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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, Central Circle- 28, New Delhi vs. Agson Global Pvt. Ltd., Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 5268/DEL/2019[2016-17]Status: DisposedITAT Delhi31 Oct 2019AY 2016-17

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

further referred to the para number 5.2 of the order of the learned CIT – A wherein he referred to the statement recorded by the investigation wing of third party in altogether different search. He submitted that such a statement recorded in the search of third party could not be considered ... fees material. In the deviation report in para number 3 (iii) the learned assessing officer himself has stated that the chart prepared by the investigation wing is factually incorrect. Therefore, the learned authorised representative submitted that even in the deviation report dated 20/12/2018 the learned assessing officer himself

ACIT, Central Circle- 28, New Delhi vs. Agson Global Pvt. Ltd., Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 5267/DEL/2019[2015-16]Status: DisposedITAT Delhi31 Oct 2019AY 2015-16

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

further referred to the para number 5.2 of the order of the learned CIT – A wherein he referred to the statement recorded by the investigation wing of third party in altogether different search. He submitted that such a statement recorded in the search of third party could not be considered ... fees material. In the deviation report in para number 3 (iii) the learned assessing officer himself has stated that the chart prepared by the investigation wing is factually incorrect. Therefore, the learned authorised representative submitted that even in the deviation report dated 20/12/2018 the learned assessing officer himself

ACIT, Central Circle- 28, New Delhi vs. Agson Global Pvt. Ltd., Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 5266/DEL/2019[2014-15]Status: DisposedITAT Delhi31 Oct 2019AY 2014-15

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

further referred to the para number 5.2 of the order of the learned CIT – A wherein he referred to the statement recorded by the investigation wing of third party in altogether different search. He submitted that such a statement recorded in the search of third party could not be considered ... fees material. In the deviation report in para number 3 (iii) the learned assessing officer himself has stated that the chart prepared by the investigation wing is factually incorrect. Therefore, the learned authorised representative submitted that even in the deviation report dated 20/12/2018 the learned assessing officer himself

ACIT, Central Circle- 28, New Delhi vs. Agson Global Pvt. Ltd., Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 5265/DEL/2019[2013-14]Status: DisposedITAT Delhi31 Oct 2019AY 2013-14

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

further referred to the para number 5.2 of the order of the learned CIT – A wherein he referred to the statement recorded by the investigation wing of third party in altogether different search. He submitted that such a statement recorded in the search of third party could not be considered ... fees material. In the deviation report in para number 3 (iii) the learned assessing officer himself has stated that the chart prepared by the investigation wing is factually incorrect. Therefore, the learned authorised representative submitted that even in the deviation report dated 20/12/2018 the learned assessing officer himself

ACIT, Central Circle- 28, New Delhi vs. Agson Global Pvt. Ltd., Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 5264/DEL/2019[2012-13]Status: DisposedITAT Delhi31 Oct 2019AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

further referred to the para number 5.2 of the order of the learned CIT – A wherein he referred to the statement recorded by the investigation wing of third party in altogether different search. He submitted that such a statement recorded in the search of third party could not be considered ... fees material. In the deviation report in para number 3 (iii) the learned assessing officer himself has stated that the chart prepared by the investigation wing is factually incorrect. Therefore, the learned authorised representative submitted that even in the deviation report dated 20/12/2018 the learned assessing officer himself

Agson Global Pvt. Ltd, Delhi vs. ACIT CC-28, New Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 3746/DEL/2019[2017-18]Status: DisposedITAT Delhi31 Oct 2019AY 2017-18

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

further referred to the para number 5.2 of the order of the learned CIT – A wherein he referred to the statement recorded by the investigation wing of third party in altogether different search. He submitted that such a statement recorded in the search of third party could not be considered ... fees material. In the deviation report in para number 3 (iii) the learned assessing officer himself has stated that the chart prepared by the investigation wing is factually incorrect. Therefore, the learned authorised representative submitted that even in the deviation report dated 20/12/2018 the learned assessing officer himself

Agson Global Pvt. Ltd, Delhi vs. ACIT Central Circle-28, New Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 3745/DEL/2019[2016-17]Status: DisposedITAT Delhi31 Oct 2019AY 2016-17

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

further referred to the para number 5.2 of the order of the learned CIT – A wherein he referred to the statement recorded by the investigation wing of third party in altogether different search. He submitted that such a statement recorded in the search of third party could not be considered ... fees material. In the deviation report in para number 3 (iii) the learned assessing officer himself has stated that the chart prepared by the investigation wing is factually incorrect. Therefore, the learned authorised representative submitted that even in the deviation report dated 20/12/2018 the learned assessing officer himself

Agson Global Pvt. Ltd, Delhi vs. ACIT CC-28, New Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 3744/DEL/2019[2015-16]Status: DisposedITAT Delhi31 Oct 2019AY 2015-16

