Meetkumar Hasmukhbhai Chaturvedi Vs ITO (ITAT Ahmedabad)
The ITAT Ahmedabad dismissed the assessee’s appeal against the order of the CIT(A) for A.Y. 2019-20. The assessee had claimed a Rs.2,00,000 deduction under Section 80GGC for a political donation made through banking channels. Based on Investigation Wing information concerning alleged bogus political donations, the Assessing Officer initiated proceedings under Section 148A, passed an order under Section 148A(d), and issued notice under Section 148 dated 20.04.2023. Reassessment was completed under Section 147 read with Section 144B, disallowing the Section 80GGC deduction.
The assessee challenged the reopening and disallowance, contending, among other grounds, that the Section 148 notice was without jurisdiction, the reassessment relied mechanically on Investigation Wing information, there was no evidence of cash being returned to the assessee, and third-party statements had been relied upon without cross-examination.
The Tribunal rejected the jurisdictional challenge, holding that the reassessment proceedings had been initiated in accordance with law and that the Section 148 notice could not be treated as invalid.
On merits, the Tribunal relied upon its Coordinate Bench decision in Saurabh Pravinbhai Patel Vs. ITO, ITA No. 1017/Ahd/2023, order dated 30.04.2025, and other decisions concerning Section 80GGC political donations. It also considered material concerning the alleged modus operandi of Rashtriya Samajwadi Party (Secular), including investigation findings, statements under Section 132(4), and bank-trail analysis showing systematic routing of donated funds.
