IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI, JM AND SHRI ARUN KHODPIA, AM ITA No. 3759/Mum/2024 (Assessment Year: 2018-19)

Deputy Commissioner of Income MGN Agro Properties Private Tax, Mumbai Limited

4^th Floor, Welspun House, Senapati Vs.

Bapat Marg, Lower Parel, Delisle Road, S.O. Mumbai – 400013.

PAN/GIR No. AAGCA6127M (Appellant) : (Respondent Assessee by : Shri Harsh Kapadia a/w. Shri Ajay Nagpal Respondent by : Shri Umashankar Prasad, (CIT DR)

Date of Hearing : 01.09.2025 Date of Pronouncement : 03.09.2025

O R D E R

Per Arun Khodpia, AM:

The captioned appeal filed by the revenue is directed against the order of Commissioner of Income Tax (Appeals), CIT(A) 51, Mumbai, (in short ‘ld. CIT(A)’), passed u/s.250 of the Income Tax Act, 1961 (in short ‘the Act'), dated 29.05.2024, for the Assessment Year (in short ‘A.Y.’) 2018-19 which in turn arises from the assessment order u/s. 147 r.w.s. 144 of the Act passed by Deputy Commissioner of Income Tax, Central Circle 3(3), Mumbai, dated 31.03.2023.

2. The grounds of appeal raised by the revenue are extracted as under:

"On the facts and in the circumstances of the case, the Ld. CIT(A) erred in deleting the add