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

further referred to the para number 5.2 of the order of the learned CIT – A wherein he referred to the statement recorded by the investigation wing of third party in altogether different search. He submitted that such a statement recorded in the search of third party could not be considered ... fees material. In the deviation report in para number 3 (iii) the learned assessing officer himself has stated that the chart prepared by the investigation wing is factually incorrect. Therefore, the learned authorised representative submitted that even in the deviation report dated 20/12/2018 the learned assessing officer himself

Deepak Kumar Gupta & Sons (HUF), Delhi vs. ITO, Ward-63(2), New Delhi

ITA 1236/DEL/2018[2009-10]Status: DisposedITAT Delhi31 Oct 2019AY 2009-10

Bench: Shri H.S. Sidhuassessment Year: 2009-10

Section 142(1)Section 143(1)Section 148

Deepak 6 Kumar Gupta & Sons. The disclosure of miniscule net profit against a huge turnover is a strong indicator of accommodation entry provider. The Investigation wing has given an opportunity to file the detail of old ornaments from Abhijeet Kunduskar, but nobody appeared. Assessing Officer also given a similar opportunity ... indicates clear cut that there is a matter of Accommodation entry and bogus purchase. 4. Assessee stated that he complied the notice of Investigation wing but no evidence submitted in this regard. Therefore, at this point, Investigatin wing is right that no compliance made by the assessee against letters/notices issued

Guthey Ramakrishna, Visakhapatnam vs. Deputy Commissioner of Income Tax, Circle-4(1), Visakhapatnam

In the result, appeals of the assessee are allowed

ITA 373/VIZ/2018[2010-11]Status: DisposedITAT Visakhapatnam30 Oct 2019AY 2010-11

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.372 & 373/Viz/2018 (ननधधारण वर्ा/Assessment Year : 2009-10 & 2010-11) Guthey Ramakrishna Vs. Dy.Commissioner Of D.No.53-21-12 Income Tax Chaitanyanagar Circle-4(1) Maddilapalem Visakhapatnam Visakhapatnam [Pan : Acypg7210N] (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 : 23.09.2019 घोर्णध की तधरीख/Date Of Pronouncement : 30.10.2019 आदेश /O R D E R

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Smt. Suman Malik, DR
Section 143(1)Section 143(2)Section 148

profits were shifted to other clients and contrived losses were availed. The 4 I.T.A. No.372 & 373/Viz/2018, A.Y.2009-10 and 2010-11 Guthey Ramakrishna, Visakhapatnam Investigation Wing of Ahmedabad Unit has passed on information stating that the assessee had availed the contrived losses for the year ... versa. The AR further submitted that the AO has not made any enquiries and simply on the basis of the data received from the Investigation Wing, Unit-1(3), Ahmedabad, issued the notice u/s 148. The AO has not even conducted the preliminary enquiry to hold that the income chargeable

Guthey Ramakrishna, Visakhapatnam vs. Deputy Commissioner of Income Tax, Circle-4(1), Visakhapatnam

In the result, appeals of the assessee are allowed

ITA 372/VIZ/2018[2009-10]Status: DisposedITAT Visakhapatnam30 Oct 2019AY 2009-10

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.372 & 373/Viz/2018 (ननधधारण वर्ा/Assessment Year : 2009-10 & 2010-11) Guthey Ramakrishna Vs. Dy.Commissioner Of D.No.53-21-12 Income Tax Chaitanyanagar Circle-4(1) Maddilapalem Visakhapatnam Visakhapatnam [Pan : Acypg7210N] (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 : 23.09.2019 घोर्णध की तधरीख/Date Of Pronouncement : 30.10.2019 आदेश /O R D E R

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Smt. Suman Malik, DR
Section 143(1)Section 143(2)Section 148

profits were shifted to other clients and contrived losses were availed. The 4 I.T.A. No.372 & 373/Viz/2018, A.Y.2009-10 and 2010-11 Guthey Ramakrishna, Visakhapatnam Investigation Wing of Ahmedabad Unit has passed on information stating that the assessee had availed the contrived losses for the year ... versa. The AR further submitted that the AO has not made any enquiries and simply on the basis of the data received from the Investigation Wing, Unit-1(3), Ahmedabad, issued the notice u/s 148. The AO has not even conducted the preliminary enquiry to hold that the income chargeable

Shri Ram Narain Yadav, Jaipur vs. Income Tax Officer, Ward-3-2, Jaipur

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

ITA 916/JPR/2018[2007-08]Status: DisposedITAT Jaipur30 Oct 2019AY 2007-08
For Appellant: Shri Madhukar Garg (CA)For Respondent: Shri A.K. Mahala (JCIT)
Section 147Section 234B

