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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

ACIT-20(1) Mumbai, Piramal Chambers, Parel vs. Anil Jagdishchandra Ahuja, Mumbai

The appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 5852/MUM/2025[2011-12]Status: DisposedITAT Mumbai03 Dec 2025AY 2011-12

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Surendra Mohan, Sr.-DR
Section 133(6)Section 250

order of the AO be upheld. 6. We heard the parties and perused the material on record. The AO based on information received from Investigation Wing that the assessee is a beneficiary of alleged bogus purchases and accordingly called for details pertaining purchases from two parties

Anil Jahdischandra Ahuja, Mumbai vs. Commissioner of Income-Tax (Appeals)-20, Mumbai

The appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 5774/MUM/2025[2011-2012]Status: DisposedITAT Mumbai03 Dec 2025AY 2011-2012

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Surendra Mohan, Sr.-DR
Section 133(6)Section 250

order of the AO be upheld. 6. We heard the parties and perused the material on record. The AO based on information received from Investigation Wing that the assessee is a beneficiary of alleged bogus purchases and accordingly called for details pertaining purchases from two parties

Amit Virendra Patel, Mumbai vs. ITO 19(1)(1), Mumbai

The appeal of the assessee is allowed

ITA 5697/MUM/2025[2012-2013]Status: DisposedITAT Mumbai03 Dec 2025AY 2012-2013

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Gunjan Kakkad, ARFor Respondent: Shri Surendra Mohan, Sr. DR
Section 132Section 143(1)Section 143(3)Section 148Section 153CSection 250Section 69C

sustain on merits. 6. The ld. DR on the other hand submitted that the AO has received information based on the findings of the Investigation Wing that the party with whom the assessee has entered into purchase transaction is a bogus entity and accordingly the AO has rightly treated ... further submitted that the documents furnished by the assessee cannot be independently accepted and has to be considered along with the findings of the Investigation Wing. The ld. DR also submitted that the AO has applied his mind and has come to the conclusion that the transactions entered into

Yashwant Raj Lalchand Bamboli, Mumbai vs. Income Tax Officer, WD-27(3)(5), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4373/MUM/2025[2014-15]Status: DisposedITAT Mumbai03 Dec 2025AY 2014-15

Bench: Shri Sandeep Singh Karhail & Shri Prabhash Shankaryashwant Raj Lalchand V/S. Income Tax Officer, Ward – Bamboli बनाम 27(3)(5), 4Th Floor, Tower 7, Trimurti Building, 105-A, No. 6, Vashi Station N.G. Acharaya Marg, Complex, Mumbai –400703, Chembur, Mumbai - 400 071, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aijpb5149A Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Prakash Jhunjhunwala,ARFor Respondent: Shri Swapnil Choudhary, (Sr.DR)
Section 10(38)Section 143(3)Section 68Section 69C

also find that the co-ordinate benches of ITAT, Mumbai have in several cases considered similar cases of addition of LTCG arising out of Investigation wing Kolkata report in such penny shares. The coordinate bench of ITAT, Mumbai in the case of Praveen Sitaram Agarwal, Mumbai vs Income Tax Officer ... produced to demonstrate manipulation of share prices by the assessee. The additions were made primarily on the basis of general observations contained in the Investigation Wing's report, without establishing any direct nexus between the assessee and the alleged operators or accommodation entry providers. 25. For the sake of clarity

Bharat Babubhai Lukhi, Mumbai vs. Income Tax Officer 30(1)(2Ti, Bandra East Mumbai

ITA 4389/MUM/2024[2012-13]Status: DisposedITAT Mumbai03 Dec 2025AY 2012-13
Section 10(38)Section 68

quoted several decisions and came to the\nconclusion that there are price manipulations of the stock, relied on the\nInvestigation Wing report of Kolkata Investigation Wing and a graphic\nrepresentation of price moments of stock. The price of the stock went as high\nas Rs.360/- and fell down to very ... nreports, assuming the transactions were part of a pre-arranged scheme\nwithout independent verification. The AO failed to appreciate that mere\nallegations by the Investigation Wing cannot be the sole basis for\nconcluding that the LTCG is bogus.\n9. That the learned AO wrongly invoked the principle of 'human\nprobabilities

Imran Ahmad, Moradabad, Uttar Pradesh vs. Income Tax Officer, Moradabad

Appeal is partly allowed

ITA 3490/DEL/2025[2013-2014]Status: DisposedITAT Delhi03 Dec 2025AY 2013-2014
Section 139Section 147Section 148

Gujarat High Court order dated 07.01.2021 (2021) 127 taxmann.com 806 wherein it has been held that where Assessing Officer after receiving information from Investigation Wing that assessee had booked bogus expenses in names of certain entities, verified return of assessee and observed that expenses were inflated by assessee by booking ... Pushpak Bullion (P.) Ltd. Vs DCIT (Entry Receiver) [2017] 85 taxmann.com 84 (Gujarat)/[2017] 250 Taxman 201 (Gujarat) wherein it was held that where investigation wing of department had during course of investigation in case of a third party found that he was indulged in providing accommodation entries and bogus

DCIT Central Circle-1, Noida vs. Nivedan Fin-Invest Lease Ltd., Delhi

In the result, Revenue’s appeal is dismissed

ITA 1713/DEL/2023[2015-16]Status: DisposedITAT Delhi03 Dec 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2015-16

Section 115BSection 133(6)Section 147Section 148Section 151Section 69A

case was selected for complete scrutiny under CASS and the assessment was completed at Rs 83,04,340/-. Subsequently, on receipt of information from Investigation Wing, Noida that the assessee company had given loan of Rs.25,00,00,000/- in cash to M/s JBK Developers Pvt. Ltd., after recording satisfaction

Manoj Anand, Guwahati vs. ITO W-2(2) Ghy, Guwahati

In the result, the appeal of the assessee is allowed

ITA 273/GTY/2024[2018-19]Status: DisposedITAT Guwahati02 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm Manoj Anand Ito W-2(2), Ghy Flat 4D, Garima Grand, Aaykar Bhawan, Christian Basti, Departmental Representative B. G.S. Road, Guwahati-781005, Vs. Baruah Road, Guwahati-781007, Assam Assam (Appellant) (Respondent) Pan No. Agbpa9883C

For Appellant: Shri Miraj D Shah, ARFor Respondent: Shri Sanjay Jha, DR
Section 144BSection 147Section 148Section 68

account of the assessee. It was also stated that during the course of inquiry by the investigation wing into the financials of Urch Trader (P) Ltd. that the said party was not having any creditworthiness and these transactions were of suspicious nature. The assessee filed the return of income ... previous year, appellant has received sum of Rs. 3,43,50,000/- from M/s. Urch Trader Pvt. Ltd. and as per the report of investigation wing of the department, the creditworthiness of M/s. Urch Trader Pvt. Ltd. was suspicious and the said sum received by the appellant

Income Tax Officer, Bhawanipatna vs. Amr Infratech Private Limited, Lane No

In the result, appeal of the revenue as well as cross objection filed by the assessee are dismissed

ITA 62/CTK/2025[2012-13]Status: DisposedITAT Cuttack02 Dec 2025AY 2012-13

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.62/Ctk/2025 ("नधा"रण वष" / Assessment Year : 2012-13) C.O. No.05/Ctk/2025 Assessment Year: 2012-13 Income Tax Officer, Bhawanipatna Vs Amr Infratech Pvt Ltd.,Irrigation Colony , Near Lane No.19, Bhawanipatna Pan No. : Aaica 3668 H .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Satyanarayan Agarwal & Shri Mahendra Kr Agarwal, Ars राज"व क" ओर से /Revenue By : Shri Vijaya Singh, Ld Sr Dr सुनवाई क" तार"ख / Date Of Hearing : 2 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 2 /12/2025 आदेश / O R D E R Per Bench

For Appellant: Shri Satyanarayan Agarwal & ShriFor Respondent: Shri Vijaya Singh, ld Sr DR
Section 143Section 143(3)Section 147

said to have been in the knowledge of the appellant without appreciating the fact that detailed verifications were carried out by the Income Tax Investigation Wing wherein M's Kirlampudi Cummece (P) Ltd was found to be Jamakharchi company. Further a cannot be stated that these throwing anything about ... facts as existed during the time of the original assessment proceeding without appreciating the fact that, the Information received from the Income Tax Investigation Wing was not in possession of the AD at the time of Original Assessment as well as the case of the assessee was re- opened based

Income-Tax Officer, Ward-1(2)(3), Ahmedabad, Aayakar Bhawan, Vejalpur vs. Jasmine Jayantibhai Sanghavi, Ahmedabad

In the result, appeal of the Revenue is dismissed

ITA 1779/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad02 Dec 2025AY 2016-17

Bench: Ms. Suchitra Raghunath Kambleआयकर अपील सं./I.T.A. No. 1779/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2016-17) बनाम/ Income-Tax Officer Jasmine Jayantibhai Ward-1(2)(3), Ahmedabad Sanghavi Vs. 7-F, Swetal Flat, Khanpur Bai Centre, Khanpur, Ahmedabad, Gujarat - 380001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aqcps1433R (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Suresh Chand Meena, Sr. Dr ""यथ" क" ओर से/Respondent By : Shri Sunil Talati, Ar Date Of Hearing 01/12/2025 02/12/2025 Date Of Pronouncement O R D E R The Appeal Is Filed By The Revenue Against The Order Dated 08.08.2025 Passed By The National Faceless Appeal Centre (Nfac), Delhi, For Assessment Year 2016-17. 2. The Grounds Of Appeal Filed By The Revenue Are As Under:

For Appellant: Shri Suresh Chand Meena, Sr. DRFor Respondent: Shri Sunil Talati, AR
Section 133ASection 142(1)Section 147Section 148Section 69ASection 69C

initiated vide notice u/s 148 dated 30.03.2021 were based on "borrowed satisfaction" and were hence invalid, without appreciating that the information received from the investigation Wing, which was specific, reliable and based on material unearthed during a survey u/s 133A, constituted sufficient "tangible material" for the formation of a bona

Krypton Distributors LLP (Earlier Known As Krypton Distributors Pvt. Ltd., Kolkata vs. ITO, Ward 12(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1733/KOL/2025[2013-2014]Status: DisposedITAT Kolkata02 Dec 2025AY 2013-2014

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Krypton Distributors Llp (Earlier Known As Krypton Ito, Ward 12(1), Distributors P. Ltd.) Aaykar Bhawan, P-7, Flat No.1A, 1, Abdul Rasul Chowringhee Square, Vs. Avenue, Kalighat, Kolkata-700069, West Bengal Kolkata-700026, West Bengal (Appellant) (Respondent) Pan No. Aadck5298G Assessee By : Shri Manoj Katuruka, Ar Revenue By : Shri Pankaj Pandey, Dr Date Of Hearing: 13.11.2025 Date Of Pronouncement: 02.12.2025

For Appellant: Shri Manoj Katuruka, ARFor Respondent: Shri Pankaj Pandey, DR
Section 139(1)Section 147Section 148Section 68

assessee was reopened u/s 147 of the by issuing notice u/s 148 of the Act, after the learned AO received information from investigation wing that the assessee is a beneficiary of bogus unsecured loans through bank account of M/s Startrack Vinimay Pvt. ltd. amounting to ₹80 lacs. Accordingly, the learned

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. Sobha Chand Bhansali, Kolkata

In the result, the appeals of the appeal of the Revenue are dismissed

ITA 1090/KOL/2025[2017-18]Status: DisposedITAT Kolkata02 Dec 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.M. Surana, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 132Section 133(6)Section 143(1)Section 143(2)Section 153A

disclosure statement unless the same is backed by seized documents or any other corroborative material. As stated, the assessee filed the disclosure statement before Investigation wing. However, I find that the assessee also filed a separate computation of undisclosed income /receipts and expenditure along with said disclosure with the heading ... order of the AO. The AO, in the remand report has taken support from the page wise explanation filed by the assessee before the Investigation wing. The assessee has filed rejoinder to remand report wherein it has been submitted that the cash inflow and outflow has been taken into account

ACIT-19(1), Mumbai vs. Parul Diamond, Mumbai

In the result, appeal and cross-objection filed by the revenue as well as the assessee respectively, stands dismissed

ITA 6992/MUM/2024[2007-08]Status: DisposedITAT Mumbai02 Dec 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 37Section 68

company of Shri Bhawarlal Jain Group, without considering the fact that the action of the AO was based on the information of the DGIT (Investigation Wing) Mumbai, who have proved beyond doubt with the evidences/documents, during and post search and seizure that M/s. Mohan Enterprises, a dummy entity , was controlled ... thereafter called for various details during the re- assessment proceedings, which were furnished by the assessee. The Ld. AO, based on the information from Investigation Wing of the Department, formed the opinion that assessee was a beneficiary of accommodation entries of bogus purchases from Mohit Enterprises managed by Bhawarlal Jain

Rak Magnum Realty LLP, Mumbai vs. Income Tax Officer-20(3)(1), Mumbai

In the result the appeal filed by the assessee stands partly allowed

ITA 4411/MUM/2024[2012-13]Status: DisposedITAT Mumbai02 Dec 2025AY 2012-13

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(3)Section 147Section 148Section 153CSection 68Section 69C

Lalbaug, Mumbai, jointly with Magnum Developers (Proprietor Shri Hemant Vyas) and the Slum Rehabilitation Authority (SRA). Subsequently, the Ld. AO received information from the Investigation Wing vide letter No. DIT(Inv.)/I/Information/PJ/2014-15 dated 07.07.2014, which was forwarded by ITO 21(1)(1), Mumbai vide letter dated 16.03.2016. 2.1. The information ... genuineness and identity of the loan transactions undertaken by assessee from Duke Business Pvt. Ltd. He submitted that based on an intimation received from Investigation Wing, the authorities below proceeded on the footing that the assessee is a beneficiary of the alleged loan from Duke Business Pvt. Ltd., which

ACIT, Chennai vs. Sri Balaji Educational Amd Trust Charitable Public Trust, Chenna

In the result, the appeal of the Assessee and that of the Department are dismissed

ITA 1471/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250

admission made during the course of search proceedings. In response, the assessee has furnished a comparative chart depicting the income admitted before the Investigation wing & income admitted which is enclosed as per annexure-I 5. On careful consideration of the above depicted chart, it is noticed that as against total ... also flagged the issue that the purported shortage of stock was based on a reference made qua that aspect in the appraisal report of Investigation Wing which, as noted above, did not find mention in the remand report, as during the search it was found that the stock worth

ACIT, Chennai vs. Rajagopalan, Chennai

In the result, the appeal of the revenue is dismissed

ITA 1443/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250Section 69

admission made during the course of search proceedings. In response, the assessee has furnished a comparative chart depicting the income admitted before the Investigation wing & income admitted which is enclosed herewith as annexure-1. 5. On careful consideration of the said chart, it is noticed that as against total donations

M/S. Sri Balaji Educational and Charitable Public Trust, Chennai vs. ACIT, Central Circle-3(4), Chennai

In the result, the appeal of the Assessee and that of the Department are dismissed

ITA 1249/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250

admission made during the course of search proceedings. In response, the assessee has furnished a comparative chart depicting the income admitted before the Investigation wing & income admitted which is enclosed as per annexure-I 5. On careful consideration of the above depicted chart, it is noticed that as against total ... also flagged the issue that the purported shortage of stock was based on a reference made qua that aspect in the appraisal report of Investigation Wing which, as noted above, did not find mention in the remand report, as during the search it was found that the stock worth

Rajendra Sahu, Katni vs. Income Tax Officer-1, Katni

ITA 162/JAB/2023[2013-14]Status: DisposedITAT Jabalpur28 Nov 2025AY 2013-14

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2013-14 Rajendra Sahu, Vs. Income Tax Officer-1, Ram Manohar Lohiya Ward No. 4, Behind Katni Durga Hospital, Adarsh Colony, Katni Pan: Auvps4330A (Appellant) (Respondent) Assessee By: Sh. Rahul Bardia, C.A. Revenue By: Sh. N.M. Prasad, Sr. Dr 1 Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Dated 20.10.2023 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Orders Passed By The Assessing Officer Under Section 147 R.W.S. 144B Of The Income Tax Act On 27.03.2022. The Grounds Of Appeal Are As Under:- “(1) The Order Passed By The Ld Cit (A) Is Bad In Law & Facts, Void Ab Initio & Without Jurisdiction. (2) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Order, When Notice Issued U/S 148 Is Defective. There Is No Application Of Mind Of Ld Ao & Also Of Sanctioning Authority. (3) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Order, When Assessee Made Specific Request To Share Copies Of All The Statement Recorded By The Investigation Wing Regarding The Sale Of Properties. These Copies Were Not Given Inspite Of Using Them Against The Assessee. (4) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Order, When The Hon'Ble Tribunal For Benami Transactions Has Released The Property & Given Relief To Alleged Benamidar & Alleged Beneficial Owner. Copy Of Order Was Filed On Record. (5) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Addition Of Rs 88,52,740/-U/S 69. 1 A.Y. 2013-14 Rajendra Sahu (6) The Appellant Reserves The Right To Add, Amend Or Alter Any Grounds Of Appeal.”

