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“investigation wing”

ReassessmentSection 147Section 14712,584 judgments

The decision most relied on for investigation wing is Sarthak Securities Co. Pvt. Ltd. v. ITO (329 ITR 110), cited in 217 judgments on BharatTax.

Leading authorities on investigation wing

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

ITO, 19(3) (4) Mumbai v. Shamim M Bharwani
69 Taxmann.com 65 · 2016 · Reported
142
citing judgments

Long Term Capital Gains (LTCG) from penny stock transactions are liable to be treated as bogus and added back under Section 68 as unexplained cash credits, especially when evidence suggests the involvement of entry operators providing accommodation entries.

1. Harikishan S. Virmani v. DCIT
394 ITR 146 · 2017 · High Court
97
citing judgments

Reassessment proceedings under section 147 cannot be initiated by the Assessing Officer based on borrowed satisfaction, vague information from the Investigation Wing, or incorrect jurisdictional facts without independent application of mind. Reopening beyond four years from the end of the relevant assessment year, especially where an original assessment was completed under section 143(3), requires specific conditions relating to the assessee's failure to disclose material facts.

PCIT v. M/s. Kesoram Industries 57
417 ITR 334 · 2019 · High Court
96
citing judgments

An assessment completed under Section 143(3) cannot be reopened after four years solely based on third-party information or opinions, such as from an Investigation Wing, without the Assessing Officer applying their own independent mind to the material and having new, independent material on record.

ITO v. Purushottam Das Bangur
224 ITR 362 · 1997 · Supreme Court
90
citing judgments

Information received from the investigation wing constitutes valid 'reason to believe' for initiating reassessment proceedings under Sections 147/148, provided the Assessing Officer applies their mind to the material and does not act mechanically. Prompt issuance of a notice based on such information does not automatically imply a lack of due diligence or borrowed satisfaction.

AGR Investment v. Additional Commissioner
197 Taxmann 177 · 2011 · High Court
81
citing judgments

A reassessment under Section 147/148 is valid if initiated based on specific, non-vague information, even from an investigation wing, provided the Assessing Officer applies independent mind to form a 'reason to believe' that income has escaped assessment.

56 (Guj.) (para 6) v. Aaspas Multimedia Ltd. v. Dy. CIT
83 Taxmann.com 82 · 2017 · High Court
78
citing judgments

Information received from the Investigation Wing, identifying the assessee as a beneficiary of accommodation entries through share application from a third party, constitutes valid tangible material and 'reasons to believe' for initiating reassessment proceedings under Section 147 of the Income Tax Act.

Aradhna Estate Pvt. Ltd. v. DCIT
91 Taxmann.com 119 · 2018 · High Court
56
citing judgments

The Assessing Officer is justified in reopening assessment proceedings based on information received from the Investigation Wing, even when recording findings also rely on documents already on record, provided all procedural requirements for reassessment are met.

Judgments citing investigation wing

L.K. Prahladka, HUF, Kolkata vs. ITO, Ward - 35(3), Kolkata

ITA 317/KOL/2018[2014-15]Status: DisposedITAT Kolkata16 Jan 2019AY 2014-15

Bench: "ी जे. सुधाकर रे"डी, लेखा सद"य एवं/And "ी ऐ. ट". वक", "यायीक सद"य) [Before Shri J. Sudhakar Reddy, Am & Shri A. T. Varkey, Jm]

Section 10(38)Section 68

with the assessee’s claim of LTCG and exemption thereof claimed by the assessee. The AO taking note of the study conducted by the Investigation Wing of the department about 84 BSE listed penny stock discusses from para 4 of assessment order, the general observations/study/modus operandi from pages ... resulted in fetching exorbitant and L.K. Prahladka,HUF, AYs 2014-15 unrealistic considerations in the scheme of amalgamation. The AO takes note of the Investigation Wing’s study report of a company M/s. Vindhywassini Niketan Pvt. Ltd. which had dealt with the shares of M/s. KAFL scrips and the statement

