“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

Futuristic Sales Pvt. Ltd., New Delhi vs. Prcit (Central), Gurugram

In the result, the appeal filed by the assessee in ITA No

ITA 1043/DEL/2019[2009-10]Status: DisposedITAT Delhi12 Jun 2019AY 2009-10

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava[A.Y 2009-10] M/S Futuristic Sales [P] Ltd Vs. The Pr. C.I.T Flat No. 97, Sfs, First Floor Central Ashok Vihar, Phase – Iv Gurgaon New Delhi Pan No: Aaacf 6597 N [Appellant] [Respondent]

For Appellant: Shri Gautam Jain, AdvFor Respondent: Ms. Nidhi Srivastava, CIT-DR

Section 132Section 143(1)Section 148Section 263

obtained certain documents from the assessee company which have neither been analysed nor enquiries were carried out in the light of findings of the Investigation Wing. The A.O. has not verified the new addresses of the shell companies supplied by the assessee either through the Inspector or by issuing commission ... behest of the assessee company mechanically without probing into the affairs of the shell companies in light of the findings of the Investigation Wing. Further, on perusal of the ITRs and financial statements of the j investor companies, these appeared to be merely paper/shell companies which were showing negligible income

M/S. Gujarat Agrochem P. Ltd, Mumbai vs. ACIT RG 9(3)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 2224/MUM/2019[2014-15]Status: DisposedITAT Mumbai11 Jun 2019AY 2014-15

Bench: Shri Pawan Singh & Shri M. Balaganeshm/S Gujarat Agrochem Pvt. Ltd. Acit-9(3)(2), 601, Express Chambers, Aayakar Bhavan, Vs. Vi Floor, No.72, Andheri Kurla M.K. Road, Road, Andheri (E), Mumbai-400020 (Now Unit No.505, Atrium-2, (Kanakia), Andheri Kurla Road, Near Hotel Courtyard Marriot, Andheri (E), Mumbai. Pan: Aabcg1228L Appellant Respondent Appellant By : Shri G. Baskar (Advocate) Respondent By : Shri Satish Rajore (Sr. Dr) Date Of Hearing : 11.06.2019 Date Of Pronouncement : 11.06.2019 Order Under Section 254(1)Of Income Tax Act

For Appellant: Shri G. Baskar (Advocate)For Respondent: Shri Satish Rajore (Sr. DR)

Section 143(3)Section 234BSection 254(1)Section 35Section 35(1)(ii)

Representative (DR) for the revenue supported the order of lower authorities. The ld. DR for the revenue submits that a survey was conducted by Investigation Wing, Kolkata, wherein it was revealed that the Institution to which the assessee has made donation was indulging in issuing bogus receipt ... recommendation of Investigation Wing, the approval of the Institution was withdrawn. Once the approval of the institution is withdrawn the assessee is not entitled for weighted deduction under section 35(1) (ii). 6. We have considered the rival submission of the parties and have gone through the orders of authorities

ACIT-32(3), Mumbai vs. Shri Satyendra Kumar Goyal, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 5562/MUM/2017[2012-13]Status: DisposedITAT Mumbai11 Jun 2019AY 2012-13

Bench: Shri Pawan Singh () & Shri N.K. Pradhan () Assessment Year: 2012-13 Asstt. Commissioner Of Shri Satyendra Kumar Income Tax-32(3), Mumbai Goyal, 1702, Pranay Nagar Vs. Room No. 108, 1St Floor, Society, Ram Mnadirextn Bldg. No. C-11, Road, Vazira Naka, Borivali Pratyakshakarbhavan, (W), Mumbai-400092. Bandrakurla Complex, Bandra (E), Mumbai- 400051. Pan No. Aaepg3578R Appellant Respondent Revenue By : Mr. Satish Chandra Rajore, Dr Assessee By : Mr. Vimal Punmiya, Ar Date Of Hearing : 13/03/2019 Date Of Pronouncement: 11/06/2019

