SHRI RAJEEV SHARMA,NAVI MUMBAI vs. THE ITO, WARD--27(2)(1), NAVI MUMBAI

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ITA 6352/MUM/2025Status: DisposedITAT Mumbai07 September 2026AY 2019-206 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since the assessee had withdrawn the bogus donation and paid taxes, and the alleged commission was a petty amount based on estimation, the addition made by the AO was not justified. Therefore, the appellate order confirming the addition was set aside.

What were the facts?

The assessee initially claimed a deduction under section 80GGC for a donation to a political party. Later, during reassessment proceedings initiated under section 147, the assessee withdrew this deduction to avoid litigation. The Assessing Officer (AO) still made an addition of Rs. 2,250/- under section 69C, presuming a commission was paid for the bogus donation.

What were the issues?

The primary issues were the validity of the reassessment proceedings initiated under section 147 and the addition made under section 69C based on a presumed commission for a bogus donation, even after the assessee withdrew the deduction.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151A,Section 144B,Section 69C,Section 115BBE,Section 234A,Section 234B,Section 234C,Section 270A,Section 80GGC

AI-generated summary — verify with the full judgment below

Before: SHRI SANDEEP GOSAIN & SHRI PRABHASH SHANKARShri Rajeev Sharma v/s.

For Appellant: Shri Nitin Khinchi, AR
For Respondent: Ms. Kanika Naroola, DR
Hearing: 01.07.2026Pronounced: 07.09.2026

आदेश की प्रतितलति अग्रेतिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आयुक्त / CIT 4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT, Mumbai

P a g e | 6 ITA No. 6352/Mum/2025 A.Y. 2019-20 Shri Rajeev Sharma 5. गार्ड फाईल / Guard file. सत्यावपि प्रवि //True Copy// आदेशानुसार/ BY ORDER,

उि/सहायक िंजीकार (Dy./Asstt. Registrar) आयकर अिीलीय अतधकरण/ ITAT, Bench, Mumbai.

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