“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

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

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.

Judgments citing investigation wing

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

ITA 711/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR

Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

along wit DCIT vs. Sapna Karnani statements of Shri Banka. This implies that the only information Ld.AO is possession of is information received from Investigation Wing, Kolkata. Admitted such information was not found during the course of search at assessee. In view the above, it is clear that during ... course of search, no incriminating documents material were found from the assessee. Subsequent to conclusion of search, some other information was received from Investigation Wing, Kolkata and considering same as incriminating in nature, additions has been made in the assessment proceedings concluded u/s 153A As per the remand report

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

In the result, the appeals of the revenue in ITA No

ITA 710/JPR/2025[2014-15]Status: DisposedITAT Jaipur14 Oct 2025AY 2014-15

For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR

Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

Nos.709/JP/2025 DCIT vs. Sapna Karnani statements of Shri Banka. This implies that the only information Ld.AO is possession of is information received from Investigation Wing, Kolkata. Admitted such information was not found during the course of search at assessee. In view the above, it is clear that during the course ... search, no incriminating documents material were found from the assessee. Subsequent to conclusion of search, some other information was received from Investigation Wing, Kolkata and considering same as incriminating in nature, additions has been made in the assessment proceedings concluded u/s 153A As per the remand report the incriminating material

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

In the result, the appeals of the revenue in ITA No

ITA 709/JPR/2025[2013-14]Status: DisposedITAT Jaipur14 Oct 2025AY 2013-14

For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR

Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

Sunil Kumar Agarwal, Jaipur vs. ACIT, Cen. Cir-2, Jaipur

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR

Section 132Section 139Section 153ASection 234B

chart, excess stock was noticed of Rs.4,86,26,574/-. During the course of assessment proceedings, the assessee explained that at the level of Investigation Wing, the stock was explained full and only s meagre difference of Rs.4,49,744/- remained. It was stated that the difference

DCIT, CC-2, Chandigarh vs. M/S Mubarikpur Royalty Company, Mohali

ITA 15/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh14 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 729/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2017-18) & 2. आयकर अपील सं. / Ita No. 15/Chandi/2023 (िनधा"रण वष" / Assessment Year: 2018-19) Acit-Central Circle 2 M/S Mubarikpur Royalty Company बनाम/ Vs. Cr Building, Sector 17 1, Mubarikpur To Ramgarh Road Chandigarh – 160017 Vpo Mubarikpur, Mohali (Punjab) "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abafm-6580-C (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. Co. No.39/Chandi/2024 (In Ita No. No. 729/Chandi/2022) (िनधा"रण वष" / Assessment Year: 2017-18) & 4. Co. No.40/Chandi/2024 (In Ita No. No. 15/Chandi/2023) (िनधा"रण वष" / Assessment Year: 2018-19) M/S Mubarikpur Royalty Company Acit-Central Circle 2 बनाम/ Sco 506, Chirag Homes-2 Cr Building, Sector 17 Near Arista Place, Sector 123 Chandigarh – 160017 Vs. Sunny Enclave, Mohali (Punjab)-140301 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abafm-6580-C (Cross Objector) (Respondent) : Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr Assessee By : Sh. Harry Rikhy (Advocate)-Ld. Ar

For Appellant: Sh. Harry Rikhy (Advocate)-Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR

Section 132Section 153A

speaking manner and without spelling out any reasons or comments on the findings in the draft order or the seized material or findings of investigation wing in appraisal report. Moreover, on the same day, Ld. Addl. CIT approved draft assessment order in more than 20 other cases of the same

ACIT, CC-2, Chandigarh vs. M/S Mubarikpur Royalty Company, Mohali

ITA 729/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh14 Oct 2025AY 2017-18

For Appellant: Sh. Harry Rikhy (Advocate)-Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR

Section 132Section 153A

Mukesh S Kedia HUF, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 678/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 132Section 144Section 147Section 148Section 250Section 68Section 69A

Sanjay Shah on 11.09.2018, during which unaccounted cash and incriminating documents indicating provision of accommodation entries were found. Based on information shared by the Investigation Wing and analysis of a Suspicious Transaction Report (STR), the Assessing Officer noted that the assessee allegedly received accommodation entries in the form of unsecured

Mukesh S Kedia HUF, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 677/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 132Section 144Section 147Section 148Section 250Section 68Section 69A

