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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

Brand India Real Estate Private Limited, Jaipur vs. Income Tax Officer Ward 6(1), Jaipur

In the result, appeal of the assessee is allowed

ITA 514/JPR/2025[2012-2013]Status: DisposedITAT Jaipur29 Sept 2025AY 2012-2013
For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Dharam Singh Meena, JCIT
Section 132Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

case and in law the ld. CIT (A) grossly erred in re-opening and confirming the assessment on the basis of information received from Investigation wing, without providing the material evidence and statement recorded u/s 132 of the Act of Shri Mukwesh Banka during the search proceeding and without providing ... garb of share capital of including share premium from the following five companies which are proven paper/shell companies as per the reports of the investigation wing : S. No. Name of Company Shares Amount Allotted 1 Harsharatna Finance & Investment Pvt. Ltd 10,000 15,00,000 2 Liberal Infrastructure Private Limited

Ramamurthy Praveen Chandra, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

ITA 622/BANG/2025[2016-17]Status: DisposedITAT Bangalore29 Sept 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Sankar Ganesh D, Add. CIT(DR)(ITAT), Bangalore
Section 132Section 143Section 153Section 153ASection 153CSection 250

rightly disallowed after recording the statement and declaring in the statement the assessee has not retracted with the separate statement before the investigation wing. These expenditures are lump sum taken in the nature of annuity. Therefore, assessment has been rightly framed by the AO. The learned CIT(A) has also ... after passing the assessment order. In the instant case, the entire expenditures were debited into P & L Account and investigation wing has not found any documents which are not recorded in the books of accounts or not shown in the financial statements and earlier not disclosed with the Income

Ramamurthy Praveen Chandra, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

ITA 621/BANG/2025[2015-16]Status: DisposedITAT Bangalore29 Sept 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Sankar Ganesh D, Add. CIT(DR)(ITAT), Bangalore
Section 132Section 143Section 153Section 153ASection 153CSection 250

rightly disallowed after recording the statement and declaring in the statement the assessee has not retracted with the separate statement before the investigation wing. These expenditures are lump sum taken in the nature of annuity. Therefore, assessment has been rightly framed by the AO. The learned CIT(A) has also ... after passing the assessment order. In the instant case, the entire expenditures were debited into P & L Account and investigation wing has not found any documents which are not recorded in the books of accounts or not shown in the financial statements and earlier not disclosed with the Income

Ramamurthy Praveen Chandra, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

ITA 620/BANG/2025[2014-15]Status: DisposedITAT Bangalore29 Sept 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Sankar Ganesh D, Add. CIT(DR)(ITAT), Bangalore
Section 132Section 143Section 153Section 153ASection 153CSection 250

rightly disallowed after recording the statement and declaring in the statement the assessee has not retracted with the separate statement before the investigation wing. These expenditures are lump sum taken in the nature of annuity. Therefore, assessment has been rightly framed by the AO. The learned CIT(A) has also ... after passing the assessment order. In the instant case, the entire expenditures were debited into P & L Account and investigation wing has not found any documents which are not recorded in the books of accounts or not shown in the financial statements and earlier not disclosed with the Income

Ramamurthy Praveen Chandra, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

ITA 619/BANG/2025[2013-14]Status: DisposedITAT Bangalore29 Sept 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Sankar Ganesh D, Add. CIT(DR)(ITAT), Bangalore
Section 132Section 143Section 153Section 153ASection 153CSection 250

rightly disallowed after recording the statement and declaring in the statement the assessee has not retracted with the separate statement before the investigation wing. These expenditures are lump sum taken in the nature of annuity. Therefore, assessment has been rightly framed by the AO. The learned CIT(A) has also ... after passing the assessment order. In the instant case, the entire expenditures were debited into P & L Account and investigation wing has not found any documents which are not recorded in the books of accounts or not shown in the financial statements and earlier not disclosed with the Income

