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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, Jaipur vs. Hem Chand Jain, Jaipur

In the result, appeal of the Revenue is dismissed and Cross Objection of the assessee is allowed

ITA 670/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT &
Section 147Section 148Section 148ASection 151Section 250

fact and in the circumstances of the case and in law, the ld. CIT (A) was justified in ignoring the evidences collected by Investigation Wing of the Department and penal action taken by SEBI against the assessee?] 3. Whether on the fact and in the circumstances of the case ... Delhi. As per the information, during the investigation proceedings in the case of M/s. Ginni Silk Mills Limited it was found by the Investigation Wing that M/s. Ginni Silk Mills Limited is a listed company and the entire shareholding of which is bought by the syndicate to provide accommodation entries

ITO, Ward-4(2)(3), Ahmedabad vs. Maheshwari Sales Corporation, Ahmedabad

In the result, the appeal filed by the Revenue stands dismissed

ITA 1306/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2018-19

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1306/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Ito Maheshwari Sales Corporation बनाम/ Ward-4(2)(3) C-111, Ganesh Meridin V/S. Ahmedabad Nr.Sola Bridge, Sola Ahmedabad-380 058 "थायी लेखा सं./Pan: Aalfm 4917 H (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 01/09/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal By The Revenue Is Directed Against The Order Of The Ld.Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Dated 11/04/2025, Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2018-2019. 2. The Revenue Has Raised The Following Grounds Of Appeal: Ito Vs. Maheshwari Sales Corporation Asst. Year : 2018-19

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Smt. Mamta Singh, Sr.DR
Section 132Section 147Section 250Section 68

furnish transportation bills, challans, entry registers, or other supporting evidence to substantiate the movement of goods. The AO relied upon the findings of the Investigation Wing, Ahmedabad, which had unearthed an accommodation entry racket operated by Kushal Tradelink Ltd. during a search under section 132 of the Act. Since ... before CIT(Appeals), the assessee submitted that the addition made by the Assessing Officer was based solely on suspicion and general findings of the Investigation Wing without any direct evidence linking the assessee to any accommodation entry provider. The assessee contended that the transactions with Kushal Tradelink Ltd. were genuine

Rohit Prakashchandra Shah, Ahmedabad vs. The Income Tax Officer, Ward-1(2)(3), Ahmedabad

In the result, appeal preferred by the assessee is dismissed

ITA 128/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2014-15

Section 147Section 148

Gujarat High Court in the case of Purviben Snehalbhai Panchhigar (101 taxmann.com 393). In that case the Assessing Officer had received information from Investigation wing that the company 'T' was a shell company and shares of said company were basically used for providing bogus claim of long- term or short ... such satisfaction/reason recorded by the “AO of the searched person” was received by the AO of the assessee. Rather the investigation report of the Investigation Wing was uploaded on the Insight Portal of the Department by the Directorate of Systems in a centralized manner and disseminated to all the concerned

The DCIT, Central Circle-2, Vadodara vs. M/S. Sigma Institute of Technology and Engineering, Vadodara

In the result, appeal filed by the Revenue is partly allowed

ITA 197/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2008-09

Bench: the Hon'ble Settlement Commission.

For Appellant: Shri Alpesh Parmar, CIT.DRFor Respondent: Shri Tushar Hemani, Sr. Advocate &
Section 132Section 148Section 250

assessee trust was ITA No.197/Ahd/2020 [DCIT vs. M/s. Sigma Institute Of Technology And Engineering] A.Y. 2008-09 - 15 – found. In its submission before the investigation wing of the Income Tax Department, the assesse accepted the transaction in this account be unaccounted but in reply to show cause notice issued during ... noted that list of other bank accounts of the trustees and related parties with unaccounted transactions was furnished by the assessee before the Investigation Wing. The same are listed at page no.42 to 44 of the assessment order. In response to the explanation sought by the AO, the assessee gave

Rucha Consultancy LLP, Pune vs. ACIT Circle-6(1), Mumbai, Nariman Point

ITA 2359/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Oct 2025AY 2022-23

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 132Section 250Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL

DCIT Central Circle 7 4 Mumbai, Mumbai vs. Indo Count Industries Ltd, Delhi

Appeal stands dismissed

ITA 3854/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 1Section 132Section 143(2)Section 143(3)Section 153ASection 250

information that the Assessee was not involved in any cash sales of FRC. 13. Apart from above, no evidence was found by the Investigation Wing with respect to the alleged cash payment being made by concerns or firms, controlled 11 Indo Count Industrial Ltd, Mumbai. or managed by Mr. Zhahid ... most reliable source of information that the Assessee is not involved in cash sales of FRC and no evidence has been found by the Investigation Wing with respect to the 38 Indo Count Industrial Ltd, Mumbai. alleged cash payment being made by concerns or firms, controlled or managed

DCIT CC 7 4, Mumbai vs. Indo Count Industries Ltd, Delhi

Appeal stands dismissed

ITA 3853/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 Oct 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 1Section 132Section 143(2)Section 143(3)Section 153ASection 250

information that the Assessee was not involved in any cash sales of FRC. 13. Apart from above, no evidence was found by the Investigation Wing with respect to the alleged cash payment being made by concerns or firms, controlled 11 Indo Count Industrial Ltd, Mumbai. or managed by Mr. Zhahid ... most reliable source of information that the Assessee is not involved in cash sales of FRC and no evidence has been found by the Investigation Wing with respect to the 38 Indo Count Industrial Ltd, Mumbai. alleged cash payment being made by concerns or firms, controlled or managed

DCIT Central Circle 7 4 Mumbai, Mumbai vs. Indo Count Industries Ltd, Delhi

Appeal stands dismissed

ITA 3850/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Oct 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 1Section 132Section 143(2)Section 143(3)Section 153ASection 250

information that the Assessee was not involved in any cash sales of FRC. 13. Apart from above, no evidence was found by the Investigation Wing with respect to the alleged cash payment being made by concerns or firms, controlled 11 Indo Count Industrial Ltd, Mumbai. or managed by Mr. Zhahid ... most reliable source of information that the Assessee is not involved in cash sales of FRC and no evidence has been found by the Investigation Wing with respect to the 38 Indo Count Industrial Ltd, Mumbai. alleged cash payment being made by concerns or firms, controlled or managed

DCIT, Central Circle - 7(4), Mumbai vs. Indo Count Industries Ltd, Delhi

Appeal stands dismissed

ITA 3826/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 1Section 132Section 143(2)Section 143(3)Section 153ASection 250

information that the Assessee was not involved in any cash sales of FRC. 13. Apart from above, no evidence was found by the Investigation Wing with respect to the alleged cash payment being made by concerns or firms, controlled 11 Indo Count Industrial Ltd, Mumbai. or managed by Mr. Zhahid ... most reliable source of information that the Assessee is not involved in cash sales of FRC and no evidence has been found by the Investigation Wing with respect to the 38 Indo Count Industrial Ltd, Mumbai. alleged cash payment being made by concerns or firms, controlled or managed

DCIT Central Circle 7 4, Mumbai vs. Indo Count Industries Ltd, Delhi

Appeal stands dismissed

ITA 3824/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Oct 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 1Section 132Section 143(2)Section 143(3)Section 153ASection 250

information that the Assessee was not involved in any cash sales of FRC. 13. Apart from above, no evidence was found by the Investigation Wing with respect to the alleged cash payment being made by concerns or firms, controlled 11 Indo Count Industrial Ltd, Mumbai. or managed by Mr. Zhahid ... most reliable source of information that the Assessee is not involved in cash sales of FRC and no evidence has been found by the Investigation Wing with respect to the 38 Indo Count Industrial Ltd, Mumbai. alleged cash payment being made by concerns or firms, controlled or managed

Jayantika Singh, DCIT Central Circle 7 4 Mumbai, Mumbai vs. Indo Count Industries Ltd, Delhi

Appeal stands dismissed

ITA 3822/MUM/2024[2014-15]Status: DisposedITAT Mumbai30 Oct 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 1Section 132Section 143(2)Section 143(3)Section 153ASection 250

information that the Assessee was not involved in any cash sales of FRC. 13. Apart from above, no evidence was found by the Investigation Wing with respect to the alleged cash payment being made by concerns or firms, controlled 11 Indo Count Industrial Ltd, Mumbai. or managed by Mr. Zhahid ... most reliable source of information that the Assessee is not involved in cash sales of FRC and no evidence has been found by the Investigation Wing with respect to the 38 Indo Count Industrial Ltd, Mumbai. alleged cash payment being made by concerns or firms, controlled or managed

