhichan Gandhi Marg, Off. Mumbai – 400 020. Katha Bazar, Masjid Bunder (W), Mumbai – 400 009 (Assessee) (Revenue) Pan No. Aabcb9349R Assessee By : S/Shri Vijay Mehta & Purushottam, A.Rs Revenue By : Ms. Shreekala Pardeshi, D.R Date Of Hearing : 18/06/2021 Date Of Pronouncement : 10/08/2021

For Appellant: S/shri Vijay Mehta & Purushottam, A.RsFor Respondent: Ms. Shreekala Pardeshi, D.R
Section 132Section 143(3)Section 147Section 153Section 234BSection 68

declaring an income of Rs. 25,310/-. Search and seizure action u/s 132 of the Act was conducted by the Investigation Wing of the Income-tax Department in the case of M/s Ruchi Soya Industries Ltd. and the assessee company was covered in the said proceedings

Dy CIT CC 1(4), Mumbai vs. M/S Hemadari Machine Tools Pvt Ltd., Mumbai

ITA 714/MUM/2020[2011-12]Status: DisposedITAT Mumbai09 Aug 2021AY 2011-12

Bench: Shri Rajesh Kumar () & Shri Ravish Sood () Dy. Commissioner Of Income-Tax M/S Hemadari Machine Tools Central Circle -1 (4), Vs. Pvt. Ltd., Podar Centre, 85 Room No. 902, 9Th Floor, Parel Post Office Lane, Off Pratishtha Bhavan, Dr. Ambedkar Road, Parel, Old Cgo Bldg, (Annexe), Mumbai – 400 012 M.K. Road, Mumbai – 400 020

For Appellant: Ms. Ritu Kamal Kishore, A.RFor Respondent: Shri Gurbinder Singh, D.R
Section 131Section 132Section 133ASection 143(1)Section 143(3)Section 68

714/Mum/2020 A.Y. 2011-12 4 Dy. CIT, C.C-1(4) Vs. M/s Hemadari Machine Tools Pvt. Ltd. survey action conducted by the Investigation wing in the case of Podar group was found to have received share premium of Rs. 2.25 crore from the following non-existent persons/entities : Sr. No. Name ... supported and evidenced by documentary evidence, the same, thus, could not be treated as bogus simply on the basis of the report of the Investigation wing or the statement of third parties. Apart from that, it was observed by the CIT(A) that qua the genuineness of the donations given

Asst CIT CC 1 (1), Mumbai vs. Shri. Nitin B Gajipara, Navi Mumbai

Appeal is dismissed

ITA 7473/MUM/2019[2012-13]Status: DisposedITAT Mumbai09 Aug 2021AY 2012-13

Bench: Shri Shamim Yahya (Am) & Shri Pavan Kumar Gadale (Jm)

Section 132(1)Section 139Section 142(1)Section 143(2)Section 153ASection 46ASection 68Section 69C

makes it apparent that during the course of search operation, only certain cash, jewellery and one brokerage bill was found and seized by the Investigation Wing. 12.1 I have also gone through the assessment order passed by the Assessing Officer u/s. 143(3) r.w.s. 153A of the Act and taken

Sjm International Ltd., New Delhi vs. DCIT, Circle- 24(20, New Delhi

ITA 3762/DEL/2018[2009-10]Status: DisposedITAT Delhi09 Aug 2021AY 2009-10

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh

For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Shri Prakash Dubey, Senior DR
Section 131Section 139(1)Section 143Section 143(3)Section 147Section 148Section 151Section 234BSection 68

case was reassessed at the returned income of Rs.58,49,432/- on 27.03.2014 u/s 147/143(3) of the Act. Again, AO received information from Investigation Wing vide letter dated 15.03.2012 that assessee had obtained accommodation entries amounting to Rs.50,00,000/- under the garb of share capital/share premium from Aseem ... Gupta group, whose residential and business premises were searched/surveyed by the Investigation Wing on 26.03.2010. Details of share capital/share premium are as under :- Name of Company used Cheque/ Cheque Bank Amount for providing Instrument Date Name and Accommodation entry address Moderate Credit Corp Ltd. RTGS 09.03.2009 Corp

Lancer Telecom India (P) Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal filed by the assessee is

ITA 5611/DEL/2016[2004-05]Status: DisposedITAT Delhi09 Aug 2021AY 2004-05

Bench: Shri R.K. Panda & Ms. Suchitra Kamble[Assessment Year: 2004-05]

Section 143(1)Section 144Section 147Section 148Section 151(2)Section 68

recording following reasons:- “Assessment in this case was completed at an income of Rs.25,81,000/- on 01.03.2005. As per the information received from Investigation Wing, Income Tax Department, New Delhi regarding list of Accommodation Entries, the above mentioned assessee was found to have taken accommodation entries amounting to Rs.30 ... form the two company as un explained u/s 68. 6. Whether the LD CIT(A) was justified by holding that the statements recorded by investigation wing are sufficient evidence to disregard the submissions of the Appellant even if neither fresh statement recorded during assessment proceedings nor a opportunity provided