“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

Shagun Jewellers P.Ltd, New Delhi vs. ACIT, Circle-23(1), New Delhi

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

ITA 9890/DEL/2019[2010-11]Status: DisposedITAT Delhi16 Jun 2020AY 2010-11

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[Assessment Year: 2010-11]

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Saras Kumar, Sr. DR

Section 131ASection 143(3)Section 148Section 153CSection 68Section 69C

which 60 such parties were transacted through Shri Sant Lal Aggarwal. 7. The Assessing Officer of the assessee was informed by the Investigation Wing of the department that from verification of documents seized, it clearly appears that Shri Sant Lal Aggarwal received cash loans from Shri Asharam and further disbursed ... assessee and the transactions recorded in the seized documents were in the books of the searched person and, therefore, information received from the Investigation Wing was a tangible material evidence which prompted the Assessing Officer to initiate proceedings u/s 148 of the Act. 10. In our considered opinion, provisions

Bimal V. Vora (HUF), Mumbai vs. ITO Ward- 19 (1)(2), Mumbai

ITA 6789/MUM/2018[2009-10]Status: DisposedITAT Mumbai15 Jun 2020AY 2009-10

Bench: Sri Mahavir Singhआयकर अपील िं./ Ita No. 6789/Mum/2018 (निर्ाारण वर्ा / Assessment Years 2009-10) Bimal V. Vora (Huf) The Income Tax Officer, 1/41, 1St Floor, Tardeo Ward 19(1)(2), Mumbai बिाम/ Airconditioned Market, Tardeo Vs. Road, Tardeo, Mumbai (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा िं./Pan No. Aafhb7543G अपीलार्थी की ओर े/ Appellant By Shri Jitendra Singh, Ar : प्रत्यर्थी की ओर े/ Respondent By : Shri Akhtar H. Ansari, Dr ुिवाई की तारीख / Date Of Hearing: 15.06.2020 घोर्णा की तारीख / Date Of Pronouncement: 15.06.2020 आदेश / O R D E R महावीर स िंह, उपाध्यक्ष / Per Mahavir Singh, Vp: This Appeal Of Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals)]-6, Mumbai, [In Short Cit(A)], In Ita No. Cit(A)-6/It-254/54/2762017-18 Dated 08.08.2018. The Assessment Was Framed By The Income Tax Officer, Ward 19(1)(2), Mumbai (In Short Ito/ Ao) For The A.Y. 2009-10 Vide Order Dated Nil Under Section 143(3) R.W.S 147 Of The Income-Tax Act, 1961 (Hereinafter ‘The Act’). Bimal V. Vora (Huf)Ay; 2009-10 2. At The Outset, The Learned Counsel For The Assessee Stated That He Is Not Interested In Prosecuting The Issue Of Reopening Under Section 147 Of The Act For Which The Assessee Has Raised The Following Grounds: -

For Respondent: Shri Akhtar H. Ansari, DR

Section 143Section 143(3)Section 147Section 148Section 69C

failed to appreciate that the notice under section 148 of the Act was issued on the basis of information received from Investigation wing without making further independent inquiry. Thus, there is no application of mind by the Ld. Assessing Officer to the evidence available on record. Hence, the notice issue

ACIT (OSD), Ward - 12(3), Kolkata vs. M/S. Amrabathi Investra Pvt. Ltd., Kolkata

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

ITA 365/KOL/2018[2009-10]Status: DisposedITAT Kolkata12 Jun 2020AY 2009-10

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.231/Kol/2018 ("नधा"रणवष" / Assessment Year:2009-10)

For Appellant: Shri Subash Agarwal, AdvocateFor Respondent: Shri Ram Bilash Meena, CIT

Section 131Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

Afterward, the assessee`s case was reopened u/s 147 of the Act on the basis of a report / information made available by Income Tax Investigation Wing, Kolkata. The said report stated that a search & seizure operation and post search investigation/ enquiry were carried out in the case of M/s Mandapam ... Commercial Ltd., the Investigation Wing found that during the relevant previous year the assessee company brought its unaccounted money of Rs. 14,85,00,000/- in its books of account through accommodation entries which were provided by M/s Mandapam Commercial Ltd. In course of enquiry, after analyzing all the related

