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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

DCIT, Circle- 1(1)(1), Ahmedabad vs. B Chokshi Chem Pvt Ltd, Ahmedabad

In the result, all the appeals of the Revenue stand dismissed

ITA 332/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Sunil Talati, ARFor Respondent: Shri Abhijit, Sr.DR
Section 132Section 147

carryout in the case of one Gujarat Polysol Chemicals Ltd. (GPCL). During the search action, certain incriminating material were found from which the Investigation Wing observed that the said GPCL was indulged in bogus purchases for the purpose of reducing its tax liability. It was found that some

Shree Saraswati Education Sansthan, Mehsana vs. The ITO, Exemption, Palanpur

The appeal of the assessee is hereby allowed

ITA 2210/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.2210/Ahd/2024 िनधा"रण वष" /Assessment Year : 2016-17 Shree Saraswati Education The Ito (Exemption) बनाम/ Sansthan Palanpur – 385 001 V/S. At & Post Rajpur Taluka Kadi Mehsana – 382 740 (Gujarat) "थायी लेखा सं./Pan: Aaits 3179 G (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Divyakant Parikh, Ar Revenue By : Shri R.P. Rastogi, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 20/08/2025 घोषणा की तारीख /Date Of Pronouncement: 28/08/2025 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 02/12/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2016-2017. Shre Saraswati Education Sansthan Vs. Ito(E) Asst.Year : 2016-17 2

For Appellant: Shri Divyakant Parikh, ARFor Respondent: Shri R.P. Rastogi, CIT-DR
Section 147Section 250

escaped assessment. The AO, despite of the records furnished before him, simply made the impugned addition solely based on the information received from the Investigation Wing. Though the initial information, in our view, may have triggered the AO to make necessary verifications and to examine the accounts of the assessee

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

In the result, all the three appeals by the Revenue are dismissed

ITA 616/MUM/2025[2014-15]Status: DisposedITAT Mumbai28 Aug 2025AY 2014-15

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Vimal Punamiya, CAFor Respondent: Mr. Virabhadra S. Mahajan, Sr. DR
Section 143(3)Section 68Section 69Section 69C

Assessing Officer took an adverse view on expression of this inability by the assessee. He relied on the findings of the Investigation Wing, Kolkata in the case of Shri Praveen Agarwal where it was held that the said companies were used for providing accommodation entries and thus, completed the assessment ... Keeping the direction of the Coordinate Bench in the context, it is noted that ld. Assessing Officer has based his findings on the investigation wing in the case of Shri Praveen Agarwal. No new evidence has been brought on record by the ld. Assessing Officer to prove that the loans

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

In the result, all the three appeals by the Revenue are dismissed

ITA 613/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Aug 2025AY 2012-13

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Vimal Punamiya, CAFor Respondent: Mr. Virabhadra S. Mahajan, Sr. DR
Section 143(3)Section 68Section 69Section 69C

Assessing Officer took an adverse view on expression of this inability by the assessee. He relied on the findings of the Investigation Wing, Kolkata in the case of Shri Praveen Agarwal where it was held that the said companies were used for providing accommodation entries and thus, completed the assessment ... Keeping the direction of the Coordinate Bench in the context, it is noted that ld. Assessing Officer has based his findings on the investigation wing in the case of Shri Praveen Agarwal. No new evidence has been brought on record by the ld. Assessing Officer to prove that the loans

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

In the result, all the three appeals by the Revenue are dismissed

ITA 612/MUM/2025[2011-12]Status: DisposedITAT Mumbai28 Aug 2025AY 2011-12

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Vimal Punamiya, CAFor Respondent: Mr. Virabhadra S. Mahajan, Sr. DR
Section 143(3)Section 68Section 69Section 69C

Assessing Officer took an adverse view on expression of this inability by the assessee. He relied on the findings of the Investigation Wing, Kolkata in the case of Shri Praveen Agarwal where it was held that the said companies were used for providing accommodation entries and thus, completed the assessment ... Keeping the direction of the Coordinate Bench in the context, it is noted that ld. Assessing Officer has based his findings on the investigation wing in the case of Shri Praveen Agarwal. No new evidence has been brought on record by the ld. Assessing Officer to prove that the loans

DCIT-2(1)(1), Mumbai vs. Inventure Growth & Securities Limited, Mumbai

In the result, the appeal of the Revenue is dismissed and the cross-objection of the assessee is also dismissed