For Appellant: Mr. Vimal Punmiya, ARFor Respondent: Mr. Satish Chandra Rajore, DR

Section 132Section 143(3)Section 68

loan from the group concerns controlled by Bhanwarlal Jain as such the AO’s finding and reliance placed on the investigation made by the investigation wing was right. iv. On the facts and in the circumstances of the case the finding of Ld. CIT(A) that the assessee has proved ... During the course of search and seizure action u/s 132 of the Act in the case of Bhanwarlal Jain Group, carried out by the Investigation Wing of the Income Tax Department, Mumbai on 03.10.2013, it was found out that the above group used to provide accommodation entries of bogus unsecured

Shantilal G. Jain, Mumbai vs. ITO WD 19(3)(3), Mumbai

In the result the ground No

ITA 3117/MUM/2017[2009-10]Status: DisposedITAT Mumbai11 Jun 2019AY 2009-10

Bench: Shri Pawan Singh & Shri M. Balaganeshshri Shantilal G. Jain, Ito Ward-19(3)(3), 122, 4Th Floor, Kika Street, Room No. 202, Vs. Gulalwadi, Matru Mandir, Tardeo Road, Mumbai-400004. Mumbai-400007 Pan: Acwpj0062D Appellant Respondent Appellant By : Ms. Dinkle Hariya (C.A) Respondent By : Shri Satish Rajore (Sr. Dr) Date Of Hearing : 11.06.2019 Date Of Pronouncement : 11.06.2019 Order Under Section 254(1)Of Income Tax Act

For Appellant: Ms. Dinkle hariya (C.A)For Respondent: Shri Satish Rajore (Sr. DR)

Section 143(2)Section 143(3)Section 145Section 147Section 148Section 254(1)

conducted enquiry which conclusively proved that the parties were engaged in providing accommodation entries. The parties were issuing bills without delivery of any goods. Investigation Wing of Income Tax Department also conducted the enquiries against such hawala parties. The assessee has adopted modus operandi to reduce the true profits ... other hand, the ld. DR for the Revenue supported the orders of authorities below. The ld. DR for the Revenue argued that the Investigation Wing of the Income-tax Department made full-fledged enquiry. The parties from whom the assessee has shown the purchases are bogus Hawala dealers. The hawala

Shri Nagendra Choudhary, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

In the result, appeal of the assessee is allowed

ITA 611/JPR/2018[2014-15]Status: DisposedITAT Jaipur10 Jun 2019AY 2014-15

Bench: The Tribunal. Only When The Assessee Enquired About

For Appellant: Shri S.L. Jain (Advocate) &For Respondent: Shri Rajendra Jha (Addl. CIT)

Section 271A

taken place between the assessee and other party. Even the receipts in respect of these payments were not found or detected by the Investigation Wing. Thus the mere entry of out go in the seized material would not constitute undisclosed income as defined in explanation to section 271AAB

Raakhi Agarwal, New Delhi vs. ITO, Ward- 52(1), New Delhi

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

ITA 1170/DEL/2018[2009-10]Status: DisposedITAT Delhi10 Jun 2019AY 2009-10

Bench: Sh. R. K. Pandaassessment Year: 2009-10

Section 133Section 133(6)Section 148Section 68Section 69B

reassessment proceedings. It was argued that the Assessing Officer has reopened the assessment on the basis of the report of the DDIT (Investigation Wing), Kolkata and there was no independent application of mind or reference to any material. It was argued that the reasons recorded are vague, indefinite and contradictory ... implies that the assessee had denied purchase of shares of Blue Print Securities Ltd., whereas the AO had received the information from the Investigation Wing that the assessee had entered into transaction related to purchase and sale of shares of this company which is nothing but a paper company