Amrabathi Investra Pvt. Ltd., Kolkata vs. ITO, Ward - 12(3), Kolkata

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

ITA 231/KOL/2018[2009-10]Status: DisposedITAT Kolkata12 Jun 2020AY 2009-10

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.231/Kol/2018 ("नधा"रणवष" / Assessment Year:2009-10)

For Appellant: Shri Subash Agarwal, AdvocateFor Respondent: Shri Ram Bilash Meena, CIT

Section 131Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

Dev Milk Foods Pvt Limited, New Delhi vs. ACIT Special Range-3, New Delhi

The appeal of the assessee stands allowed

ITA 6767/DEL/2019[2015-16]Status: DisposedITAT Delhi12 Jun 2020AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishidev Milk Foods Pvt. Ltd. Add. Cit, C/O Kapil Goel Advocate, Special Range -3 F-26/124, Sector-7, Vs. New Delhi. Rohini, Delhi-110085. Pan –Aaccd 2586M (Appellant) (Respondent)

Section 131Section 143(3)

Duari Marketing Pvt. Ltd. As per the Assessing Officer, since all these brokers were Kolkata based and since there was detailed investigation by the Investigation Wing of the Income Tax Department in cases of entry operators/shares brokers and since the assessee company had purchased shares from the brokers under investigation ... short term capital loss of Rs.4,20,94,764/- could not be accepted as genuine as it had been established by the Investigation Wing of the Department, after making detailed enquiries, that the brokers through whom the assessee had purchased shares were involved in business of providing accommodation entries

Dinesh Nemichand, Bangalore vs. The Income Tax Officer Ward-5(2)(3), Bangalore

In the result appeal filed by assessee stands allowed for statistical purposes

ITA 1030/BANG/2017[2012-13]Status: DisposedITAT Bangalore11 Jun 2020AY 2012-13

Bench: Shri A.K Garodia & Smt. Beena Pillaiassessment Year : 2012 – 13

For Appellant: Smt. Suman Lunkar, C.AFor Respondent: Shri Manjeet Singh, Addl. CIT –

book, at page 53 assessee has raised the legal plea of violation of principles of natural Justice for following reasons: (a) information received from investigation wing Mumbai has not been furnished (b) statements of Sh. Sachin Parikh and Sh. Rajendra Jain which have been relied upon for purpose of addition ... both sides in light of records placed before us. It is observed that authorities below have relied upon certain statements and the report from investigation wing for making addition in the hands of assessee. As Ld.CIT(A) has not decided legal issue raised by assessee, we are of the opinion

Omvir Singh, Ghaziabad vs. ITO, Ward- 2(1), Ghaziabad

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

ITA 7437/DEL/2018[2009-10]Status: DisposedITAT Delhi11 Jun 2020AY 2009-10

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[Assessment Year: 2009-10]

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri R.K. Gupta, Sr. DR

Section 147Section 148

Assessee for reopening the assessment: 11. Reasons for the belief Information has been received from the that Information has income has escaped Investigation Wing of been received from the the Income-tax assessment. Department income has escaped that M/s Pine View Construction & Traders Investigation Wing ... beneficiary of accommodation the Income-tax entries received from certain established assessment. entry operators identified by the Investigation Wing during the period relevant to A. Y 2004-05. A comprehensive investigation was carried out by the Investigation Wing for identification of entry operators engaged in the business of money laundering

ACIT, Central Circle - 3(4), Kolkata vs. M/S. Pkc Commodities (P) Ltd., Kolkata

In the result, the appeal of the revenue is dismissed

ITA 2632/KOL/2018[2011-12]Status: DisposedITAT Kolkata10 Jun 2020AY 2011-12

Bench: Shri A.T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2632/Kol/2018 (िनधा"रणवष"S / Assessment Year: 2011-12) Acit, Cc-3(4), Kolkata Vs. M/S Pkc Commodities (P) Ltd. 1, R.N. Mukherjee Rd, Martin Burn House, 3Rd Floor, Kolkata- 700001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. :Aabcr 5112 J (Appellant) .. (Respondent)

