“investigation wing”

ReassessmentSection 147Section 14712,584 judgments

The decision most relied on for investigation wing is Sarthak Securities Co. Pvt. Ltd. v. ITO (329 ITR 110), cited in 217 judgments on BharatTax.

Leading authorities on investigation wing

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.

PCIT v. M/s. Kesoram Industries 57

417 ITR 334 · 2019 · High Court

citing judgments

An assessment completed under Section 143(3) cannot be reopened after four years solely based on third-party information or opinions, such as from an Investigation Wing, without the Assessing Officer applying their own independent mind to the material and having new, independent material on record.

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.

Aradhna Estate Pvt. Ltd. v. DCIT

91 Taxmann.com 119 · 2018 · High Court

citing judgments

The Assessing Officer is justified in reopening assessment proceedings based on information received from the Investigation Wing, even when recording findings also rely on documents already on record, provided all procedural requirements for reassessment are met.

Judgments citing investigation wing

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1592/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh10 Mar 2026AY 2019-20

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1230/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1592/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 10.03.2026 : आदेश / O R D E R Per Bench 1.1 Aforesaid Cross-Appeals For Assessment Year (Ay) 2019-20Arises Out Of An Order Passed By Ld. Commissioner Of Income Tax (Appeals)-3

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –

Section 115BSection 132Section 153A(1)(b)Section 153DSection 65BSection 68

such, no reliance can be placed on such unsigned ‘welcome letters’ (c) The Ld. CIT(A) has brushed aside the enquiries made by the investigation wing from the persons who had purchased he SCOs / DSS and nothing adverse has been admitted by such persons and there was no incriminating evidence ... same would prove receipt of excess sale consideration in cash. 2.8 For external validation, summons was issued by investigation wing to one Shri Santokh Singh who purchased a showroom DSS-99 in joint ownership and his statement was recorded. He confirmed having made payment in two parts i.e., one part

Saraf the Jewellers, Chandigarh vs. The Deputy/Assistant Commissioner of Income Tax Cen-2 Chandigarh, Chandigarh

Appeal stand dismissed

ITA 1230/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh10 Mar 2026AY 2019-20

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –

Section 115BSection 132Section 153A(1)(b)Section 153DSection 65BSection 68

Infinity International, Ahmedabad vs. NFAC, Delhi Present Juris. the ITO, Ward-3(3)(1), Ahmedabad

In the result, appeal of the assessee is dismissed

ITA 518/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalinfinity International, Nfac, Delhi Vs. H-611, Titanium City Centre, Present Jurisdiction 100 Ft. Anandnagar Road, Ito, Ward 3(3)(1), Satellite, Ahmedabad-380015 Ahmedabad [Pan: Aaefi 2610 J] (Appellant) .. (Respondent) Appellant By: Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ar Respondent By: Shri Alpesh Parmar, Cit-Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 10.03.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 147Section 148Section 153(3)Section 250Section 68

assessment was reopened pursuant to notice issued u/s 148 dated 31.03.2021 on the basis of information received from the Investigation Wing that the assessee had received accommodation entries in the garb of unsecured loans from M/s Orange Tradex Pvt. Ltd. amounting to Rs. 586,98,84,146/- and from ... filed appeal before the Ld. CIT(A). The Ld. CIT(A) upheld the validity of reopening holding that tangible material in the form of Investigation Wing report, statement of Shri Chandresh Vyas and field enquiry constituted sufficient basis for formation of belief. On merits, the Ld. CIT(A), after considering

Shri Rajesh M. Makwana, Ahmedabad vs. The ITO, . Ward-2(2)(4), Ahmedabad

In the result, both the appeals are allowed

ITA 1535/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2007-08

Bench: Ms. Suchitra Kambleita Nos. 1534 & 1535/Ahd/2019 Assessment Year 2007-08

For Appellant: Shri Biren Shah and Shri Gulab Thakor, ARsFor Respondent: Shri Umesh Kumar Agrawal, Sr. D.R

Section 143(3)Section 271Section 271(1)(c)Section 69

company via banking channel. The ld. A.R. submitted that there was no investment and it was purely an accommodation entry as per the Investigation Wing Report. Since the substantive addition in the hands of Adarsh Engitech Projects Pvt. Ltd. was deleted, nowhere in the said order it was stated that

Shri Rajesh Manilal. Makwana, HUF, Ahmedabad vs. The Income Tax Officer, Ward-2(2)(4), Ahmedabad

In the result, both the appeals are allowed

ITA 1534/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2007-08

Bench: Ms. Suchitra Kambleita Nos. 1534 & 1535/Ahd/2019 Assessment Year 2007-08

For Appellant: Shri Biren Shah and Shri Gulab Thakor, ARsFor Respondent: Shri Umesh Kumar Agrawal, Sr. D.R

Section 143(3)Section 271Section 271(1)(c)Section 69

Siddheshwar Gems, Surat vs. ITO, Ward-3(3)(1), Surat

In the result, the appeal of the assessee stands allowed

ITA 860/SRT/2025[2018-19]Status: DisposedITAT Surat09 Mar 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.860/Srt/2025 िनधा"रण वष" /Assessment Year : 2018-19 Siddheshwar Gems The Ito बनाम Plot No.263 Ward-3(3)(1) / First Floor Surat – 395 001 V/S. Gayatrinagar Housing Society Nr. Rachna Soc. L.H. Road Kapodra, Surat – 395 006 "थायी लेखा सं./Pan: Actfs 1753 M (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Shri P.M. Jagasheth, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2025 घोषणा की तारीख /Date Of Pronouncement: 09/03/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 20/06/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Years (Ays) 2018-19. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Siddheshwar Gems Vs. Ito Asst. Year : 2018-19

For Appellant: Shri P.M. Jagasheth, CAFor Respondent: Shri Ajay Uke, Sr.DR

Section 147Section 148Section 250Section 271ASection 68

17/10/2018 of Rs.84,780/- for the year under consideration. As per information through Insight Portal of the Department in respect of enquiry conducted by Investigation Wing for the Financial Year (FY) 2017-18 relevant to AY 2018-19, the assessee had entered into transactions of Rs.22,85,010/- with M/s.Namo

ACIT CC 7(3), Mumbai vs. Nop Properties Private Limited, Mumbai

In the result, the appeal of Revenue is dismissed

ITA 7648/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Mar 2026AY 2012-13

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarassistant Commissioner Of V/S. Nop Properties Private Income Tax, Central Circle – बनाम Limited 7(3), Room No. 655, 6Th Floor, Office No. Ii-B, Mezzanine Aayakar Bhavan, M.K. Road, Floor, 289 Emca House, Shahid Mumbai – 400 020, Bhagat Singh Road, Fort, Maharashtra Mumbai – 400 001, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcn1799B Appellant/अपीलाथी .. Respondent/प्रतिवादी

For Appellant: Shri Rahul Punmiya, ARFor Respondent: Shri Brajendra Kumar (Sr. DR)

Section 132Section 143(3)Section 147Section 148Section 68

proper supporting evidences for authenticity of transactions u/s.68 of the Act demonstrating that the transaction was not sham though as per report of the Investigation Wing of the Department, Kolkata the amount received by the assessee from KCPL was sham transaction. It was observed that identity, creditworthiness or genuineness ... Properties Private Limited, Mumbai assessee. The addition was made by u/s. 68 of the Act, primarily relying on the information received from the investigation wing and statements. He concluded that the repayment, coupled with the documentary evidence on record, sufficiently established the nature of the transaction, the identity

Govind Corporation, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3233/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Mar 2026AY 2012-13

Bench: Smt. Beena Pillai & Shri Girish Agrawal

Section 143(3)Section 148Section 234Section 234BSection 251(2)Section 69A

private limited company. The Company has been aggregating land parcels in and around Dhokawade for over a decade. 6. On 7th October, 2021, the Investigation Wing of the Department conducted a search and survey action under section 132 of the Act at the premises of the Sekseria Group of Companies

Govind Corporation, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3229/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Smt. Beena Pillai & Shri Girish Agrawal

Section 143(3)Section 148Section 234Section 234BSection 251(2)Section 69A

Vimal Todi, Indore vs. Additional Commissioner of Income Tax, Indore

Appeal is allowed

ITA 188/IND/2024[2012-13]Status: DisposedITAT Indore06 Mar 2026AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshishri Vimal Todi, Additional Commissioner बनाम/ 501, Darshan Residency, Of Income-Tax, Vs. 104-105, Anand Bazar, Indore Indore

