← All Phrases

“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

DCIT, Circle-1, Siliguri vs. Vaishnodevi Buildcon Private Limited, Siliguri

In the result, both the appeals of the of the Revenue are dismissed

ITA 1383/KOL/2025[2018-19]Status: DisposedITAT Kolkata06 Nov 2025AY 2018-19

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Soumitra Choudhury &For Respondent: Shri S.B. Chakraborthy, DR
Section 143(3)Section 144BSection 147Section 148Section 148(1)Section 148ASection 68

assessee was reopened u/s 147 of the Act by issuing notice u/s 148(1) of the Act on 24.03.2022, after AO received information from investigation wing through insight portal that assessee has received loan from M/s Shivaangan Merchandise Pvt. Ltd. According to the ld. AO, the information received, the said ... carried out any independent enquiry on the evidences filed by the assessee and only relied on the report of investigation wing. We have perused the order passed by the ld. CIT (A) and find that the ld. CIT (A) has allowed the appeal of the assessee after discussing the facts

DCIT, Circle-1, Siliguri vs. Vaishnodevi Buildcon Private Limited, Siliguri

In the result, both the appeals of the of the Revenue are dismissed

ITA 1382/KOL/2025[2018-19]Status: DisposedITAT Kolkata06 Nov 2025AY 2018-19

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Soumitra Choudhury &For Respondent: Shri S.B. Chakraborthy, DR
Section 143(3)Section 144BSection 147Section 148Section 148(1)Section 148ASection 68

assessee was reopened u/s 147 of the Act by issuing notice u/s 148(1) of the Act on 24.03.2022, after AO received information from investigation wing through insight portal that assessee has received loan from M/s Shivaangan Merchandise Pvt. Ltd. According to the ld. AO, the information received, the said ... carried out any independent enquiry on the evidences filed by the assessee and only relied on the report of investigation wing. We have perused the order passed by the ld. CIT (A) and find that the ld. CIT (A) has allowed the appeal of the assessee after discussing the facts

Greenline Ecofab Pvt. Ltd., Surat vs. ACIT, Circle 1(1)(2), Surat

In the result, the appeal of the assessee is allowed

ITA 1373/SRT/2024[2012-13]Status: DisposedITAT Surat05 Nov 2025AY 2012-13

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1373/Srt/2024 Assessment Year: (2012-13) (Physical Hearing) Greenline Ecofab Pvt. Ltd. Assistant Commissioner Of बनाम/ 406, Jeevan Deep, Opp. Sub- Income-Tax, Circle- 1(1)(2), Vs. Jail, Ring Road, Surat-395 002 Surat, 1St Floor, Aaykar Bhawan, Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaecg 2881 N (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 143(3)Section 147Section 148Section 234ASection 250Section 68

issue of notice u/s 148 of the Act dated 30.03.2019. The reasons for re-opening was the information received by the AO from the Investigating Wing, Kolkata, that the assessee received accommodation entry of Rs.15,00,000/- from M/s Avtar Trading Co. (Proprietor: Deep Bhattacharya) through various shell companies ... obtaining approval of the Ld.PCIT u/s 151 of the Act. He submitted that the re-opening was based on specific information received from the Investigation Wing of Kolkata. Copy of the reasons recorded by the AO was provided to the assessee and its objection was duly disposed

Dy. Commissioner of Income Tax, Central Circle-1, Ludhiana vs. M/S Jamna Dass Nikkamal Jain Saraf Pvt. Ltd., Ludhiana

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

ITA 628/CHANDI/2025[2022-23]Status: HeardITAT Chandigarh04 Nov 2025AY 2022-23

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 143(3)Section 145(3)Section 148BSection 151Section 69A

provides a leeway to both the ld. AO as well as JCIT to even ignore the conclusion drawn in the Appraisal Report by the Investigation Wing and take a different stand in the assessment proceedings. 13.2 The argument of the Revenue that JCIT is involved in the search assessment right

Jamna Dass Nikkamal Jain Saraf Private Limited, Ludhiana vs. The Deputy Commissioner of Income Tax Central Circle 1, Ludhiana

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

ITA 403/CHANDI/2025[2022-2023]Status: HeardITAT Chandigarh04 Nov 2025AY 2022-2023

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 143(3)Section 145(3)Section 148BSection 151Section 69A

provides a leeway to both the ld. AO as well as JCIT to even ignore the conclusion drawn in the Appraisal Report by the Investigation Wing and take a different stand in the assessment proceedings. 13.2 The argument of the Revenue that JCIT is involved in the search assessment right

Deputy Commissioner of Income -Tax Central Circle-1(1), Ahmedabad, Gujarat vs. Bhaveshkumar Girishbhai Bhandari, Ahmedabad, Gujarat

