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“permanent account number”

Chapter XIV - Assessment ProcedureSection 139ASection 139A565 judgments

The decision most relied on for permanent account number is (i) Principal CIT v. Soft-line Creations Pvt. Ltd. (387 ITR 636), cited in 59 judgments on BharatTax.

Leading authorities on permanent account number

(i) Principal CIT v. Soft-line Creations Pvt. Ltd.
387 ITR 636 · 2016 · High Court
59
citing judgments

When an assessee provides the Permanent Account Numbers, affidavits of directors, and bank details of share applicants, this discharges the onus regarding the identity, genuineness of the transaction, and creditworthiness of the share applicants, precluding an addition under Section 68.

PCIT v. Vaishnodevi Refoils & Solvex
89 Taxmann.com 80 · 2018 · High Court
46
citing judgments

The addition of share application money to the income of the assessee under Section 68 is not justified if the assessee has discharged the initial onus by providing complete particulars and documentary evidence of the creditor, and the Revenue has failed to prove otherwise. The Supreme Court has also dismissed the Revenue's SLP in this matter.

Assistant Commissioner, Assessment II, Bangalore v. Velliappa Textiles Ltd.
263 ITR 550 · 2003 · Supreme Court
30
citing judgments

A body corporate is considered a juridical person and an artificial juridical person, distinct from natural persons or an association of persons. This status is recognized by the Income Tax Department, as indicated by the format of a Permanent Account Number (PAN).

CLSA India (P.) Ltd. v. Dy. CIT
149 Taxmann.com 380 · 2023 · High Court
10
citing judgments

An active Permanent Account Number (PAN) for a non-existent entity, post-amalgamation, does not justify reassessment proceedings against that entity. The revenue cannot rely on an active PAN to dilute established legal principles regarding the assessment of merged entities.

Judgments citing permanent account number

Sundip Kumar Gupta., Kolkata vs. DCIT, Cir-47, Kolkata.

Appeals of the assessee stand allowed

ITA 1172/KOL/2023[2014-15]Status: DisposedITAT Kolkata02 Jul 2024AY 2014-15

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. Nos.1170 To1173/Kol/2023 Assessment Years: 2010-11, 2012-13, 2014-15 & 2015-16 Sundip Kumar Gupta..…………………....................…...……………....Appellant Fort Oasis Complex, Flat No.040903, Block-436B, Panditya Road, Kolkata – 700029. [Pan: Aebpg7187B] Vs. Dcit, Circle-47, Kolkata…….……………............................…..…..... Respondent Appearances By: Shri Abhishek Bansal, Ar, Appeared On Behalf Of The Assessee. Shri B. K. Singh, Jcit-Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 23, 2024 Date Of Pronouncing The Order : July 02, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Are Bunch Of Four Appeals Preferred By The Assessee Against The Separate Orders Dated 06.09.2023, 06.09.2023, 15.09.2023 & 06.09.2023, Respectively, Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since The Facts & Issues Involved In All The Appeals Are Identical, Hence, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order. At The Request Of Ld. Representatives Of The Parties, Ita No.1170/Kol/2023 Is Taken As The Lead Case For The Purpose Of Narration Of Facts.

Section 147Section 250Section 68

lender. The Assessing Officer had brushed aside these documents and in a very casual manner had stated that merely filing the permanent account number details, and balance sheet did not absolve the assessee from his responsibility of proving the nature of the transaction. There was no discussion by the Assessing

Sundip Kumar Gupta., Kolkata vs. DCIT, Cir-47, Kolkata.

Appeals of the assessee stand allowed

ITA 1171/KOL/2023[2012-13]Status: DisposedITAT Kolkata02 Jul 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. Nos.1170 To1173/Kol/2023 Assessment Years: 2010-11, 2012-13, 2014-15 & 2015-16 Sundip Kumar Gupta..…………………....................…...……………....Appellant Fort Oasis Complex, Flat No.040903, Block-436B, Panditya Road, Kolkata – 700029. [Pan: Aebpg7187B] Vs. Dcit, Circle-47, Kolkata…….……………............................…..…..... Respondent Appearances By: Shri Abhishek Bansal, Ar, Appeared On Behalf Of The Assessee. Shri B. K. Singh, Jcit-Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 23, 2024 Date Of Pronouncing The Order : July 02, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Are Bunch Of Four Appeals Preferred By The Assessee Against The Separate Orders Dated 06.09.2023, 06.09.2023, 15.09.2023 & 06.09.2023, Respectively, Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since The Facts & Issues Involved In All The Appeals Are Identical, Hence, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order. At The Request Of Ld. Representatives Of The Parties, Ita No.1170/Kol/2023 Is Taken As The Lead Case For The Purpose Of Narration Of Facts.

Section 147Section 250Section 68

lender. The Assessing Officer had brushed aside these documents and in a very casual manner had stated that merely filing the permanent account number details, and balance sheet did not absolve the assessee from his responsibility of proving the nature of the transaction. There was no discussion by the Assessing

Sundip Kumar Gupta., Kolkata vs. DCIT, Cir-47, Kolkata.

Appeals of the assessee stand allowed

ITA 1170/KOL/2023[2010-11]Status: DisposedITAT Kolkata02 Jul 2024AY 2010-11

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. Nos.1170 To1173/Kol/2023 Assessment Years: 2010-11, 2012-13, 2014-15 & 2015-16 Sundip Kumar Gupta..…………………....................…...……………....Appellant Fort Oasis Complex, Flat No.040903, Block-436B, Panditya Road, Kolkata – 700029. [Pan: Aebpg7187B] Vs. Dcit, Circle-47, Kolkata…….……………............................…..…..... Respondent Appearances By: Shri Abhishek Bansal, Ar, Appeared On Behalf Of The Assessee. Shri B. K. Singh, Jcit-Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 23, 2024 Date Of Pronouncing The Order : July 02, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Are Bunch Of Four Appeals Preferred By The Assessee Against The Separate Orders Dated 06.09.2023, 06.09.2023, 15.09.2023 & 06.09.2023, Respectively, Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since The Facts & Issues Involved In All The Appeals Are Identical, Hence, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order. At The Request Of Ld. Representatives Of The Parties, Ita No.1170/Kol/2023 Is Taken As The Lead Case For The Purpose Of Narration Of Facts.

Section 147Section 250Section 68

lender. The Assessing Officer had brushed aside these documents and in a very casual manner had stated that merely filing the permanent account number details, and balance sheet did not absolve the assessee from his responsibility of proving the nature of the transaction. There was no discussion by the Assessing

Swarn Ganga Jewellers, Chandigarh vs. DCIT, Circle 4(1) Now DCIT, Circle 1(1), Chandigarh

In the result, the appeal of the assessee stands allowed

ITA 675/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh28 Jun 2024AY 2017-18

Bench: This Tribunal Being Aggrieved By An Order No. Itba/Nfac/S/250/2022-23/1045180258(1) For A.Y. 2017-18 Dt. 05/09/2022 Which Is Hereinafter Referred To As The “Impugned Order”. The Impugned Order Is Passed By Cit(A) In Terms Of Section 250 Of The Income Tax Act, 1961. Factual Matrix 2. That Survey U/S 133A Of The Income Tax Act, 1961 Was Conducted On The Business Premises Of The Assessee On 06/09/2016. The Assessee Surrendered A Sum Of Rs. 50,00,000/- During The Survey & Paid Tax Thereon. The Return Of Income Was Filed On 01/11/2017 Declaring A Total Income Of Rs. 89,48,260/-. Thereafter The Case Of The Assessee Was Selected For Scrutiny Under Compulsory Scrutiny Guidelines & Notice Under Section 143(2) Of The Act Was Issued On 11/09/2018. The Assessment Was Finalised Vide Order Dt. 23/12/2019 Whereby Addition Of Rs. 95,70,882/- Was Made U/S 68 R.W..S 115Bbe Of The Act.

