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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

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

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

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

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

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

ITA 719/MUM/2021[2014-15]Status: DisposedITAT Mumbai08 Nov 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

Section 10Section 132Section 139Section 143(3)Section 153ASection 68

submitted the details of loan received, loan repaid, Ledger account of the lenders, loan confirmation by lender stating its name, address and permanent account number, bank statement of the lender, audited annual accounts of the lender, bank statement to show that the loan has been repaid, source of loan

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

ITA 717/MUM/2021[2016-17]Status: DisposedITAT Mumbai08 Nov 2023AY 2016-17

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

Section 10Section 132Section 139Section 143(3)Section 153ASection 68

submitted the details of loan received, loan repaid, Ledger account of the lenders, loan confirmation by lender stating its name, address and permanent account number, bank statement of the lender, audited annual accounts of the lender, bank statement to show that the loan has been repaid, source of loan

Priya Mohan Gurnani, Navi Mumbai vs. Cy CIT-CC-5(2), Mumbai

ITA 716/MUM/2021[2011-12]Status: DisposedITAT Mumbai08 Nov 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

Section 10Section 132Section 139Section 143(3)Section 153ASection 68

submitted the details of loan received, loan repaid, Ledger account of the lenders, loan confirmation by lender stating its name, address and permanent account number, bank statement of the lender, audited annual accounts of the lender, bank statement to show that the loan has been repaid, source of loan

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

ITA 715/MUM/2021[2010-11]Status: DisposedITAT Mumbai08 Nov 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

Section 10Section 132Section 139Section 143(3)Section 153ASection 68

submitted the details of loan received, loan repaid, Ledger account of the lenders, loan confirmation by lender stating its name, address and permanent account number, bank statement of the lender, audited annual accounts of the lender, bank statement to show that the loan has been repaid, source of loan

Priya Mohan Gurnanai, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

ITA 708/MUM/2021[2012-13]Status: DisposedITAT Mumbai08 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

Section 10Section 132Section 139Section 143(3)Section 153ASection 68

submitted the details of loan received, loan repaid, Ledger account of the lenders, loan confirmation by lender stating its name, address and permanent account number, bank statement of the lender, audited annual accounts of the lender, bank statement to show that the loan has been repaid, source of loan

Priya Mohan Gurnanai, Navi Mumbai vs. Dy CIT -CC-5(2), Mumbai

ITA 707/MUM/2021[2015-16]Status: DisposedITAT Mumbai08 Nov 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

Section 10Section 132Section 139Section 143(3)Section 153ASection 68

submitted the details of loan received, loan repaid, Ledger account of the lenders, loan confirmation by lender stating its name, address and permanent account number, bank statement of the lender, audited annual accounts of the lender, bank statement to show that the loan has been repaid, source of loan

Deputy Conservator of Forest Forest Bhilwara, Bhilwara vs. CIT Appeal, Delhi

In the result, the appeals of the assessee are allowed

ITA 99/JODH/2023[2018-19]Status: DisposedITAT Jodhpur02 Nov 2023AY 2018-19

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Sunil Porwal, CAFor Respondent: Ms. Meenakshi Vohra, CIT-DR

Section 133ASection 194CSection 201(1)

provisions of section 194C of the Income-tax Act, 1961 are squarely applicable on them while making payments to various VFPMCs. 6.1 Further, Permanent Account Number (PAN) of these VFPMCs were not in possession of the Deductor assessee at the time of making the payment to VFPMC, thus

Deputy Conservator of Forest Forest Bhilwara, Bhilwara vs. CIT, Delhi

In the result, the appeals of the assessee are allowed

ITA 98/JODH/2023[2017-18]Status: DisposedITAT Jodhpur02 Nov 2023AY 2017-18

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Sunil Porwal, CAFor Respondent: Ms. Meenakshi Vohra, CIT-DR

Section 133ASection 194CSection 201(1)

provisions of section 194C of the Income-tax Act, 1961 are squarely applicable on them while making payments to various VFPMCs. 6.1 Further, Permanent Account Number (PAN) of these VFPMCs were not in possession of the Deductor assessee at the time of making the payment to VFPMC, thus

DCIT, Circle-1(1)(2), Surat vs. J B Syntex Pvt. Ltd, Surat

In the result, appeal filed by the Revenue is dismissed

ITA 140/SRT/2020[2011-12]Status: DisposedITAT Surat18 Oct 2023AY 2011-12

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.140/Srt/2020 Assessment Year: (2011-12) (Physical Hearing) The Dcit, Vs. J. B. Syntex Pvt. Ltd., Circle – 1(1)(2), B-25, Guj. Eco. Textile Park, Surat N. H. No.8, Palsana, Surat – 394315. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcj9389D (Appellant) (Respondent) Shri Vinod Kumar, Sr. Dr Appellant By Shri Rasesh Shah, Ca Respondent By Date Of Hearing 17/08/2023 Date Of Pronouncement 18/10/2023

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

application money and the following documents were submitted during the course of assessment proceedings: (i) Confirmation of all five share applicant-companies; (ii) Permanent account number (PAN); (iii) Resolution passed by all the five applicants for investment in M/s Ujala Dyeing and Printing Mills (P) Ltd. ITA No.140/SRT/2020/AY.2011-12

Dinesh V. Shah, Mumbai vs. DCIT Central Cir-3(4, Mumbai

In the result, the appeal by the assessee is allowed

ITA 1153/MUM/2020[2008-09]Status: DisposedITAT Mumbai17 Oct 2023AY 2008-09

Bench: Shri Sandeep Singh Karhail & Shri Gagan Goyal

For Appellant: Shri Rasesh Shah a/wFor Respondent: Smt. Sanyogita Nagpal

Section 132Section 132ASection 143Section 153A(1)Section 153CSection 153C(1)Section 250Section 254(1)Section 68

discharged its onus to prove the genuineness of the parties and transactions by filing confirmations of the parties wherein the name address and Permanent account number have been provided and also bank statements of the lender parties evidencing the alleged transactions; b) The appellant filed a written statement during

Million Traders Bhopal P Ltd, Bhopal vs. The ACIT, CPC, Bengaluru

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

ITA 125/IND/2023[2018-19]Status: DisposedITAT Indore12 Oct 2023AY 2018-19

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

Section 143(1)Section 234B

referred to in sub-rule (1). (ii) The declaration filed by the deductee under clause (i) shall contain the name, address, permanent account number of the person to whom credit is to be given, payment or credit in relation to which credit is to be given and reasons for giving ... person deducting tax at source to issue certificate to the deductee within the prescribed time. Section 206AA carries the title Requirement to furnish Permanent Account Number. Various sub-sections contained therein provide for supplying PAN by the deductee failing which tax will be collected at a higher rate. In case

Million Traders Bhopal P Ltd, Bhopal vs. The ACIT, CPC, Bengaluru

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

ITA 124/IND/2023[2017-18]Status: DisposedITAT Indore12 Oct 2023AY 2017-18

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

Section 143(1)Section 234B

referred to in sub-rule (1). (ii) The declaration filed by the deductee under clause (i) shall contain the name, address, permanent account number of the person to whom credit is to be given, payment or credit in relation to which credit is to be given and reasons for giving ... person deducting tax at source to issue certificate to the deductee within the prescribed time. Section 206AA carries the title Requirement to furnish Permanent Account Number. Various sub-sections contained therein provide for supplying PAN by the deductee failing which tax will be collected at a higher rate. In case

ACIT-24(1), Mumbai vs. M/S. H K Designs (India) LLP, Mumbai

The appeal of the assessee is allowed

ITA 2050/MUM/2023[2012-13]Status: DisposedITAT Mumbai09 Oct 2023AY 2012-13

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

claimed that M/s H.K. Jewels (old) and M/s H.K.Jewels (new) are one and the same firm. However, the above said firms carry different Permanent Account Numbers, viz., AADFH8907J and AACFH4846F respectively. Accordingly the Id D.R strongly supported the orders passed by the assessing officer and further submitted that the factual

Manohar Singh, Jodhpur vs. ITO, Ward-1(3), Jodhpur

In the result, the appeal of the assessee is partly allowed

ITA 159/JODH/2019[2013-14]Status: DisposedITAT Jodhpur04 Oct 2023AY 2013-14

Section 143(2)Section 144Section 234ASection 234BSection 271(1)(b)

which lay on it in terms of s. 68 by proving the identity of the creditors by giving their complete addresses, GIR numbers / permanent account numbers and the copies of assessment orders wherever readily available, that it had also proved the capacity of the creditors by showing that the amounts

Homi Farrok Kaka, Mumbai vs. CIT (A), NFAC, Delhi

In the result, appeal of the assessee is allowed for statistical purpose in the terms aforesaid

ITA 1840/MUM/2023[2019-20]Status: DisposedITAT Mumbai27 Sept 2023AY 2019-20

Bench: Shri Vikas Awasthy& Ms. Padmavathy.Sआअसं.1840/मुं/2023 (िन.व. 2019-20) Homi Farrok Kaka, Avabai Mansion, 15, Henry Road, Colaba, Mumbai – 400 001. Pan: Aagpk-9646-N ...... अपीलाथ"/Appellant बनाम Vs. Commissioner Of Income Tax (Appeals), Nfac, Delhi. ..... "ितवादी/Respondent Assessee By : S/Shri Porus Kaka & Manish Kanth Revenue By : Shri Prakash Kishinchandani सुनवाई की ितिथ/ Date Of Hearing : 10/08/2023 घोषणा की ितिथ/ Date Of Pronouncement : 27/09/2023 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: S/Shri Porus Kaka, &For Respondent: Shri Prakash Kishinchandani

