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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

Mehta Karyana Store, Yamuna Nagar vs. Income Tax Officer, Ward-3, Yamuna Nagar

In the result, appeal of the Assessee is allowed

ITA 371/CHANDI/2025[2014-2015]Status: DisposedITAT Chandigarh03 Sept 2025AY 2014-2015

Bench: The Ld. Cit(A). The Ld. Cit(A), After Obtaining A Remand Report From The Assessing Officer Had Confirmed The Addition Made By The Assessing Officer.

For Appellant: Shri Dhruv Goel, C.AFor Respondent: Smt. Tarundeep Kaur, CIT, DR (Virtual Mode)
Section 147Section 68Section 69A

partnership firm, filed its return declaring income of Rs. 1,69,330/-. The case was reopened on the basis of information from the Investigation Wing alleging accommodation entries in the name of Shri Ashok Kumar Gupta, proprietor of M/s Gayatri Maa Enterprises and M/s Ridhi Sidhi Impex. The AO framed

Dilipkumar Sohanlal Maheshwari, Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 29/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad03 Sept 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2015-16

Section 10(38)Section 142Section 143Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 68

Rs.39,21,390/-, which was processed under Section 143(1) of the Act. Subsequently, the Assessing Officer had received an information from the Investigation wing that the assessee was a beneficiary of penny stock investment in the shares of M/s. Vandana Knitwear. Therefore, a notice under Section

Parsan Brothers, Kolkata vs. DCIT, Circle 36, Kolkata

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

ITA 795/KOL/2025[2013-2014]Status: DisposedITAT Kolkata03 Sept 2025AY 2013-2014

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 148Section 250Section 69C

carrying out any independent enquiry and the Ld. AO made the addition u/s 69C based on surmises and on a report drawn by the Investigation Wing of the Department. Hence, it is prayed that the addition made u/s 69C be directed to be deleted [Relief Claimed - Deletion ... booking in the Books of Account of your appellant. Instead of following such course of action simply based on an information received from the Investigation Wing of the Department the notice u/s 148 was issued and also the assessment order was passed u/s 143(3) /147

Aviral Marketing Pvt. Ltd., Kolkata vs. DCIT, Circle 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1423/KOL/2025[2012-2013]Status: DisposedITAT Kolkata03 Sept 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Aviral Marketing Pvt. Ltd…….……………..............................……….……Appellant 7, Camac Street, Azimganj House, 1St Floor, Shakespeare Sarani, Kol- 700017. [Pan: Aacca3794N] Vs. Dcit, Circle-4(1), Kolkata……………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Appellant. Shri Ruchika Sharma, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 02, 2025 Date Of Pronouncing The Order : September 03, 2025 Order Per Rajesh Kumar: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

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

based on the said reasons may be quashed. Besides, the ld. counsel argued that the Assessing Officer has acted as borrowed satisfaction of the investigation wing and has not recorded his own satisfaction. In defence of his argument, the ld. counsel has relied on the decision of PCIT vs. Meenakshi

Deputy Commissioner of Income Tax, Mumbai vs. Mgn Agro Properties Private Limited, Mumbai

In the result, the appeal filed by the revenue has been rendered as dismissed, in terms

ITA 3759/MUM/2024[2018-19]Status: DisposedITAT Mumbai03 Sept 2025AY 2018-19

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Harsh Kapadia a/w. Shri AjayFor Respondent: Shri Umashankar Prasad, (CIT DR)
Section 132(4)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 69A

letter of Mr. Hotwani submitted on 01.01.2018, it is clearly explained that he had applied for copy of his statements recorded by the Investigation Wing during the search, however, till the submission of the letter of retraction, such statements were never provided to him, therefore, the delay has occurred

Edynamics Solutions Limited, Laxmi Nagar vs. Assessing Officer Ward 8 (1), Cr Building ITO

