permanent account number — 565 case laws

DCIT Cir -4(2) (1), Mumbai vs. M/S. Goddress Pharmaceuticals P.Ltd, Mumbai

The appeal is dismissed

ITA 1835/MUM/2021[2017-18]Status: DisposedITAT Mumbai29 Jun 2022AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm M/S. Goddress The Dcit Pharmaceuticals P. Ltd. Cir 4(2)(1) Unit No. 304, A-Wing, Room No. 642, Western Edge, 6Th Floor, Near Western Express Vs. Aayakar Bhavan, Highway, M.K. Road, Borivali (East), Mumbai-400 020 Mumbai-400 066 (Respondent) (Appellant) Pan No. Aadcg6434C Assessee By : Shri. Subodh Ratnaparkhi, Ar Revenue By : Smt. Sonia Kumar, Dr Date Of Hearing: 23.05.2022 Date Of Pronouncement : 29.06.2022

For Appellant: Shri. Subodh Ratnaparkhi, ARFor Respondent: Smt. Sonia Kumar, DR

Section 133Section 143Section 69A

cash deposit added u/s 69A of the act the learned CIT – A noted that assessee has submitted the name of the parties, permanent account number of the parties, addresses, location and the amount deposited by the debtors amounting to ₹ 2,346,255 along with the confirmation. Therefore, he deleted ... learned and CIT – A deleted the addition. He also verified the complete details filed by the assessee with respect to the parties, their permanent account number, address, location and the amount deposited. In view of this we do not find any reason to uphold the addition made by the learned

DCIT CC 8(1), Mumbai vs. Shri. Suresh Gurubuxsing Wadhwa, Navi Mumbai

In the result, all the appeals filed by the Revenue stand dismissed

ITA 78/MUM/2020[2012-13]Status: DisposedITAT Mumbai24 Jun 2022AY 2012-13

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singh

For Appellant: Mani JainFor Respondent: Amol B. Kirtane

Section 132Section 132(4)Section 153Section 68

were reflected in the bank accounts of the assessee as well as of the creditor. The creditor was an Income-tax assessee. Its permanent account number card was placed on record. The assessee had sufficiently discharged the burden which lay upon {It to explain the nature and source

DCIT, CC- 8 (1), Mumbai vs. Surinder Anantram Sabhlok, Mumbai

In the result, all the appeals filed by the Revenue stand dismissed

ITA 56/MUM/2020[2011-12]Status: DisposedITAT Mumbai24 Jun 2022AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singh

For Appellant: Mani JainFor Respondent: B.K. Bagchi &

Section 132Section 132(4)Section 68

were reflected in the bank accounts of the assessee as well as of the creditor. The creditor was an Income-tax assessee. Its permanent account number card was placed on record. The assessee had sufficiently discharged the burden which lay upon {It to explain the nature and source

DCIT, Cir - 4(2)(1), Mumbai vs. M/S.Ohm Stock Broker P. Ltd., Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1445/MUM/2020[2014-15]Status: DisposedITAT Mumbai21 Jun 2022AY 2014-15

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit – Circle – 4(2)(1) V. M/S. Ohm Stock Brokers Pvt. Ltd., Room No. 642, 6Th Floor 301-A, Poonam Chambers Aayakar Bhavan, M.K. Road B-Wing, Dr. A.B. Road Mumbai - 400020 Worli, Mumbai -400018 Pan: Aaaco3526E (Appellant) (Respondent) Assessee By : None Department By : Shri M.P. Ahuja

For Appellant: NoneFor Respondent: Shri M.P. Ahuja

Section 143(1)Section 143(2)Section 43(5)Section 73

every client indicating in the contract note the unique client identity number allotted under any Act referred to in sub-clause (A) and permanent account number allotted under this Act; (ii) "recognised stock exchange" means a recognised stock exchange as referred to in clause U) of section ... unique client identity number allotted under the Act, rules, regulations or bye-laws referred to in sub-clause (A), unique trade number and permanent account number allotted under this Act; (iii) "recognised association" means a recognised association as referred to in clause (I) of section 236o the Forward Contracts (Regulation

Gujarat Goods Service, Mumbai vs. ITO-17(1)(5), Mumbai

In the result, we find that the learned CIT

ITA 295/MUM/2021[2014-15]Status: DisposedITAT Mumbai31 May 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm The Income Tax Officer, Ward Gujarat Goods Service 17(1)(5), Rn.117, 1St Floor, 79/81, South Jail Road, Aayakar Bhavan, M.K. Road, Vs. Dongri, Mumbai-400 009 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaffg8339R

For Appellant: NoneFor Respondent: Shri Hoshang B. Irani, DR

Section 133(6)Section 143(3)

self made vouchers. During the remand proceedings, the assessee was asked to produce the details of parties along with complete addressand Permanent Account Number. The assessee submitted that the expenses are very small in nature and no further details can be provided. However, the expense incurred through Goods Transport Labour

Mrs. Spureet Kaur Nagi, Mumbai vs. ACIT CC 20, Mumbai

In the result ground number 9 of the appeal is allowed

ITA 6835/MUM/2019[2009-10]Status: DisposedITAT Mumbai31 May 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR

Section 143(3)Section 153ASection 37(1)Section 69A

should not have been added as income of assessee. He further submitted that the loan amount is very small and therefore, the Permanent Account Number as well as the confirmation could not be obtained. He stated that the names of the family members are already available on the record ... claimed to have been received from friends and relatives added in the hands of the assessee as assessee could not file the Permanent Account Number and confirmation of those relatives, admittedly, assessee did not furnish the confirmation and Permanent Account Numbers of the relatives. However, assessee has stated that these