M/S. Sparco Engineering Pvt. Ltd vs. Deputy Commissioner of Income-Tax

In the result, the appeal of assessee is allowed

ITA 1545/PUN/2015[2006-07]Status: DisposedITAT Pune07 Jun 2019AY 2006-07

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

For Appellant: Shri Kishore PhadkeFor Respondent: Shri Sanjeev Ghei

Section 143(3)Section 148

considered together. 3 4. Before us, Ld.A.R. submitted that the reasons for re-opening of the assessment was on the basis of Report of Investigation Wing wherein it was noted that during the course of search proceedings, evidence was found to the effect that assessee company was generating unaccounted cash ... being a quasi judicial authority is expected to arrive at a subjective satisfaction independently on an objective criteria. While the report of the Investigation Wing might constitute the material on the basis of which he forms the reasons to believe the process of arriving at such satisfaction cannot

Naresh Fibres Limited, Mumbai vs. Income Tax Officer 10(3)(1), Mumbai

In the result, appeal filed by the assessee for assessment year 2013-2014

ITA 7431/MUM/2017[2009-10]Status: DisposedITAT Mumbai07 Jun 2019AY 2009-10

Bench: Shri Shamim Yahya (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2009-10 M/S Naresh Fibres Ltd., The Income Tax Officer- Dham Industrial Premises, 10(3)(1), Marol Maroshi Road, Aaykar Bhavan, M.K. Road, Andheri (East), Vs. Mumbai - 400020 Mumbai - 400059 Pan: Aaacn1892L (Appellant) (Respondent) Assessee By : None Revenue By : Shri Satish Chandra Rajore (Dr) Date Of Hearing: 18/03/2019 Date Of Pronouncement: 07/06/2019

For Appellant: NoneFor Respondent: Shri Satish Chandra Rajore (DR)

Section 131Section 133(6)Section 143Section 147Section 148Section 64

income to the tune of Rs. 54,89,271/- has escaped assessment. Information regarding bogus transaction was received Assessment Year: 2013-14 from the Investigation Wing of the Department and the said information was based on the search and seizure conducted u/s 64 of Maharashtra Value Added ... unable to substantiate its purchases from the claim suppliers who had already established hawala dealers by the Sales Tax Department (Government of Maharashtra) and Investigation Wing of the Assessment Year: 2013-14 Income Tax Department. The suppliers were neither produced during the assessment proceedings nor during appellate proceedings when opportunity

Mannat Hospitality (P) Ltd., Delhi vs. ITO, Ward- 16(2), New Delhi

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

ITA 7348/DEL/2018[2009-10]Status: DisposedITAT Delhi07 Jun 2019AY 2009-10

Bench: Sh. R. K. Panda & Sh. Kuldip Singhassessment Year: 2009-10 Mannat Hospitality (P) Ltd. Income Tax Officer 325, Jagirit Enclave, Vs Ward – 16 (2) Delhi-110092 New Delhi Pan No.Aagcm0506Q (Appellant) (Respondent) Appellant By Sh. Repudaman Thakur, Ca Respondent By Ms. Rinku Singh, Sr Dr Date Of Hearing: 11/03/2019 Date Of Pronouncement: 07/06/2019 Order

Section 132Section 68

operation under section 132 which was conducted at the residential and business premises of Shri Surendra Kumar Jain and Shri Virendra Jain by the Investigation Wing, New Delhi which resulted in seizure of a large number of incriminating documents. During the search and post search investigation it was established that ... cheque details and money of middle men instrumental in managing the entries for the beneficiaries, i.e., the assessee. 3. As per information provided by investigation wing, the Assessing Officer noted that the assessee has obtained accommodation entries amounting to Rs.56,00,000/- from S. K. Jain group of companies