Section 132Section 254(2)Section 271DSection 275Section 275(1)(c)

this satisfaction of the AO as revealed from the reference letter is based on the information and document received from the Investigation Wing, Jaipur. Therefore, even if the said correspondence is considered as part of the proceedings of investigation carried out by the Jaipur Investigation Wing in case of Shri ... Sehgal, the limitation will reckon when the said investigation proceedings were completed and thereafter the information was sent by the Investigation Wing to the AO of the assessee. The Hon'ble Jurisdictional High Court in case of CIT vs. M.A. Presstressed Works 220 ITR 226 (Raj.) has considered the aspect

DCIT, CC-2(3), Kolkata vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2922/KOL/2025[2022-23]Status: DisposedITAT Kolkata06 Mar 2026AY 2022-23

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 148Section 250Section 68

noted that Shri Deepak Goel, could not prove the identity and genuineness of the transactions, despite being provided sufficient opportunities and time by the Investigation Wing. Now, the ld. AO relying on the report of the investigation wing and also issuing notice ... before the AO as well as before the ld CIT(A). The AO has simply made addition on the basis of report of the investigation wing without doing any enquiry himself whereas the ld CIT(A) has passed a very reasoned and speaking order while deleting the addition. Besides

DCIT, CC-2(3), Kolkata vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2921/KOL/2025[2020-21]Status: DisposedITAT Kolkata06 Mar 2026AY 2020-21

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 148Section 250Section 68

Income Tax Officer, Ward-3(1), Kolkata vs. A J Cast Alloys Private Limited, Howrah

ITA 1685/KOL/2024[2011-12]Status: DisposedITAT Kolkata06 Mar 2026AY 2011-12

Section 132(1)Section 133(6)Section 143(1)Section 147Section 148Section 250Section 69C

which was processed u/s 143(1) of the Act. Thereafter, the case of the assessee was reopened by the AO after receiving information from Investigation Wing following a search and seizure action u/s 132(1) of the Act on Sanjiw Kumar Singh a well known entry operator which revealed that ... perusal of the above reasons we find that the AO has referred to the information received from the investigation wing and thereafter, noted that the assessee was provided accommodation entries in the form of bogus billing, loans and advances by the entities controlled and managed by Sh. Sanjiw Kumar Singh

Suresh Kumar Poddar, Kolkata vs. I.T.O., Ward - 63(4), Kolkata

In the result, appeal of the assessee is allowed

ITA 1542/KOL/2024[2011-2012]Status: DisposedITAT Kolkata06 Mar 2026AY 2011-2012

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 111ASection 132Section 132(1)Section 139(1)Section 144Section 147Section 148Section 153CSection 250Section 250o

case and violated the principles of natural justice, by accepting the actions of the Ld. A.O. of not providing the information received from the investigation wing and by not providing an opportunity to cross-examine the persons whose statement were relied upon at the time of making the additions

Jayesh Kanungo HUF, Khetwadi, Mumbai vs. ITO-19(2)(1), Parel, Mumbai

In the result, the appeal of the assessee is allowed

ITA 6855/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Mar 2026AY 2014-15

Bench: Shri. Bijayananda Prusethjayesh Kanungo Huf Ito -19(2)(1), Mumbai 203, Rajgiri Apartment, A Wing, Vs. Piramal Chambers, Lalbaug, 13Thkhetwadi Back Road, Mumbai Parel Mumbai 400012 400004 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabhj8492E (Appellant) (Respondent)

For Appellant: Shri. Rajkumar Singh a/w. Ms. Asifa KhanFor Respondent: Shri. Nakul Agrawal Sr. DR

Section 10(38)Section 127Section 143(2)Section 143(3)Section 148Section 250Section 68Section 69C

holding for more than one year. 3. That the addition made u/s.68 and confirmed solely on the basis of general findings of report of Investigation Wing but without bringing any shred of adverse evidence in respect of subject transaction on assessment record is contrary to tax law provisions and more

Income Tax Officer-4(1), Raipur, Central Revenue Building vs. Mohammad Ibrahim, Prop Janta Sanitation

In the result, this appeal of Revenue is allowed for statistical purposes

ITA 698/RPR/2025[2022-23]Status: DisposedITAT Raipur05 Mar 2026AY 2022-23

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 698/Rpr/2025 (िनधा"रण वष" Assessment Year: 2022-23) Income Tax Officer, Ward - 4(1), Vs Mohammand Ibrahim, Aayakar Bhawan, Civil Lines, Ring Road No. 1, Pachpedinaka Raipur- 492001, C.G. Raipur- 492001, C.G. Pan: Aigpm6755J (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : None राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 घोषणा की तारीख / Date Of : 05/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: The Appeal For Assessment Year (‘Ay’) 2022-23 Filed By The Revenue Is Directed Against The Order Dated 08.09.2025 Of The Commissioner Of Income Tax (Appeals) [Cit(A)], National Faceless Appeal Centre (“Nfac”), Delhi.

