SUNIL PIYUSH SHAH,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. -THE ITO, WARD-5(3)(2), AHMEDABAD

ITA 1917/AHD/2025Status: DisposedITAT Ahmedabad16 January 2026AY 2019-20Bench: Ms. Suchitra Kamble (Judicial Member)5 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal found that the reassessment proceedings under sections 148A(b) and 148A(d) were conducted as per procedure, and the assessee was given opportunities to respond. It noted that the disallowance was based on both third-party statements and the assessee's conduct, as the assessee failed to provide details or demonstrate the genuineness of the donations. Consequently, the disallowance of Rs. 1,00,000 was confirmed.

What were the facts?

The assessee claimed a deduction of Rs. 1,00,000 under sections 80G/80GGC for a donation to Manvadhikar National Party for AY 2019-20. Following a search and seizure operation, the President of the political party admitted to bogus donations. Reassessment proceedings were initiated under sections 147/148, and the Assessing Officer disallowed the deduction, a decision upheld by the CIT(A).

What were the issues?

Whether the reassessment proceedings were valid despite alleged procedural irregularities and lack of cross-examination. Whether the disallowance of deduction for donation to a political party under section 80GGC was justified as it was deemed a bogus entry.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A(b),Section 148A(d),Section 144B,Section 250,Section 80G,Section 80GGC,Section 132,Section 132(4),Section 270A,Section 270AA,Section 244A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD “SMC” BENCH

Before: Ms. Suchitra Kamble

For Appellant: Shri Sunil Piyush Shah, A.R
For Respondent: Shri Suresh Chand Meena, Sr. D.R

This is an appeal filed against the order dated 05-09- 2025 passed by National Faceless Appeal Centre(NFAC), Delhi for assessment year 2019-20. 2. The grounds of appeal are as under:- “1. That the order under section 250 dated 05.09.2025 passed by the learned CIT(A), NFAC, New Delhi, upholding the reassessment order dated 11.02.2025 passed under section 147 read with section 144B of the Income-tax Act, 1961 ("the Act"), is bad in law, void ab initio, without juri iction, and contrary to the settled principles of law.

2.

That both the reassessment order dated 11.02.2025 passed under section 147 read with section 144B and the appellate order dated 05.09.2025 passed under section 250 are vitia

The order continues below.

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