“investigation wing”

ReassessmentSection 147Section 14712,584 judgments

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

Leading authorities on investigation wing

Sarthak Securities Co. Pvt. Ltd. v. ITO

329 ITR 110 · 2010 · High Court

217

citing judgments

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

ITO, 19(3) (4) Mumbai v. Shamim M Bharwani

69 Taxmann.com 65 · 2016 · Reported

142

citing judgments

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

1. Harikishan S. Virmani v. DCIT

394 ITR 146 · 2017 · High Court

citing judgments

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

PCIT v. M/s. Kesoram Industries 57

417 ITR 334 · 2019 · High Court

citing judgments

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

ITO v. Purushottam Das Bangur

224 ITR 362 · 1997 · Supreme Court

citing judgments

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

AGR Investment v. Additional Commissioner

197 Taxmann 177 · 2011 · High Court

citing judgments

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

56 (Guj.) (para 6) v. Aaspas Multimedia Ltd. v. Dy. CIT

83 Taxmann.com 82 · 2017 · High Court

citing judgments

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

Aradhna Estate Pvt. Ltd. v. DCIT

91 Taxmann.com 119 · 2018 · High Court

citing judgments

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

Judgments citing investigation wing

Aniket Singal, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 939/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh13 Mar 2026AY 2016-17

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal, C.A'sFor Respondent: Shri Manav Bansal, CIT, DR

Section 10(38)Section 132Section 132(4)Section 250(6)Section 68Section 69C

n1961 was also conducted on Sh. R.K. Kedia and his key employee\n(Accountant), Sh. Manish Arora, by the DI (Investigation) Wing, New Delhi along\nwith the Bhushan Group on 13.06.2014. During the course of search, the\nstatement of Sh. Shrish Chandrakant Shah (SCS) was recorded ... only paper work was done to give a colour of authenticity\nto the transactions by creating a façade of legitimate transactions.\n9.5 The Investigation Wing and the AO has brought on record sufficient\nmaterial to support the findings that appellant has introduced unaccounted\nmoney by camouflaging the share transactions with

Aniket Singal, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

In the result, all the above appeals are allowed

ITA 1146/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh13 Mar 2026AY 2017-18

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 939/Chd/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Shri Aniket Singal बनाम The DCIT 4, Amritashergil Marg, New Delhi- 110003 Central Circle-1 Chandigarh स्थायी लेखा सं./ PAN NO: CZCPS6126E अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1145/Chd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Smt. Aarti Singal बनाम The DCIT 53, Jor Bagh, New Delhi-110003 Central Circle-1 Chandigarh स

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal, C.A’sFor Respondent: Shri Manav Bansal, CIT, DR

Section 10(38)Section 132Section 132(4)Section 250(6)Section 68Section 69C

also conducted on Sh. R.K. Kedia and his key employee (Accountant), Sh. Manish Arora, by the DI (Investigation) Wing, New Delhi along with the Bhushan Group on 13.06.2014. During the course of search, the statement of Sh. Shrish Chandrakant Shah (SCS) was recorded ... only paper work was done to give a colour of authenticity to the transactions by creating a façade of legitimate transactions. 9.5 The Investigation Wing and the AO has brought on record sufficient material to support the findings that appellant has introduced unaccounted money by camouflaging the share transactions with

Aarti Singal, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

In the result, all the above appeals are allowed

ITA 1145/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh13 Mar 2026AY 2017-18

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 939/Chd/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Shri Aniket Singal बनाम The DCIT Central Circle-1 Chandigarh 4, Amritashergil Marg, New Delhi- 110003 स्थायी लेखा सं./ PAN NO: CZCPS6126E अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1145/Chd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Smt. Aarti Singal बनाम The DCIT Central Circle-1 Chandigarh 53, Jor Bagh, New Delhi-110003 स

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal, C.A’sFor Respondent: Shri Manav Bansal, CIT, DR

Section 10(38)Section 132Section 132(4)Section 250(6)Section 68Section 69C

Rbz Jewellers Limited, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

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

ITA 61/AHD/2026[2023-24]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2023-24

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri C Dharani Nath, Sr. DRFor Respondent: Shri C Dharani Nath, Sr. DR

Section 132Section 133(6)Section 142(1)Section 143(2)

digital data relating to various branches such as Tirth Gold–Surat, Rajkot, Delhi, Ahmedabad and Bangalore were maintained in a common database. The Investigation Wing observed that the said software contained records of both accounted as well as unaccounted transactions and that a substantial part of the transactions recorded therein ... correspond with the transactions reported in their Income-tax and GST returns. On the basis of the material found during the search, the Investigation Wing came to the conclusion that the entities of Tirth Gold were engaged in unaccounted purchase and sales transactions. During the course of investigation

