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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

Microsoft Corporation (India) Private Limited, New Delhi vs. DCIT, Circle-16(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1863/DEL/2022[2018-19]Status: DisposedITAT Delhi28 Feb 2024AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usmicrosoft Corporation (India) Vs. Dcit, Pvt. Ltd, Circle-16(1), 807, New Delhi House, New Delhi Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aaacm5586C Assessee By : Shri Nageswar Rao & Parth, Adv Revenue By: Shri Rajesh Kumar, Cit(Dr) Date Of Hearing 22/02/2024 Date Of Pronouncement 28/02/2024

For Appellant: Shri Nageswar Rao & Parth, AdvFor Respondent: Shri Rajesh Kumar, CIT(DR)
Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153BSection 92C

mail address available in the last income-tax return furnished by the addressee; or (iii) the e-mail address available in the Permanent Account Number database relating to the addressee; or (iv) in the case of addressee being an individual who possesses the Aadhaar number, the e-mail address

True-Man Consultants Pvt. Ltd., Kolkata vs. ITO, Ward-7(2), Kolkata.

In the result, the appeal filed by the assessee is partly allowed

ITA 1158/KOL/2023[2012-13]Status: DisposedITAT Kolkata23 Feb 2024AY 2012-13

Bench: Sri Rajpal Yadav & Dr. Manish Borad

Section 131Section 142(1)Section 143(2)Section 143(3)Section 14ASection 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

ITO 28 (1)(1), Mumbai vs. Gahlot Construction, Mumbai

In the result, the appeal of the revenue & CO of the assessee is dismissed

ITA 2475/MUM/2021[2008-09]Status: DisposedITAT Mumbai23 Feb 2024AY 2008-09

Bench: Shri Br Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T. A. No. 2475/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2008-09) Ito-28(1)(1) बिधम/ M/S. Gahlot Construction Room No. 329, Tower No. Plot No-28A, Gahlot Vs. 6, 3Rd Floor, Vashi Railway Complex, Sector-10, Station, Navi Mumbai- Nerul, Navi Mumbai- 400703. 400703. Cross Objection No. 82/Mum/2023 Arising Out Of I.T.A. No.2475/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2008-09) M/S. Gahlot Construction बिधम/ Ito-28(1)(1) Plot No-28A, Gahlot Room No. 329, Tower Vs. No. 6, 3Rd Floor, Vashi Complex, Sector-10, Nerul, Navi Mumbai-400703. Railway Station, Navi Mumbai-400703. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaofm5698J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Ms. Ritika Agarwal Revenue By: Shri Raj Singh Meel (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 30/01/2024 घोषणा की तारीख /Date Of Pronouncement: 23/02/2024 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Revenue; & The Assessee Has Filed A Cross Objection (Co) Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [Hereinafter Referred To As The “Cit(A)”] Dated 30.10.2021 For The Ay. 2008-09. 2. The Main Grievance Of The Revenue Is Against The Action Of The Ld. Cit(A) Deleting The Addition Of Rs.5 Cr Which Was Added By The

For Appellant: Ms. Ritika AgarwalFor Respondent: Shri Raj Singh Meel (Sr. AR)
Section 132Section 139Section 147Section 151Section 153CSection 68

discharged the onus by placing (i) confirmation letters of the cash creditors; (ii) their affidavits; (iii) their full addresses and GIR numbers and permanent account numbers. It has found that the assessee's burden stood discharged and so, no addition to his total income on account of cash credit ... Gehlot Construction 16. In the case before us, the appellant by producing the loan- confirmation-certificates signed by the creditors, disclosing their permanent account numbers and address and further indicating that the loan was taken by account payee cheques, no doubt, prima facie, discharged the initial burden and those materials

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2990/MUM/2023[2018-19]Status: DisposedITAT Mumbai22 Feb 2024AY 2018-19

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

belonging to her sisters is supported by an affidavit. The affidavit of Smt. Anita Devi Baldeva, shows her residential address and her Permanent Account Number, which clearly shows that she has kept a sum of ₹2 lacs in cash with him, which was kept by assessee into locker. The source ... such sum is from her past savings and out of Stredhan. She has also given her permanent Account Number. This is the explanation of the assessee since the date of search. Then, permanent Account number is also given and money is owned by his sister, the addition cannot be made

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2989/MUM/2023[2019-20]Status: DisposedITAT Mumbai22 Feb 2024AY 2019-20

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

belonging to her sisters is supported by an affidavit. The affidavit of Smt. Anita Devi Baldeva, shows her residential address and her Permanent Account Number, which clearly shows that she has kept a sum of ₹2 lacs in cash with him, which was kept by assessee into locker. The source ... such sum is from her past savings and out of Stredhan. She has also given her permanent Account Number. This is the explanation of the assessee since the date of search. Then, permanent Account number is also given and money is owned by his sister, the addition cannot be made

