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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

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

In the result, appeal of the assessee is allowed

ITA 4042/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

Ritu Jain, Delhi vs. Joint Commissioner of Income Tax (OSD), CC - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4038/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

ACIT, New Delhi vs. Vrinda Farms Private Limited, New Delhi

In the result, the appeal of the Revenue as well as cross objections of the assessee are dismissed

ITA 4849/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Acit, Central Circle 4, Vs. Vrinda Farms Private Limited, New Delhi. 43, Community Centre, Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) Co Nos.13 & 19/Del/2025 (In Ita No.4849/Del/2024) (Assessment Year: 2016-17) Vrinda Farms Private Limited, Vs. Acit, Central Circle 4, 43, Community Centre, New Delhi. Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) (Appellant) (Respondent) Assessee By : Shri Biren Shah, Ca Revenue By : Shri Dheeraj Kumar Jain, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Order : 29.10.2025 Order Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short]

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Section 132(4)Section 133(6)Section 68

failed to appreciate that there is no information of conduct of any audit/investigation by SEBIIRBI, while the search conducted by Investigation Wing brought out substantial evidence about actual financial conduct of these entry operators, masquerading in the guise of NBFC. 6. Whether the Ld. CIT(A) is correct in holding

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4671/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 148

Income-tax Act, 1961 (for short ‘the Act’). Subsequently, information received from Pr. CCIT, Delhi vide letter dated 27.03.2018 intimating that the Investigation Wing of the Department conducted a search on the residential premises of Surendra Kumar Jain on 14.09.2010 thereby it was found that assessee has taken accommodation entry ... case of the assessee was reopened by issue of notice under section 148 of the Act by recording the reasons as supplied by the Investigation Wing with the observation that the assessee has taken accommodation entry of Rs.30,00,000/- from Surendra Kumar Jain of M/s. RKG Finvest Pvt. Limited

DCIT, Circle - 10(1), New Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4670/DEL/2024[2015-16]Status: DisposedITAT Delhi29 Oct 2025AY 2015-16

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 148

Income-tax Act, 1961 (for short ‘the Act’). Subsequently, information received from Pr. CCIT, Delhi vide letter dated 27.03.2018 intimating that the Investigation Wing of the Department conducted a search on the residential premises of Surendra Kumar Jain on 14.09.2010 thereby it was found that assessee has taken accommodation entry ... case of the assessee was reopened by issue of notice under section 148 of the Act by recording the reasons as supplied by the Investigation Wing with the observation that the assessee has taken accommodation entry of Rs.30,00,000/- from Surendra Kumar Jain of M/s. RKG Finvest Pvt. Limited

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4669/DEL/2024[2011-12]Status: DisposedITAT Delhi29 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 148

Income-tax Act, 1961 (for short ‘the Act’). Subsequently, information received from Pr. CCIT, Delhi vide letter dated 27.03.2018 intimating that the Investigation Wing of the Department conducted a search on the residential premises of Surendra Kumar Jain on 14.09.2010 thereby it was found that assessee has taken accommodation entry ... case of the assessee was reopened by issue of notice under section 148 of the Act by recording the reasons as supplied by the Investigation Wing with the observation that the assessee has taken accommodation entry of Rs.30,00,000/- from Surendra Kumar Jain of M/s. RKG Finvest Pvt. Limited

Omkar Singh, Noida vs. ITO Ward - 5(2)(1), Noida

In the result, the appeal of the assessee is allowed

ITA 3574/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Oct 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 115BSection 139(1)Section 143(2)Section 147Section 148Section 151Section 69A

been taken cognizance of by the Id. AO and he merely relied whatever information reached the Investigation Wing and how it was examined. It appears that the AO has merely reproduced the facts coming up from the Investigation Wing and added his remark of escapement of income. It is coming

Archit Gupta, Delhi vs. ACIT, Central Circle-29, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 2527/DEL/2022[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Archit Gupta Vs. Assistant Commissioner Of B-41, Kailsah Colony, Income Tax, Circle 29, New Delhi Jhandewalan Extension Pan: Aeupg2360R New Delhi Appellant Respondent Assessee By Sh. Ruchesh Sinha, Adv, Ms.Monalisa Maity, Adv Revenue By Sh. Shankar Lal Verma, Sr. Dr Date Of Hearing 10/09/2025 Date Of Pronouncement 29/10/2025 Order

