“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

Pushkar Corporation, Ahmedabad vs. The Pr.CIT, Central, Ahmedabad

In the result, we do not find any force in the appeal of the assessee

ITA 356/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad26 Jul 2019AY 2012-13

Bench: Shri Pradip Kumar Kedia & Smt. Madhumita Roy

For Appellant: Shri M. S. Chhajed, A.R

Section 143(3)Section 263

deemed as is assessed by the Stamp Valuation authority for the purpose of payment stamp duty. h. The AO as well as the Investigation Wing has not brought anything on record to prove that on money has changed hands. 6.1 The assessee has also relied upon various judicial pronouncements challenging

Rajendra Kumar Bagmar, Chennai vs. ACIT Non Corp. Circle 6(1), Chennai

In the result, both the appeals of the assessees are treated as partly allowed for statistical purposes

ITA 2650/CHNY/2018[2010-11]Status: DisposedITAT Chennai26 Jul 2019AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.2649 /Chny/2018 ("नधा"रण वष" / Assessment Year: 2010-11) Late Ugama Kavar, Vs The Acit, Rep.By Legal Heir Shri Rajendra Non Corporate Circle 6(1), Kumar Bagmar, Chennai Victor Grace & Co., Spencer Plaza, O-704, 769, Anna Salai, Chennai – 600 002. Pan: Aaipk6224G (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./I.T.A.No.2650 /Chny/2018 ("नधा"रण वष" / Assessment Year: 2010-11) Shri Rajendra Kumar Bagmar, Vs The Acit, Victor Grace & Co., Spencer Non Corporate Circle 6(1), Plaza, O-704, 769, Anna Salai, Chennai Chennai – 600 002. Pan: Aafpb8319Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri M. Abhishek, Ca ""यथ" क" ओर से/Respondent By : Dr.S. Pandian, Jcit

For Appellant: Shri M. Abhishek, CAFor Respondent: Dr.S. Pandian, JCIT

/17-18 dated 29.06.2018, respectively, for the assessment year 2010-11. 2. The above assessees, individuals, filed their return of income. Based on the investigation wing report from Ahmedabad, their returns were re-opened. The Ld.AO found that the transaction of purchase and sale of shares entered into by the respective ... respective cases, as alleged adjustment of profit by way of CCM through M/s. Inventure Growth & Securities Ltd., based on the report of the Departmental Investigation Wing, Ahmedabad. During the year, the appellant, late Ugama Kavar, has traded in Futures through Inventure Growth and Securities Ltd., on nine days

Late Ugama Kavar Legalheir Rajendra Kumar Bagmar, Chennai vs. ACIT Non Corp Circle 6(1), Chennai

In the result, both the appeals of the assessees are treated as partly allowed for statistical purposes

ITA 2649/CHNY/2018[2010-11]Status: DisposedITAT Chennai26 Jul 2019AY 2010-11

For Appellant: Shri M. Abhishek, CAFor Respondent: Dr.S. Pandian, JCIT

Rajendra Ladakchand Jain, Mumbai vs. DCIT, CC -1 (3), Mumbai

The appeal of the assessee is allowed

ITA 2825/MUM/2018[2010-11]Status: DisposedITAT Mumbai26 Jul 2019AY 2010-11

Bench: Shri Ravish Sood & Shri N.K. Pradhan

For Appellant: Shri Rajesh Shah, A.RFor Respondent: Shri Manjunath Swami, CIT D.R

Section 131Section 133ASection 153C

Rajesh Bhanwarlal Jain namely, M/s Nakoda Floor Mills Pvt. Ltd. having its registered office at 9thFlour, Novelty Chamber, Mumbai, was also covered by the Investigation wing, Mumbai under Sec.133A of the Act. The aforesaid premises were found to be inhabited by the assessee i.e Shri Rajesh Ladakchand Jain ... director/partner/proprietor. As regards the claim of the assessee that certain loans had been advanced by him through cheques, it was observed by the investigation wing of the department that such loan entries which were provided by the assessee vide cheques/RTGS were in lieu of receipt of cash as against