Veer Sawarkar Katyal, Delhi vs. ITO Ward -43 (6), Delhi

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

ITA 8834/DEL/2025[2007-08]Status: DisposedITAT Delhi13 Mar 2026AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shuklaassessment Year: 2007-08 Veer Sawarkar Katyal, Vs Ito, 329, Sainik Vihar, Ward 43(6), Pitampura, Delhi. Rani Bagh, New Delhi – 110 034. Pan: Abdpk7569E

For Appellant: Shri Ved Jain, Advocate &For Respondent: Shri Ravi Kant Chaudhary, Sr. DR

Section 142(1)Section 147Section 148Section 250Section 254

Section 254 r.w.s. 144 r.w.s. 147 of the Act for Assessment Year 2007-08. 2. On the basis of an information received from the Investigation Wing that the assessee along with Mrs. Brij Bala and M/s Yogum Developers Ltd. purchased a property lying and situated at V3S-Omaxe ... various decisions cited before us. We find, the Assessing Officer, in the instant case, on the basis of the information obtained from the Investigation Wing that the assessee had purchased one property V3S-Omaxe from Mrs. Brij Bala & M/s Yogum Developers Ltd. for Rs.1,05,55,375/- in cash, made

Namah Shivaya Marketing Private Limited, Delhi vs. Income Tax Officer, Ward 18(1), Delhi

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

ITA 6011/DEL/2025[2008-09]Status: DisposedITAT Delhi13 Mar 2026AY 2008-09

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarnamah Shivaya Marketing Income Tax Officer, Private Limited, Ward-18 (1), 206, Hans Bhawan, 1 Bahadur Vs. Delhi-110002. Shah Zafar Marg, Delhi-110002 . Pan-Aabcn7435Q (Appellant) (Respondent) Assessee By Shri Suresh Kumar Gupta, Ca Department By Shri Manish Gupta, Sr. Dr Date Of Hearing 09.03.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 07.08.2025 Of The Learned Commissioner Of Income Tax (Appeals)-Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 28.11.2019 Of The Ld. Assessing Officer, Ward No.18(1), New Delhi [Hereinafter Referred As ‘The Ao’] U/S 143(3)/263 Of The Act For Assessment Year 2008-09. 2. Brief Facts Of The Case Are That Assessee Filed Return Declaring Total Income Of Rs.7,070/- On 09.07.2008. Assessment Order Dated 21.03.2016 Was Passed. Hon’Ble

Section 142(1)Section 143(3)Section 147Section 153CSection 250Section 68

enquiry based on such evidences brought on records by the appellant/ shareholders. The Id AO appears to be influenced by the Information from the Investigation Wing to take adverse view regarding credits from the shareholders without establishing any nexus of the appellant with the so-called entry operator which ... Assessee had filed details regarding identity and creditworthiness of transaction and establish creditworthiness of the shareholders. The Ld. AO relied on information from Investigation Wing to take the adverse view. Regarding creditworthiness of the shareholders without any nexus of assessee with so called entry operators which was the premises

Ms. Bestech Hospitalities Pvt. Ltd, New Delhi vs. Deputy Commissioner of Income Tax, Faridabad

ITA 3796/DEL/2023[2011-12]Status: DisposedITAT Delhi13 Mar 2026AY 2011-12

Bench: Shri C.N. Prasad & Shri M. Balaganesh, Accontant Member Assessment Year 2011-12 Ms. Bestech Hospitalities Vs. Dcit Pvt. Ltd. Faridabad Unit No.5D, 5Th Floor, Aria, Signature Offices, Jw Marrior Hotel, New Delhi -110037 Pan No.Aaccb2540F Appellant Respondent Appellant Sh. R. S. Ahuja, Ca Sh. Push Deep Singh, Advocate Respondent Smt. Kranti, Cit Dr

Section 132Section 132(1)Section 153ASection 68

independent search proceedings u/s 132 have also been carried out in the case of Shri S.K. Jain by the Investigation Wing, Delhi and it was alleged that Shri S.K Jain through various paper companies such as M/s Apoorva Leasing Finance & Investment Co. Ltd, M/s Transnational Growth Fund Ltd etc. were ... addition of share application money/ share capital received from M/s Apoorva Leasing Finance & Investment Company Ltd. merely on the basis of observation/ allegation by Investigation wing, Delhi that one of the director of Apoorva Leasing Finance & Investment Company Ltd. is also engaged in the activities of providing accommodation entries whereas