Therefore, in the absence of computation of capital gain at Nil or Loss in the return of income and the information forwarded by the Investigation Wing regarding the sale of properties deemed full value consideration under section 50C, indexation cost of acquisition and long term capital gain on each ... construction/improvement before the AO. It was the contention of the appellant that the AO has relied solely on the information received from the Investigation Wing without deciding the correctness of the information and the AO cannot reopen the assessment on the basis of borrowed satisfaction. (iii) I have duly considered

Shri Ram Narain Yadav, Jaipur vs. Income Tax Officer, Ward-3-2, Jaipur

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

ITA 915/JPR/2018[2006-07]Status: DisposedITAT Jaipur30 Oct 2019AY 2006-07
For Appellant: Shri Madhukar Garg (CA)For Respondent: Shri A.K. Mahala (JCIT)
Section 147Section 234B

Therefore, in the absence of computation of capital gain at Nil or Loss in the return of income and the information forwarded by the Investigation Wing regarding the sale of properties deemed full value consideration under section 50C, indexation cost of acquisition and long term capital gain on each ... construction/improvement before the AO. It was the contention of the appellant that the AO has relied solely on the information received from the Investigation Wing without deciding the correctness of the information and the AO cannot reopen the assessment on the basis of borrowed satisfaction. (iii) I have duly considered

Smt. Ragini Jain, Kota vs. Income Tax Officer, Ward-1-2, Kota

In the result, the appeal of the assessee is dismissed

ITA 1130/JPR/2018[2014-15]Status: DisposedITAT Jaipur30 Oct 2019AY 2014-15

Bench: The Date Of Hearing.”

For Appellant: Shri Shrawan Kumar Gupta (Advocate)For Respondent: Shri A.K. Mahala (JCIT)
Section 10(38)Section 143(3)Section 271(1)(c)

made the addition to the total income of the assessee. The addition was made by the AO on the basis of report of the Investigation Wing, Kolkata, however, no specific finding was given regarding the bogus transactions in case of purchase and sale of shares by the assessee ... under section 10(38) of the Act in the return filed. The AO conducted an enquiry and referred the investigation carried out by the Investigation Wing of the Department, Kolkata where these transactions were found to be bogus in the nature of entries provided by various persons. The case

M/S.Valsons Metal, Mumbai vs. ITO Ward 19(3)(5), Mumbai

In the result, appeals filed by the assessee for assessment years 2010-11

ITA 5831/MUM/2018[2010-11]Status: DisposedITAT Mumbai30 Oct 2019AY 2010-11

Bench: Shri S. Rifaur Rahman (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2010-2011 & Assessment Year: 2011-2012 M/S Valsons Metal, The Ito – 19(3)(5), 110, Gulal Wadi, 1/19, Room No. 201, Matru Mandir, Bharja Bhavan, Kika Street, Tardeo Road, Mumbai - 400004 Vs. Mumbai - 400007 Pan: Aaafv3006B (Appellant) (Respondent) Assessee By : Shri Vimal Punmiya (Ca) Revenue By : Shri C.S. Sharma (Dr) Date Of Hearing: 25/09/2019 Date Of Pronouncement: 30/10/2019

For Appellant: Shri Vimal Punmiya (CA)For Respondent: Shri C.S. Sharma (DR)
Section 133(6)Section 143Section 147Section 148Section 234ASection 271Section 3

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 Years: 2010-11 and 2011-12 c) Reassessment proceeding cannot be initiated when the Ld. CIT (A) have reason to suspect and not reason ... counsel submitted that the initiation of reassessment proceedings by the AO is bad in law as the same was based on information received from investigation wing of the department that too without any reason to believe that the income of the assessee has escaped assessment. Since, the action

Sushma Devi Jain, Delhi vs. ITO, Ward- 63(2), New Delhi

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

ITA 600/DEL/2019[2010-11]Status: DisposedITAT Delhi30 Oct 2019AY 2010-11

Bench: Shri Prashant Maharishi & Shri K. Narasimha Charysmt. Sushma Devi Jain, Vs. Income-Tax Officer, 4327, Galibahuji,Bahadur Garh Ward 63(2), New Delhi. Road,Sadar Bazar, Delhi. Pan: Adbpj3890P Appellant Respondent Revenue By : Ms Ekta Vishnoi, Sr. Dr Assessee By: Shri Rajesh Dureja, Ca Date Of Hearing 16.10.2019 Date Of Pronouncement 30.10.2019 O R D E R Per K. Narasimha Chary, Jm Aggrieved By The Order Dated 16.11.2018Passed By The Learned Commissioner Of Income Tax (Appeals)- 20, New Delhi(“Ld. Cit(A)”), The Assessee Filed This Appeal For The Assessment Year 2010-11. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed Her Return Of Income For The Asstt. Year 2010-11. On Information Received Regarding The Sale Of Property At Rs.21,25,000/- From The Investigation Wing, The Case Was Examined & The Learned Ao Found That The Assessee Had Declared Sale Consideration Of House Property At Rs.9,80,000/- Whereas The Information Regarding Sale Of The Said Property Was Rs.21.25 Lacs. Learned Ao, Therefore, Doubted The Genuineness Of The Transaction & Issued Notice U/S 148 Of The Income- Tax Act, 1961 (“The Act”).

For Appellant: Shri Rajesh Dureja, CAFor Respondent: Ms Ekta Vishnoi, Sr. DR
Section 143(2)Section 148Section 50CSection 50C(2)

return of income for the Asstt. Year 2010-11. On information received regarding the sale of property at Rs.21,25,000/- from the Investigation Wing, the case was examined and the learned AO found that the assessee had declared sale consideration of house property at Rs.9,80,000/- whereas

Bina Aggarwal, New Delhi vs. ACIT Central Circle-08, New Delhi

Appeal of the assessee is allowed and the stay application is dismissed

ITA 2349/DEL/2019[2015-16]Status: DisposedITAT Delhi30 Oct 2019AY 2015-16

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

Section 132Section 139(1)Section 139(4)Section 153ASection 69A

search and seizure operation u/s 132 of the Act was conducted in the case of Priyagold Group of cases on 16.12.2014 by Investigation Wing, New Delhi. The assessee’s case was also covered in search operation u/s 132 of the Act. Consequent upon search action, search assessment proceedings were taken ... statutory notices were issued. Subsequent to the aforesaid search action, information was received from Investigation Wing, Kolkata that a search & seizure operation u/s 132 of the Act was conducted upon the assessee on 19.11.2015. In view of the subsequent search on 19.11.2015, assessment proceedings initiated in consequence to search operation

Mr.Anil M. Kadakia, Mumbai vs. ACIT Circle-17(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5854/MUM/2018[2013-14]Status: DisposedITAT Mumbai29 Oct 2019AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Bleshri Anil M. Kadakia V. A.C.I.T., Circle – 17(1) Room No. 117, 1St Floor 404, Sharada Chambers 33, New Marine Lines Aayakar Bhavan, M.K. Road Mumbai – 400 020 Mumbai – 400 020 Pan: Aadpk7331F (Appellant) (Respondent) Assessee By : Ms. Dinkle Haria Department By : Shri Ram Tiwari

For Appellant: Ms. Dinkle HariaFor Respondent: Shri Ram Tiwari
Section 143(1)

reopened the assessment based on the information received from the DIT(lnv.), Mumbai on the basis of search and seizure action conducted by the investigation wing during the course of which Rajendra Jain have given categorical statements clearly stating the modus operandi followed by them in providing the accommodation bills ... They have also admitted unequivocally before the investigation wing that they were not involved in any real trading of diamonds except giving bogus bills to those who need them for certain commission. Having observed that those parties in question are non-existant sellers and they have not made any sales

Chitralekha, Mumbai vs. A.C.I.T.- 17(1), Mumbai

In the result, appeal filed by the assessee for assessment years 2009-10

ITA 5220/MUM/2018[2009-10]Status: DisposedITAT Mumbai29 Oct 2019AY 2009-10

Bench: Shri S. Rifaur Rahman (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2009-2010 & Assessment Year: 2010-2011 Chitralekha, The Asst. Commissioner Of 25, Andheri Industrial Estate, Income Tax-17(1), Veera Desai Road, Andheri (West), Aayakar Bhavan, M.K. Road, Mumbai - 400053 Vs. Mumbai - 400020 Pan: Aaafc1152B (Appellant) (Respondent) Assessee By : Ms. Aarti Vissanji (Ar) Revenue By : Shri Kumar Padmapani Bora (Dr) Date Of Hearing: 09/09/2019 Date Of Pronouncement: 29/10/2019

For Appellant: Ms. Aarti Vissanji (AR)For Respondent: Shri Kumar Padmapani Bora (DR)
Section 133(6)Section 143Section 143(3)Section 147Section 148

entries, which information was given to him by the Directorate of Investigation, the AO stated: “ I have also perused various materials and report from Investigation Wing and on that basis it is evident that the assessee company has introduced its own unaccounted money in its bank account

Manoj Khetan, Mumbai vs. ITO - 17(2)(3), Mumbai

In the result, appeal is allowed for statistical purposes

ITA 5392/MUM/2018[2014-15]Status: DisposedITAT Mumbai25 Oct 2019AY 2014-15

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: NoneFor Respondent: Smt. Jyothi Lakshmi Nayak
Section 68Section 69C

After verifying the details furnished by the assessee, the Assessing Officer made further enquires with regard to the share transaction and found that the investigation Wing of the Department at Kolkata had undertaken investigation into various penny stocks and found that Matra Kaushal Enterprises Ltd., the shares whereof were claimed