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2025 Supreme(Online)(ITAT) 3148

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
T.R. Senthil Kumar, J, BRR Kumar, VP
SAURABH PRAVINBHAI PATEL AND BRIJESH PRAVINBHAI PATEL AOP ANAND – Appellant
Versus
ASSESSMENT UNIT INCOME TAX DEPARTMENT NEW DELHI – Respondent


Advocates:
For the Appellants/Petitioners: Shri Saiyam Shah, A.R., Shri Prakash D Shah, A.R.
For the Respondents: Shri Ankit Jain, Sr. D.R.

Table of Content
1. claim of deduction for donations to political parties. (Para 2 , 3)
2. allegations of financial misconduct regarding political donations. (Para 4 , 5)
3. court's ruling on the burden of proof and dismissal of appeal. (Para 6 , 7)

आदेश/ORDER

PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

This appeal is filed by the Assessee as against the appellate order dated 12-10-2023 passed by Commissioner of Income Tax [Appeals], National Faceless Appeal Centre arising out of the assessment order passed under section 143[3] of the Income Tax Act, 1961 [hereafter referred as the Act] relating to the Assessment year 2021-21.

2. Brief facts of the case is that the assessee is an Association of Person (AOP) engaged in the business of real estate and renting services. The assessee filed its Return of Income for the Asst. Year 2020-21 on 30-03-2021 declaring total income of Rs.25,93,260/-. The assessee made the following donations and claimed deduction u/s. 80G and 80GGC of the Act. To verify the genuineness of the donations made by the political parties namely Kisan Party of India and Rashtriya Samajwadi Party (S) notices u/s. 133(6) were issued to confirm the receipt of donations along wi

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