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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

Birendra Singh Nirbhay, Sirsi Road Jaipur Rajasthan vs. ITO Ward 3(1) Jaipur, Ncrb Income Tax Department Statue Circle Jaipur Rajasthan

In the result, the appeal of the assessee is allowed

ITA 704/JPR/2024[2015-16]Status: DisposedITAT Jaipur09 Oct 2025AY 2015-16
For Appellant: Shri Deepak Sharma, CAFor Respondent: Shri Shri Gautam Singh Choudhary, JCIT-DR
Section 10(38)Section 132(4)Section 69C

from penny stock and routed in the disguise of long term capital gain. The notice being issued on the basis of information received from investigation wing and produced the same "as it is "without looking the facts and documents possessed with the assessee proving its valid claim. The Assessing Officer ... beneficiaries namely Sh. Sanjeev Kumar Agarwal, Sh. Ajit Gupta, Sh. Charchit Gupta and others, who categorically admitted in their statements under oath before Investigation Wing of the department that they paid commission for getting bogus LTCG entries, prove it beyond doubt the entry operators charged commission for providing bogus entry

Nitu Khadariya, Jaipur vs. ITO Ward 1(3), Ncrb Building

In the result, the appeal of the assessee is allowed

ITA 1360/JPR/2024[2014-15]Status: DisposedITAT Jaipur09 Oct 2025AY 2014-15

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

For Appellant: Shri C.L. Yadav, CAFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR
Section 143(3)Section 144BSection 147Section 69A

contention of the assessee is not acceptable. The search and seizure action in the case of M/s Banka Group was carried out by the Investigation Wing of 3 SMT. NITU KHADARIYIA VS ITO,WARD 1(3), JAIPUR Department on 21.05.2018 resulting in to collection of evidences and recording ... dated 26-23-2019 that a search and seizure action in the case of M/s. Banka Group was carried out by the Investigation Wing of Department on 21-05-2018 resulting into collection of evidences and recording of the statements of various persons including Mukesh Banka. The Department noted that

Nitaben Girishbhai Patel, Ahmedabad vs. The ITO, Ward-3(3)(2), Ahmedabad

In the result, while upholding the validity of reopening, we set aside the ex parte order of the CIT(A) on merits and restore the matter to his file for fresh adjudication in accordance with law

ITA 1560/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad09 Oct 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Nitaben Girishbhai Patel The Ito, Ward-3(3)(2) 33/B, Swi Park, Private Plot Vejalpur Madhuvrund Society Ahmedabad. Ghatlodiya, Ahmedabad. Pan : Aappp 5738 F (Applicant) (Responent) : Shri Parimalsinh B. Parmar, Ar Assessee By : Shri B.P. Srivastava, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 06/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 09/10/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri B.P. Srivastava, Sr.DR
Section 144BSection 147Section 148Section 271ASection 69A

recorded by the AO, as placed in the paper book, reveal that the reopening was initiated on the basis of information received from the Investigation Wing pursuant to search action in the case of Kushal Group of Ahmedabad. The reasons specifically state that the assessee was a beneficiary of accommodation ... course of reassessment proceedings, and not while testing the validity of reopening. In the facts of the present case, the information received from the Investigation Wing, when read in conjunction with the assessee’s own disclosure of capital gains from sale of shares of M/s Kushal Ltd., clearly constituted tangible

Jayaram Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

In the result the appeal of the assessee is hereby partly allowed for statistical purposes

ITA 711/BANG/2025[2021-22]Status: DisposedITAT Bangalore09 Oct 2025AY 2021-22

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

laid out for personal pleasure but are wholly connected with the conduct of business. 7.3 The assessee also pointed out that the Investigation Wing did not provide any factual or circumstantial evidence to prove that the cars were used for non-business purposes. No working or material was furnished ... Investigation Wing to justify the disallowance. . ITA No.705 - 711/Bang/2025 Page 4 of 36 7.4 Further, the assessee submitted that while recording the statement he agreed to disallow total expenditure, including depreciation on these cars, amounts to approximately ₹5.46 crores over the years in question. But the impugned statement was given

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

ITA 710/BANG/2025[2020-21]Status: DisposedITAT Bangalore09 Oct 2025AY 2020-21

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

laid out for personal pleasure but are wholly connected with the conduct of business. 7.3 The assessee also pointed out that the Investigation Wing did not provide any factual or circumstantial evidence to prove that the cars were used for non-business purposes. No working or material was furnished ... Investigation Wing to justify the disallowance. 7.4 Further, the assessee submitted that while recording the statement he agreed to disallow total expenditure, including depreciation on these cars, amounts to approximately 5.46 crores over the years in question. But the impugned statement was given without verification of books of accounts

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

ITA 709/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

laid out for personal pleasure but are wholly connected with the conduct of business. 7.3 The assessee also pointed out that the Investigation Wing did not provide any factual or circumstantial evidence to prove that the cars were used for non-business purposes. No working or material was furnished ... Investigation Wing to justify the disallowance. 7.4 Further, the assessee submitted that while recording the statement he agreed to disallow total expenditure, including depreciation on these cars, amounts to approximately 5.46 crores over the years in question. But the impugned statement was given without verification of books of accounts

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

ITA 708/BANG/2025[2016-17]Status: DisposedITAT Bangalore09 Oct 2025AY 2016-17

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

laid out for personal pleasure but are wholly connected with the conduct of business. 7.3 The assessee also pointed out that the Investigation Wing did not provide any factual or circumstantial evidence to prove that the cars were used for non-business purposes. No working or material was furnished ... Investigation Wing to justify the disallowance. 7.4 Further, the assessee submitted that while recording the statement he agreed to disallow total expenditure, including depreciation on these cars, amounts to approximately 5.46 crores over the years in question. But the impugned statement was given without verification of books of accounts

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle 2(4), Bengaluru

ITA 706/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Oct 2025AY 2014-15

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

laid out for personal pleasure but are wholly connected with the conduct of business. 7.3 The assessee also pointed out that the Investigation Wing did not provide any factual or circumstantial evidence to prove that the cars were used for non-business purposes. No working or material was furnished ... Investigation Wing to justify the disallowance. 7.4 Further, the assessee submitted that while recording the statement he agreed to disallow total expenditure, including depreciation on these cars, amounts to approximately 5.46 crores over the years in question. But the impugned statement was given without verification of books of accounts

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax Central Cirlce-2(4), Bengaluru

ITA 705/BANG/2025[2013-14]Status: DisposedITAT Bangalore09 Oct 2025AY 2013-14

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

laid out for personal pleasure but are wholly connected with the conduct of business. 7.3 The assessee also pointed out that the Investigation Wing did not provide any factual or circumstantial evidence to prove that the cars were used for non-business purposes. No working or material was furnished ... Investigation Wing to justify the disallowance. ITA No.705 - 711/Bang/2025 Page 4 of 36 7.4 Further, the assessee submitted that while recording the statement he agreed to disallow total expenditure, including depreciation on these cars, amounts to approximately 5.46 crores over the years in question. But the impugned statement was given

DCIT, Central Circle 8(4), Mumbai vs. Akshat Vinimay Private Limited, Kolkata

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

ITA 1949/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Oct 2025AY 2014-15

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Dhaval ShahFor Respondent: Shri Rajesh Kumar Yadav (CIT-DR)
Section 132Section 143Section 143(3)Section 153ASection 250

seized during the search. The additions were made purely on the basis of the Project Falcon report and post- search investigations conducted by the Investigation Wing, Mumbai. The statements recorded under section 132(4) from the directors of the assessee also did not contain any admission or reference ... basis of Project – Falcon report and post search 20 ITA No.1949 /Mum/2025 & c.o. 94/Mum/2025 Akshat Vinimay Private Limited investigation conducted by the Investigation Wing, Mumbai. As strongly canvassed by Ld. DR during the course of hearing and also through the written submissions that on the basis of such investigation, where

Deputy Commissioner of Income Tax, Circle 3(1), Visakhapatnam vs. Vizag Re-Bars Private Limited, Visakhapatnam

In the result, the cross objection filed by the assessee is allowed

ITA 428/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.428/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2017-18) Dy. Cit – Circle – 3(1) Vs. M/S. Vizag Re-Bars Private Limited 35, 50-92-35, Sankara Matam Road Plot No. 1 Ida, Edulapaka Bonangi, Opposite Reliance Fresh Parawada Mandal – 531021 Beside Reliance Fresh, Near By Main Road Andhra Pradesh Madhuranagar, Dwaraka Nagar Visakhapatnam – 530016 [Pan:Aabcv2581M] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 10(38)Section 115JSection 143(3)Section 147Section 148Section 148A

16/VIZ/2024 M/s. Vizag Re-Bars Private Limited., across the country. On analysis of data found during the course of search/survey operation, the investigation wing identified the case of the assessee i.e. M/s. Vizag Re-Bars Pvt. Ltd. as one of beneficiaries in claiming bogus Long Term Capital Gain ... received in the “Insight Portal under the category High Risk CRIU/VRU Information” on 26.03.2021, regarding Naresh Jain and Others who were provided by the Investigation wing during the A.Y.2017-18. On the analysis of the above information, it was noticed by the Ld. AO that the quantum of incomes which

Paramjeet Singh, Yamuna Nagar vs. DCIT/ACIT, Central Circle (2), Chandigarh, DCIT/ACIT(Cen)-2

Appeal stands dismissed

ITA 204/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh08 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 204/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2018-19) Shri Paramjeet Singh Dcit-Central Circle-2 बनाम/ (C/O Rajiv Goel & Associates) Sector-17 Sco No 823-24, Sector 22-A Chandigarh-160017 Vs. Chandigarh-160022 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Astps-8898-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Dhruv Goel(Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) -Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 18-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 08/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)- 3, Gurgaon [Cit(A)] Dated 26-09-2022 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 153A Of The Act On 23-06-2021. The Sole Grievance Of The Assessee Is Confirmation Of Addition Of Rs.82.18 Lacs. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under.

For Appellant: Shri Dhruv Goel(CA) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) -Ld. AR
Section 132Section 153ASection 153D

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 Northern Royalty Company, Yamunanagar

Appeal stands dismissed

ITA 730/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh08 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No. 730/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19 Acit-Central Circle 2 M/S Northern Royalty Company बनाम/ Vs. Cr Building Sector 17 603-604, Model Town, Santpura Road Chandigarh-160017 Yamuna Nagar (Haryana) "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aalfn-9130-H (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Co. No. 38/Chandi/2024 [In Ita No. 730/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Northern Royalty Company Acit-Central Circle 2 बनाम/ 603-604, Model Town, Santpura Road Cr Building Sector 17 Vs. Yamuna Nagar (Haryana) Chandigarh-160017 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aalfn-9130-H (Cross-Objector) : (Respondent) Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr Assessee By : Shri Dhruv Goel (Ca)-Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 18-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 08/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax

For Appellant: Shri Dhruv Goel (CA)-Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 132Section 153C

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. Shri Karaj Singh, Yamuna Nagar

In the result, the revenue’s appeal ITA No

ITA 726/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh08 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No. 726/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19) Acit-Central Circle 2 Shri Karaj Singh बनाम/ Cr Building Sector 17 H. No 1379, Modern Colony, Near Iti Vs. Chandigarh 160017 Yamuna Nagar (Haryana) "ायीलेखासं./जीआइआरसं./Pan/Gir No. Atups-5528-A (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. Co. No. 16/Chandi/2024 [In Ita No. 726/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19) Shri Karaj Singh Acit-Central Circle 2 बनाम/ H. No 1379, Modern Colony, Near Iti, Cr Building Sector 17 Vs. Yamuna Nagar (Haryana) Chandigarh 160017 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Atups-5528-A (Cross-Objector) : (Respondent) Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr Assessee By : Shri Dhruv Goel (Ca) - Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 18-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 08/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal By Revenue For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)- 3, Gurgaon [Cit(A)] Dated 26-09-2022 In The Matter Of An Assessment

For Appellant: Shri Dhruv Goel (CA) - Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 143(3)Section 153Section 153ASection 153DSection 68

Central charges, all search and seizure assessments are regularly supervised and monitored by the range heads. One copy of appraisal report prepared by the investigation wing after conducting post search enquiries along with copies of the core seized documents is forwarded to Addl. CIT by the investigation wing. Thus, Addl ... 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

Pitti Holdings Private Limited, Hyderabad vs. ACIT., Central Circle-1(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 450/HYD/2025[2018-19]Status: DisposedITAT Hyderabad08 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

For Appellant: Shri A. Srinivas, C.AFor Respondent: Dr. Sachin Kumar, DR
Section 148Section 148A

procedure as prescribed u/s.148 and 148A of the Act. The Assessing Officer has 21 ITA.No.450/Hyd./2025 reproduced the details as received from the Investigation Wing as detected in search operation u/s.132 of the Act conducted in the case of M/s. Vamsiram Builders Pvt. Ltd. and group concerns, Hyderabad

Deputy Commissioner of Income Tax, Central Circle - 3(2), Kolkata vs. Eskag Sanjeevani Pvt. Ltd., Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 1638/KOL/2024[2019-20]Status: DisposedITAT Kolkata08 Oct 2025AY 2019-20

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Rajeeva Kumar, ARFor Respondent: Shri P.N. Barnwal, DR
Section 133(6)Section 139(1)Section 153ASection 68

recurring income to advance made to the assessee. The relied heavily on statement of Shri Manohar Lal Nangalia recorded on 14.11.2014, by the investigation wing, wherein he confirmed that the company is a shell company controlled by him for the purpose of ITA No. 1638 & 1639/KOL/2024 ESKAG Sanjeevani

Income Tax Officer, Piramal Chambers vs. Soni Ajay Jain, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3841/MUM/2025[2016-17]Status: DisposedITAT Mumbai08 Oct 2025AY 2016-17

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankar

For Appellant: Shri G. V. GindeFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 10(38)Section 147Section 148Section 148ASection 149Section 151Section 250

return of income on 23.07.2016, declaring a total income of Rs.8,94,490/-. Subsequently, on the basis of the information received from the Investigation Wing that the assessee is a beneficiary of accommodation entry transaction of bogus long term capital gains, the AO issued notice under section

Harendra Pratapray Doshi (HUF), Mumbai vs. ITO Ward 41(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3788/MUM/2025[2012-13]Status: DisposedITAT Mumbai08 Oct 2025AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Bhadresh Doshi, CAFor Respondent: Shri Hemanshu Joshi, (Sr. DR)
Section 143(2)Section 143(3)Section 147Section 292B

written confirmation in this regard from the broker M/s Sharekhan Ltd. However, the CIT(A) rejected the contention by observing that enquiries by the Investigation wing of the Department Ahmedabad revealed the above loss by CCM through its broker who carried out 8 precise transactions on 23.05.2011, thereby profit earned ... course of assessment proceedings, the AO has merely doubted transactions undertaken on the recognized stock exchange, primarily relying upon the report of the Investigation wing and has brushed aside the explanation of the assessee and the documentary evidences furnished. Further, the AO has not made any independent enquiry/verification during

Shri Parin Seventilal Shah, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 1(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3690/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Oct 2025AY 2013-14
Section 10(38)Section 143(3)Section 147Section 234ASection 254(1)Section 271(1)(c)Section 68

exempt u/s.10(38) treating the same as not genuine on the basis of information received from Insight portal and the Investigation reports of the Investigation Wing, Kolkata that certain operators and intermediaries had provided accommodation entries of bogus Long term capital gains using certain penny stock companies

ITO Ward - 1(2)(4), Meerut vs. Livros Publishing Pvt Ltd, Meerut

In the result, the appeal of the Revenue is dismissed

ITA 1971/DEL/2020[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2012-13 Income Tax Officer, Vs. M/S. Livros Publishing Pvt. Ward-1(2)(4). Ltd., 37, Chippi Tank, Meerut (U.P) Meerut Pan: Aabcl7313B (Appellant) (Respondent)

For Appellant: Shri Lalit Mohan, Adv. & Shri AnkitFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 142(1)Section 143(1)Section 143(2)Section 250Section 68

cash to a large number of beneficiary company through paper and dummy companies floated and controlled by them. This could be established by the investigation wing after careful examination of seized material, including computer hard disks and tally data which contained the books of accounts. The wing had enough evidences ... Apoorva Leasing Finance and Investment 6 Company Limited didn't had any credit worthiness of its own. The documents as provided by the Investigating wing clearly suggested that at one side the company operative were receiving the money in cash, depositing in their sister concern and then transferring