Namah Shivaya Marketing (P) Ltd., New Delhi vs. ITO, Ward- 17(3), New Delhi

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

ITA 7456/DEL/2017[2008-09]Status: DisposedITAT Delhi07 Jun 2019AY 2008-09

Bench: Shri R.K.Panda

For Appellant: : Sh. Mukul Gupta, C.AFor Respondent: Sh. Amit Jain, Sr.D.R

Section 143(1)Section 147Section 148Section 68

Income Tax Act, 1961 (the Act) on 05th June,2009. Subsequently the Assessing Officer (AO) received information from the Investigation Wing of the Department that the assessee has ITA No.7456/Del/2017 AY:2008-09 M/s Namah Shivaya Marketing (P) Ltd. Vs. ITO received accommodation entry of Rs.30 lakhs in the garb ... proceedings are concerned, he submitted that the AO without independent application of mind has mechanically acted on the basis of information received from the Investigation Wing which were obtained behind the back of the assessee and no opportunity of cross examination was given. He submitted that S.148 notice was issued

Anil Kumar Shaw (HUF), Hooghly vs. ITO, Ward - 24(1), Hooghly

ITA 2411/KOL/2018[2015-16]Status: DisposedITAT Kolkata04 Jun 2019AY 2015-16

Bench: Shri A. T. Varkey, Jm]

Section 10(38)Section 68

assessee claimed exemption u/s 10(38) of the Act of Rs.13,66,366/-. However, the AO relying on the report of the Investigation Wing, Kolkata and an order by SEBI alleged that the claim of assessee of exempt income (LTCG) was bogus in nature. The AO further alleged that ... evidence against the assessee, much less to speak of direct evidence. 5 Anil Kumar Shaw-HUF., AY 2015-16 The enquiry by the Investigation Wing and/or the statements of several persons recorded by the Investigation Wing in connection with the alleged bogus transactions in the shares of KAFL also

DCIT, Central Circle - 2(1), Kolkata vs. M/S. Kakrania Properties Pvt. Ltd., Kolkata

In the result, the both appeals of Revenue are dismissed and cross objections of Assessee are also dismissed being infructuous

ITA 2144/KOL/2017[2009-10]Status: DisposedITAT Kolkata04 Jun 2019AY 2009-10

Bench: Shri A.T. Varkey, J.M. & Dr.A.L.Saini, A.M.) Asstt. Year : 2009-10 Dcit, C.C -2(1), Kolkata Vs M/S. Kakrania Properties Pvt. Ltd Pan: Aadck 6121C ( Department ) (Respondent) C.O No. 91/Kol/2017 [Ita No. 2144/Kol/2017 A.Y : 2009-10] M/S. Kankaria Properties Pvt. Ltd Vs Dcit, C.C -2(1), Kolkata Pan: Aadck 6121C ( Cross Objector ) ( Department ) Asstt. Year : 2009-10 Acit, C.C -2(1), Kolkata Vs M/S. Liza Vincom Pvt. Ltd Pan: Aaacl-5419R Department. (Respondent) C.O No. 90/Kol/2017 [Ita No. 2145/Kol/2017 A.Y : 2009-10] M/S. Liza Vincom Pvt. Ltd Vs Acit, C.C -2(1), Kolkata Pan: Aaacl-5419R ( Cross Objector ) ( Department )

For Appellant: S/Shri R.P. Agarwal, Sr.AdvocateFor Respondent: Shri C.J. Singh, JCIT, ld.Sr.DR

Section 143(3)Section 147Section 148Section 151Section 43(1)(a)Section 68

through which mode the bogus entries were made by the assessee. (3). The reasons recorded does not show, what was the information given by Investigation wing. (4). The date of the information received by the AO has not been spelt out in the reasons recorded. (5). In the reasons recorded ... through which mode the bogus entries were made by the assessee. The reasons recorded does not show, what was the information given by Investigation wing. In the reasons recorded, the Assessing Officer has not mentioned how he came to the conclusion that share allotee companies are paper/jamakharchi companies

Smt Maya Devi Khemka, Bangalore vs. The Income Tax Officer Ward-4(3)(3), Bangalore

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 2539/BANG/2018[2015-16]Status: DisposedITAT Bangalore04 Jun 2019AY 2015-16

