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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

Shri Dipendra Singh, Tonk vs. ACIT Cen Cir 2, Jaipur

In the result, the appeals of the assessee in ITA

ITA 248/JPR/2024[2014-15]Status: DisposedITAT Jaipur15 Oct 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 115BSection 143(3)Section 153CSection 250Section 68Section 69Section 69A

assessee that the approving authority is statutorily required to examine the seized material, appraisal report, enquiries made by the Investigation Wing, and replies of the assessee, and then apply his independent mind before granting approval. It was further contended that in the present case, approval was granted for multiple years ... purpose of approval, the Approving Authority is required to see all search material including incriminating material, seized documents, appraisal reports, enquiries made by the Investigation Wing and various enquiries made by the Assessing Officer during the assessment proceedings and the reply submitted by the assessee, and after due application

Shri Dipendra Singh, Tonk vs. ACIT Cen Cir 2, Jaipur

In the result, the appeals of the assessee in ITA

ITA 247/JPR/2024[2013-14]Status: DisposedITAT Jaipur15 Oct 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 115BSection 143(3)Section 153CSection 250Section 68Section 69Section 69A

assessee that the approving authority is statutorily required to examine the seized material, appraisal report, enquiries made by the Investigation Wing, and replies of the assessee, and then apply his independent mind before granting approval. It was further contended that in the present case, approval was granted for multiple years ... purpose of approval, the Approving Authority is required to see all search material including incriminating material, seized documents, appraisal reports, enquiries made by the Investigation Wing and various enquiries made by the Assessing Officer during the assessment proceedings and the reply submitted by the assessee, and after due application

Income Tax Officer, Ludhiana vs. Bhavneet Kaur Walia, Ludhiana

In the result, appeal filed by the Revenue is dismissed

ITA 247/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh15 Oct 2025AY 2015-16

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

For Appellant: Shri Vipin Gupta, C.A (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 147Section 69

assessee, Smt. Bhavneet Kaur Walia, was subjected to reassessment proceedings under section 147 of the Act on the basis of information received from the Investigation Wing, alleging that the assessee had made undisclosed investment of Rs.2,86,42,500/- in an immovable property during the relevant year. 3.1 During ... submissions of the assessee, recorded categorical findings as under: “The case of the appellant has been re-opened based on an information from the Investigation Wing. However, the Ld. A.O. has not stated the details of the property in which the appellant has allegedly made undisclosed investment amounting

Girish Vrajlal Soni, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1462/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Kirit B. Soni, ARFor Respondent: Shri Sudhakar Verma, Sr. DR
Section 133(6)Section 68Section 69A

assessee has provided Bank Statements, Copy of sales Invoice, Ledger of VIKO ENTERPRISE, Stock Statement to the Assessment Unit. However, based on Enquiry by investigation wing, Ahmedabad with VIKO Enterprise, The transaction is treated as accommodation Entry by the assessment wing. No Incriminate document from VIKO enterprise against Soni Girishkumar ... appellant has challenged the addition worth Rs./- 11,27.000u/s. 69A of the Income Tax Act. 1961. The information was received from the Investigation wing that the appellant has taken accommodation entry worth RS. 11.27.000/- The appellant replied to the AO that he has sold gold bar to Mis Vico

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1296/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2017-18

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

under section 139(1) of the Act, declaring modest taxable income, as detailed in the table below. Subsequently, based on information received from the Investigation Wing, Surat, the Assessing Officer noticed that during the relevant previous years, the assessee had allegedly made substantial cash deposits with Shri Renuka Mata Multi ... Assessing Officer completed the assessment under section 144 read with sections 147 and 144B on the basis of information received from the Investigation Wing that the assessee had deposited substantial cash in the Shri Renuka Mata Multi-State Urban Co-operative Credit Society Ltd. during the relevant year. The said

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1295/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2016-17

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

under section 139(1) of the Act, declaring modest taxable income, as detailed in the table below. Subsequently, based on information received from the Investigation Wing, Surat, the Assessing Officer noticed that during the relevant previous years, the assessee had allegedly made substantial cash deposits with Shri Renuka Mata Multi ... Assessing Officer completed the assessment under section 144 read with sections 147 and 144B on the basis of information received from the Investigation Wing that the assessee had deposited substantial cash in the Shri Renuka Mata Multi-State Urban Co-operative Credit Society Ltd. during the relevant year. The said

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1294/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2015-16