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 133ASection 143(2)Section 250Section 253Section 68

cash sale was below the value of Rs. 2 lakhs which is the threshold above which buyers have to provide the permanent account number (PAN) issued by the income tax department and TCS has to be deducted u/s 206 of IT Act, 1961. While it is possible that a majority

Rajani Sharma, Sultanpur vs. ITO, Raisen

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 278/IND/2023[2016-17]Status: DisposedITAT Indore27 Jun 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanirajani Sharma Ito House No.10, Ward No.11, Raisen Sultanpur, Goharganj Vs. Raisen (Appellant / Assessee) (Respondent/ Revenue) Pan: Fcyps5335B Assessee By Shri Arpit Gaur, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 26.06.2024 Date Of Pronouncement 27 .06.2024

Section 143(2)Section 143(3)Section 250

filing the present appeal. The contents of the affidavit are reproduced as under: “1. That, I am regularly assessed to income-tax under Permanent Account Number (PAN) - FCYPS5335B. 2. That, during the financial year 2015-16, relevant to the assessment year 2016-17, I was engaged in the business

DCIT (Exemption)- 2(1), Mumbai vs. Maharashtra Energy Development Agency, Mumbai

ITA 1765/MUM/2023[2013-14]Status: DisposedITAT Mumbai27 Jun 2024AY 2013-14

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Kishore PhadkeFor Respondent: Smt. Sanyogita Nagpal
Section 10Section 11Section 143(3)

would be pertinent to take into consideration the conduct of the Assessee/MEDA since its incorporation. The Assessee/MEDA was established in 1987; obtained permanent account number and has been filing income tax returns since then. As per material on record, the returns filed for the Assessment Year

Meena Bharat Gohil, Mumbai vs. The Income Tax Officer Ward No 20(2)(2), Lalbaug Parel

In the result, these grounds of appeal of the assessee are restored back to the file of AO

ITA 4803/MUM/2023[2017-18]Status: DisposedITAT Mumbai24 Jun 2024AY 2017-18

Bench: Shri Prashant Maharishi (Am) I.T.A. No. 4803/Mum/2023 (A.Y. 2017-18) Vs. Meena Bharat Gohil Ito, Ward-20(2)(2) Room No. 60, New Piramal Chamber Bhawan Chawl, Cotton Mumbai. Green, Veer Tanaji Malusare Marg, Kala Chowki S.O. Mumbai-400 033. Pan : Ajnpg2509G (Appellant) (Respondent) Assessee By Shri Satya Prakash Singh Department By Shri R.R. Makwana Date Of Hearing 04.06.2024 Date Of Pronouncement 24.06.2024 O R D E R 1. This Appeal Is Filed By Mrs. Meena Bharat Gohil (The Assessee/Appellant) Against The Appellate Order By The National Faceless Appeal Centre (Nfac, Delhi (The Learned Cit – A) For Assessment Year 2017 – 18 Dated 7/11/2023 Wherein The Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 143 (3) Of The Income Tax Act 1961 (The Act) Dated 24/12/2019 Passed By The Income Tax Officer Ward – 20 (2) (2), Mumbai (The Learned Ao) Was Dismissed. 2. Assessee Aggrieved With The Same Is In Appeal Before Us Challenging The Order Passed By The Learned That Appellate Authority For Passing The Order Can The Addition Under Section 69A In Respect Of Rs. 4,605,000/- Cash Deposited During Demonetization In The Bank Account Of The Assessee Despite Providing Sufficient Explanation With Page 1 Of 6

Section 115BSection 133Section 142Section 143Section 69A

deposit and earlier withdrawals are available. He stated that there is also an affidavit of the gift received from Brother along with their permanent account number to show that she received gift from her relatives. He also submitted that in the explanation assessee also gave a reason that ... assessee would produce from gifts received of small amounts from her brother and sister more than affidavit from those parties along with their permanent account number and sources of the funds. In the affidavits submitted the brother and sister have given the sources of funds and by such funds were