Section 10(38)Section 132Section 143(1)Section 147Section 68

Income Tax Act, 1961 ('Act' for short). A search and seizure action was conducted u/s 132 of the Act by the Investigation Wing, Mumbai on some share brokers and on the basis of the information received from the said investigation wing, assessment of the Assessee was reopened ... planned manner to evade taxes. The AO extensively relied upon the search and survey operations conducted by the 6 Archit Gupta Vs. ACIT Investigation Wing of the Income Tax Department in Kolkata, Delhi, Mumbai and Ahmedabad on penny stocks, which sets out the modus operandi adopted in the business

Joint Commissioner of Income Tax (in Situ) Circle-I, Ludhiana vs. Kapil Thapar, Ludhiana

In the result, appeal of the Department is dismissed and Cross

ITA 246/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh28 Oct 2025AY 2016-17

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 148Section 153CSection 69A

also erred in not considering the 2. submissions of the assessee that the Assessing Officer has only relied upon the report of the Investigation Wing and did not apply his own mind for framing the reason to believe that the income of the assessee had escaped assessment and, further ... assessee was reopened by way of notice u/s 148 issued on 31.03.2023, since as per information received by the Assessing Officer from the 'Investigation Wing' that during the course of search in the case of "Kewal Chhabra Group", it was found that one L.G. Promoters had purchased 1500 sq. yards

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Vivek Gupta, Kolkata

The appeal of the revenue is dismissed

ITA 1557/KOL/2025[2013-14]Status: DisposedITAT Kolkata28 Oct 2025AY 2013-14

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 131Section 133ASection 143(3)Section 195Section 250Section 40Section 68

very casual manner. The Ld. CIT(A) also referred to the observations of the AO that during the course of survey proceedings done by Investigation Wing in the case of Avima Group, Shri Viswanath Gupta and Shri Vivek Gupta, directors and key person of the said group wherein Shri Viswanath

Deputy Commssioner of Income Tax, Central Circle, 4(3), Kolkata vs. Privi Exports Private Limited, Kolkata

Accordingly the ground No. 2 is dismissed by upholding the order of Ld

ITA 1456/KOL/2025[2017-18]Status: DisposedITAT Kolkata28 Oct 2025AY 2017-18

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 131Section 133ASection 250Section 68

also referred to the observations of the AO as regards the survey proceedings done by Investigation Wing wherein in the case of Avima Group, Shri Viswanath Gupta and Shri Vivek Gupta, directors and key persons of the said group had admitted to be involved in availing accommodation entries from several

DCIT Central Circle 1 4 Kolkata, Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2245/KOL/2024[2016-17]Status: DisposedITAT Kolkata28 Oct 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

no.6.12(4) of the Act noted that the ld. AO heavily relied on the statement of the entry operators and data base of the investigation wing, Kolkata for arriving at the conclusion that loan creditors were Jama Karchi companies, however, forgotten to evaluate and examine the evidences produced before ... Similarly, the ld. CIT (A) noted that the ld. AO has relied on the statement of the entry operators and data base of the investigation wing, Kolkata to arrive at a conclusion that the lenders were shell/ bogus companies, however, did not allow any opportunity to assessee

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2196/KOL/2024[2018-19]Status: DisposedITAT Kolkata28 Oct 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

no.6.12(4) of the Act noted that the ld. AO heavily relied on the statement of the entry operators and data base of the investigation wing, Kolkata for arriving at the conclusion that loan creditors were Jama Karchi companies, however, forgotten to evaluate and examine the evidences produced before ... Similarly, the ld. CIT (A) noted that the ld. AO has relied on the statement of the entry operators and data base of the investigation wing, Kolkata to arrive at a conclusion that the lenders were shell/ bogus companies, however, did not allow any opportunity to assessee

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2187/KOL/2024[2015-16]Status: DisposedITAT Kolkata28 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

no.6.12(4) of the Act noted that the ld. AO heavily relied on the statement of the entry operators and data base of the investigation wing, Kolkata for arriving at the conclusion that loan creditors were Jama Karchi companies, however, forgotten to evaluate and examine the evidences produced before ... Similarly, the ld. CIT (A) noted that the ld. AO has relied on the statement of the entry operators and data base of the investigation wing, Kolkata to arrive at a conclusion that the lenders were shell/ bogus companies, however, did not allow any opportunity to assessee

