← All Phrases

“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

Sachin Anantray Ghelani, Mumbai vs. Income Tax Officer-27(3)(2), Mumbai

In the result, the appeal filed by the assessee is hereby ordered to be dismissed

ITA 2078/MUM/2018[2010-11]Status: DisposedITAT Mumbai31 Jul 2019AY 2010-11

Bench: Shri Ramit Kochar, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.2078/Mum/2018 (निर्धारण वर्ा / Assessment Year: 2010-11) Sachin Anantray Ghelani बिधम/ Ito 27(3)(2) 4Th Floor, Tower No. 6 A/12, Mahavir Mansion, Vs. Vallabh Baug Lane Railway Station, Extension, Ghatkopar (E), Commercial Complex Vashi, Mumbai-400077. Mumbai-400703. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Achpg2092D (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Nilesh Nandkumar Pitale Revenue By: Shri Chaudhary Arun Kumar Singh (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 25/07/2019 घोषणा की तारीख /Date Of Pronouncement: 31/07/2019 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 19.01.2018 Passed By The Commissioner Of Income Tax (Appeals) -25, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2010- 11. 2. The Assessee Has Raised The Following Grounds: -

For Appellant: Shri Nilesh Nandkumar PitaleFor Respondent: Shri Chaudhary Arun Kumar
Section 143(1)Section 143(2)Section 148

embedded in impugned purchases of Rs.1,90,47,912/-, treated as bogus purchases by the AO. The AO had received information from the Investigation Wing of the department that the assessee had taken accommodation bills for purchases from the parties declared as hawala operators by Maharashtra Sales Tax Department. During

Electromac Industries, Mumbai vs. Income Tax Officer-24(1)-5, Mumbai

In the result,appeals filed by the assessee for all assessment

ITA 4700/MUM/2017[2011-12]Status: DisposedITAT Mumbai31 Jul 2019AY 2011-12

Bench: Shri Pawan Singh & G. Manjunatha

For Appellant: Sh. Ashwin Chhag, ARFor Respondent: Sh. Manoj Kumar Singh, Sr, DR
Section 133(6)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 41

under:- 5.5. HELD. At the outset, it is categorically untrue that AO has not made efforts beyond getting information from Investigation Wing. The notices u/s. 133(6) of the Act was issued to the above listed party which was returned unserved. AO has afforded opportunities to the appellant to produce ... alleged supplier. Here, it is relevant to take into account that the enquiries conducted by the Sales Tax Department as well as the Investigation Wing of Income Tax Department/the Assessing Officer have established that the said suppliers are not genuine. The said parties were not produced for examination

Electromac Industries, Mumbai vs. Income Tax Officer-24(1)-5, Mumbai

In the result,appeals filed by the assessee for all assessment

ITA 4697/MUM/2017[2008-09]Status: DisposedITAT Mumbai31 Jul 2019AY 2008-09

Bench: Shri Pawan Singh & G. Manjunatha

For Appellant: Sh. Ashwin Chhag, ARFor Respondent: Sh. Manoj Kumar Singh, Sr, DR
Section 133(6)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 41

under:- 5.5. HELD. At the outset, it is categorically untrue that AO has not made efforts beyond getting information from Investigation Wing. The notices u/s. 133(6) of the Act was issued to the above listed party which was returned unserved. AO has afforded opportunities to the appellant to produce ... alleged supplier. Here, it is relevant to take into account that the enquiries conducted by the Sales Tax Department as well as the Investigation Wing of Income Tax Department/the Assessing Officer have established that the said suppliers are not genuine. The said parties were not produced for examination

ACIT 29(1), Mumbai vs. Dhiren P. Nandu (HUF), Mumbai

In the result, the appeal filed by the revenue is hereby ordered to be dismissed and the cross-objection of the assessee is hereby ordered to be dismissed