Balaka Vinimay Pvt. Ltd., Kolkata vs. ITO, Ward-2(1), Kolkata

In the result, appeals of the assessee in ITA No

ITA 161/KOL/2024[2008-09]Status: DisposedITAT Kolkata21 Jun 2024AY 2008-09

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 160 & 161/Kol/2024 Assessment Year: 2008-09 Balaka Vinimay Pvt. Ltd. Income Tax Officer, Ward – 2(1), 9/12, Lal Bazar Street Vs Kolkata Kolkata - 700001 [Pan : Aadcb2610B] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A.K. Tibrewal, A/R & Saurav Gupta, A/R Revenue By : Shri Abhijit Kundu, Cit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 09/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/06/2024 आदेश/O R D E R Per Dr. Manish Borad: The Instant Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre, Delhi, (Hereinafter The “Ld. Cit(A)”). Ita No. 160/Kol/2024 Is Against The Order Of The Ld. Cit(A) Dt. 29/11/2023, Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter ‘The Act’) Arising Out Of The Penalty Order Passed By The Ld. Assessing Officer U/S 271(1)(C) Of The Act & Ita No. 161/Kol/2023, Is Against The Order Of The Ld. Cit(A) Dt. 28/11/2023, Arising Out Of The Order Of The Ld. Assessing Officer Passed U/S 143(3) R.W.S. 254 Of The Act, For Assessment Year 2008-09. 2. Though The Assessee Has Raised Various Grounds In Both These Appeals, But The Effective Issue Raised In Ita No. 161/Kol/2024 Is Against The Addition Made U/S 68 Of The Act For Unexplained Share Capital Confirmed By The Ld. Cit(A) & In Ita No. 160/Kol/2024 Is Against The Levy Of Penalty U/S 271(1)(C) Of The Act On The Addition Made

For Appellant: Shri A.K. Tibrewal, A/R and Saurav Gupta, A/RFor Respondent: Shri Abhijit Kundu, CIT, Sr. D/R
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 263Section 271(1)(c)Section 68

lender. The Assessing Officer had brushed aside these documents and in a very casual manner had stated that merely filing the permanent account number details, and balance sheet did not absolve the assessee from his responsibility of proving the nature of the transaction. There was no discussion by the Assessing

Balaka Vinimay Pvt. Ltd., Kolkata vs. ITO, Ward-2(1), Kolkata

In the result, appeals of the assessee in ITA No

ITA 160/KOL/2024[2008-09]Status: DisposedITAT Kolkata21 Jun 2024AY 2008-09

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 160 & 161/Kol/2024 Assessment Year: 2008-09 Balaka Vinimay Pvt. Ltd. Income Tax Officer, Ward – 2(1), 9/12, Lal Bazar Street Vs Kolkata Kolkata - 700001 [Pan : Aadcb2610B] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A.K. Tibrewal, A/R & Saurav Gupta, A/R Revenue By : Shri Abhijit Kundu, Cit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 09/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/06/2024 आदेश/O R D E R Per Dr. Manish Borad: The Instant Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre, Delhi, (Hereinafter The “Ld. Cit(A)”). Ita No. 160/Kol/2024 Is Against The Order Of The Ld. Cit(A) Dt. 29/11/2023, Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter ‘The Act’) Arising Out Of The Penalty Order Passed By The Ld. Assessing Officer U/S 271(1)(C) Of The Act & Ita No. 161/Kol/2023, Is Against The Order Of The Ld. Cit(A) Dt. 28/11/2023, Arising Out Of The Order Of The Ld. Assessing Officer Passed U/S 143(3) R.W.S. 254 Of The Act, For Assessment Year 2008-09. 2. Though The Assessee Has Raised Various Grounds In Both These Appeals, But The Effective Issue Raised In Ita No. 161/Kol/2024 Is Against The Addition Made U/S 68 Of The Act For Unexplained Share Capital Confirmed By The Ld. Cit(A) & In Ita No. 160/Kol/2024 Is Against The Levy Of Penalty U/S 271(1)(C) Of The Act On The Addition Made

