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Harvest Agriculture Private Limited Vs. ITO Ward 2(1)(3)

Case No: ITA No. 7393/Mum/2025, ITA No. 7395/Mum/2025, ITA No. 7396/Mum/2025
Court: Income Tax Appellate Tribunal, 'E' Bench Mumbai
Date: 1/21/2026

Parties Involved

appellantHarvest Agriculture Private Limited
respondentITO Ward 2(1)(3)

Facts Summary

The assessee, Harvest Agriculture Private Limited, is a private limited company. For the assessment years 2019-20, 2021-22, and 2022-23, the original assessments were completed under section 143(1) of the Income-tax Act, 1961. Subsequently, based on information received from the Investigation Wing, Mumbai, following a search and survey action on Invent Assets Securitisation and Reconstruction Pvt. Ltd. and its group concerns, the Assessing Officer initiated reassessment proceedings under section 148 of the Act. The Assessing Officer treated certain loans and advances as unexplained cash credits under section 68 of the Act and made additions accordingly. The assessee explained that the transactions were recorded in its books and supported by documentary evidence, but the Assessing Officer was not satisfied. The appeals before the CIT(A) were disposed of ex parte as the assessee did not file written submissions or supporting material.

Decision in favour of

Assessee

Legal Issues

  • 1. Ex parte disposal by the CIT(A)
  • 2. Validity of reopening under section 148
  • 3. Confirmation of additions under section 68
  • 4. Consequential penalty proceedings

Judgment Outcome

Decided in favour of Assessee.

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