“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

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

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

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

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

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

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, New Delhi vs. M/S. Rbrl Agro Commodities Ltd., New Delhi

In the result, appeals of the Revenue are allowed for statistical purpose

ITA 6679/DEL/2016[2011-12]Status: DisposedITAT Delhi14 Aug 2020AY 2011-12

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Ms. Sushma Singh, Sr. DR

Section 132Section 143(1)Section 143(2)Section 153A

28/9/2011 respectively and the same was processed under section 143(1) of the Income Tax Act, 1961 (for short “the Act”). Subsequently the investigation wing of the Department conducted search and seizure operations under section 132 of the Act in Sharp Group of cases on 20/1/2014, and according

ACIT, New Delhi vs. M/S. Rbrl Agro Commodities Ltd., New Delhi

In the result, appeals of the Revenue are allowed for statistical purpose

ITA 6678/DEL/2016[2010-11]Status: DisposedITAT Delhi14 Aug 2020AY 2010-11

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Ms. Sushma Singh, Sr. DR

Section 132Section 143(1)Section 143(2)Section 153A

Dipesh Ramesh Vardhan, Mumbai vs. Dy CIT CC 2 (2), Mumbai

The appeal stands partly allowed in terms of our above order

ITA 7648/MUM/2019[2014-15]Status: DisposedITAT Mumbai11 Aug 2020AY 2014-15

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am

Section 68

during the course of search action/proceedings. The learned Assessing Officer has just acted mechanically relying upon third party statement and reference made by the Investigation Wing without taking cognizance of and completely disregarding the direct documentary evidences submitted by the Appellant during the assessment proceeding pertaining which were sufficient enough ... prove the genuineness of the transactions by providing all the relevant direct documentary evidences. The Ld. AO heavily relied upon the findings of investigation wing without carrying out any independent investigation of his own. Nothing was brought on record which would establish that the assessee was beneficiary of alleged accommodation

Ramesh Babulal Vardhan, Mumbai vs. Dy CIT CC 2 (2), Mumbau

The appeal stands partly allowed in terms of our above order

ITA 7662/MUM/2019[2014-15]Status: DisposedITAT Mumbai11 Aug 2020AY 2014-15

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am

Section 68

Anurag Agarwal, Mumbai vs. ITO - 24(1)(3), Mumbai

ITA 3186/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Aug 2020AY 2014-15

Bench: Shri Rajesh Kumar & Shri Ram Lal Negiassessment Year: 2014-15 Shri Anurag Agarwal, Ito – 24(1)(3), C-303, Orchid Enclave, 4Th Floor, J.B. Nagar, Vs. Piramal Chambers, Andheri (E), Lal Baug, Mumbai - 400059 Parel, Pan: Adtpa6534H Mumbai - 400012 (Appellant) (Respondent) Present For: Assessee By : Shri Hari Raheja, A.R. Shri Mani Jain, A.R. Revenue By : Shri Michael Jerald, D.R. Date Of Hearing : 04.03.2020 Date Of Pronouncement : 06.08.2020 O R D E R

For Appellant: Shri Hari Raheja, A.RFor Respondent: Shri Michael Jerald, D.R

Section 143(1)Section 68

operated in a concerted and structured manner. The Ld. D.R. referred to the order of AO and also various investigations carried out by the investigation wing which established beyond the doubt these are not actual transactions of sale and purchase of shares but a mode to convert the assessee ... lacs 161 lacs 31.3.2015 3836 lacs 76 lacs 6.3. We find that the ld AO had placed reliance on certain statements recorded by the Investigation wing of Kolkata Income Tax Department during some survey proceedings conducted in third party cases. We find that in none of those statements, the name

DCIT Cen Cir -5(1), Mumbai vs. Cikura Properties Ltd, Mumbai

ITA 457/MUM/2018[2009-10]Status: DisposedITAT Mumbai06 Aug 2020AY 2009-10

Bench: Shri Rajesh Kumar& Shri Ramlal Negi & Co. No. 181/Mum/2018 (Arising Out Of Ita No. 457/Mum/2018) Dcit, Circle – 5(1) बनाम/ Cikura Properties Ltd., Room No. 1928, 19Th Vs. 324, Master Mind Iv, Royal Floor, Air India Building Palms, Aarey Milk Colony, Nariman Point, Mumbai - Goregaon (E), Mumbai – 65 21 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaccc4109P Appellant/Respondent .. Respondent/Appellant अपीलाथ" ओर से/ Appellant By : Shri K. Madhusudan, Cit(Dr) ""यथ" क" ओर से/Respondentby: Shri Vijay Mehta, Ar सुनवाई क" तारीख/ Date Of Hearing 04/03/2020 06/08 /2020 घोषणा क" तारीख /Date Of Pronouncement आदेश / O R D E R Per Rajesh Kumar- Am: The Appeal Of The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Thecommon Order Of The Ld. Cit(A)-53, Mumbai. The Revenue Has Challenged The Order Of The Ld. Cit(A) On Merit, Whereas, The Assessee Has Challenged The Jurisdiction

For Appellant: Shri K. Madhusudan, CIT(DR)For Respondent: Shri Vijay Mehta, AR

Section 132(1)Section 139(1)Section 143(3)Section 147Section 148Section 153A

declaring income at Rs. Nil. A search action u/s 132(1) of the Act was conducted by the investigation wing on Jogia Group of Companies on 04.03.2010. In response to the notice u/s 153A of the Act, the return ITA No. 457/Mum/2018, CO No. 181/Muml/2018. Cikura Properties Ltd., Mumbai ... Thereafter, the case of the assessee was re-opened u/s 147 r.w.s 148 of the Act after the AO received information from investigation wing of the department thattheassessee has invested Rs. 43,50,00,000/- with M/s Shree Global Tradefin Ltd., as share application money. The said reopening was consequent

M/S Kapoor Rice & General Mills, Narwana vs. ITO, W-2, Jind

In the result, the appeal of the assessee stands allowed

ITA 948/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh03 Aug 2020AY 2011-12

Bench: Shri Sanjay Gargआयकर अपील सं./ Ita No. 948/Chd/2019 "नधा"रण वष" / Assessment Year : 2011-12 M/S Kapoor Rice & General Mills, The Ito, बनाम 226/3, Tohana Road, Ward-2, Nirwana, Haryan A- 126116 Jind "थायी लेखा सं./Pan No: Aacfk4061F अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Nikhil Goyal & Shri Ashok GoyalFor Respondent: Shri Arvind Sudershan, JCIT

Section 145(3)Section 147Section 148

erred in confirming the action of Assessing Officer in issuing the notice u/s 148 on the basis of information received from the Investigation Wing without any independent application of mind. 2. That the Ld. CIT(A) has failed to appreciate the fact that there was no reason to believe ... Assessing Officer on vague ground and without any material on records. 6. That the Authorities below have merely relied on the report of the Investigation Wing about the statement of Sh. Vipin Garg and Others at the back of assessee and no opportunity to cross examine Sh. Vipin Garg have

ITO - 19(2)(3), Mumbai vs. Mithalal Bhavarlal Jain, Mumbai

In the result, appeal filed by the Revenue and appeal filed by the assessee for Asst

ITA 3777/MUM/2018[2011-12]Status: DisposedITAT Mumbai03 Aug 2020AY 2011-12

Bench: Shri Saktijit Dey & Shri G. Manjunathaito-19(2)(3) Vs. Mr. Mithalal Bhavarlal Jain Room No.218, 2Nd Floor Pro.M/S.Aristo Pipe & Matru Mandir, Tardeo Road Fittings, Shop No.3 Mumbai-400 007 Ground Floor,86/72 Durgadevi Street Mumbai-400 004 Pan/Girno.Admpj5673P (Appellant) .. (Respondent) & Mr. Mithalal Bhavarlal Jain Vs. Ito-19(2)(3) Room No.218, 2Nd Floor Pro.M/S.Aristo Pipe & Fittings, Shop No.3 Matru Mandir, Tardeo Road Ground Floor,86/72 Mumbai-400 007 Durgadevi Street Mumbai-400 004

although assesee has filed certain 5 Mithalal Bhavarlal Jain basic evidences, but failed to file further evidence in the backdrop of clear finding by Investigation wing that those parties are involved in providing accommodation entries without actual delivery of goods. The Ld. AO had also taken support from the investigation ... also failed to take the investigation to a logical conclusion by carrying out necessary enquires, but he solely relied upon information received from investigation wing, which was further supported by information received from Maharashtra Sales Tax Department. Under these circumstances, it is difficult to accept arguments of both the sides