For Appellant: Shri A.K. Tibrewal, A/R and Saurav Gupta, A/RFor Respondent: Shri Abhijit Kundu, CIT, Sr. D/R
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 263Section 271(1)(c)Section 68

lender. The Assessing Officer had brushed aside these documents and in a very casual manner had stated that merely filing the permanent account number details, and balance sheet did not absolve the assessee from his responsibility of proving the nature of the transaction. There was no discussion by the Assessing

Income Tax Officer-12(3)(1), Mumbai vs. M/S Laxmi Realty and Advisory Pvt Ltd, Mumbai

ITA 2986/MUM/2022[2015-2016]Status: DisposedITAT Mumbai20 Jun 2024AY 2015-2016

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Respondent ……………. [PAN: AABCL1116C] CORRIGENDUM 1. In the order, dated 11/12/2023, passed by “A” Bench of the Tribunal in ITA No. 2986/Mum/2022 the Permanent Account Number of the Assessee has been incorrectly mentioned as ‘AAATG0260C’ instead of ‘AABCL1116C’ in the cause title. The said mistake is hereby rectified ... present corrigendum. The Permanent Account Number mentioned as ‘AAATG0260C’ in the cause title on the first page of the order, dated 11/12/2023, shall stand replaced by and be read as ‘AABCL1116C’. (Amarjit Singh) Judicial Member मुंबई Mumbai; िदनांक Dated : 20.06.2024 Alindra, PS Corrigendum Assessment Year: 2015-16 आदेश की "ितिलिप

Assistant Commissioner of Income Tax, Circle (Exemption ), Nagpur vs. M/S Maharshtra Live Stock Development Board, Akola

In the result, appeal filed by the Revenue is allowed

ITA 355/NAG/2019[2016-17]Status: DisposedITAT Nagpur13 Jun 2024AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Abhay Y. Marathe
Section 11Section 12A

imposed on it. However, we are not impressed by this argument, because the assessee is an independent entity having Permanent Account Number (PAN) and has been regularly filed return of income. Just because functionaries of the assessee are senior bureaucrat appointed by the Government of Maharashtra, it does not mean

DCIT Circle-23(1), New Delhi vs. Ram Kumar Shokeen, New Delhi

In the result, the appeal of the Revenue is dismissed whereas the Cross Objection of the assessee is allowed

ITA 1009/DEL/2020[2011-12]Status: DisposedITAT Delhi13 Jun 2024AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Kumar

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Vivek Vardhan, Sr.DR
Section 143(3)Section 147Section 148Section 148(1)Section 148(2)Section 151

Income Tax” 1. Name and Address of the assessee Ram Kumar Shokeen D-9, Pushpanjali Farms, VPO Bijwasan, New Delhi- 110061 2. Permanent Account Number ATSPS5897A 3. Status Individual 4. District/Circle/Range ACIT, Circle-23, New Delhi 5. Assessment Year in respect of which it is 2011-12 proposed to issue

Mahavir Kumar Jain, Ujjain vs. I.T.O. 1(1), Ujjain

In the result, All appeals of the assessee are partly allowed

ITA 424/IND/2023[2015-16]Status: DisposedITAT Indore31 May 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

hands of the office bearer namely Shri Manish Kothari since the society is a "seperately legal entity" having its Permanent Account Number and working under the registered bye laws since last many years. Secondly we have held that the alleged transactions of cash deposits and corresponding entries of cheque issued

Mahavir Kumar Jain, Ujjain vs. I.T.O. 1(1), Ujjain

In the result, All appeals of the assessee are partly allowed

ITA 423/IND/2023[2014-15]Status: DisposedITAT Indore31 May 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

hands of the office bearer namely Shri Manish Kothari since the society is a "seperately legal entity" having its Permanent Account Number and working under the registered bye laws since last many years. Secondly we have held that the alleged transactions of cash deposits and corresponding entries of cheque issued

