“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

Assistant Commissioner of Income Tax, Circle - 6(3)(2), Mumbai vs. M/S Jeevandeep Prakashan Private Limited, Mumbai

In the result, appeal of the revenue is dismissed

ITA 2693/MUM/2019[2010-11]Status: DisposedITAT Mumbai21 Jul 2020AY 2010-11

Bench: Shri Pawan Singh & Shri M. Balaganeshacit Circle 6(3)(2), M/S Jeevandeep Prakashan Aayakar Bhavan, Pvt. Ltd., M.K. Road, Mumbai-400020. Vs. Plot No. 7, Industrial Estate, Off Ba Road, Opposite Lalbaug, Mumbai-400012, Pan: Aabcj0182E Appellant Respondent Revenue By : Miss Samatha ( Sr. Dr) Assessee By : Shri Prashant Shah (Dr) Date Of Hearing : 21.07.2020 Date Of Pronouncement : 21.07.2020 Orderunder Section 254(1)Of Income Tax Act Per Pawan Singh; 1. This Appeal By Revenue Is Directed Against The Order Of Ld. Commissioner Of Income-Tax Appeals (Ld. Cit(A)-12, Mumbai Dated 14.01.2019 For Assessment Year 2020-11. 2. Brief Facts Of The Case Are That The Assessee Is A Company Engaged In The Business Of Publication Of Educational Books, Filed Its Return Of Income For Assessment Year 2020-11 Declaring Income Of Rs. 1.60 Crore. The Return Of Income Was Selected For Scrutiny & Assessment Was Completed Under Section 143(3) On 14.03.2013 Accepting The Return Income. Subsequently, Case Was Reopened Under Section 147. The Assessing Officer Reopened The Case On The Basis Of Information Received From The Dgit (Inv.), Mumbai

For Appellant: Shri Prashant Shah (DR)For Respondent: Miss Samatha ( Sr. DR)

Section 143(2)Section 143(3)Section 147Section 148Section 254(1)

order of the tax authorities below. The ld. DR for the revenue supported the order of Assessing Officer. The ld. DR submits that the investigation wing of the income tax department made full-fledged investigation about the modus operandi of the hawala traders who were engaged in providing bogus entry

I.T.O. - 25(2)(5), Mumbai vs. Smt. Leena Haresh Harde, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 6429/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Jul 2020AY 2013-14

Bench: Shri Shamim Yahya, Hon'Ble & Shri C.N. Prasad, Hon'Bleincome Tax Officer – 25(2)(5) V. Smt Leena Haresh Harde Room No. 506, C-10, 5Th Floor 502, 5Th Floor, Padmawati Palace Pratyakshakar Bhavan Nanda Patkar Road Bandra Kurla Complex Vile Parle (E), Mumbai – 400 057 Bandra (E), Mumbai - 400 051 Pan: Aaxph1737Q (Appellant) (Respondent) Assessee By : Shri Rushabh Mehta Department By : Shri Michael Jerald

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Michael Jerald

Section 132Section 133(6)Section 145(3)Section 148Section 68

557/DEL/2010) wherein the Tribunal dismissed the Revenue appeal by holding that the Assessing Officer has primarily relied upon the Report of the Investigation wing which cannot conclusively prove that assessee's own money was invested in the form of share application money. Further, it may be pointed out that section ... them; and d) Copy of Bank Statement through which cheques were issued. 20. Tribunal noted that Assessing Officer had referred the matter to the investigation wing of the department at Kolkata for making inquiries into the three creditors from whom share application money was received. Though report from the investigation

Mrs. Renu Tikamdas Tharani, Mumbai vs. DCIT (It)-4(2)(1), Mumbai

ITA 2333/MUM/2018[2006-07]Status: DisposedITAT Mumbai16 Jul 2020AY 2006-07

Section 127Section 143(3)Section 147Section 148

where she was resident, in one year. Learned Departmental Representative then submits that as per the base note, received by the investigation wing, the assessee was holding an account in HSBC Private Bank Geneva, with BUP Code as 5090178411, and this account was created on 28th July ... income tax return, on 29th July 2006, disclosing an income of Rs 1,70,800 for the relevant previous year, but subsequently the investigation wing of the income tax department, as noted in the earlier part of this order, received information that the assessee is having a bank account with