Ankur Chaudhary, Noida vs. DCIT, Central Circle-1, Noida

ITA 2139/DEL/2023[2017-18]Status: DisposedITAT Delhi29 Sept 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 132Section 132ASection 153Section 153D

fact that the as per the CBDT guideline F. No. 286/161/2006-IT (Inv. II) dt. 22.12.2006, copy of appraisal report is shared by Investigation Wing with both that the assessing officer and Joint CIT. In fact, CBDT guideline dt. 22.12.2006 (Copy enclosed) on the subject of the search and Seizure Assessments

Ankur Chaudhary, Noida vs. DCIT, Central Circle-1, Noida

ITA 2120/DEL/2023[2016-17]Status: DisposedITAT Delhi29 Sept 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 132Section 132ASection 153Section 153D

fact that the as per the CBDT guideline F. No. 286/161/2006-IT (Inv. II) dt. 22.12.2006, copy of appraisal report is shared by Investigation Wing with both that the assessing officer and Joint CIT. In fact, CBDT guideline dt. 22.12.2006 (Copy enclosed) on the subject of the search and Seizure Assessments

DCIT, Central Circle-1, Noida vs. Braj Pal Singh, Noida

ITA 2386/DEL/2022[2015-16]Status: DisposedITAT Delhi29 Sept 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 132Section 132ASection 153Section 153D

fact that the as per the CBDT guideline F. No. 286/161/2006-IT (Inv. II) dt. 22.12.2006, copy of appraisal report is shared by Investigation Wing with both that the assessing officer and Joint CIT. In fact, CBDT guideline dt. 22.12.2006 (Copy enclosed) on the subject of the search and Seizure Assessments

Sudesh Chaudhary, Noida vs. DCIT, Central Circle- 1, Noida

ITA 2229/DEL/2022[2017-18]Status: DisposedITAT Delhi29 Sept 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 132Section 132ASection 153Section 153D

fact that the as per the CBDT guideline F. No. 286/161/2006-IT (Inv. II) dt. 22.12.2006, copy of appraisal report is shared by Investigation Wing with both that the assessing officer and Joint CIT. In fact, CBDT guideline dt. 22.12.2006 (Copy enclosed) on the subject of the search and Seizure Assessments

Braj Pal Singh, Noida vs. DCIT, Central Circle-1, Noida

ITA 2228/DEL/2022[016-17]Status: DisposedITAT Delhi29 Sept 2025

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 153D

fact that the as per the CBDT guideline F. No. 286/161/2006-IT (Inv. II) dt. 22.12.2006, copy of appraisal report is shared by Investigation Wing with both that the assessing officer and Joint CIT. In fact, CBDT guideline dt. 22.12.2006 (Copy enclosed) on the subject of the search and Seizure Assessments

Sudesh Chaudhary, Noida vs. DCIT, Central Cercle-1, Noida

ITA 2227/DEL/2022[2015-16]Status: DisposedITAT Delhi29 Sept 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 132Section 132ASection 153Section 153D

fact that the as per the CBDT guideline F. No. 286/161/2006-IT (Inv. II) dt. 22.12.2006, copy of appraisal report is shared by Investigation Wing with both that the assessing officer and Joint CIT. In fact, CBDT guideline dt. 22.12.2006 (Copy enclosed) on the subject of the search and Seizure Assessments

Sudesh Chaudhary, Noida vs. DCIT, Central Circle-1, Noida

ITA 2226/DEL/2022[2014-15]Status: DisposedITAT Delhi29 Sept 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan R
Section 153D

fact that the as per the CBDT guideline F. No. 286/161/2006-IT (Inv. II) dt. 22.12.2006, copy of appraisal report is shared by Investigation Wing with both that the assessing officer and Joint CIT. In fact, CBDT guideline dt. 22.12.2006 (Copy enclosed) on the subject of the search and Seizure Assessments

Ajay Garg, Dehradun vs. ACIT Central Circle Dehradun, Dehradun

In the result, appeal of the assessee is partly allowed

ITA 200/DDN/2024[2015-2016]Status: DisposedITAT Dehradun26 Sept 2025AY 2015-2016

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 132(4)Section 139(1)Section 147Section 148Section 148(2)Section 151Section 250

case of the assessee is re-opened on vague reasons which were recorded without application of mind solely based on the information received from Investigation Wing that too with respect to the cash loan and not related to any undisclosed/ unaccounted for income. - 17. Looking to these facts and circumstances