Canyon Financial Services Ltd., New Delhi vs. ITO, New Delhi

ITA 461/DEL/2017[2012-13]Status: DisposedITAT Delhi26 Jul 2019AY 2012-13

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

For Appellant: NoneFor Respondent: Ms. Ashima Neb, Senior DR

Section 143Section 153CSection 68

Mohta Building, 4-Bhikaji Cama Place, New Delhi, as a part search operation on M/s Dalmia Group on zs" January, 2012 by the investigation wing, Unit-VI(l), New Delhi. 2. That on the facts and circumstances of the case, the Ld CIT(A) erred in law and facts ... hand are : On the basis of search and seizure operation carried out at the premises of Dalmia Group of cases on 28.01.2012 by the Investigation Wing, Unit-VI (1), New Delhi, certain documents viz. A-3/DB-8 were found and seized belonging to the assessee. On the basis of seized

DCIT, New Delhi vs. M/S. Senorita Enterprises Pvt. Ltd., New Delhi

ITA 5388/DEL/2015[2007-08]Status: DisposedITAT Delhi26 Jul 2019AY 2007-08

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

For Appellant: Sh. Yogesh Jagia, AdvFor Respondent: Sh. Amit Katoch, Sr. DR

Section 131(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 151(2)Section 68

assessment order that the Directorate of Income Tax (Investigation)-I, New Delhi vide its letter dated 19.3.2014 informed the Assessing Officer that Investigation Wing carried out enquiries in the matter of the assessee based upon three STRs in the name of Valiant Agencies, Senorita Enterprises Pvt. Ltd. And Enliven Developers ... reproduced in the assessment order at Page No. 2. On the basis of these STRs and upon further investigation conducted by the Investigation Wing, it was noticed that the Assessee Company had taken share capital of Rs. 465.98 lacs from Investee companies, but identity, genuineness and creditworthiness of the investors

The ITO, Ward-2(3)(8), Surat vs. Shri Yogendraraj U. Singhvi, Surat

In the result, the appeal of the assessee is partly allowed

ITA 79/AHD/2017[2007-08]Status: DisposedITAT Surat25 Jul 2019AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O. P. Meenaआ.अ.सं./I.T.A No.2926/Ahd/2016: िनधा"रण वष"/Assessment Year: 2007-08 Shri Yogendraraj U Singhvi, V. Income Tax Officer, Office No. 103, Ist Floor, H. No. 6/1946-B, Ward- 2(3)(8), Dalagia Street, Mahidharpura Surat Aayakar Bhavan Surat [Pan: Anjps 9745 G] अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.79/Ahd/2017: िनधा"रण वष"/Assessment Year: 2007-08 Income Tax Officer, V. Shri Yogendraraj U Singhvi, Ward- 2(3)(8), Office No. 103, Ist Floor, H. No. 6/1946- Aayakar Bhavan Surat B, Dalagia Street, Mahidharpura Surat [Pan: Anjps 9745 G] अपीलाथ" Appellant ""यथ"/Respondent Shri Prakash Jhunjhunwala, C.A. िनधा"रती क" ओर से Assessee By Shri S.R. Meena, Sr. D.R. राज"व क" ओर से Revenue By 24.07.2019 सुनवाई क" तारीख Date Of Hearing 25.07.2019 उ"ोषणा क" तारीख Date Of Pronouncement

Section 143Section 147

Brief facts as discernible from the orders of lower authorities are that a search and survey operations were carried out by the Investigation Wing, Mumbai in the case of Shri Praveen Kumar Jain and his group on 01.10.2013, which resulted in collection of evidences and other findings, which conclusively proved ... that the Ld.AO has not brought any evidence on records in forming reason to believe. It is well settled principle that just information from investigation wing or statement of one person cannot became reason to believe for reopening, without bringing any independent material evidence on record

Shri Yogendraraj U.Singhvi, Surat vs. The Income Tax Officer, Ward-2(3)(8), Surat

