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“investigation wing”

ReassessmentSection 147Section 14712,583 judgments

The decision most relied on for investigation wing is PCIT v. RMG Polyvinyl (I) Ltd. (396 ITR 5), cited in 272 judgments on BharatTax.

Leading authorities on investigation wing

PCIT v. RMG Polyvinyl (I) Ltd.
396 ITR 5 · 2017 · High Court
272
citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

109 TTJ 700 (Del) SMC Share Brokers Ltd. v. DCIT
293 ITR 43 · 2007 · High Court
264
citing judgments

Where an assessment order is merely a copy-paste of observations from an investigation wing's appraisal report without independent verification, it is not a valid basis for making additions to income.

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.

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.

Judgments citing investigation wing

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1060/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Nov 2025AY 2016-17

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

269T of the Act. The information was based on the material found during the course of Search and Seizure action conducted on 23.11.2021 by Investigation wing in the case of Radha Mohan Maheshwari (a finance broker) wherein the said information was found. The information so gathered in that search ... section 269T of the Act. The above facts were came to revenue's possession while Search and Seizure action conducted on 23.11.2021 by Investigation wing in the case of Radha Mohan Maheshwari (a finance broker). Based on that information collected in search assessment/ re-assessment was made in the assessee

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1059/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Nov 2025AY 2016-17

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

269T of the Act. The information was based on the material found during the course of Search and Seizure action conducted on 23.11.2021 by Investigation wing in the case of Radha Mohan Maheshwari (a finance broker) wherein the said information was found. The information so gathered in that search ... section 269T of the Act. The above facts were came to revenue's possession while Search and Seizure action conducted on 23.11.2021 by Investigation wing in the case of Radha Mohan Maheshwari (a finance broker). Based on that information collected in search assessment/ re-assessment was made in the assessee

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1058/JPR/2025[2012-13]Status: DisposedITAT Jaipur10 Nov 2025AY 2012-13

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

269T of the Act. The information was based on the material found during the course of Search and Seizure action conducted on 23.11.2021 by Investigation wing in the case of Radha Mohan Maheshwari (a finance broker) wherein the said information was found. The information so gathered in that search ... section 269T of the Act. The above facts were came to revenue's possession while Search and Seizure action conducted on 23.11.2021 by Investigation wing in the case of Radha Mohan Maheshwari (a finance broker). Based on that information collected in search assessment/ re-assessment was made in the assessee

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1057/JPR/2025[2012-13]Status: DisposedITAT Jaipur10 Nov 2025AY 2012-13

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

269T of the Act. The information was based on the material found during the course of Search and Seizure action conducted on 23.11.2021 by Investigation wing in the case of Radha Mohan Maheshwari (a finance broker) wherein the said information was found. The information so gathered in that search ... section 269T of the Act. The above facts were came to revenue's possession while Search and Seizure action conducted on 23.11.2021 by Investigation wing in the case of Radha Mohan Maheshwari (a finance broker). Based on that information collected in search assessment/ re-assessment was made in the assessee

Income Tax Officer, Parwanoo vs. Saboo Tor Private Limited, Kala Amb. Distt Sirmour

In the result, the appeal stand dismissed

ITA 786/CHANDI/2025[2011-12]Status: DisposedITAT Chandigarh10 Nov 2025AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.786/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2011-12) Ito M/S Saboo Tor Private Limited बनाम/ Sector-2 Trilokpur Road, Kala Amb Parwanoo-173220 Dist: Sirmour-173030 Vs. Himachal Pradesh Himachal Pradesh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcs-8995-C (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Sudhir Sehgal (Advocate) – Ld. Ar Revenue By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 27-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 10/11/2025

For Appellant: Shri Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 143(3)Section 148

Having heard rival submissions, the appeal is disposed-off as under. 2. The assessee’s case was reopened pursuant to receipt of information from investigation wing stating that during search on Indiabulls group on 13-07-2016, it transpired that those group entities indulged in booking bogus purchases in their ... could be drawn only because the confirmation from the customer was not furnished. As against this, Ld. AO merely relied upon information received from investigation wing and did not carry out any independent examination or verification of the transaction. No cash trail in support of accommodation entry has been established

Narendra Khimji Savla, Mumbai vs. ITO Ward 6(1)(1), Mumbai

In the result, the appeal is allowed for statistical

ITA 4197/MUM/2025[2013-14]Status: DisposedITAT Mumbai10 Nov 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Himanshu Gandhi,ARFor Respondent: Shri Leyaqat Ali Aafaqui (Sr. AR)
Section 132Section 132(4)Section 147Section 148Section 149Section 151Section 234ASection 271(1)(c)

relevant documentary evidences with respect to the above transaction. Considering the facts and circumstances and in view of the findings recorded by the Investigation Wing, it was clear that tangible material in the instant case existed in the form of information received from Investigation Wing. In view of the above ... merits of the addition, it was stated by him that considering the facts and circumstances and in view of the findings recorded by the Investigation Wing, it was clear that tangible material in Page | 6 ITA No. 4197/Mum/2025 Α.Υ. 2013-14 Narendra Khimji Savla, Mumbai the instant case existed

DCIT(CC)-8(3), Mumbai vs. Girraj Kishor Agrawal, Mumbai

In the result, the grouds of appea raised by the revenue are

ITA 3769/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Nov 2025AY 2011-12

Bench: Shri Pawan Singh& Smt. Renu Jauhri(Physical Hearing)

Section 143(1)Section 143(3)Section 148Section 151Section 254(1)Section 68

furnished purchase bills, bank statement and other details to substantiate the claim of long term capital gain. The assessing officer recorded the report of Investigation Wing in para 3 and 4 of his order. In para 5 of assessment order, the assessing officer recorded that assessee purchased 29000 share ... assessee indulged in sale and purchase of scrip of Shreenath which is proved a penny stock company by the investigation carried out by the Investigation Wing of department. The assessing officer has given detail background of penny scrip companies’ modus operandi and method of price rigging. The assessee has shown

ACIT, Mumbai vs. Romil Diam, Mumbai

In the result, above appeal of the Revenue is allowed

ITA 2167/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Nov 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Sanjay R. Parikh, CAFor Respondent: Shri Annavaran Kosuri, (Sr. AR)
Section 143(3)Section 68Section 74

ignoring the fact that action of the Assessing officer was based on the information of the DGIT (Investigation Wing) Mumbai, who has proved beyond doubt with the evidences & recorded statements that all these Three paper concerns/entities were managed controlled by Mr. Bhanwarlal & Rajendra Jain Groups with a sole purpose ... return declaring total income of Rs. 6,49,860/-.The case was reopened u/s 147 of the Act based on certain information by the Investigation wing of the Department that she availed entries of bogus purchases from a few parties i.e Rare Diamond, KALASH,AADI etc. aggregating

ACIT-19(3), Mumbai, Piramal Chamber vs. Romil Diam, Mumbai

In the result, above appeal of the Revenue is allowed

ITA 2166/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Nov 2025AY 2010-11

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Sanjay R. Parikh, CAFor Respondent: Shri Annavaran Kosuri, (Sr. AR)
Section 143(3)Section 68Section 74

addition of Rs.2,14,04,724 by ignoring the fact that action of the Assessing officer was based on the information of the DGIT (Investigation Wing) Mumbai, who has proved beyond doubt with the evidences & recorded statements that all these Three paper concerns/entities were managed controlled by Mr. Bhanwarlal & Rajendra ... return declaring total income of Rs. 6,49,860/-.The case was reopened u/s 147 of the Act based on certain information by the Investigation wing of the Department that she availed entries of bogus purchases from a few parties i.e Rare Diamond, KALASH,AADI etc. aggregating to Rs.2

Rajesh Agarwal, Delhi vs. Income Tax Officer, Delhi

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

ITA 1277/DEL/2025[2015-2016]Status: DisposedITAT Delhi07 Nov 2025AY 2015-2016

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarrajesh Agarwal, Vs. Ito, Ward 61(2), C/O Shri Kapil Goel, New Delhi. F-26/124, Sector 7, Rohini, Delhi – 110 085. (Pan : Ahapk5921B) (Appellant) (Respondent) Assessee By : Shri Kapil Goel, Advocate Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 03.11.2025 Date Of Order : 07.11.2025 O R D E R Per S.Rifaur Rahman, Am: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax Appeals-29, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.10.2024 For Assessment Year 2015-16 Raising Following Grounds Of Appeal :- “(A) That Ld Cit-A Vide Impugned Order Passed Order U/S 250 Dated 21.10.2024 Erred In Not Quashing The Impugned Assessment Order Passed U/S 143(3)/144 Dated 22.12.2017 Which Is Ex Facie Passed Without Any Application Of Mind, In Most Arbitrary Manner As Evident From Fact That Sec 143(3) & Sec 144 Are Used Interchangeably.

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 132Section 143(3)Section 144Section 250

Kumar and Deepak Aggarwal who were claimed to be involved in bogus transactions. Since assessee has filed Power of Attorney to represent them before Investigation Wing, the Assessing Officer has estimated the income considering the share transactions carried on by the third parties to whom assessee was representing, the addition

DCIT, Central Circle-1, Noida vs. Raghav Bahl, Noida

In the result, Appeals filed by the Assessee in ITA

ITA 995/DEL/2023[2015-16]Status: DisposedITAT Delhi07 Nov 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 120Section 143(2)Section 143(3)Section 153ASection 153BSection 153D

other than the person searched from the searched premises as was referred u/s 153A of the Act was to be handed over by the investigation wing to the AO of such other person (searched) and then that AO of the searched person shall handover the same ... Central Range, the ld. ACIT is involved in the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing and is involved with the Ld. AO from time to time while issuing various questionnaires. The ld. ACIT in Central Range also examined the seized

Raghav Bahl, New Delhi vs. DCIT, Central Circle-1, Noida

In the result, Appeals filed by the Assessee in ITA

ITA 742/DEL/2023[2016-17]Status: DisposedITAT Delhi07 Nov 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 120Section 143(2)Section 143(3)Section 153ASection 153BSection 153D

other than the person searched from the searched premises as was referred u/s 153A of the Act was to be handed over by the investigation wing to the AO of such other person (searched) and then that AO of the searched person shall handover the same ... Central Range, the ld. ACIT is involved in the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing and is involved with the Ld. AO from time to time while issuing various questionnaires. The ld. ACIT in Central Range also examined the seized

Raghav Bahl, New Delhi vs. DCIT, Central Circle-1, Noida

In the result, Appeals filed by the Assessee in ITA

ITA 741/DEL/2023[2015-16]Status: DisposedITAT Delhi07 Nov 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 120Section 143(2)Section 143(3)Section 153ASection 153BSection 153D

other than the person searched from the searched premises as was referred u/s 153A of the Act was to be handed over by the investigation wing to the AO of such other person (searched) and then that AO of the searched person shall handover the same ... Central Range, the ld. ACIT is involved in the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing and is involved with the Ld. AO from time to time while issuing various questionnaires. The ld. ACIT in Central Range also examined the seized

Raghav Bahl, New Delhi vs. DCIT, Central Circle-1, Noida

In the result, Appeals filed by the Assessee in ITA

ITA 740/DEL/2023[2014-15]Status: DisposedITAT Delhi07 Nov 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 120Section 143(2)Section 143(3)Section 153ASection 153BSection 153D

other than the person searched from the searched premises as was referred u/s 153A of the Act was to be handed over by the investigation wing to the AO of such other person (searched) and then that AO of the searched person shall handover the same ... Central Range, the ld. ACIT is involved in the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing and is involved with the Ld. AO from time to time while issuing various questionnaires. The ld. ACIT in Central Range also examined the seized

Raghav Bahl, New Delhi vs. DCIT, Central Circle-1, Noida

In the result, Appeals filed by the Assessee in ITA

ITA 739/DEL/2023[2013-14]Status: DisposedITAT Delhi07 Nov 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 120Section 143(2)Section 143(3)Section 153ASection 153BSection 153D

other than the person searched from the searched premises as was referred u/s 153A of the Act was to be handed over by the investigation wing to the AO of such other person (searched) and then that AO of the searched person shall handover the same ... Central Range, the ld. ACIT is involved in the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing and is involved with the Ld. AO from time to time while issuing various questionnaires. The ld. ACIT in Central Range also examined the seized

Deputy Commissioner of Income Tax, Delhi vs. Indian Hydro Electric Power Pvt. Ltd., Delhi

ITA 3907/DEL/2023[2019-20]Status: DisposedITAT Delhi07 Nov 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 132Section 132(4)Section 153ASection 250Section 68Section 69C

claimed loss of INR 11,05,11,469/-. A search & seizure operation u/s 132 of the Act was conducted by Investigation Wing on 07.04.2019 on Moser Baer group and office premises of the assessee was also search as assessee is one of the company of that group. Thereafter, notice ... evidentiary value. 8. Ld. CIT DR further submits that additions were not only based on the statements of aforesaid two persons, but the Investigation Wing had made independent inquiries with respect to the companies from whom loans were received by the assessee wherein it was found that those companies were

Deputy Commissioner of Income Tax, Central Circle-20, Delhi vs. Indian Hydro Electric Power Pvt. Ltd., Delhi

ITA 3906/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Nov 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 132Section 132(4)Section 153ASection 250Section 68Section 69C

claimed loss of INR 11,05,11,469/-. A search & seizure operation u/s 132 of the Act was conducted by Investigation Wing on 07.04.2019 on Moser Baer group and office premises of the assessee was also search as assessee is one of the company of that group. Thereafter, notice ... evidentiary value. 8. Ld. CIT DR further submits that additions were not only based on the statements of aforesaid two persons, but the Investigation Wing had made independent inquiries with respect to the companies from whom loans were received by the assessee wherein it was found that those companies were

ACIT, C R Building vs. Gurpreet Kochar, K.G.Marg

In the result, Revenue’s appeal ITA No

ITA 3465/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Nov 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2017-18

Section 132Section 143(3)Section 69Section 69A

case, in brief, as emerging from the records, are that a search & seizure operation u/s 132 of the Act was conducted by the Investigation Wing of the Department on 22.10.2016 in Sukhija Group of cases along with other cases at various residential and business premises including the premises ... submitted that the search and seizure operation u/s 132 of the Act was conducted by the investigation wing on 22.10.2016 on "Sukhija Group of cases" including the assessee. 4. It is submitted that the assessee was living in the joint family and during the course of search jewellery weighing

Axiomatic Itech Pvt. Ltd., Ahmedabad vs. The ITO, Ward-1(1)(4), Ahmedabad

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

ITA 191/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divatia, ARFor Respondent: Shri C Dharani Nath, Sr. DR
Section 133(6)Section 143(1)Section 250Section 35(1)Section 35(1)(ii)

also referred to an information letter from the CIT (Exemptions), Ahmedabad, which conveyed that a survey had been carried out by the Investigation Wing, Kolkata, at the premises of Matrivani Institute, revealing that it was engaged in facilitating bogus donations under section 35(1)(ii). It was found that donors ... relied upon cogent material viz. the CBDT notification rescinding the approval of Matrivani Institute with retrospective effect and the findings of the Investigation Wing confirming that the institute was involved in issuing bogus donation receipts. The CIT(A) also observed that despite several opportunities, the assessee failed to substantiate

Income Tax Officer 1(1)(3), Ahmedabad vs. Sureshkumar Bhikalal Thakker, Ahmedabad

In the result, the appeal of the Department is allowed

ITA 1593/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2015-16

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Dipen Shukhadia, ARFor Respondent: Shri Ravindra, Sr. DR
Section 10(38)Section 147Section 69A

case was reopened under section 147 of the Income-tax Act, 1961 (the “Act”), on the basis of information received from the Investigation Wing, Ahmedabad, that the assessee was one of the beneficiaries of accommodation entries in respect of bogus Long-Term Capital Gains (LTCG) arising from transactions in penny