For Appellant: Shri Supriyo Pal, JCITFor Respondent: Shri Miraj D Shah, A.R

Section 147Section 148Section 68

various concerns through which the money, which JKT paid to the assessee was traced. With reference to the information received from the Investigation Wing of traced. With reference to the information received from the Investigation Wing of traced. With reference to the information received from the Investigation Wing of Kolkata ... conducted between various concerns through which the money, which JKT paid to the appellant was traced. With reference to the information received from the Investigation Wing of Kolkata, the Ld. AO has claimed that the certain monies was deposited in the ING Vysya Bank A/c of M/s Rupam Traders

DCIT, Circle - 10(2), Kolkata vs. M/S. Svarna Infrastructure & Builders Pvt. Ltd., Kolkata

In the result, the appeal of the Revenue is partly allowed for statistical purposes and the cross objection of the assessee is also partly allowed for statistical purposes to the extent indicated a...

ITA 1265/KOL/2018[2012-13]Status: DisposedITAT Kolkata10 Jun 2020AY 2012-13

Bench: Shri A.T.Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1265/Kol/2018 ("नधा"रणवष" / Assessment Year: 2012-13)

For Appellant: Smt. Ranu Biswas, Addl. CITFor Respondent: Shri R. P. Agarwal, Sr. Advocate & Shri Nirav Sheth, FCA

Section 143(3)Section 2(22)Section 2(22)(e)

framed. All the records including all the books of account were before the AO. Appraisal report prepared by the Investigation Wing was also before the AO. In the original assessment order itself in para 4 the AO notes that assessee has been served notice

Nemichand Jain, Mumbai vs. ACIT-18(2), Mumbai

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

ITA 2953/MUM/2018[2012-13]Status: DisposedITAT Mumbai10 Jun 2020AY 2012-13

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Years: 2012-13 Shri Nemichand Jain, Acit - 18(2), 28, Sham Seth Street, 302, Earnest House, Vs. Zaveri Bazar, Nariman Point, Mumbai – 400002 Mumbai - 400021 Pan: Aabpj4736H (Appellant) (Respondent) Assessment Year: 2013-14 Shri Nemichand Jain, Dcit, Cc - 1(3), 28, Sham Seth Street, Pratishtha Bhavan, Vs. Zaveri Bazar, Old Cgo Bldg., Mumbai – 400002 M.K. Road, Pan: Aabpj4736H Mumbai - 400020 (Appellant) (Respondent) Present For: Assessee By : Ms. Ritu Kamal Kishor, A.R. Revenue By : Ms. Kavita P. Kaushik, D.R. Date Of Hearing : 19.03.2020 Date Of Pronouncement : 10.06.2020 O R D E R

For Appellant: Ms. Ritu Kamal Kishor, A.RFor Respondent: Ms. Kavita P. Kaushik, D.R

lender, acknowledgement of the ITR, TDS certificate qua the interest paid on the above loan etc., however, AO relying on the report of investigation wing treated these loans as bogus accommodation entries and accordingly added the same to the income of the assessee. 16. In the appellate proceedings

M/S Sunstar Gems Corporation, Jaipur vs. Income Tax Officer, Ward-2-1, Jaipur

In the result, appeal of the revenue is dismissed

ITA 638/JPR/2019[2008-09]Status: DisposedITAT Jaipur09 Jun 2020AY 2008-09

For Appellant: NoneFor Respondent: Ms. Chanchal Meena (Addl. CIT) fu/kZkfjrh dh vksj ls@

case and in law, the ld. CIT(A) was justified in deleting the additions made on the basis of corroborate information received from Investigating Wing, Mumbai which is a law enforcement agency under the Ministry of Finance and accordingly the 2 ITO Vs M/s Sunstar Gems Corporation case falls under ... agencies are specified in para 10(e) of the Circular No. 03/2018 are in the nature of law enforcement external agencies then the Investigation Wing of the Income Tax Department itself would not fall in the 4 ITO Vs M/s Sunstar Gems Corporation said category of external law enforcement agencies

