VANDANABEN RAJBHAI PARIKH,AHMEDABAD vs. THE PR.CIT, AHMEDABAD-1, AHMEDABAD
What did the Tribunal hold?
The tribunal upheld the Principal CIT's order, confirming that the Assessing Officer's failure to properly verify the genuineness of the political donations and the eligibility of donee entities rendered the assessment order erroneous and prejudicial to the interests of the Revenue. The tribunal noted factual discrepancies in donation receipts and distinguished the case from prior precedents cited by the assessee, concluding that the PCIT was justified in invoking Section 263.
What were the facts?
The assessee claimed a deduction of Rs. 32,50,000/- under section 80GGC for donations to political parties, which the Assessing Officer accepted in the assessment. Subsequently, the Principal CIT initiated revision proceedings under section 263, alleging that some donee political parties were bogus and the AO failed to conduct adequate verification, leading to an erroneous assessment prejudicial to the revenue. The PCIT set aside the assessment order for fresh verification.
What were the issues?
Whether the Principal CIT was justified in invoking Section 263 to revise an assessment order that allowed a deduction under Section 80GGC, on the grounds that the Assessing Officer's inquiry into the genuineness of political donations and donee eligibility was inadequate, rendering the assessment erroneous and prejudicial to the revenue.
Which sections of the Income-tax Act were involved?
Section 263,Section 143(2),Section 142(1),Section 143(3),Section 144B,Section 80GGC
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, AHMEDABAD “B” BENCH
Before: DR. BRR Kumar & Shri Siddhartha Nautiyal
आदेश आदेश आदेश
PER : SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER:-
The present appeal has been filed by the Assessee against the order of the Principal Commissioner of Income Tax (Appeals)-1, Ahmedabad vide order dated 08-03-2025 passed for A.Y. 2020-21. 2. The Grounds of Appeal raised by the Assessee reads as under:
The PCIT has erred in laws and facts by revising and setting aside the Assessment Order u/s section 263 of the Income Tax Act, for an issue which was the sole reason for the selection of scrutiny under CASS for Limited Scrutiny and the same has been verified in-depth by the AO.
The PCIT has erred in laws and facts by revising and setting aside the
The order continues below.
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- J.D. Marketing, Kolkata vs ITO, Ward 37(1), KolkataITA 1492/KOL/2026[2013-2014]Status: Disposed15 Oct 2026AY 2013-2014
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