RAJKUMAR GUPTA,JHANSI vs. CIRCLE 2(1)(1) AGRA, AGRA

ITA 203/AGR/2026Status: DisposedITAT Agra19 August 2026AY 2019-20207 pages
AI SummaryAllowed

What did the Tribunal hold?

The ITAT held that the notice issued under Section 148 was bad in law due to an invalid sanction under Section 151. The sanctioning authority showed a non-application of mind, making the subsequent assessment order void. Therefore, the assessment order was quashed.

What were the facts?

The assessee claimed a deduction under Section 80GGC for a donation to a political party. The Assessing Officer disallowed the deduction, treating the donation as bogus and adding it to the assessee's income. The CIT(A) upheld the disallowance. The assessee appealed to the ITAT.

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated under Section 148 due to an alleged invalid sanction under Section 151. The secondary issues involved the disallowance of the Section 80GGC deduction and additions to income.

Which sections of the Income-tax Act were involved?

Section 80GGC,Section 148,Section 147,Section 151,Section 149(1)(b),Section 69C,Section 10(13A)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA (SMC

Before: SUNIL KUMAR SINGHBRAJESH KUMAR SINGH

For Appellant: Shri Pankaj Gargh, Adv
For Respondent: Shri Anil Kumar, Sr (DR)
Hearing: 06.08.2026Pronounced: 19.08.2026

PER:SUNIL KUMAR SINGH, JUDICIAL MEMBER

This appeal is directed against the impugned order dated 06.01.2026 passed in appeal No NFAC/2018-19/10429876 by the ld. Commissioner of Income Tax(Appeals)/ NFAC(Delhi) (hereinafter referred to as the “CIT(A) u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) for the A.Y. 2019-20, wherein ld CIT(A) has dismissed assessee’s appeal.

2.

The brief facts of the case are that assessee filed his return of income for A.Y. 2019-20 on 06.07.2019, declaring total income of Rs. 10,39,650/-. The case was reopened by issuance of notice u/s 148 of the Act dated 12.04.2023 for examining assessee’s claim of deduction and exemption. Assessee filed return on 08.05.2023 in c

The order continues below.

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