Jayantika Singh DCIT Central Circle 7 4 Mumbai, Mumbai vs. Indo Count Industries Ltd, Delhi

Appeal stands dismissed

ITA 3820/MUM/2024[2016-17]Status: DisposedITAT Mumbai30 Oct 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 1Section 132Section 143(2)Section 143(3)Section 153ASection 250

information that the Assessee was not involved in any cash sales of FRC. 13. Apart from above, no evidence was found by the Investigation Wing with respect to the alleged cash payment being made by concerns or firms, controlled 11 Indo Count Industrial Ltd, Mumbai. or managed by Mr. Zhahid ... most reliable source of information that the Assessee is not involved in cash sales of FRC and no evidence has been found by the Investigation Wing with respect to the 38 Indo Count Industrial Ltd, Mumbai. alleged cash payment being made by concerns or firms, controlled or managed

M/S. Peerless Consultancy Services Pvt. Ltd., New Delhi vs. ACIT, Central Circle-20, Delhi

Appeal is allowed

ITA 5999/DEL/2025[2019-20]Status: DisposedITAT Delhi30 Oct 2025AY 2019-20

Bench: Sh. Satbeer Singh Godaraita No. 5999/Del/2025 : Asstt. Year : 2019-20 M/S Peerless Consultancy Services Vs Acit, Pvt. Ltd., C/O R. C. Rai & Associates, Central Circle-30, 203, Akashdeep Building, 26A, New Delhi Barakhamba Road, New Delhi-110001 (Appellant) (Respondent) Pan No. Aacct0544M Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement: 30.10.2025 Order

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 69A

departmental representative vehemently argues during the course of hearing that the Assessing Officer herein had rightly reopened the assessee’s assessment placed on the investigation wing’s report for the purpose of treating it’s loan amount of Rs.35,00,000/- as unexplained u/s 69A; in 2 Peerless Consultancy Services

Cryptographic It Solutions Private Limited, Delhi vs. DCIT Circle 4(2), C R Building

In the result, appeal of the assessee is allowed for statistical purposes

ITA 4075/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Oct 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh

Section 147Section 148Section 5

4075/Del/2025 Cryptographic IT Solu"ons Pvt. Ltd. F.Y. 2015-16. Since, the assessee has not complied to any notice issued by the Investigation Wing, it is clear that the amount so credited in the bank account of the assessee was held to be unexplained. 5. During assessment proceedings, the assessee

Kajal Batra, Delhi vs. ACIT, Circle-52(1), Delhi

In the result, the appeal of the assessee stands dismissed as above

ITA 2419/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 151Section 68Section 69A

constitute material for reopening and reopening pursuant to such information was held valid. It may be appreciated that if the information received from the investigation wing and the notices issued pursuant to such information the reopening was held valid and get as mentioned in the judicial pronouncement as under

Satish Vishnu Thombare, Income Tax Officer, Ward-1, Ahmednagar vs. Varsha Prafulla Zende, Ahmednagar

In the result, the appeal of the Revenue is dismissed

ITA 1656/PUN/2024[2010-11]Status: DisposedITAT Pune29 Oct 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

For Appellant: Miss Shivani Shah (Virtual)For Respondent: Shri Akhilesh Srivastva
Section 132(1)Section 147Section 148Section 151Section 68

reasons:- "All information has been received from the ACIT, Central Circle 2(3), Ahmedabad that a search and survey proceeding was conducted by the Investigation Wing, Ahmedabad on 18.12.2014 on the commodity traders groups such as Affluence Commodities Pvt. Ltd. Bhagwati Investments and R P Jambuwala. During the investigation

Mahesh Narsing Choudhary, Navi Mumbai vs. ITO Ward 28(2)(1), Navi Mumbai

ITA 4769/MUM/2025[2019-2020]Status: DisposedITAT Mumbai29 Oct 2025AY 2019-2020

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Khushiram JadhwaniFor Respondent: Shri Paresh Deshpande
Section 144BSection 147Section 148Section 148ASection 69A

been followed. 1.4 The appellant contends that the learned Assessing Officer has simply relied upon the alleged Report of the Investigation Wing of the Department for invoking the provisions of Section 147 of the Act. The learned Assessing Officer has not applied his independent mind to the facts available ... Assessment has been completed in gross violation of principles of natural justice. The learned Assessing Officer has simply relied upon alleged Report of the Investigation Wing of the Department without affording sufficient opportunity to the Appellant to verify and rebut the same. 2.4. The appellant contends that

Suresh Maheshwari, Mumbai vs. The DCIT, Circle 19(3), Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 3370/MUM/2025[2015-16]Status: DisposedITAT Mumbai29 Oct 2025AY 2015-16

Bench: Shri Saktijit Dey & Ms. Padmavathy Ssuresh Maheshwari, The Dcit, 3Rd Floor, 16, New Silk Bazar, Circle 19(3) Vs. Gandhi Mansion, Piramal Chambers, Lalbaug, Mumbai-400002 Parel, Mumbai 400012 (Appellant) : (Respondent) Pan No. Aafpm 4397R

For Appellant: NoneFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 10(38)

claimed exempt u/s. 10(38) of the Act. From the materials available with him, the AO found that as per the report of the investigation wing of Kolkata the scrip of M/s. Pine Animation Ltd is identified as a penny stock scrip. As per the Investigation Wing Report, the promoters ... genuine and in the garb of said transaction the promoters were providing accommodation entries to a number of beneficiaries. Based on the Investigation Wing Report, the AO issued summons to the assessee and examined him on oath. In the statement recorded, the assessee claimed the transaction relating to purchase

ACIT 4(3)(1), Mumbai vs. Narayan Dalpatram Thakkar, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3619/MUM/2017[2008-09]Status: DisposedITAT Mumbai29 Oct 2025AY 2008-09

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2008-09 Assistant Commissioner Of Vs Narayan Dalpatram Income-Tax - 4(3)(1), Thakkar Mumbai Abhay Bldg, 5Th Floor, Ns 9Th Rdm Jvpd Scheme, Juhu Vile Parle (W), Mumbai - 400032 [Pan: Aaipt0713F] Appellant Respondent Present For: Assessee : Shri Parag Shah, Ca Revenue : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 05.08.2025 Date Of Pronouncement : 29.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Cit(A) – 9, Mumbai, Vide Order No. Cit(A)-9/Cir.4/529/2015-16, Dated 17.03.2016 Passed Against The Assessment Order By Deputy Commissioner Of Income-Tax-4(3)(1), U/S.143(3) R.W.S. 147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 29.01.2016 For Ay 2008-09. 2. Grounds Taken By The Revenue Are Reproduced As Under: “1. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Directing The Ao To Delete The Addition Made Towards Unexplained Unsecured Loan Of Rs.65,00,000/- U/S.68 Of The I.T. Act.

For Appellant: Shri Parag Shah, CAFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 143(3)Section 148Section 68Section 69C

assessee. It is seen that ld. AO has merely relied on the statements by alleged Shri Praveen Kumar Jain as recorded by Investigation Wing. It is also noted that ld. AO could not establish and demonstrate with cogent documentary evidence of any relationship between the assessee and the Praveen Kumar ... worth noting that ld. AO has not made any further enquiry to probe into the matter and has rested on the findings of the investigation wing and the statement recorded of Shri Praveen Kumar Jain in the course 8 Narayan Dalpatram Thakkar AY 2008-09 of his search to taint

Anoop Jain HUF, Delhi vs. Joint Commissioner of Income Tax (OSD), Central Circle - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4043/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

year under appeal is unabated year and the additions were made solely on the basis of statement of third parties, report of the Investigation Wing with respect to the penny stock transaction and the adjudication order dated 31.05.2021 passed by SEBI in the case of PMC Fin Corp Ltd, which ... dates, unrelated to the Appellants' search:  Statement of Shri Dhirendra Kumar Gupta on 12.10.2018 and Shri Manish Gupta's 133(6) reply dated 29.01.2021;  Investigation Wing reports and modus operandi charts, and  SEBI adjudication order dated 31.05.2021, which was subsequently quashed by the Securities Appellate Tribunal on 12.09.2023 20. None