Mr. Hanuman Dhanania, Mumbai vs. ITO Ward 17 (1)(5), Mumbai

The appeal of the assessee is allowed, and appeal of the Assessing Officer is dismissed

ITA 1255/MUM/2019[2009-10]Status: DisposedITAT Mumbai15 Jul 2020AY 2009-10

Bench: Shri C. N. Prasad, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 1255/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2009-10)

For Appellant: Shri Hanuman DhananiaFor Respondent: Shri Beraram, DR

Section 143(1)

I.T.A. No. 1255/Mum/2019 Mr. Hanuman D. Dhanania, assessee could not produce any of the party to confirm the transactions and the information received from investigation wing revealed that all the suppliers were engaged in carrying out only paper transactions without actual delivery of material. The complete onus to prove

Asst CIT 9(2)(1), Mumbai vs. Bygging India P.Ltd, Mumbai

ITA 1482/MUM/2015[2010-11]Status: DisposedITAT Mumbai15 Jul 2020AY 2010-11

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Year: 2010-11 Acit 9(2)(1), M/S. Bygging India Pvt. Room No.204, Ltd., 2Nd Floor, 9, R.N.A. Arcade, Vs. Aayakar Bhavan, Lokhandwala Complex, M.K. Road, Andheri West, Mumbai - 400020 Mumbai – 400053 Pan: Aaacb0642E (Appellant) (Respondent) Present For: Assessee By : Shri Satish R. Mody, A.R. Revenue By : Ms. Kavita P. Kaushik, D.R. Date Of Hearing : 19.03.2020 Date Of Pronouncement : 15.07.2020 O R D E R

For Appellant: Shri Satish R. Mody, A.RFor Respondent: Ms. Kavita P. Kaushik, D.R

Section 115JSection 131(1)(d)Section 142(1)Section 143(1)

assessee and on 13.02.2013 a letter was issued to the assessee company informing about the non compliance of summon issued by DDIT, Investigation wing, Kolkata. Thereafter, the DDIT (Inv.) Wing, Kolkata forwarded its report on 08.03.2003. In the said report, the DDIT (Inv.) Wing Kolkata stated that 7 parties ... DDIT(Inv.) vide letter dated 08.03.2013 informed the AO that a discreet enquiry was undertaken,by the Inspector attached with the unit of investigation wing in order to find out the existence and where about or the companies namely M/s Mehandipura Trade link Pvt. Ltd., M/s Abharani Vinmay

Ak Lumber Limited, Delhi vs. ACIT, Circle-1(1), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 8761/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Jul 2020AY 2011-12

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2011-12]

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Jagdish Singh Dahiya, Sr. DR

Section 131Section 132Section 143(1)Section 143(3)

assessee cannot be found faulted with. 11. Had the Assessing Officer applied his mind, then he would have not believed the theory of the Investigation Wing that the appellant is engaged in providing accommodation entries as the total turnover of the appellant is Rs. 37.58 crores and the quarrel ... instant case, the Assessing Officer has recorded vague reasons based on wrong facts. The escapement of income based on accommodation entry as informed by Investigation Wing have been mentioned at Rs.3.20 crores which in fact was Rs 2.20 crores. Such fact is mentioned in the balance sheet of the assessee

Shri. Pinal D Shah, Surat vs. ITO 25(3)(3), Mumbai

In the result, the appeal is allowed for statistical purposes, in the terms indicated above

ITA 1796/MUM/2019[2007-08]Status: DisposedITAT Mumbai09 Jul 2020AY 2007-08

Section 144Section 147Section 234ASection 274

reassessment can be made just to make an enquiry or verification. b) Reassessment proceeding cannot be initiate merely on the information received from investigation wing. Assessment year: 2007-08 Page 2 of 3 c) Reassessment proceeding cannot be initiated when the LD. CIT(A) have reason to suspect

ACIT-4(2)(1), Mumbai vs. M/S.Vgc Diamond Private Limited, Mumbai

The appeal of the assessee is allowed, and appeal of the Assessing Officer is dismissed

ITA 7004/MUM/2017[2014-15]Status: DisposedITAT Mumbai08 Jul 2020AY 2014-15

Bench: Shri Pawan Singh, Jm& Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 7004/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2014-15)

For Appellant: Mrs. SamathaFor Respondent: Shri Vimal Punamiya, AR

Section 133(6)Section 143(2)Section 143(3)Section 271(1)(c)Section 68

extent of Rs.3,86,58,127/-. 3. AO observed that Kalash Enterprises is part of Rajendra Jain group concern and he observed that the investigation wing, Mumbai, has investigated thoroughly on this group and found that this group involves in providing accommodation entries. Since, Kalash Enterprises is part of this ... proved to be genuine and assessee has taken these purchases from the group concerns which are controlled by Rajendra Jain, she submitted that the investigation wing has found that these group is involved in hawala and providing of accommodation entries. Therefore, AO 12 I.T.A. No. 7004/Mum/2017 M/s VGC Diamond

Malkai Sudershan, Nizamabad vs. Income Tax Officer, Ward-1, Nizamabad

In the result, appeal of the assessee is allowed

ITA 2159/HYD/2018[2014-15]Status: DisposedITAT Hyderabad01 Jul 2020AY 2014-15

Bench: Shri A. Mohan Alankamonyassessment Year:2014-15 Malkai Sudershan, Vs. Income Tax Officer, Nizamabad. Ward-1, Pan: Akqpm 8572 R Nizamabad. (Appellant) (Respondent) Assessee By: Sri K.V. Chalamaiah Revenue By: Sri Rajat Mitra, Dr Date Of Hearing: 05/02/2020 Date Of Pronouncement: 01/07/2020 Order Per A. Mohan Alankamony, Am.:

For Appellant: Sri K.V. ChalamaiahFor Respondent: Sri Rajat Mitra, DR

Section 143(3)Section 147Section 250(6)Section 56(2)(vii)

assessee is an individual engaged in jewellery business as partner in M/s. Shri Raghavendra Jewellers. Information was received from the Intelligence and Criminal Investigation Wing of the Department that the assessee had purchased an immovable property vide Doc. No.12722/2013 wherein the SRO value of the property purchased

Tulip Global Pvt. Ltd.C/O- Shri Vinod Kumar Gupta, Ca H-406-B Azad Marg, C-Scheme Jaipur-302001, Jaipur vs. DCIT, Circle-3, Jaipur

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

ITA 614/JPR/2019[2010-11]Status: DisposedITAT Jaipur30 Jun 2020AY 2010-11

For Appellant: Shri Vinod Kumar Gupta (C.A.)For Respondent: Smt. Rooni Pal (Addl.CIT)

Section 133ASection 147Section 148Section 154

speculative transactions on the commodities exchange has escaped assessment. He has appointed that the Assessing Officer has referred to the information received from the Investigation Wing, Ahmedabad and that too under Section 133A of the Act at the premises of NMCE wherein certain brokers/persons were found to be indulged ... submitted that the Assessing Officer has reopened the assessee on the borrowed satisfaction as the information received from the Principal Director of income tax Investigation Wing, Ahmedabad is the basis of reopening without any independent application of mind. Even the said information as referred by the AO in the reasons

ACIT, Central Circle-19, New Delhi vs. K.R. Pulp & Papers Ltd, New Delhi

In the result, the appeal of the revenue in ITA No

ITA 6170/DEL/2018[2012-13]Status: DisposedITAT Delhi30 Jun 2020AY 2012-13

Bench: Shri Bhavnesh Saini & Shri N.K. Billaiya[Assessment Year: 2012-13]

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri J.K. Mishra, DR

Section 132(1)Section 153ASection 69C

addition made by AO and submissions of appellant. As it is reflected from assessment order, a search and seizure operation was conducted by the Investigation Wing of the Department in the cases of M/s K. R. Pulp and Papers Ltd. Group and during the searches, the appellant's case

Suresh Kumar Aggarwal, New Delhi vs. ACIT, Central Circle-25, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 8703/DEL/2019[2011-12]Status: DisposedITAT Delhi29 Jun 2020AY 2011-12

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishia Y 2011-12 Appellant Respondent Shri Suresh Kumar Agarwal The Assistant Commissioner Of 154, Deepali Enclave Vs. Income Tax Pitampura Central Circle -25 New Delhi New Delhi Pan :- Abvpk1318H ( Appellant ) ( Respondent ) Date Of Hearing 17-06-2020 Date Of Order 29.06.2020 Present For Assessee Shri Gautam Jain , Advocate Present For Income Tax Department :- Shri Saras Kumar Senior Departmental Representative O R D E R

