MALHAR NITIN BHUPTANI,RAJKOTQ vs. ASSISSTANT COMMISSIONER OF INCOME TAX CIRCLE -2(1) , RAJKOT

ITA 1054/RJT/2026Status: DisposedITAT Rajkot09 October 2026AY 2019-203 pages
AI SummaryAllowed

What were the facts?

The assessee, Malhar Nitin Bhuptani, filed an appeal against the order dated 11.07.2026 passed by the National Faceless Appeal Centre (NFAC), Delhi (Ld. CIT(A)). This order confirmed the disallowance of Rs.1,40,000, which was claimed as a deduction under Section 80GGC of the Income-tax Act, 1961, for donations made to political parties. The disallowance arose from an assessment order passed by the Assessing Officer under Section 147 read with Section 144 of the Act, dated 20.01.2025, for the assessment year 2019-20. The assessee contended that the issue was covered by a previous ITAT Rajkot decision in the case of Nikhil Nitinbhai Bhuptani for the same assessment year.

What did the Tribunal hold?

The Tribunal held that the issue was squarely covered in favour of the assessee by the ITAT Rajkot Bench's decision in the case of Nikhil Nitinbhai Bhuptani (supra). The Tribunal noted that in the cited case, the assessee had provided evidence of donation to a registered political party through banking channels, including receipts and the party's PAN. The Tribunal observed that even if the political party failed to account for the donation in its return, the donor (assessee) should not be faulted for denying the deduction, provided the payment and receipt were established. Since the facts of the present case were similar to the precedent and the revenue could not produce any material to controvert the findings in the Nikhil Nitinbhai Bhuptani case, the Tribunal respectfully followed the binding precedent. Consequently, the addition made by the Assessing Officer was deleted. The appeal of the assessee was allowed with consequential effect.

What were the issues?

1. Whether the Ld. CIT(A) erred in law and on facts by confirming the disallowance of Rs.1,40,000, claimed as a deduction under Section 80GGC of the Income-tax Act, 1961, for donations made to political parties. Assessee's Contentions: The assessee argued that the issue is squarely covered in their favour by the decision of the ITAT Rajkot Bench in the case of Nikhil Nitinbhai Bhuptani (ITA No.479/Rjt/2025, AY 2019-20, dated 30.10.2025). They stated that in that case, the Tribunal held that donations made to political parties through banking channels, supported by valid certificates from the political party, qualified for deduction, and the addition made by the AO was deleted. Revenue's Contentions: The Ld. DR for the revenue relied on the findings of the Assessing Officer.

Which sections of the Income-tax Act were involved?

Section 80GGC,Section 147,Section 144,Section 250,Section 29A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

Hearing: 01/10/2026Pronounced: 09/10/2026

Per, Dr. Arjun Lal Saini, AM : Captioned appeal filed by the assessee, pertaining to assessment year 2019-20, is directed against the order passed under Section-250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 11.07.2026 by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals) [in short ‘Ld. CIT(A)’], which in turn arises out of an assessment order passed by the Assessing Officer u/s.14

The order continues below.

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