Shri Vibhu Grover, Kotdwara vs. PCIT, Dehradun

In the result appeal of the assessee is allowed

ITA 110/DDN/2024[2015-16]Status: DisposedITAT Dehradun26 Sept 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalvibhu Grover, Pcit, M/S Grover Sales Corporation, Dehradun. Garage Road, Kotdwara, Vs. Pauri-246169 Pan:Agdpg5842R (Appellant) (Respondent) Assessee By Shri Anil Jain, Adv. Department By Shri S.K. Chaterjee, Cit-Dr

Section 142(1)Section 147Section 148Section 263

vehemently supported the orders of the lower authorities and submits that information was available with the Assessing Officer from the Investigation Wing, Faridabad that assessee had taken accommodation entries of purchases of Rs. 6.00 lacs through Sh. Sh. Manoj Kumar, Dayanand Parasar and Sh. Pawan Mishra from a firm ... these persons. 12. Now ld. PCIT alleged that the AO has not made sufficient enquiries on the basis of so called information supplied by Investigation Wing which contained details of transactions with Sh. Ganpati Enterprises. It is seen that the same is not borne out from the reason recorded

Neeraj Kumar Sethi, Delhi vs. ITO, National Faceless Appeal Centre (NFAC)

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

ITA 9/ASR/2024[2014-15]Status: DisposedITAT Amritsar26 Sept 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashwani Kalia, C.A
Section 139Section 143(3)Section 144BSection 147Section 148Section 250Section 68

Supertech forgings ( India ) Pvt. Ltd vs DCIT ( ITA 563 / ASR/ 2018 ) , to submit that firstly the reassessment has been made on borrowed satisfaction of investigation wing, secondly proceedings initiated on the basis of reasons to suspect and thirdly without allowing any opportunity of cross examination of Mr Ashok Kumar Gupta ... allowed the appeal of the assessee stating: "Thus, the entire disallowance in this case is based on third party information gathered by the Investigation Wing of the Department, which have not been independently subjected to further verification by the AO who has not provided the copy of such statements

Nasa Agro Industries Private Limited, Fazilka vs. Deputy Commissioner of Income Tax Circle-II, Bathinda

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 236/ASR/2023[2011-12]Status: DisposedITAT Amritsar26 Sept 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Y. K. Sud & Sh. P. K. Anand, CAs
Section 132Section 142(1)Section 143(3)Section 148Section 153cSection 250

found which can be related to the present assessee. 13. Only statement recorded at the time of search , has triggered the investigation by the investigation wing , and information forwarded to the AO , who applied his mind to the said information and carried out further investigation ( as apparent from para ... assessee submitted that in the instant case his objection is against the reopening on the basis of information passed on by the DDIT investigation wing and the contention of the assessee is that there has been no independent application of mind by the AO, to the information on record

Income Tax Officer, Surat vs. Saffron Green International Private Limited, Surat

In the result, appeal of revenue is partly allowed

ITA 958/SRT/2024[2018-19]Status: DisposedITAT Surat26 Sept 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.958/Srt/2024 Assessment Year: 2018-19 (Hybrid Hearing) Income Tax Officer, Ward- Saffron Green International Pvt. बनाम/ 2(1)(3), Surat, Room No.221, Ltd. Shop No.3008, Shree Mahavir Vs. 2Nd Floor, Aaykar Bhavan, Textiles Puna Kumbhariya Road, Majura Gate, Surat-395 001 Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aawcs 3137 M (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Deven K. Kapadia, Ca राज" की ओर से /Respondent By Shri Aashish Pophare, Cit-Dr सुनवाई की तारीख/Date Of Hearing 10/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 26/09/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: This Appeal By The Revenue Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act’) Dated 16.07.2024 By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [In Short, ‘The Cit(A)’] For The Assessment Year (Ay) 2018-19, Which In Turn Arises Out Of Assessment Order Passed By The Assessing Officer (In Short, ‘Ao’) U/S. 147 R.W.S 144 R.W.S 144B Of The Act On 21.03.2023. 2. Grounds Of Appeal Raised By The Revenue Are As Under: “I. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Restricting The Addition Made By The Assessing Officer Of Rs.5,70,70,621/- On Account Of 100% Bogus Purchase To 0.25% Of The Bogus Purchases & Allowing The Appeal Of The Assessee Ignoring The Facts That These Purchases Are Sham Transactions Fabricated Through Bogus Paper Concerns Of M/S. Savitri Trading Company & Mohammed Javed Mohammed Jabir Momin Which Were Engaged In Providing Accommodation Entries.