Section 143Section 148Section 68

Above return was processed under section 143 (1) of the act on 4/3/2013. 04. Subsequently the information was received from investigation wing by the Department that the scheme was hatched by the various players to obtain and provide accommodation entries of the bogus long-term capital gain through manipulation ... stock market. From the perusal of the information and data received from the investigation wing, the learned AO noted that assessee is one of the beneficiaries who booked bogus long-term capital gain by selling 50,000 shares of Nouvea Global Ventures Ltd for ₹ 56,43,084/– in financial year

Income Tax Officer 6(3)(3), Mumbai vs. M/S.Kalash Metals Private Limited, Mumbai

The appeal of the assessee is allowed, and appeal of the Assessing Officer is dismissed

ITA 504/MUM/2018[2009-10]Status: DisposedITAT Mumbai26 Jun 2020AY 2009-10

Bench: Shri Vikas Awasthy, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 504/Mum/2018 (निर्धारणवर्ा / Assessment Year: 2009-10)

For Appellant: Shri K. Bhoopati, DR byFor Respondent: Shri S.C. Tiwari & Ms

Section 142(1)Section 143(1)Section 147Section 148Section 68Section 69C

that AO is not doubting the purchase transaction and only doubts the payment. AO reopened the assessment based on the information from Investigation wing and he should have investigated the transaction thoroughly. 11 I.T.A. No. 504/Mum/2018 M/s Kalash Metals Pvt. Ltd. Merely making addition on suspicion

ITO 14(3)(4), Mumbai vs. Nextgen Constructions P.Tld (Changed to M/S Aetius Construction P. Ltd Which Is Further Amalgamated With M/S Supergold Properties Pvt. Ltd), Mumbai

ITA 3593/MUM/2019[2011-12]Status: DisposedITAT Mumbai25 Jun 2020AY 2011-12

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

For Appellant: Dr.P.Daniel-Ld.ARFor Respondent: Shri Rahul Raman-CIT- DR

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

extracted at para 5.1 of the quantum assessment order. In the reasons, it was asserted that on the basis of inquiry conducted by the investigation wing of the department in the case of M/s KJM International (Prop. Shri Sanjoy Kumar), it was found that there were large value cash deposits ... Shri Sanjoy Kumar. On 23/12/2016, M/s MSPL also filed similar details as filed by the assessee. 3.6 However, relying upon the findings of the investigation wing in the case of Shri Sanjoy Kumar wherein it transpired that the individual bank account of Shri Sanjoy Kumar was used to covert cash

ITO 22(1)(5), Mumbai vs. Heera C. Gujrani, Mumbai

In the result, both the appeal stands dismissed

ITA 2247/MUM/2019[2010-11]Status: DisposedITAT Mumbai25 Jun 2020AY 2010-11

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) 1. आयकर अपील सं./ I.T.A. No.2246/Mum/2019 (िनधा"रण वष" / Assessment Year: 2009-10) & 2. आयकर अपील सं./ I.T.A. No.2247/Mum/2019 (िनधा"रण वष" / Assessment Year: 2010-11) Income Tax Officer-22(1)(5) Shri Heera C. Gujrani 323 3Rd Floor Piramal Chambers बनाम/ 102, 1St Floor, Shree Shakti 14Th Road, Khar (West) Lal Baug Parel Vs. Mumbai - 400012 Mumbai-400 052. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Acqpg-4540-D (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Nitesh Joshi-Ld. Ar Revenue By : Shri Bhoopathi-Ld. Dr सुनवाई की तारीख/ : 25/06/2020 Date Of Hearing घोषणा की तारीख / : 25/06/2020 Date Of Pronouncement आदेश / O R D E R Per Manoj Kumar Aggarwal ()

For Appellant: Shri Nitesh Joshi-Ld. ARFor Respondent: Shri Bhoopathi-Ld. DR

controvert the said fact but submitted that the additions were made on account of bogus purchases on the basis of information received from Investigation Wing of the Department. 4. Upon careful consideration of case records, we concur with Ld. AR’s submissions that the tax effect of quantum additions being

