“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

Crisil Ltd (in the Matter of Erstwhile Pipal Research Analytics and Information Services India P.Ltd, Mumbai vs. Asst CIT 9(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5029/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Jul 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Crisil Ltd. (In The Matter Of Erstwhile Pipal Research Analytics &Information Services Acit 9(2)(2) India Pvt. Ltd. Merged With Crisil Aaykar Bhavan, M. K. Road, Vs. Ltd.) Mumbai-400020 Crisil House, Central Avenue Road, Hiranndani Business Park,Powai Mumbai-400076 (Appellant) (Respondent) Pan No. Aaics2386Q

For Appellant: Ms. Chandani Shah, ARFor Respondent: Shri. Vachaspati Tripathi, DR

Section 143Section 144C(13)Section 92

December, 2016, assessee also filed a letter before the learned Assessing Officer by CRISIL Limited requesting the learned Assessing Officer to cancel the Permanent Account Number (PAN) of Pipal Research Analytics and Information Services India Pvt. Ltd. as it has been merged with CRISIL Limited. The learned Transfer Pricing Officer ... 22nd September, 2016. Further, on 21st December , 2016, also the learned Assessing Officer was informed about the merger and requested for cancellation of Permanent Account Number of the merged entity. On 22nd March, 2017, also similar information was given. Before the learned Dispute Resolution Panel also, the assessee has stated

Bhandari Gold and Jewellers Private Limited, Mumbai vs. CIT (Appeal), NFAC - Delhi

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 1619/MUM/2022[2017-2018]Status: DisposedITAT Mumbai19 Jul 2023AY 2017-2018

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Bledcit – 6(1)(2) V. M/S. Bandari Gold & Jewellers Pvt. Ltd., 407, Bussaudyog Bhavan Room No. 538B, 5Th Floor Tokersi, Jivraj Road, Sewree Aayakar Bhavan, M.K. Road Mumbai - 400015 Mumbai - 400020 Pan: Aadcb1291J (Appellant) (Respondent)

Section 143(3)Section 68

Copy of Monthly purchase and sales chart for existing and previousyear. D. As your Honor is aware, Transactions in relation to which permanent account number is to be quoted in all documents for the purpose of clause (c) of subsection (5) of section 139A of the Act. Rule 114B ... purchase, it is pertinent to note the following:  If any person buying gold worth Rs.2 lakhs and above, he need to provide your Permanent Account Number.  PAN will be traded as the buyer's identity. Sellers must collect tax at source on such sales which will be different  from

Cy. CIT 6(1) (2), Mumbai vs. M/S. Bhandari Gold & Jewellers Pvt. Ltd, Mumbai

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 1564/MUM/2022[2017-18]Status: DisposedITAT Mumbai19 Jul 2023AY 2017-18

Section 143(3)Section 68

Abbott India Ltd, Mumbai vs. Addl CIT RG 7(2), Mumbai

In the result appeal filed by the assessee for both the assessment years are allowed

ITA 2032/MUM/2014[2009-10]Status: DisposedITAT Mumbai12 Jul 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Chaudhary, Jm Ita No. 2032/Mum/2014 (Assessment Year2009-10)

For Appellant: Shri Madhur Agrawal,ARFor Respondent: Shri Byomkesh Pradipta Kumar

Section 143(3)Section 144CSection 144C(13)

Solvay Pharma India Ltd approved by the honourable Bombay High Court wide its order dated 15 July 2011. The assessee also submitted the permanent account number of both the entities. (Page number 51 of the paper book) xi on 14 March 2013 once again the same identical information was furnished ... further stated that the assessee has also communicated with the learned assessing officer in the name of a non-existent entity citing the permanent account number of the nonexistent entity. He further relied upon the decision of the honourable Supreme Court in case of Principal Commissioner of Income

Abbott India Ltd.(Solvay Pharma India Ltd), Mumbai vs. Addl.C.I.T. RG.7(2), Mumbai

In the result appeal filed by the assessee for both the assessment years are allowed

ITA 7778/MUM/2012[2008-09]Status: DisposedITAT Mumbai12 Jul 2023AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Chaudhary, Jm Ita No. 2032/Mum/2014 (Assessment Year2009-10)

For Appellant: Shri Madhur Agrawal,ARFor Respondent: Shri Byomkesh Pradipta Kumar

Section 143(3)Section 144CSection 144C(13)

Devender, Rohtak vs. ITO Ward - 1, Rewari

In the result, appeal of the assessee is allowed

ITA 11/DEL/2021[2013-14]Status: DisposedITAT Delhi07 Jul 2023AY 2013-14

Bench: Shri Saktijit Dey, Vice- & Shri Girish Agrawalassessment Year: 2013-14

For Appellant: Shri Rajiv Saxena & Shyam Sunder, AdvsFor Respondent: Shri Ramdhan Meena, Sr. DR

Section 148

Bank Ltd. Account No. : 14152191020701 Mode of operation : Joint 3 Davender, Rohtak- AY: 2013-14 4.1 In the said joint saving bank account, permanent account number (PAN) of the assessee is updated. During the year under consideration amount of Rs.1,07,81,000 was deposited in cash in the said

ACIT C.C. -13, Cent. RG.-3, Mumbai vs. M/S. Krishiraj Trading Ltd (Now Mergeed With Mgn Agro Properties Pvt. Ltyd, Mumbai

ITA 2219/MUM/2021[2012-13]Status: DisposedITAT Mumbai30 Jun 2023AY 2012-13

For Appellant: Shri Farrokh Irani, Sr. AdvocateFor Respondent: Shri Neehar Ranjan Pandey

Section 142(1)Section 143(3)Section 14ASection 68

company incorporated under the provisions of companies Act, 1956 and has been assessed to tax in regular basis. The Assessee had furnished the permanent account number of the Lender. The loan was taken through banking channel and the details furnished by the Appellant were sufficient to satisfy the requirements

Dhanraj Sethia, Jaipur vs. Assistant Commissioner of Income Tax, Circle-1

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

ITA 169/JPR/2023[2012-13]Status: DisposedITAT Jaipur28 Jun 2023AY 2012-13

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Praveen Saraswat, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT

Section 194ASection 194A(3)(iii)Section 271Section 271(1)Section 271(1)(c)Section 274Section 40

Attene to give evidence or produce books of accounts etc. in compliance with summons under section 131(1). (d) Apply for allotment of permanent account number in term sof Section 139A. You are hereby requested to appear before me on 21-03-2014 at Room No. 11, N.C.R.B., Statute Circle

Calibehr Business Support Services Pvt Ltd., Mumbai vs. Asst Director of Income Tax, CPC/ Asst Comm of Income Tax Circle-1(2)(1), Bangalor

In the result, appeal of the assessee for assessment year 2019 – 20 is partly allowed

ITA 257/MUM/2023[2019-20]Status: DisposedITAT Mumbai26 Jun 2023AY 2019-20

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri. Nitesh Joshi, ARFor Respondent: Ms. Agnes P. Thomas, DR

Section 115JSection 143(1)Section 143(3)Section 40Section 40A(7)Section 43

learned assessing officer may also examine that whether the assessee has furnished requisite information to the deductor with respect to correcting the permanent account number in form number 26AS by incorporating the permanent account number of the assessee against the permanent account number of vital link consultancy private limited

Calibehr Business Support Services Pvt Ltd., Mumbai vs. Asst Director of Income Tax, CPC/ Asst Comm of Income Tax Circle-1(2)(1), Bangalor

In the result, appeal of the assessee for assessment year 2019 – 20 is partly allowed

ITA 256/MUM/2023[2020-21]Status: DisposedITAT Mumbai26 Jun 2023AY 2020-21

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri. Nitesh Joshi, ARFor Respondent: Ms. Agnes P. Thomas, DR

Section 115JSection 143(1)Section 143(3)Section 40Section 40A(7)Section 43

Calibehr Business Support Services Private Limited, Mumbai vs. Assessing Officer, National E-Assessement Centre, Delhi

In the result, appeal of the assessee for assessment year 2019 – 20 is partly allowed

ITA 3227/MUM/2022[2018-19]Status: DisposedITAT Mumbai26 Jun 2023AY 2018-19

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri. Nitesh Joshi, ARFor Respondent: Ms. Agnes P. Thomas, DR