Span Realtors, Mumbai vs. ITO 2(2), Thane

ITA 6399/MUM/2019[2014-15]Status: DisposedITAT Mumbai09 Jun 2020AY 2014-15

Bench: Shri G. Manjunatha & Shri Ravish Soodm/S Span Realtors The Income Tax Officer 2(2), B 001 - 002, Gopal Darshan, Room No. 26, B Wing, 6Th Floor, Inderlok Phase Ii, Ashar It Park, Road No. 16Z, Vs. Bhayander (East), Thane, Midc, Thane, Maharashtra – 401 105 Maharashtra – 401 101 Pan – Abrfs7795J (Appellant) (Respondent) Appellant By: S/Shri Rashmikant Modi & Ketki Rajeshirke, A.Rs Respondent By: Shri V. Vinod Kumar, D.R Date Of Hearing: 02.03.2020 Date Of Pronouncement: 09.06.2020

For Appellant: S/shri Rashmikant Modi &For Respondent: Shri V. Vinod Kumar, D.R

Section 143(1)Section 143(2)Section 143(3)Section 35Section 35(1)(ii)Section 80G(5)(vi)

beneficiary had obtained accommodation entries in the guise of donation. It was noticed by the A.O, that due to extensive efforts of the investigation wing the modalities of the transactions carried out by the aforesaid institution were completely exposed. Also, it was noticed by him that before the Settlement Commission

Income Tax Officer, Ward-3-5, Jaipur vs. Smt. Laxmi Gupta, Jaipur

In the result, appeal of the revenue is dismissed

ITA 1077/JPR/2019[2011-12]Status: DisposedITAT Jaipur08 Jun 2020AY 2011-12

For Appellant: Shri Ashok Kumar Gupta (Adv.)For Respondent: Ms. Chanchal Meena (Addl. CIT) fu/kZkfjrh dh vksj ls@

Section 68

Circular No. 3/2018 as the addition is made by the AO on the basis of the information received from the Investigation Wing, Mumbai and therefore, the assessment was completed on the basis of the information of the Investigation Wing which is a law enforcement agency. Thus ... commission paid for availing such accommodation entries from the brokers. The said finding of the A.O. is based on the information received from the Investigation Wing of the Department. Thus, the question arises whether the addition made by the A.O. based on the information received from the Investigation Wing

Income Tax Officer, Ward-3-5, Jaipur vs. Smt. Jolly Singhal, Jaipur

In the result, appeal of the revenue is dismissed

ITA 1076/JPR/2019[2011-12]Status: DisposedITAT Jaipur08 Jun 2020AY 2011-12

For Appellant: Shri Ashok Kumar Gupta (Adv.)For Respondent: Ms. Chanchal Meena (Addl. CIT) fu/kZkfjrh dh vksj ls@

Section 68

Arunachal Properties Pvt. Ltd., Delhi vs. ITO, Ward- 3(2), New Delhi

In the result the appeal of the assessee is dismissed

ITA 2708/DEL/2018[2009-10]Status: DisposedITAT Delhi08 Jun 2020AY 2009-10

Bench: Ms. Suchitra Kamblea N D Shri Prashant Maharishiassessment Year: 2009-10 Arunachal Properties Pvt Ltd The Income Tax Officer House No 11 Road No 63 Vs Ward -3 (2) West Punjabhi Baug New Delhi New Delhi 110026 Pan : Aaaca0751F (Appellant) (Respondent)

Section 131Section 143Section 147Section 148Section 234A

information supplied by The Income Tax Investigation Directorate, Ahmadabad. He submitted that merely on the perusal of the above information received from the investigation wing the reopening has been made. He submitted that such a reopening of the assessment is bad and invalid. He referred to letter dated 1/06/2016

Income Tax Officer, Ward-1-4, Jaipur vs. Shri Kailash Chand Sharma, Jaipur

In the result, appeal of the revenue is dismissed

ITA 809/JPR/2019[2009-10]Status: DisposedITAT Jaipur03 Jun 2020AY 2009-10

For Appellant: NoneFor Respondent: Ms Chanchal Meena (Addl. CIT) fu/kZkfjrh dh vksj ls@

case and in law the ld. CIT (A) was justified in deleting the additions made on the basis of corroborative information received from Investigating Wing, Mumbai which is a law enforcement agency 2 Shri Kailash Chand Sharma, Jaipur. under the Ministry of Finance and accordingly the case falls under exception ... Circular No. 3/2018 as the addition is made by the AO on the basis of the information received from the Investigation Wing, Mumbai and, therefore, the assessment was completed on the basis of the information of the Investigation Wing which is a law enforcement agency. Thus

