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Issues: (i) Whether the disallowance of donation claim under section 80GGC of the Income-tax Act, 1961 was to be sustained at Rs. 8,00,000 or restricted to Rs. 6,00,000; (ii) Whether the addition of Rs. 1,00,00,000 made under section 69A read with section 115BBE of the Income-tax Act, 1961 on account of time deposit was sustainable; (iii) Whether the addition of Rs. 13,01,200 on account of gratuity, leave encashment, children education allowance and other exempt allowances was sustainable.
Issue (i): Whether the disallowance of donation claim under section 80GGC of the Income-tax Act, 1961 was to be sustained at Rs. 8,00,000 or restricted to Rs. 6,00,000.
Analysis: The appellate findings accepted the bank statement and supporting material showing that the actual donation made was Rs. 6,00,000 and not Rs. 8,00,000. The Revenue did not bring material to dislodge that factual finding. The premise for making the higher disallowance therefore did not survive.
Conclusion: The restriction of the disallowance to Rs. 6,00,000 was upheld and the Revenue failed on this issue.
Issue (ii): Whether the addition of Rs. 1,00,00,000 made under section 69A read with section 115BBE of the Income-tax Act, 1961 on account of time deposit was sustainable.
Analysis: The material on record showed regular credits in the bank account, a returned income of Rs. 5,46,84,197, and salary income reflected in Form 16. On that basis, the time deposit was treated as arising from disclosed credits, and the Revenue did not rebut the appellate finding or show any infirmity in the source explanation.
Conclusion: The deletion of the addition under section 69A read with section 115BBE was upheld and the Revenue failed on this issue.
Issue (iii): Whether the addition of Rs. 13,01,200 on account of gratuity, leave encashment, children education allowance and other exempt allowances was sustainable.
Analysis: The appellate authority accepted that the impugned receipts were supported by Form 16 and related employment records and were covered by the claimed exemptions under section 10 of the Income-tax Act, 1961. The Revenue was unable to rebut those findings with contrary material.
Conclusion: The deletion of the addition relating to exempt allowances was upheld and the Revenue failed on this issue.
Final Conclusion: All substantive additions challenged by the Revenue were found unsustainable, and the assessee's relief granted in appeal was maintained in full.
Disallowance and unexplained income additions fail where bank records, Form 16, and exemption evidence support the assessee's explanation.
The ITAT Delhi upheld relief where the assessee substantiated that the donation claim under section 80GGC was actually Rs. 6,00,000, so the higher disallowance did not survive. It also sustained deletion of the addition under section 69A read with section 115BBE on the time deposit, as bank credits, salary records and disclosed income supported the source explanation. In respect of gratuity, leave encashment, children education allowance and other exempt receipts, the tribunal accepted Form 16 and employment records showing coverage under section 10 exemptions, and the Revenue failed to rebut those findings. The assessee's appellate relief was thus maintained in full.
Deduction for political donation u/s 80GGC - Unexplained money under section 69A in respect of bank time deposit - Exemption of gratuity, leave encashment and employee allowances reflected in Form 16 Deduction for political donation u/s 80GGC - Quantum of disallowance of claimed bogus donation - determination of amount actually shown as donated through the assessee's bank account - HELD THAT: - The Tribunal held that the appellate authority had correctly found from the papers and bank details filed by the assessee that the actual donation was Rs. 6 lakhs and not Rs. 8 lakhs as taken by the AO. Once the donation reflected in the record was only to that extent, disallowance of a higher amount was neither logical nor legal. On that factual basis, no infirmity was found in restricting the disallowance to the amount actually debited. [Paras 5] The restriction of disallowance to the actual donation amount was upheld and the Revenue's challenge failed. Unexplained money u/s 69A in respect of bank time deposit - Source of term deposit from disclosed salary income - HELD THAT: - The Tribunal accepted the appellate finding that the time deposit had been created from the same bank account in which regular credits were available and that the assessee had disclosed substantial income for the year. In that background, creation of the term deposit out of disclosed income was not unusual. Since the Revenue brought nothing on record to rebut the factual finding regarding source, interference with deletion of the addition was not warranted. [Paras 9] Deletion of the addition made under section 69A read with section 115BBE was affirmed. Exemption of gratuity, leave encashment and children education allowance reflected in Form 16 - addition for alleged unsubstantiated employee benefit claims - HELD THAT: - The Tribunal found that the Commissioner (Appeals) had recorded clear findings and passed a speaking order on the claim of exemption in respect of the employee-related receipts and allowances. It further noted that, before the Tribunal, the Revenue was unable to rebut those findings. In the absence of any effective challenge to that reasoning, no interference was called for. [Paras 13] The Revenue's challenge to deletion of the addition on account of the employee benefit claims was rejected. Final Conclusion: The Tribunal dismissed the Revenue's appeal for Assessment Year 2019-20. It upheld the restriction of disallowance of donation to the amount actually shown as paid, sustained deletion of the addition on account of the bank time deposit, and affirmed the relief granted in respect of gratuity, leave encashment and other employee allowances.