SHILPA GOYAL,UDAIPUR vs. ASSESSMENT UNIT, ASSESSMENT UNIT NFAC

PDF · subscribers
ITA 984/DEL/2026Status: DisposedITAT Delhi20 July 2026AY 2019-2010 pages

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

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the issue of entitlement to Section 80GGC deduction for donations to M/s Rashtriya Samajwadi Party (Secular) was no longer res integra, having been decided in favour of the department in ITA No. 1683/AHD/2025 (Rajen Jayantilal Merchant vs Assessment Union, dated 13.11.2025). The Tribunal adopted the reasoning from a co-ordinate bench decision (ITA No. 1017/Ahd/2023, dated 30.04.2025) which had confirmed a similar disallowance. This decision relied on the finding that the bank accounts of the political party were used by accommodation entry providers, where donations received by cheque were layered through various accounts, and cash was ultimately returned to the donor. The Tribunal noted that the AO had clearly brought out facts that the bank accounts of the political parties were used by accommodation entry providers for systematic financial maneuvers to legitimize illicit moneys and evade taxes. The assessee did not dispute these facts with relevant materials, nor did they provide any fresh evidence. Therefore, the grounds raised by the assessee were considered devoid of merit. The Tribunal dismissed the appeal, confirming the disallowance of the Section 80GGC deduction.

What were the facts?

The assessee, Shilpa Goyal, filed an appeal for Assessment Year 2019-20 against an order by the CIT(A)/NFAC, Delhi. The appeal challenged assessment proceedings under Section 143(3) read with Sections 147 and 144B of the Income Tax Act, 1961. The core dispute concerns the disallowance of a deduction claimed under Section 80GGC for a donation of Rs. 1,50,000/- made to M/s Rashtriya Samajwadi Party (Secular). The Assessing Officer (AO) reopened the assessment based on search operations at M/s RUPP Group in Ahmedabad, which allegedly uncovered a network of accommodation entries for such donations. The lower appellate authority confirmed the AO's disallowance. The assessee contended that all supportive evidence was provided, and the deduction was admissible. The Revenue argued that the donation was part of a scam to claim bogus deductions.

What were the issues?

1. Whether the reopening of assessment under Section 147 by issuing notice under Section 148 was bad-in-law, considering the AO's alleged failure to record independent satisfaction and the issuance of notice by the Faceless Jurisdictional AO in view of Section 151A and CBDT Notification No. 18/2022. 2. Whether the AO erred in not allowing the deduction of Rs. 1,50,000/- claimed under Section 80GGC for a donation to a registered political party, despite fulfilling pre-conditions and providing a donation receipt and bank statements. 3. Whether the AO erred in not allowing the deduction under Section 80GGC in violation of natural justice principles by not furnishing relied-upon statements and denying cross-examination. Assessee's arguments: The assessee argued that all necessary evidence was provided for the Section 80GGC deduction. The reopening of assessment was challenged on procedural grounds. The assessee also claimed a violation of natural justice. The assessee relied on the fact that the donation was made via NEFT/RTGS and supported by a receipt and bank statements. Revenue's arguments: The Revenue contended that search operations revealed a well-orchestrated network of accommodation entries for donations to registered unrecognized political parties (RUPPs) to claim bogus deductions under Section 80GGC. The Revenue sought to confirm the disallowance based on these findings and the modus operandi of the political party.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 144B,Section 80GGC,Section 148,Section 151A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘H’, NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI KRINWANT SAHAY

For Appellant: CA Sh. Deepak Taparia, CA
Hearing: 07.07.2026Pronounced: 07.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER ITA No. 984/Del/2026 Assessment Year: 2019-20

Shilpa Goyal, Vs Assessment Unit, 24 Roop Nagar, Income Tax Department, Bhuwana, NFAC Udaipur- 313001 Delhi Rajasthan (APPELLANT) (RESPONDENT) PAN No. AJUPM0970A

Assessee by: Sh. Akhil Kakmani, CA Sh. Deepak Taparia, CA Revenue by : Sh. Sudip Majumdar, Sr. DR

Date of Hearing: 07.07.2026 Date of Pronouncement: 07.07.2026 ORDER

This assessee’s appeal for Assessment Year 2019-20 arises against the Commissioner of Income Tax(Appeals)/National Faceless Appeal Centre (for short, ‘CIT(A)/NFAC’), Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1082943921(1), dated 24.11.2025, involving proceedings u/s 143(3) r.w.s. 147 and 144B of the Income Tax Act, 1961; hereinafter referred to as, “the Act”.

Heard both the parties at length. Case file perused.

2.

It emerges during the course of hearing at the outset that the assessee raises herein sole substantive ground directed against both the learned lower authorities’ respective assessment and lower appellate findings disallowing section 80GGC deduction claim involving the alleged donation paid to M/s Rashtriya Samajwadi Parti (Secular). Learned counsel’s case accordingly is that the assessee is very much entitled for claiming the impugned section 80GGC deduction since having placed on record the entire supportive evidence in both the lower proceedings.

3.

The Revenue, on the other hand, invites our attention to page 6 paragraph 4.2.4 of the assessment discussion onwards that the learned departmental authorities had carried out a search in M/s RUPP Group at Ahmedabad on 07.09.2022 wherein it came across the corresponding supporting material indicating a well-orchestrated, accommodation entry network of such donations for the purpose of claiming section 80GGC deduction. It accordingly seeks to confirm the impugned disallowance before the tribunal as well.

4.

We have given our thoughtful consideration to the foregoing rival stands. It emerges that the instant issue of the assessee’s entitlement to section 80GGC deduction involving M/s Rashtriya Samajwadi Party (Secular) is no more res integra since decided in the department’s favour in ITA No. 1683/AHD/2025 in Rajen Jayantilal Merchant vs Assessment Union dated 13.11.2025; as under:

We adopt the above detailed reasoning mutatis mutandis to confirm the impugned section 80GCC disallowance made in both the lower proceedings. No other ground or argument has been pressed before us.

4.

This assessee’s appeal is dismissed.

Order Pronounced in the Open Court on 07.07.2026.

Sd/- Sd/- (KRINWANT SAHAY) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 20.07.2026 *Pooja Mittal, Sr. PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →