“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

Snw Smith Consultant Pvt. Ltd., Delhi vs. ACIT, Central Circle 5, Delhi

In the result, assessee’s appeals pertaining to Assessment Years

ITA 1634/DEL/2025[2013-14]Status: DisposedITAT Delhi21 Nov 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

For Appellant: Hasneeta Matta, Adv, &For Respondent: Sh. Mahesh Kumar, CIT, DR

Section 153A

principally the back-office for ASAPL. The explanations/responses to the seized material from all premises of ASG were submitted by the ASAPL to the Investigation Wing. Undisclosed Income - Unbooked Commission - separately recorded - two parallel sets of accounting servers 6. Materials were seized from the offices of ASG at Le Meridien ... Smith Consultants (appellant) and Adam Smith Consultancy, being only intermediaries, ASAPL submitted complete details and explanations of all the unbooked transactions to the Investigation Wing. 12. All the documents, physical and digital, and details of the entire unbooked commission/income for the years

Snw Smith Consultants Pvt. Ltd., Delhi vs. ACIT, Central Circle 5, Delhi

In the result, assessee’s appeals pertaining to Assessment Years

ITA 1633/DEL/2025[2012-13]Status: DisposedITAT Delhi21 Nov 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

For Appellant: Hasneeta Matta, Adv, &For Respondent: Sh. Mahesh Kumar, CIT, DR

Section 153A

Sga Infotech Private Limited, New Delhi vs. ACIT, Delhi

In the result, appeal of assessee in ITA No

ITA 5844/DEL/2024[2015-16]Status: DisposedITAT Delhi21 Nov 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Aseem Chawla, Sr. AdvFor Respondent: Shri Sushil Kumar Kulheri, Sr. DR

Section 143(3)Section 147Section 148Section 148ASection 292BSection 68

apply his mind while recording reasons to believe and issuing notice u/s 148. He mechanically relied on the report of investigation wing without conducting any independent enquiry that means belief formed is based on borrowed satisfaction and not his own satisfaction. Therefore, the notice issued u/s 148 is not valid

DCIT, Circle- 19(1), Delhi vs. Rakshit Buildcon Pvt. Ltd., Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 4727/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmadcit, Circle 19 (1), Vs. Rakshit Buildcon Pvt. Ltd., C – 1/207, 2Nd Floor, Delhi. Sector 11, Rohini, New Delhi – 110 085. (Pan : Aaecr2414E) (Appellant) (Respondent) Assessee By : Shri Salil Aggarwal, Sr. Advocate Shri Shailesh Gupta, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 21.11.2025 O R D E R Per S.Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Delhi-23 [“Ld. Cit(A)”, For Short] Dated 14.08.2024 For Ay 2017-18. “(I) "Whether On Facts & Circumstances Of The Case & In Law, The Ld. Cit(A), Has Erred In Not Appreciating That Detailed Investigation Was Already Carried Out By The Investigation Wing On The Issue Of Bogus Short Term Capital Loss From Alankit Group & The Assessee Was Not Able To Substantiate Its Claim With Evidences."

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 147Section 148Section 151

case and in law, the Ld. CIT(A), has erred in not appreciating that detailed investigation was already carried out by the Investigation Wing on the issue of Bogus Short Term Capital Loss from Alankit Group and the assessee was not able to substantiate its claim with evidences." 2 "Whether ... facts of the case and in law, the Ld.CIT(A) has erred in not appreciating that the information received from the Investigation Wing is a valid piece of information." (iii) "Whether on the facts and circumstances of the case, the Ld. CIT(A) has erred in not appreciating that

Jsm Oilfields Services Pvt. Ltd, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

In the result, appeal of the assessee is allowed

ITA 4093/DEL/2024[2013-14]Status: DisposedITAT Delhi21 Nov 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2013-14] Jsm Oilfields Services Pvt.Ltd., Vs Dcit, Farm No.14, 8Th Avenue, Radhey Circle-13(1), Mohan Drive, Gadaipur, New Delhi New Delhi-110017. Pan-Aabcj1500C Appellant Respondent Appellant By Shri Anil Jain, Adv. Respondent By Shri Om Parkash, Sr.Dr Date Of Hearing 26.08.2025 Date Of Pronouncement 21.11.2025

Section 131Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 68

statement of one Shri Vivek Kumar Jain who was alleged entry provider and his statements were recorded u/s 131 of the Act by the Investigation Wing, Delhi on 22.04.2013 wherein he had admitted of managing and controlling 30 companies for providing accommodation entries. As per Ld.AR, such statements were never ... that statements of Shri Vivek Kumar Jain are not available in assessment folder and he further observed that the statements were sought from the Investigation Wing however, till date no such statements were provided. Ld. AR submits that AO though had reproduced certain extracts of the statements in the assessment

Income Tax Officer Ward-48(1), Delhi vs. Ravinder Nath Goel, Delhi

In the result, appeal of the Revenue in ITA No

ITA 3437/DEL/2024[2012-13]Status: DisposedITAT Delhi21 Nov 2025AY 2012-13

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Navneet Singal, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 131Section 147Section 148

account maintained by M/s.JMD Trading Co the main was of the Mr.Ravinder Nath Goel i.e., ravingoel@rediffmail.com. These facts have also been established by the Investigation Wing during the course of search operations 4 The appellant craves leave to add, alter or amend any of the grounds of appeal before

Deputy Commissioner of Income Tax-(1), Raipur vs. Ajay Golechaa, Raipur

In the result, appeal of the Revenue is dismissed

ITA 454/RPR/2025[2014-15]Status: DisposedITAT Raipur20 Nov 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.454/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

For Appellant: None (Petition filed)For Respondent: Shri Ram Tiwari, CIT-DR

Section 10(38)Section 143(3)Section 271(1)(c)

later on towards loans and advances. It may not be out of place to mention here that the issue was enquired by the Investigation Wing of Kolkata The 5 DCIT-1(1), Raipur Vs. Ajay Golechaa crux of their statement are that the scrip of NCL Research and Financial Services ... also discussed the abrupt movement of share prices of this share in stock market, the financials of the shares and enquiry of Investigation wing Kolkata into 84 scrips which were used by certain persons to artificially show LTCG by business man. Statement of certain persons were recorded who were involved

Anju Parekh, Dhamtari vs. Income Tax Officer, Ward-Dhamtari, Dhamtari

In the result, appeal of the assessee is allowed

ITA 384/RPR/2023[2013-14]Status: DisposedITAT Raipur20 Nov 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.384/Rpr/2023 "नधा"रण वष" / Assessment Year : 2013-14 Anju Parekh, Prop. M/S. Kushal Investment, Near Petrol Pump, Station Road, Dhamtari, Chhattisgarh-493773 Pan No. Akepp9283A

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri Ram Tiwari, CIT-DR

Section 10(38)Section 68

year under consideration, the assessee had traded in the scrips of “NCL Research & Finance Services Pvt. Ltd.” and as per the report of the Investigation Wing, Kolkata, cracking down on penny stocks, one such scrip was that of “NCL Research & Finance Services Pvt. Ltd.”. Thereafter, the A.O has examined ... share brokers etc. and they managed the bogus companies and used them for circular transactions to rig the price of shares. The report of Investigation Wing, Kolkata further reveals that in cases of these penny stock companies although shares are listed on the Exchange, however, they are always closely held

Amit Kumar Pal, Thrissur vs. Ward 1(1) Thrissur, Thrissur

In the result, the appeal filed by the assessee stands dismissed

ITA 676/COCH/2025[2022-23]Status: DisposedITAT Cochin20 Nov 2025AY 2022-23

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2022-23 Amit Kumar Pal .......... Appellant House No. 31/321/1, Vakayil Road St. Marys Chappal, Chiyyaram, Thrissur [Pan: Bnhpp5857P] Vs. The Income Tax Officer, Wd-1(1), Thrissur .......... Respondent Assessee By: Shri Anoop V. Francis, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 20.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 30.07.2025 For Assessment Year (Ay) 2022-23. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Doing Job Work As Goldsmith. The Return Of Income For Ay 2022-23 Was Filed On 30.12.2022 Declaring Income Of Rs. 6,82,690/-. The Search & Seizure Operations U/S. 132 Of The Income Tax Act, 1961 (The Act) Were Conducted In The Business Premises Of M/S. Peeyar Exporters In The Month Of March, 2022. During The Course Of Search & Seizure Operations Certain Digital Evidences Were Found

For Appellant: Shri Anoop V. Francis, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 132Section 143(3)Section 44A

confronted with the appellant, the appellant had offered to disclose this amount as additional income in the statement recorded from the appellant by the Investigation Wing. However, in the return of income the appellant had shown the value of the gold deposit as security deposit which was offered ... holding that the addition was made based on the additional income disclosed by the appellant vide letter dated 09.04.2022 submitted on 22.04.2022 before the Investigation Wing of the Department and mere retraction of the statement 3 Amit Kumar Pal subsequently without substantiating he same cannot be accepted. In support

M/S Bajrang Lal Jindal, Kanpur vs. Astt. Commissioner of Income Tax-I, Kanpur

In the result, the appeal of the assessee is allowed

ITA 373/LKW/2017[2008-09]Status: DisposedITAT Lucknow20 Nov 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2008-09 M/S Bajrang Lal Jindal, 140, Vs. Asstt. Commissioner Of Income Anandpuri, Kanpur, U.P. Tax-I, Kanpur Pan: Aanpj5660J (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 27.08.2025 Date Of Pronouncement: 20.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A)- Kanpur, Confirming The Addition Of Rs. 1,46,11,400/- Made To The Returned Income Of The Assessee As Unexplained Cash Credits By The Assessing Officer In His Order Dated 31.03.2016 For The Assessment Year 2008-09. The Grounds Of Appeal Are As Under: - “1. That The Ld. Cit (A) I, Kanpur Has Erred In Confirming Addition Of Rs. 14611400.00 To The Returned Income Of The Assessee As Unexplained Cash Credits. 2. That The Reasons Recorded For Initiation Of Proceedings U/S 147 By Issue Of Notice U/S 148 Were Based On Improper Premise & Accordingly No Legal & Factual Lengs To Stand & Acordingly All Subsequent Proceedings Are Bad In Law. 3. That The Observation Of The Ld. Cit (A) I, Kanpur Confirming View Of Ld. A O That M/S. Maa Devasar Commodity Is Inexistant Is Factually Incorrect. 4. That Ld. Cit (A) I, Kanpur Has Erred In Not Appreciating The Fact That When The Beneficiary Of The Funds Are Not The Assessee, There Could Be No Addition In His Hands.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. Amit Kumar, DR

Section 147Section 148Section 68

IMPROPER APPRCIATION OF FACTS WITH BIASED MIND AND FINDING IT DIFFICULT TO COME OUT OF INFORMATION FORWARDED TO HIM BY THE DIRECTORATE OF INVESTIGATION WING OF INCOME TAX DEPARTMENT. 12. THAT LD. CIT (A) I, KANPUR HAS ERRED IN NOT PROPERLY APPRECIATING THE SUBMISSIONS OF THE ASSESSEE AND ALSO FAILED ... Garg Share Rs. 53,79,500/- Kanpur Investment C/o B.L. Jindal, 53/7, Naya Ganj, Kanpur Total Rs. 1,46,11,400/- The Investigation Wing also observed that most of the money deposited in these accounts was subsequently transferred to the bank account of M/s Maa Devasar Commodity. This firm could