Vaneet Aggarwal, New Delhi vs. ACIT, Circle-14(2), New Delhi

In the result, appeal of the Assessee is dismissed

ITA 2607/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 10(38)Section 143(1)Section 143(2)Section 69ASection 69C

line transactions. He submitted that there is no evidence with the Ld. AO for such negative view except relying on the findings of the investigation wing of Kolkata. In the rejoinder Ld. AR submitted that: "In addition to the note containing the facts and arguments filed before ... bogus. The differences of the case of Udit kalra attempted by the Ld. AR does not add any credence to justify the transactions. The Investigation Wing has also conducted enquiries which proved that the assessee is also one of the beneficiaries of the transactions entered by the Companies through multiple

Vikas Chandrakantbhai Shah, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

ITA 25/AHD/2026[2019-20]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Jignesh Parikh, ARFor Respondent: Shri C Dharani Nath, Sr. DR

Section 147Section 148Section 148ASection 151Section 68

return of income for the Assessment Year 2019–20 declaring total income of ₹6,53,890/-. Subsequently, based on information received from the Investigation Wing of the Department that the assessee had entered into transactions with concerns managed by Shri Sanjay Tibrewal, on whom a search was conducted ... taxmann.com 336 (Allahabad), held that where the Assessing Officer forms a reason to believe on the basis of information received from the Investigation Wing that the assessee is a Vikas Chandrakantbhai Shah vs. ITO Asst. Year –2019-20 - 5– beneficiary of accommodation entries, issuance of notice under section

Ankur Kiritkumar Mehta, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

The appeal of the assessee is allowed for statistical purposes

ITA 1647/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Deepak Soni, ARFor Respondent: Shri C Dharani Nath, Sr. DR

Section 147Section 148Section 148ASection 80G

respect of donation of ₹34,00,000/- made to a political party namely Yuva Jan Jagruti Party (YJJP). Based on information received from the Investigation Wing, the Assessing Officer observed that the said political party was allegedly involved in accepting bogus donations and returning the same in cash ... signature of an authorised person and the sequence of receipt numbers appeared irregular. The Assessing Officer also relied upon the findings of the Investigation Wing and held that the said political party was engaged in providing accommodation entries in the form of bogus donations. Accordingly, the Assessing Officer held that

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1594/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl

Section 115BSection 143(3)Section 65BSection 69C

such, no reliance can be placed on such unsigned ‘welcome letters’ (c) The Ld. CIT(A) has brushed aside the enquiries made by the investigation wing from the persons who had purchased he SCOs / DSS and nothing adverse has been admitted by such persons and there was no incriminating evidence ... tabulated and compared with prices mentioned in the seized documents and difference was computed. The statement of one Shri Santokh Singh, as recorded by investigation wing, was referred to support the allegation of receipt of on-money. In the above background, Ld. AO tabulated variation in 41 sale instances

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1593/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh12 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –

Section 115BSection 153A(1)(b)Section 153DSection 65BSection 68Section 69C

such, no reliance can be placed on such unsigned ‘welcome letters’ (c) The Ld. CIT(A) has brushed aside the enquiries made by the investigation wing from the persons who had purchased he SCOs / DSS and nothing adverse has been admitted by such persons and there was no incriminating evidence ... tabulated and compared with prices mentioned in the seized documents and difference was computed. The statement of one Shri Santokh Singh, as recorded by investigation wing, was referred to by Ld. AO to support the allegation of receipt of on-money. In the above background, Ld. AO tabulated variation

Saraf the Jeweller, Chandigarh vs. The DCIT/ACIT Central Circle- 2, Chandigarh

Appeal stand dismissed

ITA 1232/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl

Section 115BSection 143(3)Section 65BSection 69C

Saraf the Jeweller, Chandigarh vs. The DCIT/ACIT Central Circle -2, Chandigarh

Appeal stand dismissed

ITA 1231/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh12 Mar 2026AY 2020-21

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –

Section 115BSection 153A(1)(b)Section 153DSection 65BSection 68Section 69C

such, no reliance can be placed on such unsigned ‘welcome letters’ (c) The Ld. CIT(A) has brushed aside the enquiries made by the investigation wing from the persons who had purchased he SCOs / DSS and nothing adverse has been admitted by such persons and there was no incriminating evidence ... tabulated and compared with prices mentioned in the seized documents and difference was computed. The statement of one Shri Santokh Singh, as recorded by investigation wing, was referred to by Ld. AO to support the allegation of receipt of on-money. In the above background, Ld. AO tabulated variation

Nisha Dudheria, Bangalore vs. Income Tax Officer, Ward-5(2)(3), Bengaluru

In the result the ground No

ITA 316/BANG/2025[2015-16]Status: DisposedITAT Bangalore12 Mar 2026AY 2015-16

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2015-16 Ms. Nisha Dudheria, 66, Navniketan, The Income Tax Officer, Kr Road, Basavanagudi, Ward-5(2)(3), Vs. Bangalore – 560 004. Bangalore. Pan: Bkrpd5938G Appellant Respondent Shri K.R. Pradeep, Advocate & Assessee By : Ms. Girija G.P., Advocate : Shri Subramanian – Jcit Dr Revenue By Date Of Hearing : 09-02-2026 Date Of Pronouncement : 12-03-2026

For Appellant: Ms. Girija G.P., Advocate

Section 142Section 143Section 148Section 68

Assessing Officer, that Assessee has earned the long-term capital gain in some of the companies, as per the report of the investigation wing, the case of the Assessee was reopened by issuance of notice u/s. 148 of the Income Tax Act on 31.03.2018. The Assessee as per letter dated

Income Tax Officer, Mumbai vs. Jitendra Vallabhji Dedhia, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 9207/MUM/2025[2012]Status: DisposedITAT Mumbai12 Mar 2026

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarincome Tax Officer, Jitendra Vallabhji Mumbai Dedhia, Room No. 304, 3Rd Vs. 4, Kaushik Niwas, L. Floor, Piramal N. Road, Matunga, Chambers, Lalbaug, Mumbai-400 019 Parel, Mumbai – 400 012. Pan/Gir No. Afmpd4199N (Applicant) (Respondent) Revenue By Shri Nayanjyoti Nath, Ld. Dr Assessee By Shri Subhodh Ratnaparkhi, Ld. Ar Date Of Hearing 11.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 68

income on 09.04.2019 declaring income of Rs. 11,05,480/-. 3. During the course of reassessment proceedings, the Assessing Officer received information from the Investigation Wing that a search action under section 132 of the Act had been carried out in the case of M/s Evergreen Enterprises. During the course ... dropped. 8. The Assessing Officer did not accept the explanation furnished by the assessee. According to the Assessing Officer, the information received from the Investigation Wing along with the documents seized during the search proceedings in the case of M/s Evergreen Enterprises indicated that the assessee had advanced cash loans

Ganesharam Galbaram Mali, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

In the result the appeals of the assessee bearing ITA No

ITA 8349/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Mar 2026AY 2017-18

Section 132Section 153CSection 250Section 69Section 69C

covered by search action u/s 132. In fact\nthe assessee's case was assessed u/s 153C on the basis of information\nreceived from the Investigation Wing as a result of search in\nRubberwala Group.\nii) In this instant case the CIT(A) has categorically dealt with the ITAT's\ndecision ... form of excel sheet providing names of the purchasers,\nagreement value and actual value with on-money amount was seized\nby the Investigation Wing. The digital evidence substitutes\nrequirement of maintenance of records of the cash transaction in\nphysical form, which the Hon'ble ITAT had not taken into\nconsideration

Ganesharam Galbaram Mali, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result the appeals of the assessee bearing ITA No

ITA 8348/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-19

Bench: Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Arun Kanti Datta (CIT DR)

Section 132Section 132(4)Section 153CSection 250Section 69C

covered by search action u/s 132. In fact the assessee's case was assessed u/s 153C on the basis of information received from the Investigation Wing as a result of search in Rubberwala Group. ii) In this instant case the CIT(A) has categorically dealt with the ITAT's decision ... form of excel sheet providing names of the purchasers, agreement value and actual value with on-money amount was seized by the Investigation Wing. The digital evidence substitutes requirement of maintenance of records of the cash transaction in physical form, which the Hon'ble ITAT had not taken into consideration

Ganesharam Galbaram Mali, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result the appeals of the assessee bearing ITA No

ITA 8347/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Mar 2026AY 2019-20

Bench: Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Arun Kanti Datta (CIT DR)

Section 132Section 132(4)Section 153CSection 250Section 69C

Six Twenty Realty Pvt Ltd, Rajot vs. DCIT, CC-1, Rajkot

ITA 787/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21

Section 133ASection 143(3)Section 147Section 148Section 250

133A(3)(ia) dated\n03.04.2019. The copy of impounded documents had already been provided to the\nassessee during post survey inquiry by the Investigation wing. From the\nimpounded documents/ data, various set of excel sheet were found from which\ngeneration of unaccounted cash is noticed primarily from receipt