Kanal Sanatkumar Raval Vs ITO (ITAT Ahmedabad)
The Ahmedabad ITAT dismissed the assessee’s appeal against the CIT(A), NFAC order dated 24.07.2025 for A.Y. 2019-20, concerning disallowance of ₹1,80,000 claimed as deduction under Section 80GGC of the Income-tax Act, 1961 for a donation allegedly made to Rashtriya Samajwadi Party (Secular).
During assessment, the AO relied on information arising from search and survey proceedings under Sections 132 and 133A, including diaries, loose papers, WhatsApp chats and other material. The investigation indicated that donations were allegedly routed through banking channels and subsequently returned in cash through intermediaries after deduction of commission. A notice under Section 133(6) issued to the political party seeking confirmation of the donation received no response. The AO concluded that the assessee had not established the genuineness of the donation and disallowed ₹1,80,000.
The assessee challenged the disallowance and also raised grounds concerning reassessment proceedings, including approval under Sections 148 and 151, the limitation provision under Section 149(1)(b), unsigned approval, jurisdiction and other procedural issues. The Tribunal, however, focused on the substantive issue of deduction under Section 80GGC.
The Tribunal noted that the identical issue had been considered by its co-ordinate bench in Saurabh Pravinbhai Patel Vs. ITO, ITA No. 1017/Ahd/2023, order dated 30.04.2025. It also noted similar decisions in Mihir Bipinbhai Parekh Vs. DCIT, Milind Pankajbhai Shroff Vs. Pr. CIT-1, Rajkot, Ritesh Sugan Jain Vs. ITO, and Rajen Jayantilal Merchant Vs. ITO.
