PRAGNESH BHOGILAL SHAH,AHMEDABAD vs. INCOME TAX OFFICER, WARD-1(3)(1), AHMEDABAD

ITA 2338/AHD/2026Status: DisposedITAT Ahmedabad18 September 2026AY 2019-2017 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the investigation material, statements, and the established modus operandi of the recipient political party overwhelmingly demonstrated that the donation was an accommodation entry, not a genuine contribution. Mere banking transactions and receipts were insufficient to prove genuineness.

What were the facts?

The assessee claimed a deduction of Rs. 3,00,000/- under Section 80GGC for a donation made to a political party. The Assessing Officer (AO) disallowed this deduction, and the Commissioner (Appeals) upheld the disallowance, finding the donation to be bogus based on investigation into political parties providing accommodation entries.

What were the issues?

The primary issues were the validity of the reassessment proceedings, specifically the notice issued under Section 148 and the approval under Section 151, and whether the donation was genuine and eligible for deduction under Section 80GGC.

Which sections of the Income-tax Act were involved?

Section 80GGC,Section 148,Section 148A,Section 151

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC” BENCH, AHMEDABAD

Before: SHRI RAHUL CHAUDHARY, JUDICIALMEMBER &SHRI GANGADHAR PANDA

Hearing: 07.09.2026Pronounced: 18.09.2026

PER GANGADHAR PANDA - ACCOUNTANTMEMBER:

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 (in short “NFAC”), Delhi dated 07.05.2026 under Section 250 of the Income Tax Act, 1961 for A.Y. 2019-20. 2. The assessee has raised the following grounds of appeal: “Ground no.1 The Ld. CIT(A) NFAC has erred in points of law and on facts in upholding the assessment order passed by the Ld. AO on the basis of an invalid / illegal notice issued u/s 148 on the basis of an approval u/s 151 given by the PCIT instead of PCCIT / CCIT. By the said

The order continues below.

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