MAHADHAN AGRITECH LIMITED (FORMERLY KNOWN AS SMARTCHEM TECHNOLOGIES LIMITED ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE -8(1), MUMBAI

ITA 3937/MUM/2024Status: DisposedITAT Mumbai24 July 2025AY 2019-20Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)120 pages
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What did the Tribunal hold?

The Tribunal held that the NPK Fertiliser Unit qualifies as a specified business under Section 35AD, and incidental use of assets does not violate the provisions. Minor stock differences were deemed not a basis for disallowance, and Section 14A cannot be applied when no exempt income is earned.

What were the facts?

The assessee filed appeals against orders confirming disallowances made during search assessments and regular assessments. Key issues involved disallowances related to inflated capital expenditure, depreciation on goodwill, and stock differences.

What were the issues?

Whether disallowances made under Section 153A were justified without incriminating material, and whether claims for deduction under Section 35AD and Section 14A were valid.

Which sections of the Income-tax Act were involved?

Section 153A,Section 132,Section 69A,Section 35AD,Section 115JB,Section 14A,Section 133A

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Income Tax Appellate Tribunal, ‘D’ BENCH

Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWAL

Heard together (2 matters)

ITA No.2228/Mum/2024
ITA No.3937/Mum/2024

Read from the judgment's own cause title. This page is filed under one of them.

PER AMIT SHUKLA (J.M): The aforesaid appeals have been filed by the assessee against separated impugned order dated 31.03.2024 for AY 2016-17 to AY 2018-19, order dated 27.06.2024 for AY 2019-20 and order dated 30.08.2024 for AY 2020-21, passed by the Ld. Commissioner of Income-tax (Appeals) – 50, Mumbai [in short CIT(A)‟].

The appeals for AY 2016-17 to AY 2018-19 are arising out of search assessment order passed u/s 153A of Income-tax Act, 1961 (in short „the Act‟). App

The order continues below.

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