“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

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

Appeal is allowed

ITA 1442/AHD/2017[2011-12]Status: DisposedITAT Surat23 May 2023AY 2011-12

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

Dy Comm of Income Tax-14(1)(2), Mumbai vs. M/S Reliance Infrastructure Ltd., Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 234/MUM/2023[2020-21]Status: DisposedITAT Mumbai16 May 2023AY 2020-21

Section 143(1)Section 199(3)

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

Dy Comm of Income Tax-14(1)(2), Mumbai vs. M/S Reliance Infrastructure Ltd., Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 233/MUM/2023[2020-21]Status: DisposedITAT Mumbai16 May 2023AY 2020-21

Section 143(1)Section 199(3)

Sanjeev Agrawal, Jaipur vs. DCIT, Central Circle-4, Jaipur

In the result, the appeal of the assessee is allowed

ITA 71/JPR/2023[2018-19]Status: DisposedITAT Jaipur10 May 2023AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan Sogani (CA)For Respondent: Smt. Monisha Choudhary, (Addl.CIT)

Section 143(1)Section 250Section 4Section 5Section 6Section 90

country of residence of the payee. The payees to whom the payment were made by the assessee were not having any Permanent Account Number ("PAN"), in India. • Department was of the view that since the payees were not having PAN in India, then assessee should have deducted tax at source ... 206AA in case of payments made to non-resident persons having taxable income in India in spite of their failure to furnish the permanent account numbers. We, accordingly, answer the question referred to this Special Bench in the negative and in favour of the assessee and allow both the appeals

Rathi Cermics Pvt. Ltd., New Delhi vs. ITO, New Delhi

ITA 6136/DEL/2016[2006-07]Status: DisposedITAT Delhi08 May 2023AY 2006-07

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharma

Section 143(2)Section 143(3)Section 147Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘F’ : NEW DELHI) BEFORE SH. SHAMIM YAHYA, ACCOUNTANT MEMBER AND SH

Chandigarh Freight Carrier, Meerut vs. Pr. CIT, Ghaziabad

In the result, appeal of the assessee is accordingly allowed

ITA 500/DEL/2021[2015-16]Status: DisposedITAT Delhi28 Apr 2023AY 2015-16

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma[Assessment Year: 2015-16] Chandigarh Freight Carrier Vs. Pr. Cit 329, Uttam Nagar, Gupta Colony Ghaziabad Meerut, Uttar Pradesh-250 002 Pan No. Aahfc 1874 H [Appellant] [Respondent]

For Appellant: Shri Manish Jain, C.AFor Respondent: Ms Sapna Bhatia, CIT-DR

Section 143(3)Section 194Section 194C(6)Section 194C(7)Section 263Section 40

year to the account of a contractor during the course of business of plying, hiring or leasing goods carriages, on furnishing of his Permanent Account Number to the person paying or crediting the sum.” “13. The provisions of sec. 194C(6) extracted above was amended w.e.f 01.10.2009 by Finance (No.2 ... operators (as defined in section 44AE) from the purview of TDS. However, this would only apply in cases where the operator furnishes his Permanent Account Number (PAN) to the deductor. Deductors who make payments to transporters without deducting TDS (as they have quoted PAN) will be required to intimate these

M/S Tyson Marketing P. Ltd., Mumbai vs. ITO Ward-8(3)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 39/MUM/2021[2012-13]Status: DisposedITAT Mumbai18 Apr 2023AY 2012-13

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant ()

Section 143(3)Section 6Section 68

shown receipt of loan of Rs.85 lakhs from ‘M/s Josh Trading Pvt Ltd’ in its books of account. The assessee filed documents containing Permanent Account Number (PAN), bank statements, etc in support of its claim that it is a genuine loan. The Assessing Officer, for examining the identity and creditworthiness

Addl. CIT, Special Range- 7, New Delhi vs. Quippo Oil and Gas Infrastructure Ltd., New Delhi

In the result, the ground no

ITA 3544/DEL/2018[2013-14]Status: DisposedITAT Delhi23 Mar 2023AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar U.S.

For Appellant: Ms. Alka ArrenFor Respondent: Shri T. Kipgen

Section 32Section 40Section 43B

above, it could be observed that only slight modification had been introduced as to the procedure by replacing "declaration" with the words "Permanent Account Number" as the thing to be obtained from the Transporter. We are, therefore, inclined to hold that the provisions of Section 194C

Kanchan Plastics Private Limited, Cuttack vs. Deputy Commissioner of Income Tax Asmnt Circle-2(1), Cuttack

In the result, appeal filed by the assessee stands allowed

ITA 198/CTK/2022[2017-18]Status: HeardITAT Cuttack22 Mar 2023AY 2017-18

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2017-18 Kanchan Plastics Pvt Ltd., Kanchan Plastics Pvt Ltd., Vs. Dcit, Asmnt Circle Dcit, Asmnt Circle-2(1), 222, Banka Bazar, Cuttack 222, Banka Bazar, Cuttack Cuttack Pan/Gir No. Pan/Gir No. (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Mohit Sheth, Ar Mohit Sheth, Ar Revenue By : Shri S.C.Mohanty, Sr. S.C.Mohanty, Sr. Dr

For Appellant: Shri Mohit Sheth, ARFor Respondent: Shri S.C.Mohanty, Sr

Section 133(6)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH

Vikas Dugar, Jaipur vs. ACIT, Cen Circle-2 Jaipur, Jaipur

In the result the appeal filed by the assessee is allowed

ITA 27/JPR/2023[2013-14]Status: DisposedITAT Jaipur06 Mar 2023AY 2013-14

Bench: The Actual Hearing Of The Case.”

