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    <title>2026 (1) TMI 821 - ITAT MUMBAI</title>
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    <description>Reassessment under section 148A failed because the notice was founded on a mistaken factual premise and the material relied upon for reopening, including third-party statements, was not furnished to the assessee despite request; the absence of disclosed material denied a meaningful opportunity to reply and vitiated the jurisdictional notice and consequent reassessment. On merits, the deduction claim under section 80GGC was upheld because the assessee produced the donation receipt, bank statement, and proof of the recipient political party&#039;s registration, while the Revenue produced no direct corroborative evidence that the donation was returned or that the transaction was bogus. The reassessment was quashed and the disallowance was rejected.</description>
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      <description>Reassessment under section 148A failed because the notice was founded on a mistaken factual premise and the material relied upon for reopening, including third-party statements, was not furnished to the assessee despite request; the absence of disclosed material denied a meaningful opportunity to reply and vitiated the jurisdictional notice and consequent reassessment. On merits, the deduction claim under section 80GGC was upheld because the assessee produced the donation receipt, bank statement, and proof of the recipient political party&#039;s registration, while the Revenue produced no direct corroborative evidence that the donation was returned or that the transaction was bogus. The reassessment was quashed and the disallowance was rejected.</description>
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