Prasana Jayantkumar Bhatt Vs DCIT (ITAT Ahmedabad)
The appeal before the Income Tax Appellate Tribunal, Ahmedabad Bench, arose from the order dated 27.11.2025 passed by the Commissioner of Income Tax (Appeals), NFAC, for Assessment Year 2019-20. The assessee challenged the disallowance of deduction of ₹12,00,000 claimed under Section 80GGC of the Income-tax Act, 1961 in respect of a donation made to Rashtriya Samajwadi Party (Secular).
The assessee, a salaried employee, had filed the return of income declaring total income of ₹56,79,530 after claiming the deduction under Section 80GGC. The Assessing Officer disallowed the claim and added ₹12,00,000 to the assessee’s income. The CIT(A) confirmed the disallowance, leading to the present appeal.
Before the Tribunal, the assessee contended that the political party was duly registered under Section 29A of the Representation of the People Act, 1951, and that the donation had been made through banking channels under a bona fide belief that the recipient was genuine. It was argued that there was no direct evidence showing that the donated amount had been returned to the assessee. The assessee relied upon decisions including CIT v. Orissa Corporation (P.) Ltd., CIT v. Divine Leasing & Finance Ltd., K.P. Varghese v. ITO, Ashish Dubey v. ACIT, Nihil Nitinbhai Bhuptani v. ITO, Mukesh Somani v. ITO, and Vitthaldas Nathubhai Shah v. PCIT.