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2988/MUM/2023[2015-16]Status: DisposedITAT Mumbai22 Feb 2024AY 2015-16

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

belonging to her sisters is supported by an affidavit. The affidavit of Smt. Anita Devi Baldeva, shows her residential address and her Permanent Account Number, which clearly shows that she has kept a sum of ₹2 lacs in cash with him, which was kept by assessee into locker. The source ... such sum is from her past savings and out of Stredhan. She has also given her permanent Account Number. This is the explanation of the assessee since the date of search. Then, permanent Account number is also given and money is owned by his sister, the addition cannot be made

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2987/MUM/2023[2017-18]Status: DisposedITAT Mumbai22 Feb 2024AY 2017-18

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

belonging to her sisters is supported by an affidavit. The affidavit of Smt. Anita Devi Baldeva, shows her residential address and her Permanent Account Number, which clearly shows that she has kept a sum of ₹2 lacs in cash with him, which was kept by assessee into locker. The source ... such sum is from her past savings and out of Stredhan. She has also given her permanent Account Number. This is the explanation of the assessee since the date of search. Then, permanent Account number is also given and money is owned by his sister, the addition cannot be made

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2986/MUM/2023[2016-17]Status: DisposedITAT Mumbai22 Feb 2024AY 2016-17

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

belonging to her sisters is supported by an affidavit. The affidavit of Smt. Anita Devi Baldeva, shows her residential address and her Permanent Account Number, which clearly shows that she has kept a sum of ₹2 lacs in cash with him, which was kept by assessee into locker. The source ... such sum is from her past savings and out of Stredhan. She has also given her permanent Account Number. This is the explanation of the assessee since the date of search. Then, permanent Account number is also given and money is owned by his sister, the addition cannot be made

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2985/MUM/2023[2013-14]Status: DisposedITAT Mumbai22 Feb 2024AY 2013-14

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

belonging to her sisters is supported by an affidavit. The affidavit of Smt. Anita Devi Baldeva, shows her residential address and her Permanent Account Number, which clearly shows that she has kept a sum of ₹2 lacs in cash with him, which was kept by assessee into locker. The source ... such sum is from her past savings and out of Stredhan. She has also given her permanent Account Number. This is the explanation of the assessee since the date of search. Then, permanent Account number is also given and money is owned by his sister, the addition cannot be made

Shri Pawan Jajoo, Mumbai vs. Income Tax Office (7)(4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2984/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Feb 2024AY 2014-15

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

belonging to her sisters is supported by an affidavit. The affidavit of Smt. Anita Devi Baldeva, shows her residential address and her Permanent Account Number, which clearly shows that she has kept a sum of ₹2 lacs in cash with him, which was kept by assessee into locker. The source ... such sum is from her past savings and out of Stredhan. She has also given her permanent Account Number. This is the explanation of the assessee since the date of search. Then, permanent Account number is also given and money is owned by his sister, the addition cannot be made

Vish Realty Solutions Private Limited, Kolkata vs. I.T.O., Ward-5(3), Kolkata

In the result, appeal of the revenue is dismissed

ITA 250/KOL/2020[2012-13]Status: DisposedITAT Kolkata21 Feb 2024AY 2012-13

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 250/Kol/2020 Assessment Year: 2012-13 Vish Realty Solutions Private Limited Income Tax Officer, Ward-5(3), 55, Ezra Street Vs Kolkata 2Nd Floor Kolkata - 700001 [Pan : Aadcv9938N] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S. Jhajharia, A/R Revenue By : Shri Vineet Kumar, Addl. Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 16/01/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/02/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals) -10 (Hereinafter The “Ld. Cit(E)”) Dt. 02/12/2019, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2012-13. 2. The Assessee Has Raised The Following Grounds Of Appeal:- “1. That The Learned Commissioner Of Income Tax (Appeals)-Io, Kolkata Erred In Passing An Order Dated 2Nd Of December, 2019 Under Section 143(3) Of The Income Tax Act, 1961 Dismissing The Appeal Of The Appellant Without Allowing Reasonable Opportunity Of Being Heard. 2. That The Learned Commissioner Of Income Tax (Appeals) - 10, Kolkata Erred In Confirming The Addition Of Share Application Money Ofrs. 5,86,00,000/- Made By The Assessing Officer Under Section 68 Of The Income Tax Act, 1961 On Irrelevant Considerations & Arbitrary Grounds.

For Appellant: Shri S. Jhajharia, A/RFor Respondent: Shri Vineet Kumar, Addl. CIT, D/R
Section 143(2)Section 143(3)Section 14ASection 263Section 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

Baba Iron Industries Pvt. Ltd., Kolkata vs. ITO, Ward-9(1), Kolkata.

ITA 925/KOL/2023[2012-13]Status: DisposedITAT Kolkata19 Feb 2024AY 2012-13

Bench: Sri Rajpal Yadav & Dr. Manish Borad

Section 143(3)Section 144Section 144BSection 249Section 253Section 254Section 263Section 3Section 5

Income-tax Appellate Tribunal. Both these authorities primarily went by the fact that the assessee had provided sufficient indication by way of permanent account numbers, to highlight the identity of the share applicants, as well as produced the affidavits of the directors. Furthermore, the bank details of the share applicants

M/S. Lifeline Medicare Hospitals Pvt Ltd, Mumbai vs. NFAC, Mumbai

In the result ground number 3 of the appeal is dismissed

ITA 74/MUM/2023[2013-14]Status: DisposedITAT Mumbai12 Feb 2024AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm The Income Tax Officer Vs. M/S Next Avenue Ventures Ward- 12(3)(1), Pvt. Ltd. Mumbai-400020 (Earlier Known As Kbj Ventures Pvt. Ltd.) 3Rd Floor, Raheja Chambers, Link Road Main Avenue, Santacruz (W), Mumbai-400 054 (Appellant) (Respondent) Pan No. Aagck8343R

For Appellant: Shri Satyaprakash Singh, ARFor Respondent: Shri S Srinivasu, CIT DR
Section 143Section 143(2)Section 143(3)Section 144Section 144BSection 68

years which is not justifiable to support the investment of ₹ 25 crores share capital. The learned AO also noted that investor has two permanent account numbers allotted to her. The AO also asked to show the source of investment by the investor. AO issued notice under section ... known as Golden Wealth Advisory Pvt. Ltd. To substantiate the source of investment the lender submitted the ledger account along with address, permanent account number, the income tax return, the bank statements, ledger copy of account of assessee in its books. For source of the fund received by the lender

ITO 12(3)(1), Mumbai vs. Next Avenue Ventures Private Limited(Earlier Known As Kbj Ventures Private Limited), Mumbai

In the result ground number 3 of the appeal is dismissed

ITA 2420/MUM/2023[A.Y. 2018-19]Status: DisposedITAT Mumbai12 Feb 2024

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm The Income Tax Officer Vs. M/S Next Avenue Ventures Ward- 12(3)(1), Pvt. Ltd. Mumbai-400020 (Earlier Known As Kbj Ventures Pvt. Ltd.) 3Rd Floor, Raheja Chambers, Link Road Main Avenue, Santacruz (W), Mumbai-400 054 (Appellant) (Respondent) Pan No. Aagck8343R

For Appellant: Shri Satyaprakash Singh, ARFor Respondent: Shri S Srinivasu, CIT DR
Section 143Section 143(2)Section 143(3)Section 144Section 144BSection 68

years which is not justifiable to support the investment of ₹ 25 crores share capital. The learned AO also noted that investor has two permanent account numbers allotted to her. The AO also asked to show the source of investment by the investor. AO issued notice under section ... known as Golden Wealth Advisory Pvt. Ltd. To substantiate the source of investment the lender submitted the ledger account along with address, permanent account number, the income tax return, the bank statements, ledger copy of account of assessee in its books. For source of the fund received by the lender

D.C.I.T., CC-1(3), Kolkata vs. M/S. Navin Construction & Credit Pvt. Ltd., Kolkata

In the result, appeal of the revenue is dismissed and cross- objection of the assessee is allowed

ITA 580/KOL/2022[2015-2016]Status: DisposedITAT Kolkata31 Jan 2024AY 2015-2016

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Ble

For Appellant: Shri Akkal Dudhewala, A/RFor Respondent: Shri Abhijit Kundu, CIT, D/R
Section 133(6)Section 14ASection 250Section 35Section 35(1)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 I.T.A. No. 580/Kol/2022 Assessment Year: 2015-16 C.O. No. 17/Kol/2023 Assessment Year: 2015-16 M/s. Navin Constructions & Credit

M/S Jr Fiber Glass Industries Pvt Ltd, Mumbai vs. National Faceless Appeal Centre, Mumbai

The appeal is allowed

ITA 2848/MUM/2023[2008-2009]Status: DisposedITAT Mumbai31 Jan 2024AY 2008-2009

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.2848/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2009-10) M/S. Jr Fiber Glass Industries Pvt. Ltd.

For Appellant: Shri Satyaprakash SinghFor Respondent: Ms. Kavitha Kaushik (Sr. AR)
Section 133(6)Section 147Section 68

discharged the onus by placing (i) confirmation letters of the cash creditors; (ii) their affidavits; (iii) their full addresses and GIR numbers and permanent account numbers. It has found that the assessee's burden stood discharged and so, no addition to his total income on account of cash credit ... Officer to assessee. 16. In the case before us, the appellant by producing the loan-confirmation- certificates signed by the creditors, disclosing their permanent account numbers and address and further indicating that the loan was taken by account payee cheques, no doubt, prima facie, discharged the initial burden and those

DCIT, CC-5(1), Mumbai vs. Hetal N. Shah (Leagal Heir of the Assessee Shri Nitin Rajmal Shah), Mumbai

In the result, we admit the appeal of the AO as it has been replaced by bringing the legal heir of deceased assessee on record but dismissed the appeal on the merits of the addition

ITA 1080/MUM/2023[2012-13]Status: DisposedITAT Mumbai22 Jan 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Hetal Nitin Shah Dcit Legal Heir Of Nitin Rajmal Central Circle 5(1) Room No.1928, 19 Th Floor, Shah Air India Building, 301, Chandramani, Vs. Nariman Point, Hanuman Road, Mumbai-400 021 Vile Parle(E), Mumbai-400 057 (Appellant) (Respondent) Pan No. Aadps5476M Assessee By : Shri Jaiprakash Bairagra, Ar Revenue By : Shri Ashok Kumar Ambastha, Dr Date Of Hearing: 16.11.2023 Date Of Pronouncement : 22.01.2024

For Appellant: Shri Jaiprakash Bairagra, ARFor Respondent: Shri Ashok Kumar Ambastha
Section 131Section 132Section 133ASection 143Section 143(3)Section 68

assessee also provided i. copies of the bank statement of the parties along with ii. their return of income iii. their income tax permanent account number, iv. ledger confirmation and v. Financial statement of both the parties. 07. The assessee also submitted that he has taken loan by account payee ... entire transaction and the corresponding parties and therefore the assessee has discharged his primary onus by giving the bank statement, income tax returns, permanent account number is, Ledger confirmation and financial statements of the lender. The learned assessing officer has not pointed out any deficiency in the above statement

Ankit Impex Marketing Services (P) Ltd., Kolkata vs. ITO, Ward--8(1), Kolkata.

In the result, both the appeals are allowed

ITA 620/KOL/2023[2014-15]Status: DisposedITAT Kolkata17 Jan 2024AY 2014-15

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawali.T.A. Nos. 619 & 620/Kol/2023 Assessment Years: 2013-2014 & 2014-2015 Ankit Impex Marketing Services Pvt. Ltd.,...Appellant 46C, J.L. Nehru Road, Kolkata-700071 [Pan: Aalcs9318R] -Vs.- Income Tax Officer,.................................Respondent Ward-8(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069

Section 133(6)Section 68

proof cannot be shifted on the revenue by cart loads of documents. The documents submitted must be explained". 3.3. Mere filing of Permanent Account Number (PAN), acknowledgement of Income Tax Returns, Bank account statement is not sufficient to discharge the onus on the assessee. In this regard, reliance is also

Ankit Impex Marketing Services (P) Ltd., Kolkata vs. ITO, Ward--8(1), Kolkata.

In the result, both the appeals are allowed

ITA 619/KOL/2023[2013-14]Status: DisposedITAT Kolkata17 Jan 2024AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawali.T.A. Nos. 619 & 620/Kol/2023 Assessment Years: 2013-2014 & 2014-2015 Ankit Impex Marketing Services Pvt. Ltd.,...Appellant 46C, J.L. Nehru Road, Kolkata-700071 [Pan: Aalcs9318R] -Vs.- Income Tax Officer,.................................Respondent Ward-8(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069

Section 133(6)Section 68

proof cannot be shifted on the revenue by cart loads of documents. The documents submitted must be explained". 3.3. Mere filing of Permanent Account Number (PAN), acknowledgement of Income Tax Returns, Bank account statement is not sufficient to discharge the onus on the assessee. In this regard, reliance is also

Ambience Developers and Infrastructure Private Limited, New Delhi vs. JCIT, Range-73, New Delhi

In the result, the appeals of the assessee are allowed

ITA 1635/DEL/2022[2010-11]Status: DisposedITAT Delhi16 Jan 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Anand Choudhary, AdvFor Respondent: Shri Kanv Bali, Sr. DR
Section 201Section 272A(2)(k)

could not be filed electronically without remitting the requisite taxes. Further it was explained that some of the parties had not furnished their Permanent Account Number (PAN), without which the assessee could not file its TDS returns electronically. Hence there was a delay on the part of the assessee