ESTATE OF VANDRAVAN P SHAH,MUMBAI vs. ASSISTANT COMISSIONER OF INCOME TAX, CIRCLE 19(3), MUMBAI

ITA 5401/MUM/2024Status: DisposedITAT Mumbai23 December 2025AY 2011-12Bench: SANDEEP GOSAIN (Judicial Member), SHRI OM PRAKASH KANT ( (Accountant Member)21 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee failed to provide necessary documentary evidence and certificates to substantiate the eligibility of the donee institutions for deduction under Section 80GGA. Therefore, the claim for deduction was not sustainable.

What were the facts?

The assessee claimed deduction under Section 35AC and Section 80GGA for donations made to certain trusts. The Assessing Officer disallowed the deduction, treating the donations as non-genuine due to lack of proper documentation and eligibility certificates. The CIT(A) upheld the disallowance.

What were the issues?

The primary issues were the validity of the reassessment proceedings and the eligibility of the claimed deductions for donations made to charitable trusts.

Which sections of the Income-tax Act were involved?

Section 35AC,Section 80GGA,Section 147,Section 148,Section 159

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Cases cited in this judgment(1)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCH “E” MUMBAI

Before: SANDEEP GOSAIN & SHRI OM PRAKASH KANT

For Appellant: Mr. Hemanshu Joshi, Sr. DR
For Respondent: Mr. Hemanshu Joshi, Sr. DR
Pronounced: 23/12/2025

PER OM PRAKASH KANT, AM

The captioned appeals are directed against separate orders passed by the Ld. Commissioner of Income-tax (Appeals) – National Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment years 2011-12, 2012-13 and 2017-18 respectively.

2.

In these appeals, the issue on merit relates to denial of deduction u/s 35AC of the Income-tax Act, 1961 (in short ‘the Act’). In assessment years 2011-12 and 2012-13, the validity of the Estate of Vandravan P Shah Estate of Vandravan P Shah ITA No. 5401, 5402 & 5403/MUM/2024

reopening of the assessment as well as validity of th

The order continues below.

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