Mukesh S Kedia HUF, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 676/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 132Section 144Section 147Section 148Section 250Section 68Section 69A

Mukesh S Kedia HUF, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 675/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 132Section 144Section 147Section 148Section 250Section 68Section 69A

Rajesh Mangilal Purohit, Ahmedabad vs. ITO Ward 4(1)(1) Ahmedabad, Ahmedabad

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

ITA 1674/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2015-16

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

For Appellant: Shri Vivek Chavda, ARFor Respondent: Shri Uday Kishanrao Kakne, Sr. DR

Section 115BSection 133(6)Section 147Section 250

case, the Ld. CIT(A) has erred in upholding the invocation of the provisions of Section 147 merely because the AO received information from investigation wing. The AO has acted mechanically on the information which is against the principle of law. 3.1 The Ld. CIT(A) has grievously erred ... Assessing Officer and Asst. Year : 2015-16 - 4– dismissed the appeal ex parte. We further note that, based on the information received from the Investigation Wing, the Assessing Officer alleged that the assessee had entered into transactions relating to the sale of shares, which were treated as bogus transactions

Sanjay Kumar Drolia, Kolkata vs. ITO, Ward 49(1), Kolkata

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

ITA 1025/KOL/2025[2015-2016]Status: DisposedITAT Kolkata14 Oct 2025AY 2015-2016

Bench: Shri Duvvuru Rl Reddyआयकर अपील सं/Ita No.1025/Kol/2025 (नििाारण वर्ा / Assessment Year : 2015-2016) Sanjay Kumar Drolia, Vs Ito Ward-49(1), Kolkata 48/7, Tulsidham, Jessore Road, Bangur Avenue Crossing, Kolkata-700055 Pan No. : Admpd 0082 C (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri Miraz D. Shah, Ar राजस्व की ओर से /Revenue By : Ms. Monalisa Pal Mukherjee, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 29/08/2025 घोषणा की तारीख/Date Of Pronouncement : 14/10/2025 आदेश / O R D E R The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Addl./Jcit(A)-4, Chennai, Dated 24.03.2025 Passed For Assessment Year 2015-2016. 2. Facts In Brief Are That The Assessee Is An Individual & Had Filed His Original Return Of Income On 02.04.2015 Declaring A Total Income Of Rs.9,11.110/-. The A.O. Was In Receipt Of An Information From Ddit (The) Wing, Unit-3(1), Kolkata, Wherein It Was Stated That The Assessee Was Engaged In Facilitating Accommodation Entry In The Form Of Bogus Billing, Bogus Share Capital, Unsecured Loan To The Beneficiary Companies In Lieu Of Commission At The Rate Of 0.50 Percent Of Cheque Amount During The Period From F.Y.2009-10 To 2013-14. On The Basis Of The Said Information, The Ld. A.O. Issued A Notice U/S 148 Of The I. T. Act, 1961, After Obtaining Approval From Appropriate Authority. In Response To The Said Notice The Assessee E-

For Appellant: Shri Miraz D. Shah, ARFor Respondent: Ms. Monalisa Pal Mukherjee, Sr. DR

Section 131Section 143(2)Section 148

activity. The A.O. was further intimated that a statement of the assessee as a director of M/s. Silverpoint Infratech Ltd was recorded before the Investigation Wing. Kolkata, wherein he was forced to admit that commission 0.50 percent was earned for providing accommodation entry in the form of bogus billing, bogus

Manish Ravi Shendge, Mumbai vs. ACIT-27(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2383/MUM/2025[2011-12]Status: DisposedITAT Mumbai14 Oct 2025AY 2011-12

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjeemanish Ravi Shendge Vs. Acit-27(2) Flat No. 401, 4Th Floor, Vashi (It) Officer, Sai Siddhi Apartment, Plot Mumbai No. 220, 11Th Road, Chembur, Mumbai, 400071. "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Ciops0349L Appellant .. Respondent

For Appellant: Shri Rashmikant Modi Alw MsFor Respondent: Ms. Kavita P. Kaushik, Sr DR