Section 147Section 250Section 250(2)

assessee company filed its return of income for A.Y.2018-19 on 30.10.2018 declaring total income at Rs.15,49,250/-. Information was received from the Investigation Wing, Kolkata that the assessee had made bogus purchases from M/s. Savitri Trading Company, Kolkata and Mohammed Javed Mohammed Jabir Momin (Prop. J.J. Textiles ... transactions between the appellant and the above 2 parties. The entire case of the AO rests only on the information received from the Investigation Wing. However, appellant submitted all necessary documents for verification from which it is evident that appellant had received the goods and same have been consumed

Dy.Commissioner of Income Tax, CC-2, Kanpur vs. Shri.Mohammad Asfand Akhtar, Kanpur

In the result, the appeal of Revenue in ITA

ITA 144/LKW/2022[2018-19]Status: DisposedITAT Lucknow26 Sept 2025AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2018-19 Dcit, Cc-2 V. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar V. Dcit, Central Circle-Ii Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Ashish Jaiswal, AdvocateFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 143(3)Section 36(1)(va)Section 37Section 41Section 41(1)Section 68Section 69C

course of assessment proceedings for A.Y. 2016-17, a commission u/s 131 of the Act was issued on 27-02- 2018 to the Kolkata Investigation Wing to submit a report on the following points:- 1. Identity, genuineness of the transactions and creditworthiness of the companies in respect of unsecured loans ... companies mentioned in the commission but summons were returned un served by the postal authority. Further, Inspector was also deputed by the Investigation Wing, Kolkata to make enquiry for the existence of the company but no company was found at their given address as mentioned on MCA site. The scanned

Mohd. Asfand Akhtar, Kanpur vs. Deputi Commissioner of Income Tax CC-2, Kanpur

In the result, the appeal of Revenue in ITA

ITA 139/LKW/2022[2018-19]Status: DisposedITAT Lucknow26 Sept 2025AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2018-19 Dcit, Cc-2 V. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar V. Dcit, Central Circle-Ii Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Ashish Jaiswal, AdvocateFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 143(3)Section 36(1)(va)Section 37Section 41Section 41(1)Section 68Section 69C

course of assessment proceedings for A.Y. 2016-17, a commission u/s 131 of the Act was issued on 27-02- 2018 to the Kolkata Investigation Wing to submit a report on the following points:- 1. Identity, genuineness of the transactions and creditworthiness of the companies in respect of unsecured loans ... companies mentioned in the commission but summons were returned un served by the postal authority. Further, Inspector was also deputed by the Investigation Wing, Kolkata to make enquiry for the existence of the company but no company was found at their given address as mentioned on MCA site. The scanned

Income Tax Officer, Ward-3(3)(1), Ahmedabad vs. Ambalia Hitesh Chhaganlal HUF, Ahmedabad

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

ITA 1429/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad26 Sept 2025AY 2017-18

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

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri B.P. Srivastava, Sr DR
Section 115BSection 147Section 148Section 148ASection 151Section 250Section 68

lead case. 3. The case was reopened u/s 147 of the Act on the basis of information received from the Investigation Wing pursuant to a search and seizure operation conducted on the Kushal Group on 05.02.2019. During reassessment proceedings, the Assessing Officer treated the LTCG