Rmp Holding (P) Ltd., New Delhi vs. ITO, Ward- 20(3), New Delhi

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

ITA 7243/DEL/2019[2011-12]Status: DisposedITAT Delhi31 Jul 2020AY 2011-12

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2011-12 Rmp Holding (P) Ltd., Vs Ito, Shop No.9, Plot No.51, Block-C, Ward-20(3), Mahendru Enclave, Near Hans Cinema, New Delhi. New Delhi. Pan: Aaacr5533N (Appellant) (Respondent) Assessee By : Shri Suresh Gupta, Ca Revenue By : Shri M. Barnwal, Sr. Dr Date Of Hearing : 16.07.2020 Date Of Pronouncement : 31.07.2020 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 5Th August, 2019 Of The Cit(A)-7, New Delhi, Relating To Assessment Year 2011-12. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company & Filed Its Return Of Income On 17Th August, 2011, Declaring A Loss Of Rs.20,53,019/-. The Case Was Scrutinized U/S 143(3) On 10Th March, 2014, Determining The Income At Rs.20,06,714/-. Thereafter, On The Basis Of Information Received During The Course Of Search & Seizure Operation In The Case Of Entry Provider Shri Anand Kumar Jain & Shri Naresh Kumar Jain & Subsequent Investigation That The Assessee Is A Beneficiary Of Rs.39,00,055/-, The Case Of The Assessee Was Reopened By Recording Reasons U/S 147. Subsequently, Notice U/S 148 Was Issued On 26Th March, 2018 After Obtaining Prior Approval Of The Pcit-7, New Delhi. In Response To The Same, The Assessee Filed A Letter Stating That The Return Already Filed U/S 139 May Be Treated As The Return Filed In Response To The Notice U/S 148 Of The Act. However, Another Letter Dated 7Th August, 2018 Was Issued To The Assessee Requesting Him To File The Return In Response To Notice U/S 148 Of The Act. The Assessee Ultimately Filed Its Return On 13Th August, 2018 Declaring A Loss Of Rs.4,053/-. Subsequently, The Ao Issued Notice U/S 143(2) & 142(1) Of The It Act & Copies Of The Reasons Recorded Were Also Handed Over To The Assessee.

For Appellant: Shri Suresh Gupta, CAFor Respondent: Shri M. Barnwal, Sr. DR

Section 131Section 139Section 143(2)Section 143(3)Section 147Section 148Section 153CSection 68

Rs.39,00,055/- received by the assessee as accommodation entry. He considered the documents and electronic data seized from various premises by the Investigation Wing according to which a number of bank statements and signed and unsigned cheque books pertained to the shell companies of the Jain brothers were found ... been confirmed by Ld CIT(A) on basis of a finding of fact given by the Ld CIT(A) that the information from the investigation wing was specific which contains names of companies, cheques number and date of accommodation entries. The above finding is factually incorrect looking into the reasons

Assistant Commissioner of Income Tax, Circle-1, Kota vs. M/S Shiv Vegpro Pvt. Ltd., Kota

In the result, appeal of the revenue is dismissed

ITA 739/JPR/2019[2011-12]Status: DisposedITAT Jaipur30 Jul 2020AY 2011-12

For Appellant: Shri Mahendra Gargieya (Advocate)For Respondent: Shri B.K. Gupta (CIT) fu/kZkfjrh dh vksj ls@