ITA 979/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2018-19
Section 132Section 143(1)Section 143(3)Section 144BSection 147Section 250Section 37(1)Section 68

addition of Rs. 21,36,579/- for disallowance of certain expenses under section 37(1) of the Act. Later, a report from the Investigation Wing, Ahmedabad was received by the Assessing Officer (AO), which contained information regarding accommodation entries and manipulation of penny stock transactions allegedly carried ... submissions of the assessee, the CIT(Appeals) held that the AO had made the addition solely on the basis of generalized findings of the Investigation Wing without any independent verification or corroborative evidence. It was observed that the AO had not brought on record any material to prove that

Deputy Commissioner of Income -Tax Central Circle-1(1), Ahmedabad, Gujarat vs. Bhaveshkumar Girishbhai Bhandari, Ahmedabad, Gujarat

In the result, the appeal of the Department is allowed and the order of

ITA 978/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2016-17
For Respondent: Shri Abhijit Sr.DR
Section 132Section 143(1)Section 143(3)Section 144BSection 147Section 250Section 37(1)Section 68

addition of Rs.21,36,579/- for disallowance of certain expenses under section 37(1) of the Act. Later, a report from the Investigation Wing, Ahmedabad was received by the Assessing Officer (AO), which contained information regarding accommodation entries and manipulation of penny stock transactions allegedly carried out by the Kushal ... submissions of the assessee, the CIT(Appeals) held that the AO had made the addition solely on the basis of generalized findings of the Investigation Wing without any independent verification or corroborative evidence. It was observed that the AO had not brought on record any material to prove that

Deputy Commissioner of Income -Tax Central Circle-1(1), Ahmedabad, Gujarat vs. Girishkumar Amratlal Bhandari HUF, Himatnagar, Gujarat

In the result, the appeal of the Department is allowed and the order of

ITA 977/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2018-19
For Respondent: Shri Abhijit Sr.DR
Section 132Section 143(1)Section 143(3)Section 144BSection 147Section 250Section 37(1)Section 68

addition of Rs.21,36,579/- for disallowance of certain expenses under section 37(1) of the Act. Later, a report from the Investigation Wing, Ahmedabad was received by the Assessing Officer (AO), which contained information regarding accommodation entries and manipulation of penny stock transactions allegedly carried out by the Kushal ... submissions of the assessee, the CIT(Appeals) held that the AO had made the addition solely on the basis of generalized findings of the Investigation Wing without any independent verification or corroborative evidence. It was observed that the AO had not brought on record any material to prove that

Gitaben Dineshbhai Patel, Ahmedabad vs. ITO Ward 5(3)(1), Ahmedabad

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

ITA 717/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Anil Kshatriya, AdvocateFor Respondent: Shri Abhijit, Sr. DR
Section 10(38)Section 144BSection 147Section 148Section 68

assessee had earned the impugned capital gain from sale of shares of Kushal Tradelink Ltd., which, according to the information received from the Investigation Wing, was one of the penny stock companies used for providing accommodation entries of bogus capital gains and losses. The Assessing Officer relied upon the findings ... Investigation Wing and SEBI’s order on price manipulation of the said company’s shares to hold that the assessee had converted her unaccounted income into legitimate form by claiming the said LTCG as exempt. Accordingly, the entire gain of Rs. 93,92,789/- was added to the assessee

Navneetbhai Ramanlal Patel, Ahmedabad vs. The ITO, Ward-2(1)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 223/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.223/Ahd/2025 िनधा"रण वष" /Assessment Year : 2016-17 Navneetbhai Ramanlal Patel The Ito बनाम/ 19, New Ambica Park Society Ward-2(1)(2) V/S. D Cabin Sabarmati Ahmedabad – 380 051 Ahmedabad – 380 019 "थायी लेखा सं./Pan: Aqzpp 2479 D (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Hiren Trivedi, Ar Revenue By : Shri C. Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/09/2025 घोषणा की तारीख /Date Of Pronouncement: 04/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 14/10/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2016-2017. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Hiren Trivedi, ARFor Respondent: Shri C. Dharani Nath, Sr.DR
Section 143(1)Section 144Section 147Section 148Section 234ASection 250Section 271(1)(c)

income of Rs. 2,55,960/-. The return was processed under section 143(1) of the Act. Subsequently, based on information received from the Investigation Wing regarding the assessee’s involvement in transactions of sale and purchase of shares through a stockbroker, M/s. Marfatia Stock Broking Pvt. Ltd., which were ... noted that the assessee had failed to explain the alleged trading loss or provide any corroborative evidence to rebut the information received from the Investigation Wing, and therefore the AO’s action in treating the loss as fictitious was in accordance with law. The CIT(Appeals) relying on the principle

Alco Suppliers Private Limited, Guwahati vs. ITO, Ward 1(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 933/KOL/2025[2022-2023]Status: DisposedITAT Kolkata04 Nov 2025AY 2022-2023

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Alco Suppliers Private Limited M/S Alco Suppliers (P) Ltd. National Faceless Assessment C/O Subhas Agarwal & Center, Associates (Advocate) Siddha Assessment Unit, Income Tax Vs. Gibson, 1, Gibson Lane, Suit Department, New Delhi No.213, 2Nd Floor, Kolkata- 700069, West Bengal (Appellant) (Respondent) Pan No. Aacca5182E Assessee By : Shri Siddarth Agarwal, Ar Revenue By : Shri Raja Sengupta, Dr Date Of Hearing: 04.09.2025 Date Of Pronouncement: 04.11.2025