ITA 2362/MUM/2017[2009-10]Status: DisposedITAT Mumbai31 Jul 2019AY 2009-10

Bench: Shri M. Balaganesh, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.2362/Mum/2017 (निर्धारण वर्ा / Assessment Year: 2009-10) Acit-29(1) बिधम/ M/S. Dhiren P. Nandu (Huf) Room No. 108, 1St Floor, C- 3, Gupta Niwas, Vp Road, Vs. 10 Pratyankshakar Bhavan, Mulund West, Mumbai-80. B.K.C, Bandra (E), Mumbai- 51. Co. No.359/M/2018 (Arising Out Of Ita. No. 2362/Mum/2017) (निर्धारण वर्ा / Assessment Year: 2009-10) Acit-29(1) M/S. Dhiren P. Nandu (Huf) बिधम/ 3, Gupta Niwas, Vp Road, Room No. 108, 1St Floor, C- Vs. Mulund West, Mumbai-80. 10 Pratyankshakar Bhavan, B.K.C, Bandra (E), Mumbai- 51. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaahd1784L (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Shri D. G. Pansari (Sr. Ar) Assessee By: Shri Paras Savla / Pratik Poddar सुनवाई की तारीख / Date Of Hearing: 30/07/2019 घोषणा की तारीख /Date Of Pronouncement: 31/07/2019 आदेश / O R D E R Per Amarjit Singh, Jm: The Revenue As Well As Assessee Have Filed The Above Mentioned Appeals As Well As Cross-Objection Against The Order Dated 25.01.2017 Passed By The Commissioner Of Income Tax (Appeals)-40, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2009-10. Ita. No.2362/M/17 Co. No.359/M/2018 A.Y. 2009-10

For Appellant: Shri Paras Savla / Pratik PoddarFor Respondent: Shri D. G. Pansari (Sr. AR)
Section 143(1)Section 143(3)Section 147Section 148Section 69

failed to appreciate the fact that the AO has made the addition on the basis of the concrete information received from the investigation wing of the department that Mr. Pravin Kumar Jain was operating and managing 71 benami concerns through which they are involved in providing bogus entries of unsecured ... order, submission of the assessee and relevant judicial pronouncements as applicable to the facts of the case. The Ld.AO received an information from the Investigation wing that the appellant had taken accommodation entries of Rs.1,00,00,000/- from M/s Ansh Merchandise Pvt. Ltd. operated by Shri Pravin Kumar Jain

DCIT 5(1)(2), Mumbai vs. Diasqua India P.Ltd, Mumbai

In the result, appeal filed by the assessee in ITA

ITA 3234/MUM/2016[2007-08]Status: DisposedITAT Mumbai31 Jul 2019AY 2007-08

Bench: Shri G. Manjunatha & Shri Ram Lal Negidiasqua India Pvt.Ltd. Vs. Dcit-5(1)(2) Room No.568, 5Th Floor Cw-6061,6062,6063,6071 Bharath Diamond Bourse Aaykar Bhawan Bkc, Bandra(E) M.K.Road Mumbai-400 051 Mumbai-400 020 Pan/Gir No.Aaccd3418N Appellant) .. Respondent) & Dcit-5(1)(2) Vs. Diasqua India Pvt.Ltd. Room No.568, 5Th Floor Cw-6061,6062,6063,6071 Aaykar Bhawan Bharath Diamond Bourse M.K.Road Bkc, Bandra(E) Mumbai-400 020 Mumbai-400 051 Pan/Gir No. Aaccd3418N Appellant) .. Respondent) Assessee By Suchek Achalia, Ar Revenue By Somnath Wajale, Dr

Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 69C

from four parties amounting to Rs. 1,81,69,414/-, the. Ld.CIT(A) has observed that although, search and seizure carried out by the investigation wing clearly established the fact that Shri Rajendra S.Jain was involved in providing accommodation entries, but fact remains that the statement of Shri Rajendra S.Jain

Diasqua India Pvt. Ltd., Mumbai vs. DCIT - 5 (1)(2), Mumbai

In the result, appeal filed by the assessee in ITA

ITA 2283/MUM/2016[2007-08]Status: DisposedITAT Mumbai31 Jul 2019AY 2007-08

Bench: Shri G. Manjunatha & Shri Ram Lal Negidiasqua India Pvt.Ltd. Vs. Dcit-5(1)(2) Room No.568, 5Th Floor Cw-6061,6062,6063,6071 Bharath Diamond Bourse Aaykar Bhawan Bkc, Bandra(E) M.K.Road Mumbai-400 051 Mumbai-400 020 Pan/Gir No.Aaccd3418N Appellant) .. Respondent) & Dcit-5(1)(2) Vs. Diasqua India Pvt.Ltd. Room No.568, 5Th Floor Cw-6061,6062,6063,6071 Aaykar Bhawan Bharath Diamond Bourse M.K.Road Bkc, Bandra(E) Mumbai-400 020 Mumbai-400 051 Pan/Gir No. Aaccd3418N Appellant) .. Respondent) Assessee By Suchek Achalia, Ar Revenue By Somnath Wajale, Dr

Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 69C

from four parties amounting to Rs. 1,81,69,414/-, the. Ld.CIT(A) has observed that although, search and seizure carried out by the investigation wing clearly established the fact that Shri Rajendra S.Jain was involved in providing accommodation entries, but fact remains that the statement of Shri Rajendra S.Jain

Deputy Commissioner of Income Tax - Central Circle 8(1), Mumbai vs. S. B. Securities Private Limited, Mumbai

Appeal stands dismissed

ITA 7346/MUM/2017[2009-10]Status: DisposedITAT Mumbai30 Jul 2019AY 2009-10

Bench: Hon’Ble Shri Sandeep Gosain, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri Neelkanth Khandelwal-Ld. ARFor Respondent: Chaudhury Arun Kumar Singh-Ld. DR
Section 143(2)Section 143(3)Section 148

followed by statutory notices u/s 143(2) and 143(1). 2.2 The reassessment proceedings got triggered pursuant to receipt of certain information from Investigation Wing, Ahmadabad wherein it was alleged that the assessee stood beneficiary of client-code modification (CCM). The investigation arm of the department having conducted spot verifications ... transaction volume carried out by the assessee. Another plea raised was the fact that although Ld. AO grossly relied upon the inquiries conducted by Investigation Wing, Ahmedabad, however adverse material used against the assessee was never confronted which vitiated the basis principles of natural justice. Reliance was placed

Mbm Tubes Pvt Ltd., Mumbai vs. ITO 5(2)(3), Mumbai

The appeals stand partly allowed in terms of our above order

ITA 3027/MUM/2016[2010-11]Status: DisposedITAT Mumbai30 Jul 2019AY 2010-11

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

For Appellant: Shri Sanjay Kapadia- Ld. ARFor Respondent: Ms. Pooja Swaroop - Ld.DR
Section 133(6)Section 143(3)Section 148

assessee is stated to be engaged in the business of manufacturing of ferrous and non-ferrous metals. Pursuant to receipt of certain information from investigation wing of the department, it transpired that the assessee obtained hawala purchase entries aggregating to Rs.116.37 Lacs from 7 entities, the details of which have

Sajan Kumar Jain, Delhi vs. DCIT, Central Circle-25, New Delhi

In the result, the appeal of the assessee is allowed

ITA 5949/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Jul 2019AY 2013-14

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

capital gain accommodation entries from Sh. Pradeep Kumar Jindal. This version of the assessee is on the basis of the investigation made by the Investigation Wing by issuing the summons, out of 78 entities who had taken accommodation entries from Sh. Pradeep Kumar Jindal, 34 entities had paid ... assessee before AO as well as Ld. CIT(A). Ld. CIT(DR) stated that on the basis of the detailed report of the Investigation Wing regarding modus operandi of accommodation entries provided by Pradeep Kumar Jindal, various documentary evidences as well as statement of Pradeep Kumar Jindal, the addition

Anand Kumar Jain, Faridabad vs. DCIT, Central Circle-25, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4723/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Jul 2019AY 2014-15

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

capital gain accommodation entries from Sh. Pradeep Kumar Jindal. This version of the assessee is on the basis of the investigation made by the Investigation Wing by issuing the summons, out of 78 entities who had taken accommodation entries from Sh. Pradeep Kumar Jindal, 34 entities had paid ... assessee before AO as well as Ld. CIT(A). Ld. CIT(DR) stated that on the basis of the detailed report of the Investigation Wing regarding modus operandi of accommodation entries provided by Pradeep Kumar Jindal, various documentary evidences as well as statement of Pradeep Kumar Jindal, the addition

