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2025 Supreme(Online)(ITAT) 2849

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
OM PRAKASH KANT, AM
Mahadhan Agritech Ltd. (Formerly known as Smartchem Technologies Ltd.) – Appellant
Versus
Revenue – Respondent


Advocates:
For the Appellants/Petitioners:
For the Respondents:

Table of Content
1. groundes of appeal regarding reassessment. (Para 1)
2. assessment year and initial income filing. (Para 2)
3. disputes regarding depreciation and claims. (Para 3 , 4)
4. fresh claims and limitations under section 153a. (Para 5)
5. challenges regarding specific disallowances and additions. (Para 8)
6. final judgments on claims and appeal outcomes. (Para 9)

PER OM PRAKASH KANT, AM

This appeal by the assessee is directed against order dated 31.03.2024 passed by the Ld. Commissioner of Income-tax (Appeals) — 50, Mumbai [in short ‘the Ld. CIT(A)] for assessment year 2015-16 in relation to search assessment order passed u/s 153A of the Income-tax Act,1961 (in short ‘the Act). The grounds raised in its appeal by the assessee are reproduced as under:

1(a) That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming the disallowances made in the order u/s 153A in utter disregard of the express provisions of the Act since no incriminating material has been found during the course of search and seizure carried out us 132 of the Act.

1(b) That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was

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