In the result the appeal is dismissed

ITA 1391/DEL/2024[AY 2012-13]Status: DisposedITAT Delhi03 Sept 2025

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2012-13 Edynamics Solutions Limited, Vs. Assessing Officer, 103 First Floor, Plot No.2, Ward 8(1), Tiriveni Complex, Veer Savarkar Delhi Block, Shakarpur, City, Pin: 1100 02 New Delhi-1100 92 Pan :Aaace7849N (Appellant) (Respondent)

Section 143(2)Section 147Section 148Section 250Section 251

After examination of the information given by the assessee company in its original ITR and the evidence contained in the reports of the Investigation Wing conveyed to this office, proceedings under Section 147 of the Act were initiated in the case of assessee by recording reasons and satisfaction that income ... amply clear that Ld. CIT(A) in para nos. 5.1 to 5.5 observed as under “5.1 The information received in this case from the Investigation Wing and on perusal of the assessee's bank statement obtained under the provisions of section 133(6) of the IT Act from the assessee

Ismail Abdulaziz Lakhani, Bhavnagar vs. ITO, Ward-1(1), Bhavnagar

In the result, appeal filed by the assessee is allowed

ITA 803/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2014-15

Bench: the same were transferred through registered broker, on the floor of the recognized stock exchange, after suffering Security Transaction Tax and ultimately settled through proper banking channel) as unaccounted income under Section 68 of the Act amounting to Rs.1,51,12,000/-.

For Appellant: Shri Sarju Mehta, A.RFor Respondent: Shri Sudhakar Verma, Sr. DR
Section 10(38)Section 132Section 133ASection 143(3)Section 147Section 148Section 250Section 68Section 69C

reiterating the findings of the AO at para 6.2.1 as under: 6.2.1 Finding & Decision: The case has been reopened based on the report from Investigation Wing stating that the appellant was one of the beneficiaries in the transaction of claim of long term capital gains as exempt. The claim ... through synchronised trading within limited parties, mostly entities controlled by the entry operators. 7. Statement recorded during search or survey operations conducted by the investigation wing clearly established the fact that price of the shares is manipulated with the sole aim of providing bogus Capital Gain or Loss. 8.Failure

Dharmishthaben Nareshkumar Soni, Ahmedabad vs. ITO Ward 4(2)(1) Ahmedabad, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1127/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Vivek Chavda, ARFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 115BSection 133(6)Section 139Section 143(1)Section 147Section 148ASection 250Section 69

erred in law and on facts in upholding the addition made merely on the basis of information received from the investigation wing without any independent verification of facts and without providing the appellant an opportunity to rebut the same. 3.1 The Ld. CIT(A) has erred in law and/or

Manubhai Babalbhai Patel, Vadodara vs. The ITO, Ward-1(2)(1), Vadodara

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

ITA 605/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DRFor Respondent: Shri R P Rastogi, CIT-DR
Section 144BSection 147Section 250Section 69A

assessee is an individual and he did not file his income tax return for the Assessment Year 2016–17. Based on information from the Investigation Wing regarding unaccounted investments of ₹3,32,62,000/- during the year, the Assessing Officer reopened the assessment under Section 147 of the Income

Income Tax Officer-27(3)(1) Mumbai, Vashi vs. Sachin Velji Shah, Mumbai

Appeal of the revenue is dismissed

ITA 1938/MUM/2023[2014-15]Status: DisposedITAT Mumbai02 Sept 2025AY 2014-15

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Swapnil Choudhary, Sr. DRFor Respondent: Shri Prakash Jhunjhunwala, AR
Section 10(38)Section 132(4)Section 133(6)Section 143(3)Section 250Section 68Section 69C

made by the A.O. under section 68 being sale proceeds of shares on the basis of report of Investigation Wing Kolkata that the scrip of Surabhi Chemicals and Investments Limited was suspicious penny stock and the price of this share was rigged artificially to provide bogus entries of long term ... heard the parties and perused the record. We notice that the assessing officer has primarily placed reliance on the report given by the Investigation wing of the Income tax department, Kolkata to arrive at the conclusion that the long term capital gains reported by the assessee is bogus in nature