Satish Dev Jain, Delhi vs. DCIT, Central Circle-25, New Delhi

In the result, the appeal of the assessee is allowed

ITA 5955/DEL/2018[2015-16]Status: DisposedITAT Delhi30 Jul 2019AY 2015-16

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

capital gain accommodation entries from Sh. Pradeep Kumar Jindal. This version of the assessee is on the basis of the investigation made by the Investigation Wing by issuing the summons, out of 78 entities who had taken accommodation entries from Sh. Pradeep Kumar Jindal, 34 entities had paid ... assessee before AO as well as Ld. CIT(A). Ld. CIT(DR) stated that on the basis of the detailed report of the Investigation Wing regarding modus operandi of accommodation entries provided by Pradeep Kumar Jindal, various documentary evidences as well as statement of Pradeep Kumar Jindal, the addition

Anand Kumar Jain, New Delhi vs. DCIT, Central Circle- 25, New Delhi

In the result, the appeal of the assessee is allowed

ITA 5948/DEL/2018[2015-16]Status: DisposedITAT Delhi30 Jul 2019AY 2015-16

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

capital gain accommodation entries from Sh. Pradeep Kumar Jindal. This version of the assessee is on the basis of the investigation made by the Investigation Wing by issuing the summons, out of 78 entities who had taken accommodation entries from Sh. Pradeep Kumar Jindal, 34 entities had paid ... assessee before AO as well as Ld. CIT(A). Ld. CIT(DR) stated that on the basis of the detailed report of the Investigation Wing regarding modus operandi of accommodation entries provided by Pradeep Kumar Jindal, various documentary evidences as well as statement of Pradeep Kumar Jindal, the addition

Anand Kumar Jain, New Delhi vs. DCIT, Central Circle- 25, New Delhi

In the result, the appeal of the assessee is allowed

ITA 5947/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Jul 2019AY 2013-14

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

capital gain accommodation entries from Sh. Pradeep Kumar Jindal. This version of the assessee is on the basis of the investigation made by the Investigation Wing by issuing the summons, out of 78 entities who had taken accommodation entries from Sh. Pradeep Kumar Jindal, 34 entities had paid ... assessee before AO as well as Ld. CIT(A). Ld. CIT(DR) stated that on the basis of the detailed report of the Investigation Wing regarding modus operandi of accommodation entries provided by Pradeep Kumar Jindal, various documentary evidences as well as statement of Pradeep Kumar Jindal, the addition

Anand Jain HUF, New Delhi vs. DCIT, Central Circle- 25, New Delhi

In the result, the appeal of the assessee is allowed

ITA 5946/DEL/2018[2015-16]Status: DisposedITAT Delhi30 Jul 2019AY 2015-16

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

capital gain accommodation entries from Sh. Pradeep Kumar Jindal. This version of the assessee is on the basis of the investigation made by the Investigation Wing by issuing the summons, out of 78 entities who had taken accommodation entries from Sh. Pradeep Kumar Jindal, 34 entities had paid ... assessee before AO as well as Ld. CIT(A). Ld. CIT(DR) stated that on the basis of the detailed report of the Investigation Wing regarding modus operandi of accommodation entries provided by Pradeep Kumar Jindal, various documentary evidences as well as statement of Pradeep Kumar Jindal, the addition

Anand Jain HUF, New Delhi vs. DCIT, Central Circle- 25, New Delhi

In the result, the appeal of the assessee is allowed

ITA 5945/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Jul 2019AY 2014-15

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

capital gain accommodation entries from Sh. Pradeep Kumar Jindal. This version of the assessee is on the basis of the investigation made by the Investigation Wing by issuing the summons, out of 78 entities who had taken accommodation entries from Sh. Pradeep Kumar Jindal, 34 entities had paid ... assessee before AO as well as Ld. CIT(A). Ld. CIT(DR) stated that on the basis of the detailed report of the Investigation Wing regarding modus operandi of accommodation entries provided by Pradeep Kumar Jindal, various documentary evidences as well as statement of Pradeep Kumar Jindal, the addition

DCIT 5(1), Indore vs. Shri Mahesh Banasal, Indore

In the result both the appeals of the Revenue and Assessee

ITA 499/IND/2018[10-11]Status: DisposedITAT Indore29 Jul 2019

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2010-11 The Deputy Commissioner Of Vs. Shri Mahesh Bansal, Income Tax 5(1), 44, Manish Bagh, Indore Agrawal Nagar, Indore

Section 132Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 68

Search proceedings u/s 132 of the Act were conducted at the premises of CHL Hospital and its directors during F.Y. 2013-14. Investigation Wing seized a pen-drive from the residential premises of Accountant of CHL Hospital containing details of certain cash transactions including a noting relating to cash loan ... Rs.8,31 ,830/-. The appellant maintained regular books of account based on which he declares income. Post-search enquiry was also made by the Investigation Wing from the assessee regarding entry found to be recorded in the pen drive of the accountant. Assessee categorically stated that he had never dealt

Lalla Ram Maurya, New Delhi vs. ITO, Ward-32(4), New Delhi

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 6752/DEL/2018[2015-16]Status: DisposedITAT Delhi29 Jul 2019AY 2015-16

Bench: Sh. R. K. Panda & Sh. Kuldip Singhassessment Year: 2015-16

Section 10Section 68

submission of the same. So far as the issue of cross-examination is concerned she submitted that the report was given by the investigation wing after thorough enquiry and is not a random enquiry. Referring to the decision of Hon’ble Delhi High Court in the case of Udit Kalra ... considered the various decisions relied by both the sides before us. We find the Assessing officer on the basis of the report of the investigation wing and after recording the statement of the assessee u/s. 131, rejected the claim of exemption u/s. 10 (38) of the Act. We find

DCIT, Faridabad vs. M/S Lakshat Constructions P.Ltd., Faridabad

ITA 2787/DEL/2016[2011-12]Status: DisposedITAT Delhi29 Jul 2019AY 2011-12

Bench: Shri R.K. Panda & Shri Kuldip Singh

For Appellant: Shri D.C. Garg, CAFor Respondent: Ms. Ashima Neb, Senior DR
Section 143Section 68

been further given to two parties, namely, M/s. Rajesh Projects India Pvt. Ltd. and M/s. Gupta Infrastructure Ltd. for equivalent areas whereas before the Investigation Wing assessee deposed that it has given contract for development of land of 15,99,814 CUM of area for value of Rs.31 ... recording of statement of Shri Deepak Nimesh as to the categoric admission is extracted as under :- In this case information was received from “ Investigation Wing, Gurgaon that during the course of search and survey proceedings on M/s PACL evidences have been found with reference to booking of bogus expenses

M/S. Lakshit Construction Pvt. Ltd., Faridabad vs. ACIT, Faridabad

ITA 2262/DEL/2016[2011-12]Status: DisposedITAT Delhi29 Jul 2019AY 2011-12

Bench: Shri R.K. Panda & Shri Kuldip Singh

For Appellant: Shri D.C. Garg, CAFor Respondent: Ms. Ashima Neb, Senior DR
Section 143Section 68

been further given to two parties, namely, M/s. Rajesh Projects India Pvt. Ltd. and M/s. Gupta Infrastructure Ltd. for equivalent areas whereas before the Investigation Wing assessee deposed that it has given contract for development of land of 15,99,814 CUM of area for value of Rs.31 ... recording of statement of Shri Deepak Nimesh as to the categoric admission is extracted as under :- In this case information was received from “ Investigation Wing, Gurgaon that during the course of search and survey proceedings on M/s PACL evidences have been found with reference to booking of bogus expenses

M/S. Adidas India Marketing (P) Ltd., Gurgaon vs. ITO, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1431/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Jul 2019AY 2010-11

Bench: Shri Amit Shukla & Shri O.P. Kantassessment Year: 2010-11 M/S. Adidas India Marketing Vs. Income Tax Officer, (P.) Ltd., Ward-1(3), New Delhi 5Th Floor, Unitech Commercial Tower-Ii, Sector- 45, Block-B, Greenwoods City, Gurgaon Pan : Aaaca5313P (Appellant) (Respondent) Appellant By Shri Ajay Vohra, Sr. Adv; Ms. Shaily Gupta, Ca; & Mr. Ramit Katyal, Ca Respondent By Shri Sanjay I. Bara, Cit(Dr)

Section 143(3)Section 144CSection 92Section 92BSection 92C

facts in respect of the issue in dispute are that a survey action under section 133A of the Act was carried out by the Investigation Wing of Income Tax Department, New Delhi on 20/12/2010 at the premise of assessee’s company located at plot 18 Adidas India Marketing