In the result, the appeal of the assessee is partly allowed

ITA 2926/AHD/2016[2007-08]Status: DisposedITAT Surat25 Jul 2019AY 2007-08

Section 143Section 147

Sanjay Kumar Jain, New Delhi vs. ITO Ward - 63(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 825/DEL/2019[2009-10]Status: DisposedITAT Delhi25 Jul 2019AY 2009-10

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

Section 133(6)Section 147Section 153A

fact in confirming addition of Rs. 5,08,116/- being alleged profit from F&O transaction on the basis of information received from Investigation Wing without any independent and judicious application of mind on the said alleged information whereas the appellant has duly substantiated the profit declared ... action has ben taken u/s. 147 of the I.T. Act after completion of assessment u/s. 153A/143(3) on the basis of Report of the Investigation Wing and the Assessing Officer has not conducted any enquiry on the same, therefore, respectively following the decisions of the Tribunal cited (supra), I hold

Atul Bansal, Delhi vs. ACIT, Circle- 47(1), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 1247/DEL/2019[2012-13]Status: DisposedITAT Delhi25 Jul 2019AY 2012-13

Bench: Shri N.K. Billaiya & Shri Laliet Kumar[Assessment Year: 2010-11]

Section 131Section 14Section 143(1)Section 147Section 148Section 151Section 69C

substantiated by the certificate from the Union Bank of India which is placed at page-49 of the paper book. Except for the investigation wing report, there is no other evidence with the AO to demonstrate that the assessee has actually paid a sum of Rs.94 lakhs to Dkrrish builder ... lakhs but has purchased a plot at Chakmangraula, Dist. Dadri, Gautam Budh Nagar. After receiving this reply, no further enquiry was made by the Investigation Wing in respect of alleged payments of Rs.94 lakhs. The AO has emphasized that on the basis of the seized document, there is a clear

Suman Poddar, New Delhi vs. ITO, Ward-39(5), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 1006/DEL/2019[2014-15]Status: DisposedITAT Delhi25 Jul 2019AY 2014-15

Bench: Sh. H. S. Sidhudr. B. R. R. Kumarita No. 1006/Del/2019 : Asstt. Year : 2014-15 Suman Poddar, Vs Income Tax Officer, C/O Raj Kumar & Associates, Ward-39(5), Cas, L-7A (Lgf), South New Delhi-110002 Extension, Part-Ii, New Delhi-110049 (Appellant) (Respondent) Pan No. Aaopp4893N Assessee By : Sh. Raj Kumar Gupta, Ca Revenue By : Ms. Ashima Neb, Sr. Dr Date Of Hearing: 03.07.2019 Date Of Pronouncement: 25.07.2019 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. Raj Kumar Gupta, CAFor Respondent: Ms. Ashima Neb, Sr. DR

Section 10(38)Section 68

through M/s 12.09.2013 Religare Securities.(broker) 6. The ld. AR argued that the decisions have made solely on the report of the Investigation Wing and the statement of the persons recorded during the survey and opportunity of cross examination has not been provided. He further relied on the order ... bogus. The differences of the case of Udit kalra attempted by the Ld. AR does not add any credence to justify the transactions. The Investigation Wing has also conducted enquiries which proved that the assessee is also one of the beneficiaries of the transactions entered by the Companies through multiple

ITO 16(1)(5), Mumbai vs. Realstone Entertainment P.Ltd, Mumbai

ITA 1271/MUM/2017[2009-10]Status: DisposedITAT Mumbai24 Jul 2019AY 2009-10

Bench: Shri Pawan Singh () & Shri N.K. Pradhan () Assessment Year: 2009-10 Income Tax Officer- M/S Realstone 16(1)(5), Room No. Vs. Entertainment Pvt. Ltd. A- 439, 4Th Floor, Aayakar 601, Crystal Palace, Link Bhavan M.K. Road, Road, Malad (W), Mumbai- Mumbai-400020. 400064. Pan No. Aaccr8558F Appellant Respondent C.O. No. 201/Mum/2018 (Ita No. 1271/Mum/2017) Assessment Year: 2009-10 M/S Realstone Income Tax Officer- Entertainment Pvt. Ltd. C/O Vs. 16(1)(5), Room No. 439, Ajay Daga& Co. Cas, 401-A, 4Th Floor, Aayakarbhavan Pearl Arcade, Opp P K M.K. Road, Mumbai- Jewellers, Dawoodbaug 400020. Lane, Off J P Road, Andheri (W), Mumbai-400058. Pan No. Aaccr8558F Appellant Respondent Revenue By : Mr. Chaitanya Anjaria & Mr. Sachidanand Debe, Drs Assessee By : Mr. R.C. Jain, Ar Last Date Of Hearing : 03/05/2019 Date Of Pronouncement : 24/07/2019