Ppn Properties Pvt. Ltd., Delhi vs. ITO, Ward- 19(2), New Delhi

In the result, the appeals of the assessee are allowed

ITA 3060/DEL/2018[2009-10]Status: DisposedITAT Delhi16 Jan 2019AY 2009-10

Bench: Shri N.S. Sainiassessment Year: 2009-10

Section 131Section 143(3)Section 147Section 148

Income Tax Vs. Meenakshi Overseas Pvt. Ltd. reported in 395 ITR 677 where it was held as under :- “that while the report of the Investigation Wing might have constituted material on the basis of which the Assessing Officer formed the reasons to believe, the process of arriving at such satisfaction ... section 147 of the Act recording the following as reasons to believe:- M/s. Prashant Agencies Pvt. Ltd. Dated : 03.06.2016 “Information has been received from Investigation wing Ahmedabad vide letter F No ADIT(Inv.) I (BVAHD/CCM/Dissemination-mail 15-16 dt. 11.03.2016 forwarding of survey report in respect of client code modification. Vide

Prashant Agencies Pvt. Ltd., Delhi vs. ITO, Ward- 19(3), New Delhi

In the result, the appeals of the assessee are allowed

ITA 3059/DEL/2018[2009-10]Status: DisposedITAT Delhi16 Jan 2019AY 2009-10

Bench: Shri N.S. Sainiassessment Year: 2009-10

Section 131Section 143(3)Section 147Section 148

Income Tax Vs. Meenakshi Overseas Pvt. Ltd. reported in 395 ITR 677 where it was held as under :- “that while the report of the Investigation Wing might have constituted material on the basis of which the Assessing Officer formed the reasons to believe, the process of arriving at such satisfaction ... section 147 of the Act recording the following as reasons to believe:- M/s. Prashant Agencies Pvt. Ltd. Dated : 03.06.2016 “Information has been received from Investigation wing Ahmedabad vide letter F No ADIT(Inv.) I (BVAHD/CCM/Dissemination-mail 15-16 dt. 11.03.2016 forwarding of survey report in respect of client code modification. Vide

M/S Holy Faith International Pvt. Ltd, Jalandhar vs. The Dy Commissioner of Income Tax, Jalandhar

In the result, the appeal of the assessee is allowed

ITA 181/ASR/2017[2008-09]Status: DisposedITAT Amritsar15 Jan 2019AY 2008-09

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.181/Asr./2017 : Asstt. Year : 2008-09 M/S Holy Faith International Vs Deputy Commissioner Of Income Tax, Pvt. Ltd., Mbd House, Central Circle-Ii, Railway Road, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Aaach6111J Assessee By : Sh. Sudhir Sehgal, Adv. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 07.01.2019 Date Of Pronouncement : 15.01.2019 Order Per N. K. Saini: This Is An Appeal By The Assessee Against The Order Dated 20.03.2017 Of Ld. Cit(A)-I, Jalandhar. 2. Following Grounds Have Been Raised In This Appeal: “1. That The Worthy Commissioner Of Income Tax (A)-1, Jalandhar Has Erred In Dismissing The Appeal Filed By The Assessee. 2. That The Ld. Cit(A) Has Erred In Confirming The Contention Of The Assessing Officer In Reopening The Case U/S 148 Of The Income Tax Act And, Thus, Framing Of Assessment U/S 147 R.W.S.143(3)/153C At An Income Of Rs. 4,95,13,441/- Against The Returned Income Of Rs. 4,63,33,441/-. 3. That The Ld. Cit(A) Has Erred In Not Considering That There Was No Reason To Believe That The Income Of The

For Appellant: Sh. Sudhir Sehgal, AdvFor Respondent: Sh. Bhawani Shankar, DR
Section 131Section 132Section 147Section 148Section 153C

with regard to the unsecured loan was noticed. (ii) Reasons recorded by the Ld. AO is merely based on the information received from the investigation wing of the department without any independent application of mind. (iii) In the statement of Sanjay Chaudhary, he has only discussed the bogus entries given ... provided by every concern under it is bogus as no investigation with respect to the same has ever been carried out either by the investigation wing or the income tax department itself. Moreover, the concerned person has never pointed out the name of the assessee while being investigated