Section 144Section 147Section 148Section 68

Shiv Vegpro Pvt. Ltd., Kota. the case in hand, the AO has reopened the assessment based on the information received from the Investigation Wing which is very vague and general and even not pointed out how the income assessable to tax has escaped assessment. The AO has even not verified ... applied his independent mind but reopened the assessment based on the communication received by the AO without having report of the Investigation Wing which is the basis of said communication. The ld. A/R has relied upon a series of decisions in support of his contention that the reopening

Jaee Vishwas Joshi, Mumbai vs. Asst CIT Circle-21(1), Mumbai

In the result, appeal filed by the assessee is dismissed

ITA 1028/MUM/2020[2011-12]Status: DisposedITAT Mumbai29 Jul 2020AY 2011-12

Bench: Shri G. Manjunatha & Shri Ravish Soodjaee Vishwas Joshi Vs. Acit,Circle-21(1) 8Th Floor, Kautilya Bhavan 1002, Om Co-Op.Housing Society Limited Bkc M.B.Raut Road Mumbai-400 051 Shivaji Park, Dadar Mumbai-400 028 Pan/Gir No.Aelpa7074L (Appellant) .. (Respondent)

Section 143(1)Section 144ASection 147Section 148

discussed the facts of the case and the modus operandi of the assessee in detail, in light of detailed investigation was done by the investigation wing of the department wherein it was found and established that M/s. Sarvottam Advisory Pvt. Ltd. and M/s. Avron's Consultancy Services Pvt. Ltd. were ... debited under the head business counseling charges. The relevant observations of the AO are as under: “The enquiries done by the Investigation wing reveals that in case of Avron Consultancy Pvt. Ltd., the revenue of the company during the A.Y. 2011-12 was Rs.18 Crores and profit before interest

Sanjay Kaul vs. Principal Commissioner of Income Tax

ITA-203/2020HC Delhi29 Jul 2020

Section 143(3)Section 246ASection 260Section 68Section 69CSection 70

adverse findings. Therefore, the appellant has failed to discharge the onus cast upon it u/s 68 of the Act to explain the transaction. The Investigation Wing has conducted detailed enquiries, made analysis of the seized / impounded documents and made analysis of beneficiaries. The report prepared contains details of complete modus ... name of conduits. The said list contains names of companies in which the appellant dealt. Therefore, the findings in the case of Investigation wing corroborate the independent findings of the AO. Therefore, the AO was not required to allow the appellant the opportunity to cross-examine." 4.8 The Tribunal

Sanjay Kaul

ITA/203/2020HC Delhi29 Jul 2020

Section 143(3)Section 246ASection 260Section 68Section 69CSection 70

Dirisala Bala Murali, Palacole vs. The Income Tax Officer, Ward-1, Palacole

In the result, appeal of the assessee is allowed

ITA 452/VIZ/2019[2011-12]Status: DisposedITAT Visakhapatnam28 Jul 2020AY 2011-12

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.452/Viz/2019 (ननधधारण वर्ा/Assessment Year:2011-12) Dirisala Bala Murali Vs. Income Tax Officer D.No.15-8-12/2 Ward-I Shavukarpet Palakol Palakol, West Godavari Dist. [Pan : Asfpd4074J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Smt.Suman Malik, Dr सुनवधई की तधरीख / Date Of Hearing : 15.07.2020 घोर्णध की तधरीख/Date Of Pronouncement : 29.07.2020 आदेश /O R D E R Per Shri D.S.Sunder Singh: This Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals) [Cit(A)], Rajamahendravaram In Ita Nos.10090 & 10094/2017-18 Dated 29.03.2019 For The Assessment Year (A.Y.)2011-12. 2

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Smt.Suman Malik, DR

Section 143(1)Section 143(2)Section 148Section 68Section 69

return was processed u/s 143(1)of the Income Tax Act, 1961 (in short ‘Act’) and subsequently on receipt of information from Investigation Wing with regard to deposits made in the bank account of the assessee in ICICI Bank, Palakol on 03.04.2010, the Assessing Officer (AO) has reopened the assessment

Sadiq Anunali Salehmohamed, Hyderabad vs. Income Tax Officer, Ward-7(1), Hyderabad

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

ITA 130/HYD/2019[2007-08]Status: DisposedITAT Hyderabad28 Jul 2020AY 2007-08

For Appellant: Shri Laxminiwas SharmaFor Respondent: Smt. M. Narmada

Section 147Section 250(6)

Tanzanian Citizen until the year 2012 and during the year 2012 he had obtained Indian Citizenship. It was revealed by the Investigation wing of the Revenue that the assessee had opened a bank account in HSBC Bank at Geneva on 27/4/2006 jointly along with certain other individuals. Therefore, the case

M/S. Hindisthan Engineeing & Indistries Ltd., Kolkata vs. DCIT, Circle -5 Kolkata, Kolkata

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

ITA 952/KOL/2018[2011-12]Status: DisposedITAT Kolkata28 Jul 2020AY 2011-12

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.952/Kol/2018 ("नधा"रणवष" / Assessment Year:2011-12)

For Appellant: Shri S. Jhajharia, AdvocateFor Respondent: Shri Ram Bilash Meena, CIT

Section 131Section 143(3)

Appeals) allowed the appeal of the assessee stating: "Thus, the entire disallowance in this case is based on third party information gathered by the Investigation Wing of the Department, which have not been independently subjected to further verification by the AO who has not provided the copy of such statements

DCIT, Central Circle - 1(4), Kolkata vs. M/S. Hindusthan Engineering & Industries Ltd., Kolkata

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

ITA 1059/KOL/2018[2011-12]Status: DisposedITAT Kolkata28 Jul 2020AY 2011-12

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.952/Kol/2018 ("नधा"रणवष" / Assessment Year:2011-12)

For Appellant: Shri S. Jhajharia, AdvocateFor Respondent: Shri Ram Bilash Meena, CIT

Section 131Section 143(3)

ITO 24(1)(2), Mumbai vs. Arpita Enterprises, Mumbai

In the result appeal filed by the revenue is dismissed

ITA 3478/MUM/2018[2009-10]Status: DisposedITAT Mumbai27 Jul 2020AY 2009-10

Bench: Shri Pawan Singh, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 3478/Mum/2018 (निर्धारणवर्ा / Assessment Year: 2009-10)

For Appellant: Shri Michael Jerald, DR byFor Respondent: Shri M Subramanian, AR

Section 133ASection 143(2)Section 143(3)Section 147Section 148Section 263

mentioned above, I have come to the conclusion that the AO has made the addition solely on the basis of enquiries conducted by the Investigation Wing of the Income Tax Department. The modification of client code is permissible by SEBI and is in the hands of the Broker. The appellant ... using client code modification facility. However, the AO has not brought any evidence in support of the same. 4.2.4 The information received from the investigation wing was the lead which required further in-depth investigation by the AO to arrive at the logical conclusion. It was not to be taken

Sulekh Chand Singhal, Delhi vs. ACIT, Circle- 57(1), New Delhi

In the result, appeal of the Assessee allowed

ITA 6700/DEL/2019[2007-08]Status: DisposedITAT Delhi23 Jul 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

For Appellant: Shri Raj Kumar Gupta, CAFor Respondent: Shri Rakesh Gupta, Sr.D.R

Section 131Section 132Section 132(4)Section 141(1)Section 147

declaring income of Rs.78,263/-. The return was processed under section 141(1) of the I.T. Act, 1961. Later on information was received from Investigation Wing that search was conducted under section 132 of the I.T. Act, 1961 on 27.06.2013 in Santosh Group of Institutions and Dr. P. Mahalingam. During

Mukesh Chand Garg, New Delhi vs. ITO, Ward-49(3), New Delhi

In the result, both the appeals are dismissed

ITA 5418/DEL/2019[2010-11]Status: DisposedITAT Delhi23 Jul 2020AY 2010-11

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Rakesh Gupta, Sr.D.R

Section 143(1)Section 147Section 148Section 69A

return filed in response to notice under section 148 of the Income Tax Act, 1961. The A.O. on going through the details provided by Investigation Wing found that on the directions of the assessee, on many instances, broker has changed the original client code eight times from 3 ITA.No.5418/Del