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 132Section 132(4)Section 148Section 69C

Shree Balaji Enterprises, etc. The assessee is one of the beneficiaries of such accommodation entries. Based on the said information received from the Investigation Wing of UP, the Ld. Assessing Officer (‘AO’) reopened the case of 2 Income Tax Officer-4(1), Raipur vs. Mohammad Ibrahim assessee. In response

Somasundaram Vigneshwaran, Madurai vs. ACIT (Central Circle) -1, Mudarai, Madurai

In the result, the appeal of the assessee is dismissed

ITA 1728/CHNY/2025[2022-23]Status: DisposedITAT Chennai04 Mar 2026AY 2022-23

Bench: Shri S.S. Viswanethra Ravi & Ms. Padmavathy, S.आयकर अपील सं./I.T.A. No.1728/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 Somasundaram Vigneshwaran, Vs. The Assistant Commissioner Of Meenakshi Kovil Street, Income Tax, Sri Meenakshi Complex, 1St Floor, Central Circle 1, Madurai 625 001. Madurai. [Pan: Akppv0081K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 25.02.2026 घोषणा की तारीख /Date Of Pronouncement : 04.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai For The Assessment Year 2022-23. 2. When The Appeal Was Taken Up For Hearing, None Appeared On Behalf Of The Assessee Nor Filed Any Adjournment Petition. On Examination Of The Record, It Is Noted That The Assessee Filed This Appeal On 14.06.2025 & After Scrutiny, The Registry, Itat Chennai Benches Issued Notice

For Appellant: NoneFor Respondent: Shri Shiva Srinivas, CIT

Section 131Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 69A

four bags containing cash amounting to Rs.2.94 crores. Shri S. Vigneshwaran claimed that the entire amount belonged to him. Following this, the Income Tax Investigation Wing, Madurai, was informed, and summon u/s 131 of the Act, were issued to all four individuals. During the enquiry, sworn statements were recorded. Shri

Jorss Bullion Pvt Ltd, Mumbai vs. Dy Commissioner of Income Tax -Central Circle 7(1), Mumbai

ITA 4758/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Mar 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain& Shri Omkareswar Chidara

Section 69C

ITAT Delhi in ITA No.4163/Del/2014 dated 01.09.2016. The catch-note is reproduced as under: "Section 147- Reopening merely based on a report received from Investigation Wing is not permissible if AO has not examined such evidences. It is merely a case of reopening based on "Borrowed satisfaction". (iv) PCIT ... under: "Section 147-Reopening based on "Borrowed satisfaction" is impermissible. Here, AO resorted to reopening merely on the basis of report received from the Investigation Wing without any independent application of mind at his end. (v) Harikishan SunderlalVirmani V/s. DCIT394 ITR 146 (Guj). The catch-note is reproduced as under

DCIT, Central Circle 7(1), Mumbai vs. Jorss Bullion Private Limited, Mumbai

ITA 4004/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Mar 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain& Shri Omkareswar Chidara

Section 69C

DCIT-7(1)(1), Mumbai vs. Monsher Fire Protection Systems Private Limited, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 7002/MUM/2025[2011-12]Status: DisposedITAT Mumbai27 Feb 2026AY 2011-12

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethdcit – 7(1)(1) Vs. Monsher Fire Protection Systems Pvt. Ltd. Room No. 126, 1St Floor, 403, Tantia Jogani Estate 403, Tantia Aayakar Bhavan, M.K. Jogani Estate, Off. N.M. Joshi Marg, Next Road, To Lodha, Pavilion, Lower Parel, Mumbai - 400020 Mumbai-400011 Pan/Gir No: Aaccm4650R (Appellant) (Respondent) Appellant By None Respondent By Shri Akhtar Hussain Ansari, (Sr. Dr) Date Of Hearing 23.02.2026 Date Of Pronouncement 27.02.2026 O R D E R Per Bijyananda Pruseth, Am:

Section 143(3)Section 147Section 250Section 69C

made u/s 69C of the IT Act towards bogus purchases ignoring that in consequence to the evidences gathered during the investigation conducted by the investigation wing, Mumbai, the non genuine nature of these transactions is clearly emerged.?" 2. The Ld. CIT (A)'s order is contrary