Section 115JSection 143(1)Section 143(3)Section 40Section 40A(7)Section 43

Jt. CIT (OSD), CC - 5(1), Mumbai vs. Veritas India Ltd., Mumbai

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

ITA 2098/MUM/2019[2014-15]Status: DisposedITAT Mumbai21 Jun 2023AY 2014-15

For Appellant: Shri Gaurav KabraFor Respondent: Shri Samuel Pitta (Sr. AR)

Section 132(4)Section 143(3)

invested to earn unaccounted income, the A.Y. 2014-15 Veritas (India) Ltd operators operating on behalf of the exit providers having their permanent account number is and matching stock exchange trading data, unfamiliarity of the assessee with respect to trading of shares, ignorance of the assessee how he came

Veritas (India) Ltd, Mumbai vs. DCIT - CC- 5(1), Mumbai

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

ITA 1897/MUM/2019[2014-15]Status: DisposedITAT Mumbai21 Jun 2023AY 2014-15

For Appellant: Shri Gaurav KabraFor Respondent: Shri Samuel Pitta (Sr. AR)

Section 132(4)Section 143(3)

M/S. Sudarshan Nirman Co., Mumbai vs. ITO Ward 3(5), Mumbai

ITA 3176/MUM/2022[2014-15]Status: DisposedITAT Mumbai20 Jun 2023AY 2014-15

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am आयकरअपीलसं./ I.T.A. No.3176/Mum/2022 (ननधधारणवर्ा / Assessment Year: 2014-15)

For Appellant: Shri Vallabhdas D. ParmarFor Respondent: Ms. Deepika Arrora (Sr. AR)

Section 143(2)Section 143(3)Section 144

assessee submitted the details of the purchasers etc. and of the sundry creditors. As assessee could not furnish confirmation and permanent account numbers of the parties as same was not available at that time. In absence of any such evidence, the sundry creditors amounting to Rs.2,44,85,512/- were

Star India Pvt. Ltd. (Sucessor of Star Sports India Pvt. Ltd.- (Ssipl), Mumbai vs. ACIT 16 (1), Mumbai

The appeal of the assessee is allowed to the extent indicated above and Ground

ITA 657/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Jun 2023AY 2014-15

Bench: Amit Shukla & Shri Prashant Maharishim/S Star India Pvt. Ltd. A C I T (Successor Of Star Sports India -16(1) Pvt. Ltd.) Room No. 439, Star House, Urmi Estate Vs. Aayakar Bhavan 95, Ganpantrao Kadam Marg M.K. Road, Lower Parel (W) Mumbai 400020 Mumbai 400013 Pan – Aaacn1335Q Appellant Respondent Co No. 114/Mum/2021 (Assessment Year: 2014-15) A C I T -16(1) M/S Star India Pvt. Ltd. Room No. 439, Aayakar Bhavan (Successor Of Star Sports India M.K. Road, Mumbai 400020 Pvt. Ltd.) Vs. Star House, Urmi Estate 95, Ganpantrao Kadam Marg Lower Parel (W) Mumbai 400013 Cross Objector Appellant In Appeal Assessee By: Shri Porus Kaka, Sr Advocate Revenue By: Shri Biswanath Das –Cit-Dr Date Of Hearing: 27.03.2023 Date Of Pronouncement: 20.06.2023 O R D E R Per: Prashant Maharishi, A. M. 01. Assessee Has Filed Appeal For Assessment Year (Ay) 2014-15 Against The Assessment Order Passed By The Acit-16(1), Mumbai

For Appellant: Shri Porus Kaka, SR AdvocateFor Respondent: Shri Biswanath Das –CIT-DR

Section 119Section 143(2)Section 143(3)Section 92C

assessee filed its original return of income in the name of Star Sports India Pvt. Ltd. for AY 2014-15 using the permanent account number of AAACE2334C which belonged to the non existing entity Star sports India private limited. The return was signed by one Mr Sanjay Gupta ... file two original tax returns i.e. One for Star sports India private limited and second for Star India private limited under one permanent account number and one name. It was further submitted that for the period 1 April 2013 – 3 November 2013 one return was filed in the name

Rajesh Somnay, Mumbai vs. ITO, International Taxation, Ward 4(2)(1), Mumbai

The Appeal is allowed

ITA 533/MUM/2023[2015-16]Status: DisposedITAT Mumbai30 May 2023AY 2015-16

For Appellant: NoneFor Respondent: Shri Soumendu Kumar Dash

Section 143(1)Section 144C(13)Section 144C(5)Section 147Section 147rSection 148Section 54

Appellant in equal proportion with the other 2 legal heirs as per Hindu Succession Act. The Appellant had provided name and Permanent Account Number of the other two legal heirs both of whom were non-residents; and (c) the Hardship Compensation was not in the nature of receipt liable

M/S Bharti Airtel Limited, Indore vs. Deputy Commissioner of Income Tax-TDS, Indore

In the result, appeals of assessee are allowed for statistical purposes

ITA 65/IND/2018[2009-10]Status: DisposedITAT Indore25 May 2023AY 2009-10

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

Section 194HSection 201Section 201(1)

wherein it was held that Page 2 of 10 ITA No.513/Ind/2014 & ITANo.65/Ind/2018 Bharti Airtel Ltd.. Page 3 of 10 when the Permanent Account Numbers are made available to the Assessing Officer, it would not be unreasonable on the part of the assessee to ask the Assessing Officer to have

M/S. Bharti Airtel Limited, Indore vs. The ITO TDS-II, Indore

In the result, appeals of assessee are allowed for statistical purposes

ITA 513/IND/2014[2010-11]Status: DisposedITAT Indore25 May 2023AY 2010-11

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

Section 194HSection 201Section 201(1)

DCIT Central Circle-2(3), Mumbai vs. M/S Asian Star Company Ltd, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2778/MUM/2022[2012-13]Status: DisposedITAT Mumbai23 May 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm M/S Asian Star Company Ltd. Dcit, Central Circle-2(3) Room No.803, 8Th Floor, 114-C, Mitta Court, Pratishtha Bhavan, Vs. M.K. Road, Churchgate, Nariman Point, Mumbai-400 020 Mumbai-400 021 (Appellant) (Respondent) Pan No. Aaaca4856B Assessee By : Shri Suchek Anchaliya, Ms. Vaishali More, Ars Revenue By : Smt. Shailja Rai, Cit Dr Date Of Hearing: 28.02.2023 Date Of Pronouncement : 23.05.2023

For Appellant: Shri Suchek AnchaliyaFor Respondent: Smt. Shailja Rai, CIT DR

Section 133ASection 143Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND MS. KAVITHA RAJAGOPAL, JM M/s

Mumtaz Dilawar Gani, Bharuch vs. The ITO, Ward-1, Bharuch

Appeal is allowed

ITA 1443/AHD/2017[2012-13]Status: DisposedITAT Surat23 May 2023AY 2012-13

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकर अपील सं/.Ita Nos.1442 & 1443/Ahd/2017 (िनधा"रणवष" / Assessment Years: (2011-12 & 2012-13) (Physical Court Hearing) Mumtaz Dilawar Gani Income Tax Officer, 6, White House, Near Railway Ward-1, Bharuch Vs. Crossing, Dahej Byepass Road, Income Tax Officer, Ward-1(2), Bharuch-392001 Bharuch "थायीलेखासं /.जीआइआरसं /.Pan/Gir No.: Adcpg 1175 D (अपीलाथ" /Assessee ) (""थ" /Respondent) "नधा"रती क" ओर से /Assessee By : Shri Krutarth Desai, Advocate & Ms. Disha Kharod, C.A राज"व क" ओर से /Respondent By : Shri Vinod Kumar, Sr-.Dr सुनवाईकीतारीख / Date Of Hearing : 31/03/2023 घोषणाकीतारीख /Date Of Pronouncement : 23/05/2023

For Appellant: Shri Krutarth Desai, Advocate &For Respondent: Shri Vinod Kumar, Sr-.DR

Section 142(1)Section 143(3)Section 145(3)

Thus, from the facts noted hereinabove, it is evident that the assessee had produced all relevant details in its possession, namely, names, permanent account numbers, income tax returns, and bank statements of all the investors. The amounts in question had been received by way of account payee cheques. Having regard ... fact that the permanent account numbers and the income tax returns of all the investors had been furnished by the assessee, the Assessing Officer could have easily verified the same. He, however, placed reliance upon the fact that the summons issued to the parties under section