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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

Ambience Developers & Infrastructure P.Ltd, New Delhi vs. JCIT, Range-73, New Delhi

In the result, the appeals of the assessee are allowed

ITA 1634/DEL/2022[2009-10]Status: DisposedITAT Delhi16 Jan 2024AY 2009-10

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

Ambience Commercial Developers P.Ltd, New Delhi vs. JCIT, Range-73, New Delhi

In the result, the appeals of the assessee are allowed

ITA 1633/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

Rajendra Mulchand Varma, Mumbai vs. ACIT-DCIT - Central Circle 4(3), Mumbai

ITA 3214/MUM/2023[AY 2018-19]Status: DisposedITAT Mumbai05 Jan 2024

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Viraj MehtaFor Respondent: Smt. Mahita Nair
Section 142(1)Section 143(3)Section 68

rejoinder, the Learned Authorised Representative for the Appellant reiterated that the Appellant had filed its own bank statement as well as address and Permanent Account Number of the Lender. However, the CIT(A) failed to take the same into consideration. The Ld. Authorised Representative for the Appellant further submitted that

Iris Clothings Ltd, Howrah vs. DCIT, Circle-11(1), Kolkata

In the result the appeal of the assessee is allowed

ITA 1015/KOL/2023[2013-14]Status: HeardITAT Kolkata02 Jan 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Rajesh Kumar

Section 133(6)Section 143(3)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

Shri. Dinesh Acharya, Moodbidri vs. Income-Tax Officer, Ward-2(2), Mangaluru

In the result, the appeal of the assessee is dismissed

ITA 629/BANG/2023[2017-18]Status: DisposedITAT Bangalore01 Jan 2024AY 2017-18

Bench: Shri Chandra Poojariassessment Year: 2017-18

For Appellant: Ms. Harsha J., A.RFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Revenue
Section 234BSection 250Section 251Section 68Section 69A

that all the above cash creditors (12 in number) are assessed to income tax and they provided a confirmation as well as their permanent account number. They have their own respective bank accounts which they have been operating and it is not the claim of the AO that the respondent

ITO, Ward-1(3), New Delhi vs. Adception Infotech P.Ltd, New Delhi

In the result, ground no. 3(a) and (b) are allowed

ITA 5217/DEL/2017[2012-13]Status: DisposedITAT Delhi19 Dec 2023AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: N o n e
Section 133(6)Section 144Section 68

which was successfully delivered to him through mail and post. However, no response was received. The appellant has filed copy of the Permanent Account Number card and bank statement of Sh. Ajay Kumar Gupta maintained with Standard Chartered Bank. The money has been received from Standard Chartered Bank ... December, 2011. Since, he is assessed to tax and has filed copy of Permanent Account Number, share application form, copy of bank account and confirmation, therefore, in this case identity and creditworthiness has been established. Sh. Prashant Kothari He has invested Rs.21,81,382/- as share application money

Sobhagmull Gokalchand Jewellers, Mumbai vs. DCIT 19(3), Mumbai

ITA 2727/MUM/2023[2006-07]Status: DisposedITAT Mumbai18 Dec 2023AY 2006-07
For Appellant: Shri Sunil HirawatFor Respondent: Shri Ajudiya Manish
Section 143(3)Section 260A

ingredients were fulfilled in the present case. The identity of all the 5 suppliers stand proved by the fact that they are having Permanent Account Numbers and they had their own Bank Accounts at Mumbai/Surat and had independent Registration numbers under Sales Tax. The capacity to supply the goods stood

DCIT, Circle- 4(1)(1), Mumbai vs. Businessmatch Services (India) Pvt. Ltd., Mumbai

Accordingly, ITA number 2455/M/2023 for assessment year 2017 – 18 filed by the assessing officer is dismissed

ITA 2455/MUM/2023[2017]Status: DisposedITAT Mumbai18 Dec 2023

Bench: Shri Aby T Varkey, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri Madhur Agarwal &For Respondent: Shri S Srinivasu, CIT DR
Section 143(3)Section 14ASection 68

submitted its own bank account showing the amount of loan received. On 24th November 2016, assessee submitted a letter stating the name, address, Permanent Account Number (PAN), opening balance and subsequent repayment of the parties. The assessee also denied of having any connection with the accommodation entry providers. The assessee

ACIT, Circle-4(1)(1), Mumbai vs. M/S. Businessmatch Services (India) Pvt Ltd, Mumbai

Accordingly, ITA number 2455/M/2023 for assessment year 2017 – 18 filed by the assessing officer is dismissed

ITA 1136/MUM/2023[2014-15]Status: DisposedITAT Mumbai18 Dec 2023AY 2014-15

Bench: Shri Aby T Varkey, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri Madhur Agarwal &For Respondent: Shri S Srinivasu, CIT DR
Section 143(3)Section 14ASection 68

submitted its own bank account showing the amount of loan received. On 24th November 2016, assessee submitted a letter stating the name, address, Permanent Account Number (PAN), opening balance and subsequent repayment of the parties. The assessee also denied of having any connection with the accommodation entry providers. The assessee

M/S. G.P. Infraventures, Raipur vs. Income Tax Officer-1(4), Raipur

The appeal of the department stands disposed off

ITA 94/RPR/2020[2015-16]Status: DisposedITAT Raipur23 Nov 2023AY 2015-16

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.76/Rpr/2020) (Assessment Year: 2015-16) Income Tax Officer Ward-1(4), V M/S G.P. Infraventures, 1St Floor, Aayakar Bhavan, S Shree Tower, Shankar Nagar, Central Revenue Building, Raipur (C.G.) Civil Lines, Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) : (""यथ" / Respondent) (Ita No.94/Rpr/2020) (Assessment Year: 2015-16) M/S G.P. Infraventures, V Income Tax Officer-1(4), Shree Tower, Shankar Nagar, S Raipur Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) (""यथ" / Respondent) : िनधा"रती क" ओर से /Assessee By : Shri Sunil Kumar Agarwal, Ca राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 10.10.2023 घोषणा क" तार"ख / Date Of : 23.11.2023 7Pronouncement

For Appellant: Shri Sunil Kumar Agarwal, CAFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 143(3)Section 40ASection 40A(3)Section 68

departmental software, Computer Aided Scrutiny Selection, and that there was no human intervention involved in the selection. It is further stated that the Permanent Account Number (PAN) of the Petitioner fell within the jurisdiction of Respondent No. 2 and hence notice was sent by the Office of Respondent

Income Tax Officer, Ward-1(4), Raipur vs. Mesers G P Infraventures, Raipur

The appeal of the department stands disposed off

ITA 76/RPR/2020[2015-16]Status: DisposedITAT Raipur23 Nov 2023AY 2015-16

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.76/Rpr/2020) (Assessment Year: 2015-16) Income Tax Officer Ward-1(4), V M/S G.P. Infraventures, 1St Floor, Aayakar Bhavan, S Shree Tower, Shankar Nagar, Central Revenue Building, Raipur (C.G.) Civil Lines, Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) : (""यथ" / Respondent) (Ita No.94/Rpr/2020) (Assessment Year: 2015-16) M/S G.P. Infraventures, V Income Tax Officer-1(4), Shree Tower, Shankar Nagar, S Raipur Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) (""यथ" / Respondent) : िनधा"रती क" ओर से /Assessee By : Shri Sunil Kumar Agarwal, Ca राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 10.10.2023 घोषणा क" तार"ख / Date Of : 23.11.2023 7Pronouncement

For Appellant: Shri Sunil Kumar Agarwal, CAFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 143(3)Section 40ASection 40A(3)Section 68

departmental software, Computer Aided Scrutiny Selection, and that there was no human intervention involved in the selection. It is further stated that the Permanent Account Number (PAN) of the Petitioner fell within the jurisdiction of Respondent No. 2 and hence notice was sent by the Office of Respondent

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 718/MUM/2021[2016-17]Status: DisposedITAT Mumbai17 Nov 2023AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM

Mohan Thankurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 713/MUM/2021[2015-16]Status: DisposedITAT Mumbai17 Nov 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 712/MUM/2021[2013-14]Status: DisposedITAT Mumbai17 Nov 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 711/MUM/2021[2012-13]Status: DisposedITAT Mumbai17 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 710/MUM/2021[2011-12]Status: DisposedITAT Mumbai17 Nov 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM

Mohan Thakurdas Gurnani, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 709/MUM/2021[2014-15]Status: DisposedITAT Mumbai17 Nov 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM

Mohan Gurnani, Navi Mumbai vs. DCIT Central Cirle - 5(2), Mumbai

The appeal of the assessee is partly allowed for assessment year 2014 – 15 also

ITA 2089/MUM/2021[2010-11]Status: DisposedITAT Mumbai17 Nov 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Pradip Kapasi CAFor Respondent: Shri Mahesh Akhade CIT DR
Section 10Section 132Section 139Section 143Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM

DCIT, Central Circle 3(3), Mumbai vs. Avaada Ventures Private Limited, Mumbai

ITA 2089/MUM/2023[2012-13]Status: DisposedITAT Mumbai08 Nov 2023AY 2012-13
For Appellant: Shri Mani JainFor Respondent: Shri Ajay Chandra
Section 143(3)Section 153ASection 2

return was filed by the Assessee in the name of M/s Juicy International Pvt. Ltd. (merged with Avaada Power Pvt. Ltd.) using the Permanent Account Number AABCJ8216D belonging to M/s Juicy International Pvt. Ltd. on 21/06/2019. Therefore, the Assessing Officer was correct in passing the Assessment Order in the name ... merged with Avaada Power Pvt. Ltd.) (now known as Avaada Ventures Pvt. Ltd.). It was also pointed out that even the Permanent Account Number has been mentioned as AABCJ8216D (merged with AAKCS9700L). The Ld. Departmental Representative further submitted that no intimation of merger was given by the Assessee

Avaada Ventures Private Limited, Mumbai vs. DCIT, Central Circle 3(3), Mumbai

ITA 1754/MUM/2023[2012-13]Status: DisposedITAT Mumbai08 Nov 2023AY 2012-13
For Appellant: Shri Mani JainFor Respondent: Shri Ajay Chandra
Section 143(3)Section 153ASection 2

return was filed by the Assessee in the name of M/s Juicy International Pvt. Ltd. (merged with Avaada Power Pvt. Ltd.) using the Permanent Account Number AABCJ8216D belonging to M/s Juicy International Pvt. Ltd. on 21/06/2019. Therefore, the Assessing Officer was correct in passing the Assessment Order in the name ... merged with Avaada Power Pvt. Ltd.) (now known as Avaada Ventures Pvt. Ltd.). It was also pointed out that even the Permanent Account Number has been mentioned as AABCJ8216D (merged with AAKCS9700L). The Ld. Departmental Representative further submitted that no intimation of merger was given by the Assessee