Bench: Shri N.V Vasudevan, Vice Presidnet & Shri B.R Baskaranassessment Year : 2015-16

For Appellant: Shri Harish V, AdvocateFor Respondent: Dr. P.V Pradeep Kumar, Addl. CIT (DR)

Section 10(38)

same. 4. At the outset the ld AR submitted that the AO has passed the impugned order on the basis of report received from investigation wing with regard to alleged penny stocks and also by placing reliance on the statements given by certain share brokers. He further submitted that ... further notice that it is the AO who has identified the above said stock as penny stock on the basis of report given by Investigation Wing and also the report of SEBI. The AO has also recorded that the Director of Investigation, Kolkatta has investigated transactions in 84 penny Stock

Jindal Steel & Power Ltd., Hisar vs. Prcit, Gurugram

In the result appeal of the assessee is dismissed

ITA 2902/DEL/2018[2008-09]Status: DisposedITAT Delhi04 Jun 2019AY 2008-09

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishijindal Steel & Power Limited, Vs. Pr. Commissioner Of Income Delhi Road, Hissar, Tax, Haryana, India Gurugram, (Appellant) (Respondent)

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri J K Mishra, CIT DR

Section 143(3)Section 147Section 148Section 14ASection 263Section 263(2)

assessment proceedings without application of mind, such proceedings would be invalid. A.O. in the present case has failed to verify the information received from Investigation Wing. Therefore, it is non-application of mind on the part of the A.O. to record correct facts in the reasons for reopening

DCIT, New Delhi vs. M/S. Bhaijee Portfolio Pvt. Ltd., New Delhi

Appeal is dismissed

ITA 5322/DEL/2015[2007-08]Status: DisposedITAT Delhi04 Jun 2019AY 2007-08

Bench: Shri G. D. Agrawal & Ms Suchitra Kamble

Section 131Section 132Section 143(1)Section 147Section 148Section 68

Insec Pvt. ltd. the accounts were signed by Ms. Ritu Saxena in capacity of Director against whom the department had received specific information from Investigation wing as being receptionist of Sh. Tarun Goyal, who had been proved to be engaged in providing accommodation entries.” C.O No. 10/DEL/2016 “1. That ... same was processed u/s 143(1) on 26.08.2008. A search/survey operation u/s 132/133 A of the Income Tax Act, 1961 was conducted by Investigation Wing of Income Tax Department on 15/09/2008 at the office premises of Shri Tarun Goel. Various incriminating documents were seized and amended. In the present case

Assistant Commissioner of Income Tax, Central Circle-3, Jaipur vs. M/S. Kedia Real Estate LLP, Jaipur

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

ITA 289/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18

For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)

Section 132(1)Section 143(3)Section 153A

right to have a copy of any statement that is used against him by the department. After the survey/search several requests were made to Investigation wing as well as AO to provide the copy of statements recorded by the survey/search party. After the continuous efforts of the assessee group

Deputy Commissioner of Income Tax, Central Circle-3, Jaipur vs. Shri Nirmak Kumar Kedia, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 288/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18

For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)

Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES “A”, JAIPUR Jh jes'k lh

Assistant Commissioner of Income Tax, Central Circle-3, Jaipur vs. Shri Nirmal Kumar Kedia, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 287/JPR/2019[2016-17]Status: DisposedITAT Jaipur03 Jun 2019AY 2016-17

For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)

Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES “A”, JAIPUR Jh jes'k lh

Assistant Commissioner of Income Tax, Central Circle-3, Jaipur vs. Shri Nitin Kedia, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 286/JPR/2019[2015-16]Status: DisposedITAT Jaipur03 Jun 2019AY 2015-16

For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)

Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES “A”, JAIPUR Jh jes'k lh

Nitin Kedia, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

ITA 128/JPR/2019[2015-16]Status: DisposedITAT Jaipur03 Jun 2019AY 2015-16

For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)

Section 132(1)Section 143(3)Section 153A