Section 143(1)Section 143(3)Section 68

accounts, confirmation and income tax return. 12. The entire basis of making the addition by the AO is the report received from the investigation wing Kolkata that MSPL is one of the beneficiaries of the accommodation entry provider. However, for the relevant assessment year under consideration the assessee ... bench on identical set of facts where money was borrowed from Minaxi Supplier Pvt. Ltd. and the additions were made basis the report of investigation wing Kolkata has deleted the addition. 14. Considering the facts of the case in totality in the light of the decisions of the co-ordinate

Walmark Garment Compamy Pvt Ltd, Mumbai vs. ITO Ward 14(3)(1), Mumbai

In the result, the assessee’s appeal is hereby dismissed

ITA 6979/MUM/2024[2014-15]Status: DisposedITAT Mumbai14 Oct 2025AY 2014-15

Bench: Shri Pawan Singh & Smt.Renu Jauhriwalmark Garment Company Vs. Income Tax Officer Pvt. Ltd. Ward 14(3)(1), Ch. No. 9 , Shop No. 18, Aayakar Bhavan, Porbandarwala Chawl, Mumbai-400020. Chiragnagar, L.B.S Marg, Ghatkopar West, Mumbai-400086. "थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacw9438P Appellant .. Respondent

For Appellant: Shri Sharwan Kumar JhaFor Respondent: Shri Swapnil Choudhary- Sr. AR

Section 148Section 148ASection 250Section 69C

from M/s. ABN P a g e | 3 Trade Links Pvt. Ltd. These transactions came to light during enquiries conducted by the Investigation wing against M/s. ABN Trade Links Pvt. Ltd. during the course of which, from the statements of the directors recorded on oath and other documents ... information regarding alleged bogus purchases shown by the assessee through the Project Insight of the department, which was, in turn made available by the Investigation wing after conducting investigation in the case M/s. ABN Trade Links Pvt. Ltd. and other group concerns. Further, it is pertinent to note that

Assistant Commissioner of Income Tax, Kalyan vs. Manoj Gunomal Rochlani, Ulhasnagar

The appeal of the Revenue is dismissed

ITA 5876/MUM/2024[2019-20]Status: DisposedITAT Mumbai14 Oct 2025AY 2019-20

Bench: Shri Pawan Singh (Jm) & Shri Omkareshwar Chidara (Am) Acit, Circle-1 Manoj Gunomal Rochlani 1St Floor, Mohan Plaza 48, Roshan Apartment Wayle Nagar, Khadakpada Vs. Netaji Road, Ulhasnagar Kalyan West, Maharahstra Maharashtra-421 004. 421 301. Pan : Ahppr0833A Appellant Respondent

For Appellant: Shri Annavaran KasuriFor Respondent: Ms. Manisha Ghind

Section 148Section 68

facts and in the circumstances of the case, the Ld. CIT(A) erred in ignoring the information received from investigation Wing regarding providing accommodation entries. 3. It is humbly prayed that the present case is covered under exception clause no 3.1.h of the CBDT Circular no 05/2024 elated ... addition was deleted by Ld. CIT(A) stating that there was no evidence that appellant took accommodation entry except some information received from Investigation Wing. 4. Aggrieved by the order of Ld. CIT(A), Revenue filed an appeal with the above grounds of appeal. 5. During the hearing proceedings

M/S Ankur Developers & Realtors, Mumbai vs. DCIT CC-3(4), Mumbai

In the result, the appeal of the assessee is rejected

ITA 428/MUM/2020[2014-15]Status: DisposedITAT Mumbai14 Oct 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2014-15

For Appellant: NoneFor Respondent: Mr. Surendra Mohan, Sr. DR

Section 131Section 132Section 68

Following the same principle, M/s Ankur Developers & Realtors 14 various Benches of the Tribunal have consistently held that a statement recorded by the Investigation Wing under section 131(1A) is legally valid and can form part of the evidentiary material, even if no proceedings are pending before the Assessing Officer ... lenders or the genuineness of the impugned loan transactions. 9.1 The learned DR pointed out that the creditors in question were identified by the Investigation Wing as part of a well-established accommodation entry syndicate run by ‘Shri Bhawarlal Jain’ and ‘Shri Pravin Jain’, whose modus operandi was brought

DCIT, Circle- 19(1), Delhi vs. P & R Engineering Services Pvt. Ltd., Delhi

In the result, appeal of the revenue is dismissed

ITA 6058/DEL/2024[2010-11]Status: DisposedITAT Delhi14 Oct 2025AY 2010-11

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2010-11] Vs P& R Engineering Services Dcit, Circle-19(1), Pvt.Ltd., 89, Lok Nayak New Delhi Apartments, Sector-9, Rohini, Delhi-110085. Pan-Aaccp0484E Appellant Respondent Revenue By Shri Sanjeev Kumar Yadav, Cit Dr Assessee By Shri V. K.Agarwal, Ar Date Of Hearing 17.07.2025 Date Of Pronouncement 14.10.2025 Order Per Manish Agarwal, Am : This Appeal Is Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals), Delhi -31 [Cit(A), In Short] Dated 01.11.2024 In Appeal No. Cit(A), Delhi-7/10212/2017-18 Arising Out Of The Order Passed U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 [The Act, In Short] For A.Y. 2010-11. 2. Brief Facts Of The Case Are That Assessee Is A Company & Filed Its Return Of Income On 27.09.2010, Declaring Loss Of Rs. 12,89,624/-. The Case Of The Assessee Was Reopened In Terms Of The Notice Issued U/S 148 Of The Act On 30.09.2017. In Response, The Assessee Has Declared The Same Income As Was Declared In The Return Filed U/S 139(1) Of The Act. Thereafter The Ao By Alleging That The Assessee Has Received Share Application Money Of Rs. 8,28,45,000/- From Three Companies Namely, M/S Mansarovar Holdings Ltd. Rs. 4,09,00,000/-, M/S Olipha Trading & Investment Pvt. Ltd. Of Rs. 3,27,10,000/- & From M/S Sopan Merchants Pvt. Ltd. Of Rs. 92,35,000/- Which Companies Are Paper Companies & Made The Addition U/S 68 Of The Act Of The Entire Amount Of Loan Received From These Three Companies.

Section 139(1)Section 147Section 148Section 68

Before us, ld. CIT DR for the Revenue vehemently supported the order of the AO and submits that AO received an information from the Investigation Wing, Chandigarh that the assessee has taken huge amount of share premium and share capital from these three companies which are paper companies and controlled ... managed for providing accommodation entries. The ld. DR further submits that there were statements recorded of one Shri Pankaj Agarwal by the Investigation Wing, Kolkata wherein he has accepted that these companies were used for providing accommodation entries. He further submits that from the perusal of financial statements of these

Deputy Commissioner of Income Tax, Visakhapatnam vs. Sri Narasimharaju Kanumuri, Visakhapatnam

In the result, the appeal filed by the revenue in ITA No

ITA 267/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.267/Viz/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Deputy Commissioner Of Vs. Sri Narasimharaju Income Tax, Kanumuri, Visakhapatnam. Visakhapatnam. Pan: Aerpk2717F (Appellant) (Respondent)

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 195Section 201Section 201(1)

documents that were impounded DCIT vs. Sri Narasimharaju Kanumuri during the course of the survey proceedings and the sworn statements recorded by the Investigation Wing. The AO submitted that as the land originally belonged to the NRIs and that the assessee had admitted the payment

Saroj Devi Haldiya, Jaipur vs. ITO Ward-6(1), Jaipur

ITA 917/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Oct 2025AY 2015-16

For Appellant: Shri S.B. Natani, CAFor Respondent: Mrs.Anita Rinesh, JCIT-DR

Section 147Section 271(1)(c)Section 56(2)(ix)Section 57

matter detailed statements of husband of the assessee Shri Mahendra Kumar Haldiya were recorded on 16.05.2017. A copy of the statement recorded by the investigation wing is available on paper book page No... 2 to 8. The facts regarding the issue involved are enumerated hereunder chronologically. 1. Medical Design India ... Limited for sale of land situated at F-28 Malviya RIICO Industrial area, Jaipur. The learned AO has followed the report of the investigation wing as a thumb rule without application of mind. Before recording reasons the learned AO did not make any enquiry worth the name

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Karnani Solvex Private Limited, Jaipur

In the result, the appeals of the revenue in ITA No

ITA 480/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15

For Appellant: Shri Deepak Sharma, CAFor Respondent: MS. Alka Gautam, CIT

Section 127Section 132(4)Section 153ASection 68

record and the order of ITAT not being challenged on ground of perversity, no substantial question of law arises. It also held that the investigation wing directed the A O to frame the assessment in a manner that would protect the revenue’s interest. The A O performs a quasi