For Appellant: Mr. R.C. Jain, ARFor Respondent: Mr. Chaitanya Anjaria &

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

Kolkata and who were involved in giving accommodation entries of various nature to several beneficiaries including the assessee. The information supplied by the Investigation Wing to the Assessing Officer formed a prima facie basis to enable the Assessing Officer to form a belief of income chargeable to tax having escaped ... assessment. The Assessing Officer perused the information supplied by the Investigation Wing and having formed the belief that income chargeable to tax had escaped assessment, could not be stated to have acted mechanically. Further, the mere fact that the assessee had asked for certain M/s Realstone Entertainment

P Mittal Manufacturing Pvt. Ltd., New Delhi vs. ITO, Ward- 19(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 6906/DEL/2018[2010-11]Status: DisposedITAT Delhi23 Jul 2019AY 2010-11

Bench: Shri H.S. Sidhu

For Appellant: Shri Anmol Sinha, Adv. & Sh. AshviniFor Respondent: Shri S.L. Anuragi, Sr. DR

passed by the Revenue Authorities. He stated that the addition in dispute has been made on the basis of the information received from the Investigation Wing, after recording the valid reasons with the approval of the Competent Authority. Therefore, no irregularity has been committed by the AO as well ... 1002/JP/2018 & 1119/JP/2018 M/s. Kota Dall Mill Date of Pronouncement : 31/12/2018. 11.1. Even otherwise, the assessment order is solely based on the report of the Investigation Wing Kolkata which in turn is nothing but the narration of the statements recorded during the investigation and the AO was having in possession

Vinod Kumar Kundanmal (HUF), Chennai vs. ITO Ncw 6(4), Chennai

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

ITA 603/CHNY/2019[2014-15]Status: DisposedITAT Chennai22 Jul 2019AY 2014-15

Bench: Shri N.R.S. Ganesanआयकर अपील सं./Ita No.603/Chny/2019 "नधा"रण वष" / Assessment Year : 2014-15 Shri Vinod Kumar Kundanmal, The Income Tax Officer, No.44/39, E K Agraharam Street, V. Non Corporate Ward - 6(4), Park Town, Chennai - 600 003. Chennai - 600 006. Pan : Aadhv 1841 H (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Padmanabhan, CAFor Respondent: Shri Sanath Kumar Raha, JCIT

Section 10(38)

assessee involved in inflating the shares of the company. Moreover, the copy of the investigation report said to be received from the Investigation Wing of the Department at Kolkata was not furnished to the assessee. On identical circumstances, this Tribunal in the case of Kanhaiyalal & Sons ... Representative also. Admittedly, the Assessing Officer disallowed the claim of the assessees on the basis of the information said to be received from the Investigation Wing of the Department at Kolkata with regard to investment made by the assessees in the penny stock company. It is not in dispute that

Sunil Kumar Surana, Chennai vs. ITO, Ncw-10(4), Chennai

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

ITA 602/CHNY/2019[2010-11]Status: DisposedITAT Chennai22 Jul 2019AY 2010-11

Bench: Shri N.R.S. Ganesanआयकर अपील सं./Ita No.602/Chny/2019 "नधा"रण वष" / Assessment Year : 2010-11

For Appellant: Shri R. Padmanabhan, CAFor Respondent: Shri Sanath Kumar Raha, JCIT

Section 10(38)

Bidam Kawar, Chennai vs. ITO, Ncw-4(5), Chennai

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

ITA 601/CHNY/2019[2010-11]Status: DisposedITAT Chennai22 Jul 2019AY 2010-11

Bench: Shri N.R.S. Ganesanआयकर अपील सं./Ita No.601/Chny/2019 "नधा"रण वष" / Assessment Year : 2010-11 Shri Bidam Kawar, The Income Tax Officer, 13, Chandrappa Mudali Street, V. Non Corporate Ward - 4(5), Sowcarpet, Chennai - 600 079. Chennai - 600 006. Pan : Aagpb 7753 F (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Padmanabhan, CAFor Respondent: Shri Sanath Kumar Raha, JCIT

Section 10(38)

Pinky Jain, Chennai vs. ITO Non Corporate Ward 5(4), Chennai

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

ITA 3116/CHNY/2018[2014-15]Status: DisposedITAT Chennai22 Jul 2019AY 2014-15

Bench: Shri N.R.S. Ganesanआयकर अपील सं./Ita No.3116/Chny/2018 "नधा"रण वष" / Assessment Year : 2014-15

For Appellant: Shri P. Uttamchand Jain, CAFor Respondent: Shri Sanath Kumar Raha, JCIT

Section 10(38)

M/S. Aries Crafts Pvt. Ltd., New Delhi vs. DCIT, New Delhi

ITA 2208/DEL/2015[2010-11]Status: DisposedITAT Delhi22 Jul 2019AY 2010-11

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

For Appellant: Shri V.P. Gupta, AdvocateFor Respondent: Ms. Nidhi Srivastava, CIT DR

which is engaged in providing entries in share capital, loans etc.. On the basis of search and seizure operation carried out by the Investigation Wing of the Income-tax on 15.09.2008, it was found that the assessee company had transferred funds and had given accommodation entries to parties connected

Sheela Daniel, Mumbai vs. ITO 21(2)(4), Mumbai

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

ITA 2811/MUM/2015[2006-07]Status: DisposedITAT Mumbai19 Jul 2019AY 2006-07

Bench: Shri Rajesh Kumar, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.2811/Mum/2015 (निर्धारण वर्ा / Assessment Year: 2006-07) Ms. Sheela Daniel बिधम/ Ito 21(2)(4) 21, Nupur, Near Jewel Bandra (E), Mumbai-51. Vs. Nursing Home, Gulmohar Cross Road No-5, Jvpd Scheme, Mumbai-400049. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aefpd6933C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Bhupendra Shah Revenue By: Shri Chaudhary Arun Kumar Singh (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 18/07/2019 घोषणा की तारीख /Date Of Pronouncement: 19/07/2019 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 09.03.2015 Passed By The Commissioner Of Income Tax (Appeals) -38, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2006- 07. 2. The Assessee Has Raised The Following Grounds: -

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Chaudhary Arun Kumar

Section 143(1)Section 143(3)Section 148Section 234Section 271(1)(c)Section 56(2)(v)

issuance of notice u/s 148 dated 03.03.2014 after recording the reasons mentioned below: - “"In this case, an information was received from Investigation Wing that the assessee had been allotted a flat free of cost by the society (M/s. Greater Bombay Co-operative Housing Society) and the registered agreement was executed

The ITO, Ward-2(3)(7), Surat vs. Shri Dipak Banwarilal Agarwal, Surat

In the result, the appeal of the assessee is partly allowed

ITA 3277/AHD/2016[2007-08]Status: DisposedITAT Surat18 Jul 2019AY 2007-08

Bench: Shri H. S. Sidhu & Shri O. P. Meenaआ.अ.सं./I.T.A No.2932 & 3277/Ahd/2016: िनधा"रणवष"/Assessment Year: 2007-08 1. Shri Dipak Banwarilal Agarwal, V. 1. Income Tax Officer, Ward- 103 Devsagar, Dalgiya Street, 2(3)(7), Mahidarpura Surat Surat 2. Shri Dipak Banwarilal Agarwal, Pan:Afppa6178M 103 Devsagar, Dalgiya Street, Mahidarpura Surat 2. Income Tax Officer, Ward- 2(3)(7), Pan:Afppa6178M Surat अपीलाथ" Appellant ""यथ"/Respondent

Section 143Section 147