Section 199Section 199(1)

referred to in sub-rule (1).] (ii) The declaration filed by the deductee under clause (i) shall contain the name, address, permanent account number of the person to whom credit is to be given, payment or credit in relation to which credit is to be given and reasons for giving

Dhananjay G Mishra, Mumbai vs. ACIT, Cir-20(1), Mumbai

In the result, appeal filed by the Assessee stands dismissed

ITA 2066/MUM/2023[2017-18]Status: DisposedITAT Mumbai22 Sept 2023AY 2017-18

Bench: Shri B.R. Baskaran, Am & Shri N. K. Choudhry, Jm

For Appellant: Shri Satish Mody, AdvFor Respondent: Smt. Mahita Nair, CIT-DR

Section 143(1)Section 154Section 250

rule (1)] Dhananjay G. Mishra . (ii) The declaration filed by the deductee under clause (i) shall contain the name, address, permanent account number of the person to whom credit is to be given, payment or credit in relation to which credit is to be given and reasons for giving credit

Pfizer Ltd, Mumbai vs. DCIT - 14(2) (2), Mumbai

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

ITA 2132/MUM/2018[2014-15]Status: DisposedITAT Mumbai22 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

For Appellant: Shri P.J. Pardiwala Sr. AdvocateFor Respondent: Shri Ajay Kumar Sharma, CIT

Section 32Section 35D

orders of the lower authorities and submitted that where the ITS data is populated though by the others but it pertains to the permanent account number of the assessee and therefore it is for assessee to show that there is no transaction with those parties. As assessee has failed ... denied that AIR data is populated by others if they have transaction with the assessee. The AR data is populated based on permanent account number. Therefore, there are chances that certain times when AR data is populated by others, the permanent account number of the assessee may be punched wrongly

ACIT - 14(2) (2), Mumbai vs. Pfizer Ltd, Mumbai

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

ITA 2108/MUM/2018[2014-15]Status: DisposedITAT Mumbai22 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

For Appellant: Shri P.J. Pardiwala Sr. AdvocateFor Respondent: Shri Ajay Kumar Sharma, CIT

Section 32Section 35D

orders of the lower authorities and submitted that where the ITS data is populated though by the others but it pertains to the permanent account number of the assessee and therefore it is for assessee to show that there is no transaction with those parties. As assessee has failed ... denied that AIR data is populated by others if they have transaction with the assessee. The AR data is populated based on permanent account number. Therefore, there are chances that certain times when AR data is populated by others, the permanent account number of the assessee may be punched wrongly

ACIT Circle 25(1), Delhi vs. Vibhu International Ltd. (Formely Known As M/S Core International Ltd., Delhi

Appeal of the Revenue is dismissed

ITA 2005/DEL/2021[2009-10]Status: HeardITAT Delhi05 Sept 2023AY 2009-10

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharatassessment Year: 2009-10

Section 147Section 148Section 292B

Director of M/s Vibhu International Ltd. that the letter dated 30.09.2014 with subject, intimation regarding amalgamation and request for cancellation of Permanent Account Number AAFCM7101G was received in 5 the then ITO, Ward06(2) Delhi (now ITO, Ward-16(2), Delhi) office and its entry with entry number 608, dated

Income Tax Officer, Ward -1(4), Nagpur vs. Shri Prenish Umakant Pachabhaiye, Nagpur

In the result, appeal of the Revenue is dismissed

ITA 301/NAG/2019[2010-11]Status: DisposedITAT Nagpur01 Sept 2023AY 2010-11

Bench: Shri Partha Sarathi Chaudhury & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.301/Nag/2019 िनधा"रण वष" / Assessment Year : 2010-11 The Income Tax Shri Prenish Umakant Officer, Vs Pachabhaiye, Ward-1(4), Nagpur. Plot No.185, Shastri Layout, Saikrupa Apartment, Khamla, Nagpur – 440025. Pan: Anjpp 4784 G Appellant / Revenue Respondent / Assessee Assessee By Shri Dilip Lohiya – Ar Revenue By Shri Kailash Kanojiya – Sr.Dr Date Of Hearing 25/08/2023 Date Of Pronouncement 01/09/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Cit(A)-1, Nagpur Dated 18.07.2019 For A.Y.2010-11 Emanating From Assessment Order Passed By The Ito, Ward-25(3)(2), Mumbai Dated 30.06.2017 Under Section 147 R.W.S 144 Of The Income Tax Act, 1961. Shri Prenish Umakant Pachabhaiye [R]

Section 127Section 147

Ward-25(3)(2), Mumbai, before the ld.CIT(A)-1, Nagpur. It is mentioned in the order of the ld.CIT(A) that the Permanent Account Number(PAN) of the assessee was received on transfer from ITO, Ward-25(3)(2), Mumbai to ITO, Nagpur. 3. The clause