Pritiben Jagdishbhai Mehta, Rajkot vs. The Pr. Commissioner of Income Tax-1, Rajkot

In the result, appeal filed by the assessee is allowed

ITA 333/RJT/2024[2015-16]Status: DisposedITAT Rajkot01 Sept 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Vipul Dattani, Ld. A.RFor Respondent: Shri Sanjay Pungalia, Ld. CIT(DR)
Section 147Section 263

provide the opportunity of cross examination regarding details reported on AIMS module of ITBA portal, whether the information was reported based on any Investigation Wing Report / Statement of any person reported by Income Tax Department. However, no such information was shared with assessee. Hence in absence of providing opportunity

Deputy Commissioner of Income Tax Central Circle-2, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 360/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh01 Sept 2025AY 2020-21

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos.356, 357, 358 & 360/Chd/2024 निर्धारण वर्ष / A.Y. : 2016-17, 2017-18, 2019-20 & 2020-21 The Dcit, Central Circle-2, Ludhiana. Vs Ab Alcobev Pvt. Ltd., 154, 1St Floor, Aggarwal Plaza-1, Anandvas Shakurpur, North West, Delhi. अपीलार्थी/Appellant स्थायी लेखा सं./Pan No: Aalca0327J प्रत्यर्थी/Respondent & C.O. Nos.17 To 20/Chd/2025 In

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5

JCIT is involved with the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing, still, the ld. JCIT, while granting the approval u/s 153D of the Act has to independently apply his mind dehors the conclusions drawn either by the Investigation Wing ... appraisal report or by the Ld. AO in the draft assessment order. The copy of the appraisal report submitted by the Investigation Wing to the Ld. AO and ld. JCIT are merely guidance to the Ld. AO and are purely internal correspondences on which the assessee does not have

Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 358/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh01 Sept 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos.356, 357, 358 & 360/Chd/2024 निर्धारण वर्ष / A.Y. : 2016-17, 2017-18, 2019-20 & 2020-21 The Dcit, Central Circle-2, Ludhiana. Vs Ab Alcobev Pvt. Ltd., 154, 1St Floor, Aggarwal Plaza-1, Anandvas Shakurpur, North West, Delhi. अपीलार्थी/Appellant स्थायी लेखा सं./Pan No: Aalca0327J प्रत्यर्थी/Respondent & C.O. Nos.17 To 20/Chd/2025 In

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5

JCIT is involved with the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing, still, the ld. JCIT, while granting the approval u/s 153D of the Act has to independently apply his mind dehors the conclusions drawn either by the Investigation Wing ... appraisal report or by the Ld. AO in the draft assessment order. The copy of the appraisal report submitted by the Investigation Wing to the Ld. AO and ld. JCIT are merely guidance to the Ld. AO and are purely internal correspondences on which the assessee does not have

Deputy Commissioner of Income Tax Central Circle-2, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 357/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh01 Sept 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos.356, 357, 358 & 360/Chd/2024 निर्धारण वर्ष / A.Y. : 2016-17, 2017-18, 2019-20 & 2020-21 The Dcit, Central Circle-2, Ludhiana. Vs Ab Alcobev Pvt. Ltd., 154, 1St Floor, Aggarwal Plaza-1, Anandvas Shakurpur, North West, Delhi. अपीलार्थी/Appellant स्थायी लेखा सं./Pan No: Aalca0327J प्रत्यर्थी/Respondent & C.O. Nos.17 To 20/Chd/2025 In

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5

JCIT is involved with the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing, still, the ld. JCIT, while granting the approval u/s 153D of the Act has to independently apply his mind dehors the conclusions drawn either by the Investigation Wing ... appraisal report or by the Ld. AO in the draft assessment order. The copy of the appraisal report submitted by the Investigation Wing to the Ld. AO and ld. JCIT are merely guidance to the Ld. AO and are purely internal correspondences on which the assessee does not have

Deputy Commissioner of Income Tax Central Circle-2 Ludhiana, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 356/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh01 Sept 2025AY 2016-17

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos.356, 357, 358 & 360/Chd/2024 निर्धारण वर्ष / A.Y. : 2016-17, 2017-18, 2019-20 & 2020-21 The Dcit, Central Circle-2, Ludhiana. Vs Ab Alcobev Pvt. Ltd., 154, 1St Floor, Aggarwal Plaza-1, Anandvas Shakurpur, North West, Delhi. अपीलार्थी/Appellant प्रत्यर्थी/Respondent स्थायी लेखा सं./Pan No: Aalca0327J & C.O. Nos.17 To 20/Chd/2025 In

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5

JCIT is involved with the search assessment proceedings right from the time of receipt of appraisal report from the Investigation Wing, still, the ld. JCIT, while granting the approval u/s 153D of the Act has to independently apply his mind dehors the conclusions drawn either by the Investigation Wing ... appraisal report or by the Ld. AO in the draft assessment order. The copy of the appraisal report submitted by the Investigation Wing to the Ld. AO and ld. JCIT are merely guidance to the Ld. AO and are purely internal correspondences on which the assessee does not have

Deputy Commissioner of Income Tax, Central Circle-4(2), Kolkata, Aayakar Bhawan Poorva vs. Dharmendra Singh, Kolkata

Appeal of the revenue is allowed

ITA 1433/KOL/2024[2012-13]Status: DisposedITAT Kolkata01 Sept 2025AY 2012-13

Bench: The Hon’Ble Itat Received From The Office Of The Pr. Cit, Central-2, Kolkata 26.06.2024 Filed 2Nd Appeal U/S 253 Before The Hon’Ble Itat, Kolkata

For Respondent: “Dates
Section 143(1)Section 147Section 148Section 250Section 253Section 68

total income at Rs.44,49,200/-. The said return was processed u/s 143(1) of the Act, 1961. Thereafter, an information was received from Investigation Wing, Kolkata regarding a Survey action conducted on an entry operator. Further, after examining the data and evidence on records, this case was reopened

Deputy Commissioner of Income Tax, Circle-1(1)(1), Mumbai vs. Gm Modular Private Limited, Mumbai

ITA 2942/MUM/2025[2019-20]Status: DisposedITAT Mumbai01 Sept 2025AY 2019-20

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Ms. Padmavathy S, Hon’Bledy. Cit Circle 1(1)(1), G M Modular Private Limited, Mumbai 405 Shalimar Morya Park Vs. Premises Chs Ltd., Off. New Link Road, Andheri, Azad Nagar S.O, Mumbai 400 053. Pan Aabcg3313Q (Appellant) (Respondent)

For Appellant: Shri Swapni Choudhary- Sr. DRFor Respondent: Shri Rushabh Mehta
Section 142(1)Section 68Section 69C

brief facts necessary for the disposal of the present appeal are that during the relevant year the Assessing Officer had received information from Investigation Wing, Mumbai and “Insight Portal” indicating that the respondent assessee was beneficiary of bogus unsecured loans taken from M/s. Aneri Fincap

Dawn Chemicals, Rajkot vs. ACIT, Circle-2(1), Rajkot

The appeal of the assessee is allowed for statistical purpose

ITA 332/RJT/2024[2009-10]Status: DisposedITAT Rajkot29 Aug 2025AY 2009-10

Bench: Dr. Arjun Lal Saini & Shri Diesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 147Section 148Section 44ASection 68