Bhagwant Merchants Private Limited, Kolkata vs. I.T.O., Ward-13(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2614/KOL/2019[2011-12]Status: DisposedITAT Kolkata29 May 2020AY 2011-12

Bench: Shri J. Sudhakar Reddy]

Section 14Section 143(2)Section 143(3)Section 147Section 250

reply, the AO admits that the re-assessment was on the basis of the report of the Investigation Wing. The information given by the Investigation Wing is factually wrong as the assessee did not receive any amount of deposit of ₹57,48,996/- that there is no figure ... said to be undisclosed and unaccounted for. 3 I.T.A. No. 2614/Kol/2019 Assessment Year: 2011-12 Bhagwant Merchants Private Limited. 8. The report of the Investigation Wing only rises doubts and re-opening cannot be made on mere suspicion. 9. On merits, the ld. Counsel for the assessee submitted that

Bajaj Parivahan Private Limited, Kolkata vs. I.T.O., Ward-13(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2609/KOL/2019[2011-12]Status: DisposedITAT Kolkata29 May 2020AY 2011-12

Bench: Shri J. Sudhakar Reddy]

Section 143(3)Section 147Section 148Section 194ASection 2Section 250

where the original assessment was completed u/s 143(3) of the Act is bad in law. 5. That the information received from the Investigation Wing was vague and the AO simply relying on this information, without application of mind has re-opened the assessment. That no fresh tangible material ... chain of jama-kharchi companies and had no real business. He submitted that the re-opening was based on the information received from the Investigation Wing of the Department. He took this Bench to the reasons and submitted that the AO has sufficient material to come to a conclusion that

Aero Dealcomm Pvt. Ltd., Kolkata vs. I.T.O., Ward-4(3), Kolkata

ITA 2484/KOL/2019[2009-10]Status: DisposedITAT Kolkata29 May 2020AY 2009-10

Bench: Sri J. Sudhakar Reddy, Hon’Ble) Assessment Years: 2009-10 Aereo Dealcomm Pvt. Ltd………….………...........................................................……………….…......Appellant C/O. S.N. Ghosh & Associates, Advocates 2, Garstin Place 2Nd Floor Suite No. 203 Off Hare Street Kolkata West Bengal – 700 001 [Pan : Aacca 5934 G] Vs. Income Tax Officer, Ward-4(3), Kolkata…………………..……………….............….……....…....Respondent Appearances By: Shri Somnath Ghosh, Advocate & Shri M. Jhawar, Fca, Appeared On Behalf Of The Assessee. Shri Jayanta Khanra, Jcit Sr. D/R, Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : February 26Th, 2020 Date Of Pronouncing The Order : May 29Th, 2020 Order Per J. Sudhakar Reddy, Am :-

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

entry) (Accommodation entry) - Assessment year 2008-09 - Information was received from Information was received from 6 Assessment Years: 2009-10 Aereo Dealcomm Pvt. Ltd. investigation wing that assessee investigation wing that assessee-company was a beneficiary of accommodation entries pany was a beneficiary of accommodation entries received from certain established ... entry had escaped assessment chargeable to tax to extent of accommodation entry had escaped assessment - Whether information received from investigation wi information received from investigation wing could not be said to be tangible material ng could not be said to be tangible material per se without a further inquiry being

M/S Ananda Social & Educational Trust, Bangalore vs. Assistant Commissioner of Income Tax Central Circle-1(3), Bangalore

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue are dismissed

ITA 2542/BANG/2017[2008-09]Status: DisposedITAT Bangalore29 May 2020AY 2008-09

Bench: Shri B.R.Baskaran & Shri P.K.Gadale

For Appellant: Smt Tanmayee Rajkumar, AdvocateFor Respondent: Shri Vilas V Shinde, CIT

Section 11Section 12ASection 153A

cases, as all the actions will be covered up and the evidences will be destroyed after the event. The circumstantial evidences gathered by the Investigation wing and the facts marshalled by the Assessing Officer are enough to draw a reasonable conclusion that there is suppression of receipts. 16. The assessee