ITA 4163/MUM/2025[2013-14]Status: DisposedITAT Mumbai28 Aug 2025AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 10(38)Section 115JSection 143(3)Section 144Section 147Section 148Section 148ASection 68

initially scrutinised under section 143(3), and assessment was completed at ₹2,35,10,210/-. 5. Subsequently, based on information emanating from the Investigation Wing under ―Project Bogus Long-Term Capital Gain,‖ the case was reopened. The general information suggested that many assessees across the country had availed accommodation entries ... plain reading of the reassessment order, it becomes apparent that the Assessing Officer was unduly influenced by the general report of the Investigation Wing on penny stock transactions. He applied the modus operandi described therein, almost mechanically, without pausing to examine the peculiar facts of the assessee‘s case

Nalin Jayantilal Shah, Mumbai vs. ITO Ward 34(3)(5), Mumbai

In the result, appeal of the assessee is allowed

ITA 1235/MUM/2025[2013-14]Status: DisposedITAT Mumbai28 Aug 2025AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Suchek Anchaliya, CAFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 143(3)Section 147Section 148Section 68

entries provided by concerns controlled by Bhavarlal Jain/Praveen 4 Nalin Jayantilal Shah AY 2013-14 Kumar Jain and family members as established by the investigation wing of the department. He thus, made the addition u/s. 68 as unexplained cash credit. 4.2. In the first appeal before ... explanation given thereon. Admittedly, it is a fact on record that ld. Assessing Officer had proceeded on the basis of information received from the investigation wing of the department. Details called for in the course of assessment proceedings were placed on record by the assessee for which index

Shakuntalam Investment and Leasing Limited, New Delhi vs. ACIT, Central Circle-01, New Delhi

ITA 135/DEL/2021[2016-17]Status: DisposedITAT Delhi28 Aug 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Shri R.P. Mall, AdvocateFor Respondent: Ms Monika Singh, CIT-DR
Section 143(3)Section 153ASection 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

Rnam Finlease Pvt. Ltd., New Delhi vs. ITO, Ward- 15(1), New Delhi

The appeals of the assessee are allowed

ITA 7969/DEL/2019[2006-07]Status: DisposedITAT Delhi28 Aug 2025AY 2006-07

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Shri Abhishek Mathur, CAFor Respondent: Ms Harpreet Kaur Hansra, Sr. DR
Section 132Section 147Section 148Section 151Section 68

vehemently defended the issue by submitting that reasons are based on independent examination of information ITAs No.7968 & 7969/Del/2019 and not just the report of investigation wing. What we find is that at page Nos.334 to 336 the copy of reasons recorded u/s 147 is provided. The same is in fact ... same. It is very much apparent from the reasons that it is merely a narration of the content of information received from the Investigation Wing. The reasons mentioned about escapement of income of Rs.45 lakhs on the basis of accommodation entries. However, what was the nature of accommodation entry

Rnam Finlease Pvt. Ltd., New Delhi vs. ITO, Ward- 15(1), New Delhi

The appeals of the assessee are allowed

ITA 7968/DEL/2019[2005-06]Status: DisposedITAT Delhi28 Aug 2025AY 2005-06

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Shri Abhishek Mathur, CAFor Respondent: Ms Harpreet Kaur Hansra, Sr. DR
Section 132Section 147Section 148Section 151Section 68

vehemently defended the issue by submitting that reasons are based on independent examination of information ITAs No.7968 & 7969/Del/2019 and not just the report of investigation wing. What we find is that at page Nos.334 to 336 the copy of reasons recorded u/s 147 is provided. The same is in fact ... same. It is very much apparent from the reasons that it is merely a narration of the content of information received from the Investigation Wing. The reasons mentioned about escapement of income of Rs.45 lakhs on the basis of accommodation entries. However, what was the nature of accommodation entry

Rnam Finlease Pvt. Ltd., New Delhi vs. ITO, Ward- 20(3), New Delhi

The appeals of the assessee are allowed

ITA 7895/DEL/2018[2010-11]Status: DisposedITAT Delhi28 Aug 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Shri Abhishek Mathur, CAFor Respondent: Ms Harpreet Kaur Hansra, Sr. DR
Section 132Section 147Section 148Section 151Section 68

vehemently defended the issue by submitting that reasons are based on independent examination of information ITAs No.7968 & 7969/Del/2019 and not just the report of investigation wing. What we find is that at page Nos.334 to 336 the copy of reasons recorded u/s 147 is provided. The same is in fact ... same. It is very much apparent from the reasons that it is merely a narration of the content of information received from the Investigation Wing. The reasons mentioned about escapement of income of Rs.45 lakhs on the basis of accommodation entries. However, what was the nature of accommodation entry

ACIT, New Delhi vs. Sh. Vipin Kapur, New Delhi

ITA 3788/DEL/2014[2010-11]Status: DisposedITAT Delhi28 Aug 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Shri Ved Jain, Advocate &For Respondent: Ms Monika Singh, CIT-DR
Section 144Section 153DSection 254(1)

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

Deputy Commissioner of Income Tax, Circle 1(1)(1), Dehradun, Rajpur Road vs. Hotel Surbhi Palace India Private Limited, Rajpur Road, Dehradun

In the result, the Appeal of the Revenue is dismissed

ITA 191/DDN/2024[2018-19]Status: DisposedITAT Dehradun27 Aug 2025AY 2018-19

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

Section 143(3)Section 144BSection 28Section 35D

registered with ROC, Delhi and the names of those Companies do not appear in the list of apparent shell companies as prepared by the Investigation Wing at Kolkata, accordingly, deleted the addition, which is our opinion requires no interference in the absence of any contrary material or facts brought

Income Tax Officer, Ward-2(1)(2), Aayakar Bhavan Vejalpur vs. Vipul Jagdishbhai Patel(HUF), Naranpura Ahmedabad

In the result, the appeal filed by the Revenue is dismissed and CO filed by the assessee is allowed

ITA 1324/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad27 Aug 2025AY 2012-13

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1324/Ahd/2025 A/W. Cross Objection No. 59/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2012-13) बनाम/ Income Tax Officer Vipul Jagdishbhai Patel Ward-2(1)(2), Ahmedabad (Huf) Vs. A-302, Aryan-2, Nr. Kabir School, B/H. St. Xaviers School, Naranpura, Ahmedabad, Gujarat - 380013 & Vipul Jagdishbhai Patel Income Tax Officer (Huf) Ward-2(1)(2), A-302, Aryan-2, Nr. Kabir Ahmedabad School, B/H. St. Xaviers School, Naranpura, Ahmedabad, Gujarat - 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaghv7848P (Appellant / Cross Objector) .. (Respondent) Assessee By : Shri Kirit P Shah, A.R. Revenue By : Shri Nitin Kulkarni, Sr. Dr Date Of Hearing 19/08/2025 Date Of Pronouncement 27/08/2025 O R D E R The Present Appeal Of The Revenue & Cross Objection Of The Assessee Are Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), Addl/Jcit (A)-1, Siliguri (Hereinafter Referred To As “Cit(A)”), Dated 30.03.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As The “Act”) & Relate To Assessment Year (A.Y.) 2012-13. Ita No. 1324/Ahd/2025 A/W. Co No. 59/Ahd/2025 [Vipul Jagdishbhai Patel (Huf)] A.Y. 2012-13 - 2 – 2. The Appeal Of The Assessee Is Delayed For Filing By 16 Days. The Ao Has Explained The Cause Of Delay As Being Preoccupied In Pressing Matters Including Time Barring Matters, High Court Matters & Others. Considering The Smallness Of The Delay, We Consider It Fit To Condone The Delay. Order Was Pronounced In The Open Court.

For Appellant: Shri Kirit P Shah, A.RFor Respondent: Shri Nitin Kulkarni, Sr. DR
Section 132Section 143(1)Section 147Section 250

deletion of the addition made during reassessment. Examination of the assessment order reveals that AO has relied solely on the report sent by the investigation wing. In that report, account no the beneficiary was given to be 226101100618 stated to be belonging to the present appellant. However, the fact ... others, accommodation entry provider group of ahmedabad' In the above stanza, AO has referred to the existence of some cogent evidence received from the investigation wing but it remains to be stated how the evidence can be reliably used against the assessee when there is no mention of the bank

DCIT, Circle-7(1), Delhi vs. Sumita Siddhartha, Uttar Pradesh

In the result, both the appeals filed by the Revenue are dismissed

ITA 991/DEL/2025[2017-18]Status: DisposedITAT Delhi27 Aug 2025AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Ms. Sumita Siddhartha, Self (assessee)For Respondent: Ms. Amisha S. Gupt, CIT DR
Section 148

rightly deleted the additions made by the Assessing Officer in AYs 2016-17 and 2017-18 considering the fact that information received from Investigation Wing is relating to AY 2015-16 only. Accordingly, she prayed that the appeals preferred by the Revenue may be dismissed. 4. On the other hand ... represented the case during assessment proceedings, the Assessing Officer proceeded to make the same addition in all the three assessment years even though the Investigation Wing forwarded the requisite information which is relating to AY 2015-16 only. Since the Assessing Officer has proceeded to make the same addition

DCIT, Circle-7(1), Delhi vs. Sumita Siddhartha, Uttar Pradesh

In the result, both the appeals filed by the Revenue are dismissed

ITA 990/DEL/2025[2016-17]Status: DisposedITAT Delhi27 Aug 2025AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Ms. Sumita Siddhartha, Self (assessee)For Respondent: Ms. Amisha S. Gupt, CIT DR
Section 148

rightly deleted the additions made by the Assessing Officer in AYs 2016-17 and 2017-18 considering the fact that information received from Investigation Wing is relating to AY 2015-16 only. Accordingly, she prayed that the appeals preferred by the Revenue may be dismissed. 4. On the other hand ... represented the case during assessment proceedings, the Assessing Officer proceeded to make the same addition in all the three assessment years even though the Investigation Wing forwarded the requisite information which is relating to AY 2015-16 only. Since the Assessing Officer has proceeded to make the same addition

Income Tax Officer Ward 52(1) New Delhi, New Delhi vs. M/S Novel Infratech, New Delhi

In the result appeal of the revenue is dismissed

ITA 188/DEL/2025[2013-14]Status: DisposedITAT Delhi27 Aug 2025AY 2013-14

Bench: Shri M. Balaganesh & Shri Sudhir Kumarito, Vs. M/S. Novel Infratech, Ward-52(1), Flat No. 915, Indra Prakash New Delhi Building, 21, Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aajfn0187A

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 131(1)(d)Section 133(6)Section 143(3)Section 68

were residing in Mumbai but replies were filed by persons from Delhi. The ld AO also issued commission u/s 131(1)(d) to Kolkata Investigation Wing who made enquiries with some of the lender companies. The Kolkata Investigation Wing suggested that the lender company had admitted that they were providing ... post office with identical replies. M/s. Novel Infratech The Assessing Officer has also stated that summons u/s 131 were issued to the parties by Investigation Wing Kolkata. The Assessing Officer based on the investigation wing report of Kolkata and relying upon the Income Tax Inspector Report had concluded that

Income Tax Officer, Income Tax Department vs. Mahavir Singhal, Delhi

In the result, the appeal filed by the revenue and cross objection filed by the assessee are dismissed

ITA 3428/DEL/2024[2014-15]Status: DisposedITAT Delhi27 Aug 2025AY 2014-15

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2014-15 Ito Vs. Mahavir Singhal Delhi 149, Tarun Enclave, Pitampura, Delhi-34 Pan No.Aixps8088B (Appellant) (Respondent) C.O. No.411/D/2025 (In Ita No.3428/Del/2024) Assessment Year: 2014-15 Mahavir Singhal Vs. Ito 149, Tarun Enclave, Delhi Pitampura, Delhi-34 Pan No.Aixps8088B (Appellant) (Respondent)

Section 10(38)Section 142Section 143Section 69C

during the FY 2013-14 by ignoring the fact that the information, enquiries, studies and analysis done by the Investigation wing of the department clearly depicting the fact that M/s Kailash Auto Finance Limited is BSE listed Penny Stock Company. 2. The Ld. CIT(A) erred ... during the FY 2013-14 by ignoring the fact that the information, enquiries, studies and analysis done by the Investigation wing of the department clearly depicting the fact that M/s Kailash Auto Finance Limited is BSE listed Penny Stock Company. 3 3. The Ld. CIT(A) erred

Mahayana Theravada Vajrayana Buddhist Religious and Chaitable Trust, Meerut vs. ACIT Central Circle, Meerut

ITA 1709/DEL/2024[2015-16]Status: DisposedITAT Delhi27 Aug 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Manoj Tiwari, Sr. DR
Section 142(1)Section 143(3)Section 147Section 68

Hans Kumar who is an accommodation entry provider. Relevant to mention that such reopening was done on the basis of an information received from Investigation Wing. The assessee duly filed return of income on 27.01.2021 against the said notice dated 08.01.2021 disclosing loss at Rs.40,54,83,624/-. Questionnaire dated ... Rs.29,43,610/-. Subsequently, notice under Section 148 of the Act was issued on 08.01.2021 reopening the assessment on the basis of information from Investigation Wing on the ground that assessee company has taken accommodation entry of Rs.82 lakhs by transferring unaccounted money from various layers of accounts

Mahayana Theravada Vajrayana Buddhist Religious and Charitable Trust, Meerut vs. ACIT Central Circle, Meerut

ITA 1708/DEL/2024[2013-14]Status: DisposedITAT Delhi27 Aug 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Manoj Tiwari, Sr. DR
Section 142(1)Section 143(3)Section 147Section 68

Hans Kumar who is an accommodation entry provider. Relevant to mention that such reopening was done on the basis of an information received from Investigation Wing. The assessee duly filed return of income on 27.01.2021 against the said notice dated 08.01.2021 disclosing loss at Rs.40,54,83,624/-. Questionnaire dated ... Rs.29,43,610/-. Subsequently, notice under Section 148 of the Act was issued on 08.01.2021 reopening the assessment on the basis of information from Investigation Wing on the ground that assessee company has taken accommodation entry of Rs.82 lakhs by transferring unaccounted money from various layers of accounts