Corporation Ltd (hereinafter referred as to the "BCCL"] and statements of Shri Prakash Bagrecha director was recorded by the Assistant Commissioner of Income-tax, Investigation Wing Circle-1(2), , Rajkot (hereinafter referred as to the "AO"] alleged that director of above companies were indulge in business of providing accommodation entries ... wherein minor addition was made on the ground of non- deduction of tax at source. On the basis of information received from Investigation wing by AO that in search proceeding carried out at the business premises of one Shri Prakash Bagrecha, a director of M/s. Bhumidev Credit Corporation Ltd. (hereinafter

The ACIT, Central Circle-2, Rajkot vs. Shri Bhagvanji Prabhubhai Amrutiya, Morbi

In the result, cross objection filed by the assessee, ( in CO No

ITA 142/RJT/2021[2019-20]Status: DisposedITAT Rajkot29 Aug 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.139/Rjt/2021 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Expert Particle Board बनाम Cent.Cir.2, Rajkot. Survey No.111, 8-A National Vs. Highway B/H. Bharatinagar Iti, Ravapar Nadi Morbi 363 642. Pan : Aahfe 0299 G आयकर अपील सं /.Ita No.142/Rjt/2021 With Cross Objection No.05/Rjt/2022 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Bhagvaji Prabhubhai बनाम Cent.Cir.2, Rajkot. Amrutiya, Meera Park-2 Vs. House No.1, Vavdi Road Morbi. Pan : Aiwpa 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 05/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/08/2025 Order Per, Dr. Arjun Lal Saini: The Captioned Two Appeals Filed By The Revenue Pertaining To Assessment Year 2019-20 & The Cross Objection Filed By The Assessee, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income-Tax

For Appellant: Shri Mehul Ranpura, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 133ASection 143(3)Section 37Section 69ASection 69B

circumstances of the case and in law, AO has duly investigated and applied his mind on the report of the DDIT, Investigation wing and after satisfying himself in framing the assessment on the basis of cogent material and relevant evidence on record. ACIT Vs. Expert Particle Board and Others ... have carried out any transaction as per noting made in the said impounded diary. Shri Bhagwanjibhai Amruitya in his reply furnished before the investigation wing as well as in his affidavit dated 16.05.2019 stated the reasons behind maintaining such diary, i.e., window-dressing book results of the firm in order

The ACIT, Cen. Cir.-2, Rajkot vs. Expert Particle Board, Morbi

In the result, cross objection filed by the assessee, ( in CO No

ITA 139/RJT/2021[2019-20]Status: DisposedITAT Rajkot29 Aug 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.139/Rjt/2021 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Expert Particle Board बनाम Cent.Cir.2, Rajkot. Survey No.111, 8-A National Vs. Highway B/H. Bharatinagar Iti, Ravapar Nadi Morbi 363 642. Pan : Aahfe 0299 G आयकर अपील सं /.Ita No.142/Rjt/2021 With Cross Objection No.05/Rjt/2022 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Bhagvaji Prabhubhai बनाम Cent.Cir.2, Rajkot. Amrutiya, Meera Park-2 Vs. House No.1, Vavdi Road Morbi. Pan : Aiwpa 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 05/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/08/2025 Order Per, Dr. Arjun Lal Saini: The Captioned Two Appeals Filed By The Revenue Pertaining To Assessment Year 2019-20 & The Cross Objection Filed By The Assessee, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income-Tax

For Appellant: Shri Mehul Ranpura, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 133ASection 143(3)Section 37Section 69ASection 69B

circumstances of the case and in law, AO has duly investigated and applied his mind on the report of the DDIT, Investigation wing and after satisfying himself in framing the assessment on the basis of cogent material and relevant evidence on record. ACIT Vs. Expert Particle Board and Others ... have carried out any transaction as per noting made in the said impounded diary. Shri Bhagwanjibhai Amruitya in his reply furnished before the investigation wing as well as in his affidavit dated 16.05.2019 stated the reasons behind maintaining such diary, i.e., window-dressing book results of the firm in order