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

under section 139(1) of the Act, declaring modest taxable income, as detailed in the table below. Subsequently, based on information received from the Investigation Wing, Surat, the Assessing Officer noticed that during the relevant previous years, the assessee had allegedly made substantial cash deposits with Shri Renuka Mata Multi ... Assessing Officer completed the assessment under section 144 read with sections 147 and 144B on the basis of information received from the Investigation Wing that the assessee had deposited substantial cash in the Shri Renuka Mata Multi-State Urban Co-operative Credit Society Ltd. during the relevant year. The said

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1293/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2014-15

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

under section 139(1) of the Act, declaring modest taxable income, as detailed in the table below. Subsequently, based on information received from the Investigation Wing, Surat, the Assessing Officer noticed that during the relevant previous years, the assessee had allegedly made substantial cash deposits with Shri Renuka Mata Multi ... Assessing Officer completed the assessment under section 144 read with sections 147 and 144B on the basis of information received from the Investigation Wing that the assessee had deposited substantial cash in the Shri Renuka Mata Multi-State Urban Co-operative Credit Society Ltd. during the relevant year. The said

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward2(1)(1), Ahmedabad

ITA 1292/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2013-14

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

under section 139(1) of the Act, declaring modest taxable income, as detailed in the table below. Subsequently, based on information received from the Investigation Wing, Surat, the Assessing Officer noticed that during the relevant previous years, the assessee had allegedly made substantial cash deposits with Shri Renuka Mata Multi ... Assessing Officer completed the assessment under section 144 read with sections 147 and 144B on the basis of information received from the Investigation Wing that the assessee had deposited substantial cash in the Shri Renuka Mata Multi-State Urban Co-operative Credit Society Ltd. during the relevant year. The said

Wazeera Saleh Mithiborwala, Mumbai vs. DCIT Circle 35(3) Mumbai, Mumbai

In the result, the appeal by the assessee is allowed

ITA 484/MUM/2025[2014-2015]Status: DisposedITAT Mumbai15 Oct 2025AY 2014-2015

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankarwazeera Saleh Mithiborwala, 1001/1002 Natura, Tapovan, Co-Op. Housing Society, J.K. Mehta Marg, Santacruz West, Mumbai - 400054 ............... Appellant Pan: Acgpm5141G V/S Deputy Commissioner Of Income Tax, Circle – 35(3), ……………… Respondent Mumbai

For Appellant: Shri Nishit Gandhi, AdvocateFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 10(38)Section 143Section 143(2)Section 143(3)Section 144Section 147Section 148Section 250Section 68

failed to appreciate that: 3 (a) The re-assessment was initiated on the Assessee simply on the basis of information received from investigation wing without any application of mind thereto by the AO and therefore invalid; (b) A copy of the actual reasons as recorded

Mukul Hasteer, Karnal vs. ITO Ward-1, Karnal

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 96/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Oct 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 234A

year whereas they are purchased through off market transaction just few days before the sale of equity shares. Through this modus operandi, as per Investigation Wing, assessee is one of such oh beneficiary through dealing in equity shares of Eicher Motors. The assessee in his submission has submitted that

Raghav Kumar, New Delhi vs. ACIT Central Circle-29, New Delhi

In the result, the appeal filed by the assessee being ITA

ITA 3215/DEL/2025[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Shri R.S. Singhvi, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 153CSection 69Section 69A

case of M/s. Mahagun (India) P. Ltd. for AY 2020-21 wherein returned income was accepted without any addition or disallowance.  The AO or investigation wing has not brought on record any evidence attributing the transactions to the appellant or the year to which it relates. In fact, except alleged ... detailed finding. The CIT(A) has merely relied on Whatsapp Chat without taking into consideration statement of the parties, nature of enquiry by investigation wing or assessing officer and existence of any evidence in support of alleged transactions. The order of CIT(A) is rather cryptic and mechanical

Raghav Kumar, Delhi vs. ACIT Central Circle 29, New Delhi

In the result, the appeal filed by the assessee being ITA

ITA 3214/DEL/2025[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Shri R.S. Singhvi, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 153CSection 69Section 69A

case of M/s. Mahagun (India) P. Ltd. for AY 2020-21 wherein returned income was accepted without any addition or disallowance.  The AO or investigation wing has not brought on record any evidence attributing the transactions to the appellant or the year to which it relates. In fact, except alleged ... detailed finding. The CIT(A) has merely relied on Whatsapp Chat without taking into consideration statement of the parties, nature of enquiry by investigation wing or assessing officer and existence of any evidence in support of alleged transactions. The order of CIT(A) is rather cryptic and mechanical