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2179/KOL/2024[2014-15]Status: DisposedITAT Kolkata28 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

no.6.12(4) of the Act noted that the ld. AO heavily relied on the statement of the entry operators and data base of the investigation wing, Kolkata for arriving at the conclusion that loan creditors were Jama Karchi companies, however, forgotten to evaluate and examine the evidences produced before ... Similarly, the ld. CIT (A) noted that the ld. AO has relied on the statement of the entry operators and data base of the investigation wing, Kolkata to arrive at a conclusion that the lenders were shell/ bogus companies, however, did not allow any opportunity to assessee

Mayank Jayantilal Desai, Mumbai vs. ITO- Ward 19(2)(2), Mumbai

In the result appeal filed by the assessee stands allowed and appeal filed by the revenue stands dismissed

ITA 706/MUM/2025[2007-08]Status: DisposedITAT Mumbai28 Oct 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Arun Khodpia ()

Section 145(3)Section 147

made of Rs. 3,06.16.578/, by ignoring the fact that action of the AO was based on the information Report received from the DCT (Investigation Wing), Mumbai about Rajendra Group, Sanjay Choudhary Group, Dharmichand Jain Group, that these hawala traders were indulged only in providing accommodation entries in the form ... assessee and that the assessing officer did not carry out any independent verification in respect of the information received against assessee from the investigation wing based on the documents furnished by the assessee. 3.1 The assessee also furnish application dated 08/03/2017 requesting admission of additional evidence under rule

DCIT, Central Circle-8(1), Mumbai vs. Ei Resorts & Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3926/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Oct 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

around Kolgaon. The Company has been aggregating land parcels in and around Kolgaon for over a decade. 2. On 7th October, 2021, the Investigation Wing of the Department conducted a search and survey action under section 132 of the Act at the premises of the the Sakseria Group of Companies ... cannot, by itself, form the sole basis for an addition. Particularly so when the authorship and authenticity of such documents are in dispute. The Investigation Wing, which carries out the search, may record statements or seized documents; however, the same are merely inputs for further enquiry. Once the material

DCIT, Central Circle-8(1), Mumbai vs. E I Resorts and Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3886/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

around Kolgaon. The Company has been aggregating land parcels in and around Kolgaon for over a decade. 2. On 7th October, 2021, the Investigation Wing of the Department conducted a search and survey action under section 132 of the Act at the premises of the the Sakseria Group of Companies ... cannot, by itself, form the sole basis for an addition. Particularly so when the authorship and authenticity of such documents are in dispute. The Investigation Wing, which carries out the search, may record statements or seized documents; however, the same are merely inputs for further enquiry. Once the material

Shri Dilip J Thakkar, Mumbai vs. DCIT, Central Circle -6(4), Mumbai

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

ITA 37/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13

Bench: Smt. Beena Pillai () & Shri Arun Khodpia ()

Section 131

assessment year 2006-07 fell within the block period of search. 4.1 The assessee submitted that, based on identical documents received from the investigation wing assessment for assessment year 2006-07 was completed by making addition of the peak balance for the relevant assessment year. He submitted that this ... settled abroad and are citizens of UK and Canada. There is no dispute of these facts. 25. From the ‘Base Note’ forwarded by the Investigation wing, it has been informed that in Chagganlal Suchak Family Trust which had bank accounts in HSBC Bank, Geneva, Mr. Dilip Thakkar and his wife

Tarun Nandkumar Seksaria, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3239/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

Dapoli. The Assessee has been aggregating land parcels in and around Dhokawade and Dapoli for over a decade. 6. On 7th October, 2021, the Investigation Wing of the Department conducted a search and survey action under section 132 of the Act at the premises of the Sakseria Group of Companies ... cannot, by itself, form the sole basis for an addition. Particularly so when the authorship and authenticity of such documents are in dispute. The Investigation Wing, which carries out the search, may record statements or seized documents; however, the same are merely inputs for further enquiry. Once the material