Sanjeev Jain, Saharanpur vs. ITO, Saharanpur

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

ITA 3381/DEL/2017[2013-14]Status: DisposedITAT Delhi15 Jan 2019AY 2013-14

Bench: Sh. R.K. Pand & Ms. Suchitra Kambleassessment Year: 2013-14

Section 10(38)

statement recorded during survey action was reproduced by the Assessing Officer in the body of the Assessment Order. He also issued commission to the investigation wing, Thane to examine some of the buyers of the scrip to ascertain whether these entities had the required sources to buy the scrip ... elaborate enquiries made from the bankers of the assessee company, company allotting the shares and other shareholders, SEBI and the report of the investigation wing etc came to the conclusion that the amount of Rs.2,36,97,101/- represents unexplained cash credit to be taxed

Satish Kumar, Faridabad vs. ITO, Ward- 2(3), Faridabad

In the result, appeal of assessee is allowed

ITA 3586/DEL/2018[2008-09]Status: DisposedITAT Delhi14 Jan 2019AY 2008-09

Bench: Shri H.S. Sidhua.Y. 2008-09

For Appellant: Sh. Somil Aggarwal, AdvFor Respondent: Sh. S.L. Anuragi, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

/147 was completed on 21.3.2016 at an assessed income fo Rs. 45,21,010/-. AO on going through the information received from Investigation Wing, found that the assessee has made payment of Rs. 1,83,43,517/- to M/s Maa Durga Trading Company on account of accommodation entries provided

Shree Sai City Promoters and Developers Pvt. Ltd., Delhi vs. Pr.CIT- 8, New Delhi

In the result ITA No. 2841/Del/2017 is dismissed

ITA 6905/DEL/2017[2007-08]Status: DisposedITAT Delhi14 Jan 2019AY 2007-08

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishishri Sai City Promoters & Developers Vs. Pr. Cit,8 Pvt Ltd, New Delhi H. No. 25 Block & Pockets C-3, Sector- 11, Rohini, Delhi Pan: Aajcs1878A (Appellant) (Respondent)

For Appellant: Shri S. Krishnan, CAFor Respondent: Shri S.S. Rana, CIT DR
Section 147Section 263

finding of the Id CIT that said order was passed without making enquiries and presumption of Id CIT that seized documents forwarded by investigation wing has not been considered/verified by the Id assessing officer before passing the assessment order and accordingly order under section 263 passed by Id CIT needs ... accepted from M/s Victory Software Pvt Ltd after conducting due enquiry on the basis of the information received from the Investigation Wing of the department. 2.1 That on the facts and circumstances of the case and in law, the Pr. CIT erred in exercising jurisdiction u/s 263 by setting aside

Sse Commodities Pvt. Ltd., New Delhi vs. Pr. CIT- 8, New Delhi

In the result ITA No. 2841/Del/2017 is dismissed

ITA 2841/DEL/2017[2010-11]Status: DisposedITAT Delhi14 Jan 2019AY 2010-11

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishishri Sai City Promoters & Developers Vs. Pr. Cit,8 Pvt Ltd, New Delhi H. No. 25 Block & Pockets C-3, Sector- 11, Rohini, Delhi Pan: Aajcs1878A (Appellant) (Respondent)

For Appellant: Shri S. Krishnan, CAFor Respondent: Shri S.S. Rana, CIT DR
Section 147Section 263

finding of the Id CIT that said order was passed without making enquiries and presumption of Id CIT that seized documents forwarded by investigation wing has not been considered/verified by the Id assessing officer before passing the assessment order and accordingly order under section 263 passed by Id CIT needs ... accepted from M/s Victory Software Pvt Ltd after conducting due enquiry on the basis of the information received from the Investigation Wing of the department. 2.1 That on the facts and circumstances of the case and in law, the Pr. CIT erred in exercising jurisdiction u/s 263 by setting aside

M/S. Snb Enterprises Pvt. Ltd., New Delhi vs. Pr. CIT- 8, New Delhi

In the result ITA No. 2841/Del/2017 is dismissed

ITA 2544/DEL/2017[2008-09]Status: DisposedITAT Delhi14 Jan 2019AY 2008-09

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishishri Sai City Promoters & Developers Vs. Pr. Cit,8 Pvt Ltd, New Delhi H. No. 25 Block & Pockets C-3, Sector- 11, Rohini, Delhi Pan: Aajcs1878A (Appellant) (Respondent)

For Appellant: Shri S. Krishnan, CAFor Respondent: Shri S.S. Rana, CIT DR
Section 147Section 263

finding of the Id CIT that said order was passed without making enquiries and presumption of Id CIT that seized documents forwarded by investigation wing has not been considered/verified by the Id assessing officer before passing the assessment order and accordingly order under section 263 passed by Id CIT needs ... accepted from M/s Victory Software Pvt Ltd after conducting due enquiry on the basis of the information received from the Investigation Wing of the department. 2.1 That on the facts and circumstances of the case and in law, the Pr. CIT erred in exercising jurisdiction u/s 263 by setting aside

Surya Irrigation Pvt. Ltd., New Delhi vs. Pr. CIT- 8, New Delhi

In the result ITA No. 2841/Del/2017 is dismissed

ITA 2182/DEL/2017[2010-11]Status: DisposedITAT Delhi14 Jan 2019AY 2010-11

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishishri Sai City Promoters & Developers Vs. Pr. Cit,8 Pvt Ltd, New Delhi H. No. 25 Block & Pockets C-3, Sector- 11, Rohini, Delhi Pan: Aajcs1878A (Appellant) (Respondent)

For Appellant: Shri S. Krishnan, CAFor Respondent: Shri S.S. Rana, CIT DR
Section 147Section 263

finding of the Id CIT that said order was passed without making enquiries and presumption of Id CIT that seized documents forwarded by investigation wing has not been considered/verified by the Id assessing officer before passing the assessment order and accordingly order under section 263 passed by Id CIT needs ... accepted from M/s Victory Software Pvt Ltd after conducting due enquiry on the basis of the information received from the Investigation Wing of the department. 2.1 That on the facts and circumstances of the case and in law, the Pr. CIT erred in exercising jurisdiction u/s 263 by setting aside

Santoshsingh Hukumsingh Karnawat, Surat vs. The Income Tax Officer, Ward-2(3)(8), Surat

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

ITA 23/AHD/2017[2012-13]Status: DisposedITAT Surat11 Jan 2019AY 2012-13

Bench: Smt. Diva Singh & Shri O.P.Meenaआ.अ.सं./I.T.A No.23 /Ahd/2017 िनधा"रण वष"/A.Y.:2012-13 Shri Santosh Singh Hukum Singh Vs. Income Tax Officer, Karnawat, Prop. Shilpa Exports, 402, Ward- 2(3)(8) Surat Parmukh Darshan Apartment, Rampara Main Road Opp. Patidar Bhawan Mahidharpura, Surat - 395 003. [Pan: Arapk 9181 B] अपीलाथ" Appellant ""यथ"/Respondent

Section 132(4)Section 133(6)Section 143

provided accommodation entries to various parties in respect of bogus purchases/ sales through his benami concerns. It was noticed from the report of Investigation Wing, Mumbai that the assessee has received accommodation entries of Rs.43,83,431/- from Euro Diam and Rs.67,77,719/- Little Diam aggregating to Rs.1 ... stated that he has floated various dummy concerns who are providing accommodation entries. The AO observed that investigation made by Investigation Wing, Mumbai has also revealed that actual importers of diamonds imports part of their diamond requirements through benami entities operated by the Shri Bhanwarlal M. Jain and family

M/S. Alpesh Babubhai Panchal, Surat vs. The Income Tax Officer, Ward-2(3)(1), Surat

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

ITA 2078/AHD/2016[2007-08]Status: DisposedITAT Surat11 Jan 2019AY 2007-08

Bench: Smt.Diva Singh & Shri O.P.Meenaआ.अ.सं./I.T.A. No.2078/Ahd/2016 "नधा"रणवष"/Assessment Year : 2007-08 Alpesh Babubhai Panchal, Shop Vs. The Income Tax Officer, No.3, Hojiwala Shopping Center, Ward 2 (3) (1), Majura Sachin Udhyognagar, Surat-394230 Gate, Surat. [Pan: Aqtpp 1775 A] अपीलाथ" Appellant ""यथ"/Respondent

Section 131Section 147Section 148

Plot no. 274, Village: Pardi Kande, Tal: Choryasi by executing a “Sathakhat” for a Rs.10.51 lakhs. The A.O has received this information from the investigation wing. The A.O noticed that as per as registered deed of purchase dated 13.02.2008, the assessee has executed the deed for a consideration

Dy. Commissioner of Income Tax (Central)-1, Indore vs. M/S Pumarth Commodities Pvt. Ltd. Indore, Indore

In the result appeal of the revenue is dismissed

ITA 455/IND/2017[2013-14]Status: DisposedITAT Indore11 Jan 2019AY 2013-14

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2013-14 Deputy Commissioner Of M/S. Pumarth Income Tax (Central)-1 Vs. Commodities Pvt. Ltd, Indore 5/5A, Navratan Bagh, Opp. Geeta Bhawan Square, Behind Vishesh Hospital, Indore (Appellant) (Respondent ) Pan No.Aadcp5381K Revenue By Smt. Ashima Gupta, Cit Assessee By S/Shri Sumit Nema, Sr.Adv & Gagan Tiwari, Adv. Date Of Hearing 10.01.2019 Date Of Pronouncement 11.01.2019 O R D E R

Section 132Section 142(1)Section 143(2)Section 143(3)Section 153A

amounts recorded are precise to the last rupee. 4.3.1 In the written submissions filed by the group before the Investigation Wing during post search inquiries and in the reply given to the questionnaire issued by the Assessing Officer, this seized paper was explained as a "rough document" prepared

Deputy Commissioner of Income Tax, Central Circle, Kota vs. M/S Baran Roller Flour Mills Pvt. Ltd., Kota

ITA 1207/JPR/2018[2011-12]Status: DisposedITAT Jaipur11 Jan 2019AY 2011-12
For Appellant: Shri Vijay Goyal (CA)For Respondent: Shri Varinder Mehta (CIT) fu/kZkfjrh dh vksj ls@
Section 14ASection 68

cash credit on the basis of the report of the 4 ITA No. 1206(4)/JP/2018 M/s. Baran Roller Flour Mills Pvt. Ltd., Kota. Investigation Wing Kolkata. The AO treated these companies as Shell company and held that these companies are controlled by Shri Amit Kedia, & Shri Alok Harlalka ... were found to be bogus entry providers by the Investigation Wing Kolkata. On appeal, the ld. CIT (A) has deleted the addition made by the AO by considering the fact that the AO has made the disallowance merely on the basis of information received from Investigation Wing Kolkata and without

Deputy Commissioner of Income Tax, Central Circle, Kota vs. M/S Baran Roller Flour Mills Pvt. Ltd., Kota

ITA 1206/JPR/2018[2010-11]Status: DisposedITAT Jaipur11 Jan 2019AY 2010-11
For Appellant: Shri Vijay Goyal (CA)For Respondent: Shri Varinder Mehta (CIT) fu/kZkfjrh dh vksj ls@
Section 14ASection 68

cash credit on the basis of the report of the 4 ITA No. 1206(4)/JP/2018 M/s. Baran Roller Flour Mills Pvt. Ltd., Kota. Investigation Wing Kolkata. The AO treated these companies as Shell company and held that these companies are controlled by Shri Amit Kedia, & Shri Alok Harlalka ... were found to be bogus entry providers by the Investigation Wing Kolkata. On appeal, the ld. CIT (A) has deleted the addition made by the AO by considering the fact that the AO has made the disallowance merely on the basis of information received from Investigation Wing Kolkata and without

Marks Consolidated Business Ltd., New Delhi vs. ITO, Ward-6(2), New Delhi

In the result, the Appeal filed by the Assessee stands allowed

ITA 7312/DEL/2018[2003-04]Status: DisposedITAT Delhi11 Jan 2019AY 2003-04

Bench: Shri H.S. Sidhu & Shri Prashant Maharishiassessment Year : 2003-04 Marks Consolidated Vs. Ito, Ward 6(2), Business Ltd., New Delhi 1497, Bhardwaj Bhawan, Wazir Nagar, Kotla , New Delhi (Pan: Aaacm8113H)

For Appellant: Sh. Mushtaq Ahmed Mir, CAFor Respondent: Ms. Rinku Singh, Sr. DR
Section 144Section 147Section 148Section 151Section 253(3)Section 68

assessee has taken after paying unaccounted cash to the accommodation entry giver, who is a known entry operator as per the report of the Investigation Wing. In view of these facts, the alleged transaction is not the bonafide one. Therefore, I have reason to believe that an Income

Bhim Sain Jain, New Delhi vs. ITO, Ward-1(2), Faridabad

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

ITA 5576/DEL/2018[2014-15]Status: DisposedITAT Delhi11 Jan 2019AY 2014-15

Bench: Shri R.K. Pandaassessment Year: 2014-15 Bhim Sain Jain, Vs. Ito, C/O Kapil Goel, Advocate, Ward-1(2), F-26/124, Sector-7, Faridabad. Rohini. Pan: Abupj6954B (Appellant) (Respondent) Assessee By : Shri Kapil Goel, Advocate Revenue By : Shri P.S. Thuingaleng, Sr. Dr Date Of Hearing : 11.12.2018 Date Of Pronouncement : 11.01.2019 Order This Appeal By The Assessee Is Directed Against The Order Dated 29Th June, 2018 Of The Cit(A), Faridabad, Relating To Assessment Year 2014-15. 2. Although A Number Of Grounds Have Been Raised By The Assessee, These All Relate To The Order Of The Cit(A) In Sustaining The Addition Of Rs.23,70,761/- Made By The Assessing Officer Treating The Long-Term Capital Gain Arising From Sale Of Shares As Income From Undisclosed Sources U/S 68 Of The It Act, 1961. 3. The Facts Of The Case, In Brief, Are That The Assessee Is An Individual & Filed His Return Of Income On 29Th September, 2014 Declaring Total Income Of Rs.17,85,350/-. The Assessee Derives Income From A Proprietary Concern M/S Gomti Food Products.

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri P.S. Thuingaleng, Sr. DR
Section 10(38)Section 68

assessee strongly challenged the order of the CIT(A). Relying on various decisions, he submitted that there was no material from the Investigation Wing of the Department that the assessee is a beneficiary of some entries. It is also not the allegation of the Department that it is a penny

Dilwara Leasing & Investment Ltd., Delhi vs. ITO, Ward-7(3), New Delhi

In the result, the Appeal filed by the Assessee

ITA 3927/DEL/2018[2009-10]Status: DisposedITAT Delhi11 Jan 2019AY 2009-10

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

For Appellant: Sh. Kapil Goel, AdvFor Respondent: Sh. S.L. Anuragi, Sr. DR
Section 143(2)Section 147Section 148

order passed by the AO u/s. 147/143(3) without appreciating that “rubber stamp” reasons in present case are based on unconfronted “Appraisal Report” of investigation wing and are without independent application of mind. 1.2 That on the facts and in the circumstances of the case ... order passed by Ld AO u/s 147/143(3) without appreciating that material referred in reasons has not been confronted to assessee namely report of investigation wing Ahmedabad, broker surveyed u/sl33A, statement of broker surveyed and material found from survey and connection of that broker with the assessee, lack of which

Ashok Kumar Bothra & Sons, New Delhi vs. ITO, Ward- 36(4), New Delhi

In the result, the Appeal filed by the Assessee stands allowed

ITA 3260/DEL/2018[2009-10]Status: DisposedITAT Delhi11 Jan 2019AY 2009-10

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

For Appellant: Ms. Himani Agarwal, CAFor Respondent: Sh. S.L. Anuragi, Sr. DR
Section 148Section 271(1)

arranged. A perusal of the reasons recorded by the AO clearly show that the AO has simply acted upon the information received from the Investigation Wing and did not apply his own mind to the said information. Being aggrieved the assessee carried the matter

Smt. Dropadi Kalra, Indore vs. The DCIT (Central-I), Indore

In the result, the appeals filed by different assessees in ITA Nos

ITA 97/IND/2017[2009-10]Status: DisposedITAT Indore10 Jan 2019AY 2009-10

Bench: Shri Kul Bharat & Shri Manish Borad

Section 153ASection 271(1)(c)Section 271A

precaution to safeguard from future litigation/penal actions. The said additional income was admitted during the course of search itself u/s 132(4) before Investigation Wing. The appellant has submitted that no incriminating documents/entries were found during the course of the search. 3.3. It is seen that the appellant ... instant casae a statement was given on the date of search disclosing additional income which was reiterated in the letter filed before the investigation wing. In the details of the surrender made by the appellant before the Investigation Wing only the details of the disclosure have been given