For Appellant: Shri Surendra Sha (C.A.)For Respondent: Smt Monisha Choudhary (Addl. CIT) a

Section 133(6)Section 143(3)Section 148

Overseas by furnishing following documents during assessment proceedings u/s 143(3) which are:- (i) Purchase bill. (ii) TIN under Rajasthan VAT Act. (iii) Permanent Account Number under Income-Tax Act. (iv) Confirmation duly signed by them. (v) Copy of Bank statement of October 2013 showing payment Payments made by RTGS ... Overseas by furnishing following documents during assessment proceedings u/s 143(3) which are:- (vi) Purchase bill. (vii) TIN under Rajasthan VAT Act. (viii) Permanent Account Number under Income-Tax Act. (ix) Confirmation duly signed by them. (x) Copy of Bank statement of October 2013 showing payment Payments made by RTGS

Mr. Prem Mukundan, Ernakulam vs. The ITO Ward-2(2), Kochi

In the result, appeals of the assessee are allowed

ITA 790/COCH/2022[2011-2012]Status: DisposedITAT Cochin03 Mar 2023AY 2011-2012

Bench: Shri George George K. (Judicial Member), Ms. Padmavathy S. (Accountant Member)

For Appellant: Shri Deepak Padmanabhan, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR

Section 143(1)Section 192Section 199Section 250

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

Ramesh Karaka, Ardhavaram vs. ITO, Ward-1, Tanuku

In the result, appeal of the assessee is dismissed

ITA 50/VIZ/2022[2017-18]Status: DisposedITAT Visakhapatnam28 Feb 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.50/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2017-18) Ramesh Karaka Vs. Income Tax Officer 1-47, Velamapeta Ward-1 Ardhavaram Tanuku Ganapavaram Mandalam West Godavari [Pan : Eiepk7762M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri K.Siva Ram Kumar, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 23.02.2023 घोर्णध की तधरीख/Date Of : 28.02.2023 Pronouncement

For Appellant: Shri K.Siva Ram Kumar, ARFor Respondent: Shri O.N.Hari Prasada Rao, DR

Section 115BSection 133ASection 143(3)Section 69

that though the assessee had substantial taxable income, he was not filing the returns of income. The assessee himself admitted that he has permanent account number, but he is neither filing the returns of income nor maintaining any books of accounts for the business carried on by him. The assessee

Saif Partners India IV Limited, Delhi vs. ACIT Int. Taxation-3(1)(2), Delhi

In the result, the appeal of the assessee in ITA No

ITA 1138/DEL/2022[2017-18]Status: DisposedITAT Delhi13 Feb 2023AY 2017-18

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri Kanchun Kaushal, FCAFor Respondent: Ms. Meenakshi Singh – CIT-DR

Section 10(34)Section 10(38)Section 142Section 142(1)Section 143(2)Section 143(3)Section 263

Minto Road New Delhi-110002 India Dear Sir Re: SAIF Partners India IV Limited (hereinafter referred to as the "Company" or the "Assessee") Permanent Account Number : AAOCS8595D Assessment Year : 2017-18 Financial Year : 2016-17 Subject: Notice dated 8 November 2019 issued under Section 142(1) of the Income

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 586/COCH/2022[2018-2019]Status: DisposedITAT Cochin20 Jan 2023AY 2018-2019

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR

Section 143(3)Section 144Section 153ASection 245C(1)

Undisputedly, the assessee, his family members as well as all the entities of the group are separately assessed to Income Tax under separate Permanent Account Numbers (PAN) and subjected to separate assessments. It could be seen that the present assessee does not hold any position in the management and control

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 585/COCH/2022[2017-2018]Status: DisposedITAT Cochin20 Jan 2023AY 2017-2018

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR

Section 143(3)Section 144Section 153ASection 245C(1)

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 584/COCH/2022[2016-2017]Status: DisposedITAT Cochin20 Jan 2023AY 2016-2017

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR

Section 143(3)Section 144Section 153ASection 245C(1)

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 583/COCH/2022[2015-2016]Status: DisposedITAT Cochin20 Jan 2023AY 2015-2016

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR

Section 143(3)Section 144Section 153ASection 245C(1)

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 582/COCH/2022[2014-2015]Status: DisposedITAT Cochin20 Jan 2023AY 2014-2015

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR

Section 143(3)Section 144Section 153ASection 245C(1)

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 581/COCH/2022[2013-2014]Status: DisposedITAT Cochin20 Jan 2023AY 2013-2014

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR

Section 143(3)Section 144Section 153ASection 245C(1)

M.K Rajendran Pillai, Pathanamthitta vs. Assistant Commissioner of Income Tax, Central Circle, Kollam

In the result the appeals for AYs 2012-13 to 2017-18 stand partly allowed whereas the appeal for AY 2018-19 stands allowed on legal grounds in terms of our above order

ITA 580/COCH/2022[2012-2013]Status: DisposedITAT Cochin20 Jan 2023AY 2012-2013

Bench: Hon’Ble Shri Satbeer Singh Godara, J.M. & Hon’Ble Shri Manoj Kumar Aggarwal, A.M.

For Appellant: Shri Sajjan Kumar Tulsiyan (Advocate)-Ld. ARFor Respondent: Smt. J.M Jamuna Devi (Addl. CIT) – Ld. DR

Section 143(3)Section 144Section 153ASection 245C(1)