Mahavir Kumar Jain, Ujjain vs. ITO 1(1), Ujjain

In the result, All appeals of the assessee are partly allowed

ITA 422/IND/2023[2013-14]Status: DisposedITAT Indore31 May 2024AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

hands of the office bearer namely Shri Manish Kothari since the society is a "seperately legal entity" having its Permanent Account Number and working under the registered bye laws since last many years. Secondly we have held that the alleged transactions of cash deposits and corresponding entries of cheque issued

Mahavir Kumar Jain, Ujjain vs. ITO 1(1), Ujjain

In the result, All appeals of the assessee are partly allowed

ITA 421/IND/2023[2012-13]Status: DisposedITAT Indore31 May 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

hands of the office bearer namely Shri Manish Kothari since the society is a "seperately legal entity" having its Permanent Account Number and working under the registered bye laws since last many years. Secondly we have held that the alleged transactions of cash deposits and corresponding entries of cheque issued

Mahavir Kumar Jain, Ujjain vs. I.T.O. 1(1), Ujjain

In the result, All appeals of the assessee are partly allowed

ITA 420/IND/2023[2010-11]Status: DisposedITAT Indore31 May 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

hands of the office bearer namely Shri Manish Kothari since the society is a "seperately legal entity" having its Permanent Account Number and working under the registered bye laws since last many years. Secondly we have held that the alleged transactions of cash deposits and corresponding entries of cheque issued

Mahavir Kumar Jain, Ujjain vs. I.T.O. 1(1), Ujjain

In the result, All appeals of the assessee are partly allowed

ITA 419/IND/2023[2009-10]Status: DisposedITAT Indore31 May 2024AY 2009-10

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

hands of the office bearer namely Shri Manish Kothari since the society is a "seperately legal entity" having its Permanent Account Number and working under the registered bye laws since last many years. Secondly we have held that the alleged transactions of cash deposits and corresponding entries of cheque issued

M/S. Datalog Technologies Private Limited, Coimbatoree vs. DCIT, International Taxation, Coimbatore

In the result, appeals filed by the assessee for all the three assessment years are allowed

ITA 937/CHNY/2023[2014-15]Status: DisposedITAT Chennai31 May 2024AY 2014-15

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 935, 936 & 937/Chny/2023 िनधा"रण वष" / Assessment Years: 2012-13, 2013-14 & 2014-15 Deputy Commissioner Of M/S. Datalog Technologies V. Income-Tax, Private Limited, International Taxation, Flat No. 6, 3Rd Street, Coimbatore. Narayandas Layout, Tatabad, Coimbatore – 641 012. [Pan: Aabcd-5720-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Vikram Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 31.05.2024 आदेश /O R D E R

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. D. Hema Bhupal, JCIT
Section 195Section 201(1)Section 9Section 9(1)(vii)

India in respect of the commission agency business so carried out." (3.6) The rate charged by invoking section 206AA for non- mentioning of Permanent Account Number of non-resident, is contrary to the provisions of DTAA applicable between India and Indonesia. Recently, the Honourable Delhi High Court, in Danisco India

M/S. Datalog Technologies Private Limited, Coimbatore vs. DCIT, Inernational Taxation, Coimbatore

In the result, appeals filed by the assessee for all the three assessment years are allowed

ITA 936/CHNY/2023[2013-14]Status: DisposedITAT Chennai31 May 2024AY 2013-14

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 935, 936 & 937/Chny/2023 िनधा"रण वष" / Assessment Years: 2012-13, 2013-14 & 2014-15 Deputy Commissioner Of M/S. Datalog Technologies V. Income-Tax, Private Limited, International Taxation, Flat No. 6, 3Rd Street, Coimbatore. Narayandas Layout, Tatabad, Coimbatore – 641 012. [Pan: Aabcd-5720-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Vikram Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 31.05.2024 आदेश /O R D E R

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. D. Hema Bhupal, JCIT
Section 195Section 201(1)Section 9Section 9(1)(vii)

India in respect of the commission agency business so carried out." (3.6) The rate charged by invoking section 206AA for non- mentioning of Permanent Account Number of non-resident, is contrary to the provisions of DTAA applicable between India and Indonesia. Recently, the Honourable Delhi High Court, in Danisco India