Manoj Jayram Sarang Vs ITO (ITAT Mumbai)
The assessee, an employee of M/s. JP Morgan Services India Pvt. Ltd., appealed against the CIT(A), NFAC order dated 24.12.2025 for AY 2019-20 concerning disallowance of deduction under Section 80GGC for a donation to Rashtriya Samajwadi Party (Secular). The reassessment followed information from the Investigation Wing concerning a search of Registered Unrecognized Political Parties (RUPPs), which allegedly revealed an arrangement involving receipt of donations through banking channels, routing of funds through intermediary entities and return of cash to donors after deduction of commission. The assessee had originally filed his return on 14.07.2019 declaring total income of Rs.5,01,250/-. Following notices under Sections 148A(b), 148A(d) and 148, he filed a return on 06.05.2023 declaring the same income.
During reassessment, the assessee furnished the donation receipt, bank statement and political party registration details, contending that the contribution was genuine and made through banking channels. The AO nevertheless disallowed the Section 80GGC deduction, relying on investigation material, statements recorded during search proceedings and the political party’s alleged non-compliance with contribution-reporting and annual-report requirements. The CIT(A) upheld the disallowance, observing that banking-channel payment and a receipt did not by themselves establish genuineness when surrounding material raised doubts concerning the recipient entity.
