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Facts
The assessee's appeal was filed with a delay of 60 days, which was condoned due to bonafide reasons. The core issue was that the assessee, by mistake of her counsel, obtained a second Permanent Account Number (PAN) instead of re-applying for a copy of a misplaced PAN.
Held
The Tribunal held that the issue of having two PANs and the associated bank deposits requires examination by the Assessing Officer (AO) for proper reconciliation and verification. The matter was restored to the AO for fresh adjudication.
Key Issues
Whether the delay in filing the appeal should be condoned, and whether the existence of two PANs necessitates a fresh assessment by the AO to correctly bring income to tax.
Sections Cited
147, 148, 143(3)
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Income Tax Appellate Tribunal, “D” BENCH, KOLKATA
Before: SHRI RAJESH KUMAR, AM & SHRI PRADIP KUMAR CHOUBEY, JM
O R D E R
Per Rajesh Kumar, AM:
This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 21.05.2025 for the AY 2017-18.
At the outset, we note that the appeal of the assessee is barred by limitation by 60 days. At the time of hearing the counsel of the assessee explained the reasons for delay in filing the appeal. The Ld. D.R did not raise any objection in condoning the delay. After hearing the rival contentions and perusing the materials available on record, we find that the delay is for bonafide and genuine reasons and hence, we condone the delay and admit the appeal for adjudication.
The ld. Counsel of the assessee submitted that the assessee was having double Permanent Account Number by mistake of the counsel. The PAN Card of the assessee was mis-placed and the consultant of the assessee applied for fresh PAN in stead of re- applying for the copy of the PAN Card misplaced. The ld. AO noted
In the result, the appeal of the assessee is partly allowed for statistical purposes.
Order pronounced in the open court on 13.01.2026.