Deepak Agarwal, Delhi vs. DCIT, Central Circle- 25, Delhi

ITA 2309/DEL/2025[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

assessee has received bogus entries. There is no specific assertion about nature of deposit. Then it leads to conclusion that merely the investigation wing report was relied and there was otherwise no live link between the information and the reasoning. 7.1 Though Ld. DR has relied the decision

Deepak Agarwal, Delhi vs. DCIT, Central Circle- 13, Delhi

ITA 2308/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Oct 2025AY 2018-19

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

assessee has received bogus entries. There is no specific assertion about nature of deposit. Then it leads to conclusion that merely the investigation wing report was relied and there was otherwise no live link between the information and the reasoning. 7.1 Though Ld. DR has relied the decision

Deepak Agarwal, Delhi vs. DCIT, Central Circle-25, Delhi

ITA 2306/DEL/2025[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

assessee has received bogus entries. There is no specific assertion about nature of deposit. Then it leads to conclusion that merely the investigation wing report was relied and there was otherwise no live link between the information and the reasoning. 7.1 Though Ld. DR has relied the decision

Deepak Agarwal, Delhi vs. DCIT, Central Circle- 25, Delhi

ITA 2305/DEL/2025[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

assessee has received bogus entries. There is no specific assertion about nature of deposit. Then it leads to conclusion that merely the investigation wing report was relied and there was otherwise no live link between the information and the reasoning. 7.1 Though Ld. DR has relied the decision

Dharampal Satyapal Ltd., New Delhi vs. ACIT Central Circle 29, New Delhi

ITA 5519/DEL/2024[2015-16]Status: DisposedITAT Delhi15 Oct 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2015-16 Dharampal Satyapal Ltd., Vs. Acit, 98, Okhla Industrial Estate Central Circle-29, Phase Iii, New Delhi. Tehkhand, New Delhi – 110 020. Pan: Aaacd0132H (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi; Shri Satya Jeet Goel; & Shri Rajat Garg, Cas Revenue By : Shri Amit Jain, Cit-Dr Date Of Hearing : 11.09.2025 Date Of Pronouncement : 15.10.2025 Order

For Appellant: Shri R.S. SinghviFor Respondent: Shri Amit Jain, CIT-DR
Section 115JSection 144CSection 147Section 148Section 148ASection 149Section 69ASection 80ISection 92C

reproduced above, show that same are based on an email containing FIR against the appellant company as forwarded by the investigation wing. The substance of allegations had to yet pass through judicial scrutiny of criminal courts. Appellant has disputed the allegations in the FIR and has demonstrated

Hiteshi Leasing and Housing Pvt Ltd, New Delho vs. DCIT, Circle-1, Faridabad

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

ITA 4620/DEL/2024[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarhiteshi Leasing & Housing Pvt. Ltd., Vs. Dcit, Circle 1, Yogi Associates, Faridabad. E – 335, East Of Kailash, New Delhi – 110 005. (Pan : Aaach8298J) (Appellant) (Respondent) Assessee By : Shri Pushpdeep Singh, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 28.08.2025 Date Of Order : 15.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals), Gurgaon-3 [For Short ‘Ld. Cit (A)] Dated 04.081.2024 For Assessment Year 2011-12 Raising Following Grounds Of Appeal :- “(A) That On The Facts & Circumstances Of The Case The Learned Assessing Officer & Cit(A), While Passing The Order Erred In: A. Passing The Assessment Order Dated 26.03.2015 U/S 153A Despite The Fact The Assessee Was Not Searched & The Assessee Was Issued Notice Under Section 153C On 29.1 1.2013. This Is A Jurisdictional Error

For Appellant: Shri Pushpdeep Singh, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 131Section 153ASection 153CSection 68

Distribution Private Limited. Golden Mercantile Limited, Pine View Investment Private Limited. and M/s. Shalini Holdings Ltd merely on the basis of observation/ allegation by Investigation Wing. Delhi that one of the director of Shalini Holdings Limited is a relative of S.K. Jain who was allegedly engaged in the activities

DCIT Central Circle-06, New Delhi vs. Praveen Kumar Jolly, New Delhi

In the result, appeal of the Revenue in No

ITA 1654/DEL/2023[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2011-12] Dcit, Vs Praveen Kumar Jolly, Central Circle-06, 39/1, East Patel Nagar, New Delhi New Delhi-110008. Pan-Aagpj0144C Appellant Respondent

Section 139(1)Section 147Section 148Section 250Section 68

confirming the reopening despite the fact that the same has been made by the AO on the basis of information received from the investigation wing without independent application of his own mind. 8. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts