Bogus donation accommodation entry defeats section 80GGC deduction where evidence shows a sham political contribution.

A deduction claimed under section 80GGC for donation to a political party was disallowed where search material and recorded statements showed a bogus donation scam. The transaction was found to be routed through banking channels, layered through intermediary entities, and returned in cash after commission, indicating a sham accommodation entry rather than a genuine political contribution. On that factual foundation, the appellate forum held that the assessee's claim could not survive because the underlying donation was non-genuine, and the disallowance was upheld.

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Issues: Whether the disallowance of deduction claimed under section 80GGC on account of donation made to the political party was sustainable on the basis that the donation was part of a bogus donation scam.

Analysis: The factual foundation for the disallowance was the search material and statements recorded during the investigation into a group of registered unrecognized political parties, indicating that donations were routed through banking channels, layered through intermediary entities, and ultimately returned in cash after deduction of commission. On the basis of those materials, the donation claimed by the assessee was treated as non-genuine. The appellate finding was that the assessee's donation formed part of the same modus operandi and that the claim under section 80GGC could not survive where the underlying transaction itself was bogus.

Conclusion: The disallowance of the deduction under section 80GGC was upheld and the issue was decided against the assessee.

Final Conclusion: The appellate challenge failed, and the addition made by the Revenue authority was sustained.

Ratio Decidendi: A deduction claim based on a donation transaction can be denied where the surrounding evidence establishes that the donation was a sham or bogus accommodation entry and not a genuine contribution.

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