For Appellant: Shri Siddarth Agarwal, ARFor Respondent: Shri Raja Sengupta, DR
Section 143(2)Section 143(3)Section 144BSection 68

treated as unexplained cash credit in the hands of the assessee which was duly replied by the assessee. Finally, the ld. AO held that investigation wing has provided information that the private limited companies of whose unlisted shares were sold by the assessee company were shell company which was further

M/S. Rukmini Educational Charitable Trust, Bengaluru vs. Principal Commissioner of Income Tax, Central, Bengaluru

ITA 2108/BANG/2024[2019-2020]Status: DisposedITAT Bangalore04 Nov 2025AY 2019-2020

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Vijaya Mehta, CA & Shri Avinash Mallya, AdvocateFor Respondent: Smt. Srinandini Das CIT(DR)(ITAT), Bengaluru
Section 12Section 12ASection 132Section 132(4)Section 143(3)

four years and submitted that not a single inquiry, information sought from assessee, was carried out. Even the figures mentioned by the Investigation wing are reproduced as it is. Thus, there is no application of mind and therefore there cannot be any" satisfaction' of AO. It is a borrowed satisfaction

Saloni Girrajkishor Agrawal, Mumbai vs. Income Tax Officer, Ward - 25(1)(1), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 3234/MUM/2024[2013-14]Status: DisposedITAT Mumbai04 Nov 2025AY 2013-14

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankarsaloni Girrajkishor Agrawal V/S. Income Tax Officer, Ward 1601/1602, Green Acre, बनाम –25(1)(1),Kautilya Bhavan, Lokhandwala Complex, Andheri Bandra Kurla Complex, (West), Mumbai – 400 053, Bandra (East), Mumbai – Maharashtra 400051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Anupa1692D Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Prakash Jhunjhunwala, ARFor Respondent: Shri Swapnil Choudhary, (Sr. DR)
Section 10(38)Section 143(3)Section 148Section 68

shares of Esaar India Ltd.(‘EIL’) by holding that it was penny stock. In this regard, the AO relied upon various information from the Investigation wing of the Department which suggested that the sale transaction of these shares was a bogus transaction being part of huge penny scam and accordingly ... Exit Providers/ counter parties at an exorbitant rates. It is pointed out by the AO that many of the purchasers had been named in Investigation wing reports. As per the said report, exit providers had purposely bought the shares of aforesaid penny stock company ESL at huge values

DCIT, Central Circle-28, New Delhi vs. Bajrang Lal Aggarwal, New Delhi

In the result, appeal filed by the Revenue is dismissed

ITA 1247/DEL/2025[2015-16]Status: DisposedITAT Delhi04 Nov 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No.1247/Del/2025 िनधा"रणवष"/Assessment Year:2015-16 बनाम Dcit, Bajrang Lal Aggarwal Central Circle-28, Vs. Room No.327, E-2, Ara Centre, New Delhi. Jhandewalan Extension, New Delhi. Pan No.Aagpa0771J अपीलाथ" Appellant ""यथ"/Respondent

Section 10(38)Section 132Section 132ASection 143(1)Section 143(2)Section 153ASection 68

case are that a search and seizure operation u/s 132A was conducted on Stonex Group of cases on 19.12.2019 by Unit-2(2) of Investigation Wing, New Delhi. A warrant of authorization for search was issued in the name of appellant at locker No. 679 held in HDFC Bank, West

Gayatri Ankit Chona, Mumbai vs. ITO 23(1)(1), Mumbai

In the result, the appeal stands allowed for statistical

ITA 5170/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Nov 2025AY 2018-19

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankar

For Appellant: Shri Saurabh Soparkar – Sr. Advocate(virtually appear)For Respondent: Shri Arun Kanti Datta (CIT DR)
Section 10(35)Section 133ASection 144BSection 147Section 148Section 69A

received from a mutual Fund. Later, her case was reopened u/s 148 of the Act on the basis of information received from the Investigation wing of the Department that the exemption claimed was not allowable. A Survey operation u/s 133A of the Act was conducted by the Wing

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 38/ALLD/2023[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL ALLAHABAD BENCH, ALLAHABAD BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 37/ALLD/2023[2006-07]Status: DisposedITAT Allahabad31 Oct 2025AY 2006-07

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL ALLAHABAD BENCH, ALLAHABAD BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 36/ALLD/2023[2005-06]Status: DisposedITAT Allahabad31 Oct 2025AY 2005-06

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL ALLAHABAD BENCH, ALLAHABAD BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 127/ALLD/2023[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL ALLAHABAD BENCH, ALLAHABAD BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 126/ALLD/2023[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL ALLAHABAD BENCH, ALLAHABAD BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT