PRIYANKKUMAR PRAVINBHAI THAKKAR,AHMEDABAD vs. THE ITO, WARD-1, NADIAD

ITA 2659/AHD/2025Status: DisposedITAT Ahmedabad18 September 2026AY 2019-207 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal admitted the additional ground, holding that the reassessment proceedings conducted by the NFAC were validly resumed by the JAO. However, it found that the addition under Section 69A and the disallowance under Section 80C were not warranted based on the evidence provided.

What were the facts?

The assessee appealed against the CIT(A)'s order disallowing a claim under Section 80GGC, confirming an addition under Section 69A, and enhancing income by disallowing a deduction under Section 80C. The assessee also raised an additional ground challenging the jurisdiction of the Assessing Officer.

What were the issues?

Whether the reassessment proceedings were conducted with proper jurisdiction and whether the additions/disallowances made were justified based on the evidence.

Which sections of the Income-tax Act were involved?

Section 80GGC,Section 69A,Section 115BBE,Section 80C,Section 250,Section 148A,Section 143(3),Section 147,Section 144B,Section 144C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC” BENCH, AHMEDABAD

Before: DR. B.R.R. KUMAR, VICE-SHRI RAHUL CHAUDHARY

For Appellant: Shri P K Modi, AR
For Respondent: Shri Drop Singh Meena, Sr. DR
Hearing: 07.07.2026Pronounced: 18.09.2026

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:

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The captioned appeal has been filed by the assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals) (hereinafter referred to as “Ld. CIT(A)”), National Faceless Appeal Centre (NFAC), Delhi vide order dated 18.11.2025, under section 250 of the Income-Tax Act, 1961 (hereinafter referred to as “the Act”) for the Assessment Year 2019-20. 2. The assessee has raised the following grounds of appeal:

“1. The Ld. CIT(A) erred in law and on facts arbitrary disallowing the claim under Section 80GGC of the Act without appreciating that the Ld. Assessing Officer failed to independently evaluate the evidences pr

The order continues below.

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