Income Tax Officer, Ward-6(1), Pune vs. Shravani Land Private Limited, Pune

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

ITA 857/PUN/2024[2009-10]Status: DisposedITAT Pune20 Nov 2025AY 2009-10

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.857/Pun/2024 िनधा"रण वष" / Assessment Year : 2009-10 Ito, Ward-6(1), Pune. Vs. Shravani Land Private Limited, Utkarsha, Plot No.14, Yogi Arbindo Society, Sahakar Nagar-2, Pune- 411009. Pan : Aalcs1473M Appellant Respondent Revenue By : Shri Manish Kumar Sinha Assessee By : None Date Of Hearing : 15.09.2025 Date Of Pronouncement : 20.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 26.02.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2009-10. 2. The Revenue Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case & In Law, The Id. Cit(A) Erred In Deleting The Addition Of Rs. 2,43,35,511/-

For Appellant: NoneFor Respondent: Shri Manish Kumar Sinha

Section 142(1)Section 143(3)Section 148Section 68

circumstances of the case and in law, the Id. CIT(A) failed to take note of the fact that the assessee before the Investigation Wing had stated that the unsecured loan was taken from M/s Vinamra Universal Traders Pvt. Ltd. whereas before the Assessing Officer, the unsecured loan was stated ... Mumbai vide letter dated 3 21.03.2016 that the assessee company purchased land out of the unsecured loan and during the enquiry conducted at Investigation Wing, the identity of the creditors the creditworthiness and genuineness of transaction could not be proved by the assessee company and therefore on the basis

Tirupati Timbers & Packaging P. Ltd., Kolkata vs. ITO, Ward 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1428/KOL/2025[2011-2012]Status: DisposedITAT Kolkata20 Nov 2025AY 2011-2012

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1428/Kol/2025 Assessment Year: 2011-2012 Tirupati Timbers & Packaging P. Limited,…Appellant Room No. 563, Marshall House, 33/1, N.S. Road, Dalhousie, G.P.O., Kolkata-700001, W.B. [Pan:Aabct2720Q] -Vs.- Income Tax Officer,……………………………..Respondent Ward-4(1), Kolkata, Aayakar Bhawan, 8Th Floor, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Girdhar Dhelia, Advocate, Appeared On Behalf Of The Assessee Shri Kallol Mistry, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 02, 2025 Date Of Pronouncing The Order: November 20, 2025 O R D E R

Section 142(1)Section 143(2)Section 147Section 148Section 154Section 250

even when no opportunity has been given to the assessee to confront the back materials relied extensively in impugned orders like statement, investigation wing report, etc. and not allowing the cross examination to the appellant and hence the impugned assessment order passed u/s 147/143(3) of the Act dated

Deputy Commissioner of Income Tax, Kolkata vs. Santosh Promoters Private Limited, Kolkata

In the result, the appeal of Revenue is dismissed

ITA 94/KOL/2024[2012-13]Status: DisposedITAT Kolkata20 Nov 2025AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dy. Commissioner Of Income Tax Santosh Promoters Private O/O The Dcit, Cc-1(1), Limited Room No.305, 3Rd Floor, 145, Rash Behari Avenue, Vs. Aayakar Bhawan Poorva, Gariahat, Kolkata-700029 Kolkata-700107 West Bengal West Bengal (Appellant) (Respondent) Pan No. Aadcs7546M Assessee By : Shri Siddharth Agarwal, Ar Revenue By : Shri Sandeep Lakra, Dr Date Of Hearing: 29.10.2025 Date Of Pronouncement: 20.11.2025

For Appellant: Shri Siddharth Agarwal, ARFor Respondent: Shri Sandeep Lakra, DR

Section 132Section 133(6)Section 50C

discrepancy in respect of such trading. The learned CIT (A) further noted that the learned AO has relied only the information received from Investigation Wing that the transactions through M/s. Marigold Vanijya Pvt. Ltd were not genuine. Besides the CIT (A) also noted that the director of the said company ... transactions executed on the exchange before the learned AO. We note that the learned AO has only acted on the report of the investigation wing and retracted statement of Shri Sachet Saraf . Thus, we do not find any infirmity in the order of the learned CIT (A) and are inclined

M/S. Muse Advertising and Media Pvt. Ltd., Kolkata vs. I.T.O., Ward - 10(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2202/KOL/2024[2011-2012]Status: DisposedITAT Kolkata20 Nov 2025AY 2011-2012

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(3)Section 147Section 148Section 250

material facts in course of original assessment, then the concluded assessment u/s 143(3) could not be reopened simply based on information provided by investigation wing. 5. The Ld. AR also invited our attention to the letter for approval obtained by the AO u/s 151 from the Principal Commissioner

Jayvadan Amratlal Rughnathwala, Surat vs. PCIT-1, Surat

In the result, the appeal of the assessee is allowed

ITA 348/SRT/2025[2018-19]Status: DisposedITAT Surat19 Nov 2025AY 2018-19

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.348/Srt/2025 Assessment Year: (2018-19) (Hybrid Hearing) Jayvadan Amratlal Rughnathwala, Vs. The Pcit - 1, 6/7, Khatodara Ind Service Society, Surat B/H Sub Jail Khatodara, Surat – 395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpr4348L (Appellant) (Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Ravinder Sindhu, Cit-Dr Date Of Hearing 26/08/2025 Date Of Pronouncement 19/11/2025

Section 115BSection 139Section 147Section 148Section 263Section 270ASection 271ASection 69C

declaring total income at Rs.17,69,010/-. In this case, information had been received from the Investigation Wing that M/s. S.K. Enterprise (Prop. Shahrukhkhan Pathan) was primarily engaged in generating and passing on GST credit to their buyers without any physical movement of goods. During investigation, it had been found

Joint Commissioner of Income Tax, Ajmer vs. Vijeta Lodha, Jaipur

ITA 390/JPR/2023[2015-16]Status: DisposedITAT Jaipur19 Nov 2025AY 2015-16

For Appellant: Shri Rajeev Sogani, C.A. (through V.C.)For Respondent: None

Section 10(38)Section 142(1)Section 143(2)Section 68Section 69C

trade through\nthem/their terminal.\n24. In para 6.6, the Assessing Officer observed that the modus operandi\nmentioned in para 6.5 was deduced by various Investigation Wings of the\nIncome Tax Department, SEBI and government agencies. He is also stated\nto have spelt out the above said modus operandi adopted ... merit in the contention on behalf of the\nassessee that the Assessing Officer place reliance only on the general\nobservations of the Investigation Wing of Kolkatta, or that the Assessing\nOfficer on the basis of pre-conceived notion completed the assessment\nmaking the above said additions or that

Sudhir Babu Chalasani, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 1352/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Nov 2025AY 2017-18

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 10(38)Section 69A

assessment has been subsequently reopened u/s 147 of the Income Tax Act, 1961, for the reasons recorded, as per which, information received from Investigation Wing shows that, the assessee had sold shares of penny stocks from Stampede Capital Ltd during the F.Y. 2012-13 relevant to assessment year ... Rs.28,67,659/-. Further, Stampede Capital Ltd is one of the penny stock companies, as identified by Investigation Wing, was engaged in the activity to provide accommodation entries by accepting undisclosed cash. Therefore, notice u/s 148 of the Act, dated 31.03.2021 was issued and duly served upon the assessee

Sudhir Babu Chalasani, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 1351/HYD/2025[2016-17]Status: DisposedITAT Hyderabad19 Nov 2025AY 2016-17

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 10(38)Section 69A

Sudhir Babu Chalasani, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 1349/HYD/2025[2014-15]Status: DisposedITAT Hyderabad19 Nov 2025AY 2014-15

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 10(38)Section 69A

Sudhir Babu Chalasani, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 1348/HYD/2025[2013-14]Status: DisposedITAT Hyderabad19 Nov 2025AY 2013-14

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 10(38)Section 69A