For Appellant: Sh. Rahul Bardia, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR 1
Section 131Section 147Section 148Section 69

facts of the case in sustaining the order, when assessee made specific request to share copies of all the statement recorded by the Investigation wing regarding the sale of properties. These copies were not given inspite of using them against the assessee. (4) The Ld CIT (A) erred ... since he himself was a railway employee and he constructed an apartment scheme at Katni, Madhya Pradesh. At the time of enquiry, by the Investigation Wing, Sh. Amarnath Pyasi began to deny the investment because Sh. Mukesh Agarwal had died in 2019 before the notice was issued under section

ACIT, Central Circle-3, Patna vs. Radha Mohan Roy, Purnea

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

ITA 264/PAT/2023[2019-20]Status: DisposedITAT Patna28 Nov 2025AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Acit, Central Circle-3, Patna Radha Mohan Roy, 6Th Floor, Room No.602 Mohan Nivas At Chopra Bazar, Central Revenue Building Ramnagar, Farshi Banmanki, Vs. (Annexe), Beer Chand Patel Purnea, Bihari-854102 Marg, Patna, Bihar-800001 (Appellant) (Respondent) Pan No. Buzpr3181H Co No. 03/Pat/2025 (Arising In Ita No. 264/Pat/2025 For A.Y. 2019-20) Acit, Central Circle-3, Patna Radha Mohan Roy, 6Th Floor, Room No.602 Mohan Nivas At Chopra Bazar, Central Revenue Building Ramnagar, Farshi Banmanki, Vs. (Annexe), Beer Chand Patel Purnea, Bihari-854102 Marg, Patna, Bihar-800001 (Applicant) (Respondent) Assessee By : S/Shri A.K. Rastogi, Rakesh Kumar, Ars Revenue By : Shri Md. Ah Chowdhary, Dr Date Of Hearing: 26.11.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Rajesh Kumar, Am:

For Appellant: S/Shri A.K. RastogiFor Respondent: Shri Md. AH Chowdhary, DR
Section 131(1)(d)Section 132ASection 143(2)Section 143(3)Section 153ASection 69C

legislative assembly election and same was taken into custody on 08.10.2020. On receipt of information, Commission u/s 131(1)(d) was issued by the investigation Wing to QRT Purnea for enquiry. The enquiry was conducted by them and consequently the intercepted cash of ₹40 lacs was requisition u/s 132A ... Department and deposited in the PDA account of PDA. Investigation Wing, Patna. The assessee accepted the ownership for the cash. Based on the said information search and seizure action u/s 132A and 133A of the Act were conducted in various premises including the residential premises of Manoj Kumar Group

Rajveer Leaf Springs Private Limited, Palda. Indore vs. DCIT/ACIT- 4(1), Aayakar Bhawan, Residency Area, Indore

The appeal of the assesse is allowed for statistical purpose

ITA 245/IND/2025[2018-19]Status: DisposedITAT Indore28 Nov 2025AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M Joshirajveer Leaf Springs Dcit/Acit-4(1), बनाम/ Private Limited, Indore Vs. D-405, Shubh City, Palda, Indore

Section 133(6)Section 147rSection 246ASection 250Section 253Section 69C

gathered during investigations. The two entities in question, M/s RA Enterprises and M/s Radha Rani Traders, were conclusively identified as non-genuine by the Investigation Wing and the GST Department. Statements from the proprietors of these entities confirmed that no actual goods were traded. Investigations revealed that neither entity ... registers, or communications with suppliers, were provided to substantiate the transactions. The claim that the purchases were genuineis contradicted by the findings of the Investigation Wing and the statements of the flagged entities' proprietors. The AO's addition is a proportionate response to the evidence of bogus purchases. Adding