ITO 22(1)(5), Mumbai vs. Heera C. Gujrani, Mumbai

In the result, both the appeal stands dismissed

ITA 2246/MUM/2019[2009-10]Status: DisposedITAT Mumbai25 Jun 2020AY 2009-10

For Appellant: Shri Nitesh Joshi-Ld. ARFor Respondent: Shri Bhoopathi-Ld. DR

M/S Garware Synthetics Limited, Mira Road vs. Asst CIT Circle-15 (1)(2), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 6832/MUM/2019[2016-17]Status: DisposedITAT Mumbai24 Jun 2020AY 2016-17

Bench: Shri G. Manjunatha & Shri Ravish Soodgarware Synthetics Limited Vs. Acit,Circle-15(1)(2) Manish Textile Ind. Premises Aaykar Bhawan Opp. Golden Chemicals M.K.Road Penkar Pada, Post Mira Mumbai-400 020 Thane-401 104 Pan/Gir No.Aaacg4208M (Appellant) .. (Respondent)

Section 133(6)Section 68

additions towards difference of Rs.15 Lacs u/s 68 of the I.T.Act, 1961. The AO, while, doing so has taken support from the report of Investigation wing, Mumbai, as per which M/s. Arya Global Shares & Securities Pvt.Ltd. is a shell company, which is engaged in providing accommodation entries to various beneficiaries ... been discharged by the assessee. 5.10 Further, it is not out of place to mention here that inquiries has recently been conducted by the Investigation Wing, Mumbai which has revealed that M/s Arya Global Shares & Securities Pvt. Ltd. Is a bogus company that has been used by the entry operators

Rmp Holding (P) Ltd., New Delhi vs. ITO, New Delhi

In the result, appeal of Assessee dismissed

ITA 3298/DEL/2017[2006-07]Status: DisposedITAT Delhi24 Jun 2020AY 2006-07

Bench: Shri Bhavnesh Saini & Shri Anil Chaturvedi

For Appellant: Shri Suresh K. Gupta, C.AFor Respondent: Shri R.K. Gupta, Sr. D.R

Section 133(6)Section 143(3)Section 147Section 148

they are the persons who have controlled the whole affairs of the said party. It was stated by them that earlier also before Investigation Wing they have not admitted that they are engaged in the business of providing accommodation entries. The A.O, therefore, noted that their statements cannot be relied ... upon as the Investigation Wing has established that they are the entry providers and providing accommodation entries in the shape of share capital in lieu of cash received by them. The A.O. after considering the material on record found that entire transactions are paper work and assessee failed to prove

Raghuveer Metal Industries Ltd., Delhi vs. ACIT, Alwar

In the result, we affirm the findings of the lower authorities in this regard

ITA 566/JPR/2013[2009-10]Status: DisposedITAT Jaipur23 Jun 2020AY 2009-10

For Appellant: Sh. Himanshu Goyal (CA)For Respondent: Sh. K. C. Gupta (JCIT)

Section 132Section 143(3)

reads as under:- “(iv) Surrender of Rs. 2.5 crores by Sh. Pradeep Agarwal then Director of the company: In the post search proceedings before Investigation wing, Jaipur Sh. Pradeep Agarwal then Director of the company surrendered undisclosed income of Rs. 2.5 crores as unaccounted income of M/s Raghuveer Metal Industries

DCIT 6 (2)(1), Mumbai vs. M/S Della Technica Interior Design Pvt. Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1217/MUM/2019[2010-11]Status: DisposedITAT Mumbai22 Jun 2020AY 2010-11

Bench: Hon’Ble Shri Mahavir Singh & Hon’ Ble Shri G. Manjunathadcit-6(2)(1) Vs. M/S Della Technica Interior Room No.504 Design Pvt.Ltd Aaykar Bhawan Rati Villa, Ground Floor M.K.Road Motibal Street Mumbai-400 020 Opp. Bhatia Hospital Tardeo, Sion(W) Mumbai-400 007 Pan/Gir No.Aabcd2765K (Appellant) .. Respondent) Assessee By Shri Forum Mehta, Ar Revenue By Ms. Samatha Mullamudi, Cit-Dr

Section 143(3)Section 147Section 40

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. The AO neither pointed out any discrepancies in books 5 ITA.No.1217/Mum/2019 Della