Mrs. Spureet Kaur Nagi, Mumbai vs. ACIT CC-20, Mumbai

In the result ground number 9 of the appeal is allowed

ITA 6458/MUM/2019[2008-09]Status: DisposedITAT Mumbai31 May 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR

Section 143(3)Section 153ASection 37(1)Section 69A

should not have been added as income of assessee. He further submitted that the loan amount is very small and therefore, the Permanent Account Number as well as the confirmation could not be obtained. He stated that the names of the family members are already available on the record ... claimed to have been received from friends and relatives added in the hands of the assessee as assessee could not file the Permanent Account Number and confirmation of those relatives, admittedly, assessee did not furnish the confirmation and Permanent Account Numbers of the relatives. However, assessee has stated that these

Mrs. Spureet Nagi, Mumbai vs. ACIT CC-20, Mumbai

In the result ground number 9 of the appeal is allowed

ITA 5944/MUM/2019[2007-08]Status: DisposedITAT Mumbai31 May 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR

Section 143(3)Section 153ASection 37(1)Section 69A

should not have been added as income of assessee. He further submitted that the loan amount is very small and therefore, the Permanent Account Number as well as the confirmation could not be obtained. He stated that the names of the family members are already available on the record ... claimed to have been received from friends and relatives added in the hands of the assessee as assessee could not file the Permanent Account Number and confirmation of those relatives, admittedly, assessee did not furnish the confirmation and Permanent Account Numbers of the relatives. However, assessee has stated that these

Mrs. Spureet Nagi, Mumbai vs. ACIT CC-20, Mumbai

In the result ground number 9 of the appeal is allowed

ITA 5943/MUM/2019[2006-07]Status: DisposedITAT Mumbai31 May 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR

Section 143(3)Section 153ASection 37(1)Section 69A

should not have been added as income of assessee. He further submitted that the loan amount is very small and therefore, the Permanent Account Number as well as the confirmation could not be obtained. He stated that the names of the family members are already available on the record ... claimed to have been received from friends and relatives added in the hands of the assessee as assessee could not file the Permanent Account Number and confirmation of those relatives, admittedly, assessee did not furnish the confirmation and Permanent Account Numbers of the relatives. However, assessee has stated that these

Mrs. Spureet Nagi, Mumbai vs. ACIT CC-20, Mumbai

In the result ground number 9 of the appeal is allowed

ITA 5942/MUM/2019[2005-06]Status: DisposedITAT Mumbai31 May 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR

Section 143(3)Section 153ASection 37(1)Section 69A

should not have been added as income of assessee. He further submitted that the loan amount is very small and therefore, the Permanent Account Number as well as the confirmation could not be obtained. He stated that the names of the family members are already available on the record ... claimed to have been received from friends and relatives added in the hands of the assessee as assessee could not file the Permanent Account Number and confirmation of those relatives, admittedly, assessee did not furnish the confirmation and Permanent Account Numbers of the relatives. However, assessee has stated that these

Mrs. Supreet Kaur Nagi, Mumbai vs. ACIT CC 20, Mumbai

In the result ground number 9 of the appeal is allowed

ITA 5941/MUM/2019[2004-05]Status: DisposedITAT Mumbai31 May 2022AY 2004-05

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR

Section 143(3)Section 153ASection 37(1)Section 69A

should not have been added as income of assessee. He further submitted that the loan amount is very small and therefore, the Permanent Account Number as well as the confirmation could not be obtained. He stated that the names of the family members are already available on the record ... claimed to have been received from friends and relatives added in the hands of the assessee as assessee could not file the Permanent Account Number and confirmation of those relatives, admittedly, assessee did not furnish the confirmation and Permanent Account Numbers of the relatives. However, assessee has stated that these

Mrs. Supreet Kaur Nagi, Mumbai vs. ACIT CC 20, Mumbai

In the result ground number 9 of the appeal is allowed

ITA 5940/MUM/2019[2003-04]Status: DisposedITAT Mumbai31 May 2022AY 2003-04

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR

Section 143(3)Section 153ASection 37(1)Section 69A

should not have been added as income of assessee. He further submitted that the loan amount is very small and therefore, the Permanent Account Number as well as the confirmation could not be obtained. He stated that the names of the family members are already available on the record ... claimed to have been received from friends and relatives added in the hands of the assessee as assessee could not file the Permanent Account Number and confirmation of those relatives, admittedly, assessee did not furnish the confirmation and Permanent Account Numbers of the relatives. However, assessee has stated that these

Hinduja Finance Ltd., Mumbai vs. DCIT, Range -7(1)(2) (Earlier DCIT 6(1)), Mumbai

In the result, this ground of appeal of assessee is dismissed and order of Ld

ITA 7154/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 May 2022AY 2010-11

Bench: Shri Vikas Awasthy & Shri Gagan Goyalhinduja Finance Ltd. 171, Hinduja House, Dr. Annie Besant Road, Worli, Mumbai-400018 Pan: Aagca0533R ...... Appellant Vs. Dy.Cit, Range-7(1)(2) Aayakar Bhavan, M.K. Road, Mumbai-400020. ..... Respondent Appellant By : Sh. Ruturaj Gurjar Respondent By : Sh. B.K. Bagchi, Cit-Dr Date Of Hearing : 25/03/2022 Date Of Pronouncement : 20/05/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-13, Mumbai [Hereinafter Referred To As ‘The Cit (A)’] Vide Order Dated 05.09.2019 For The Assessment Year (Ay) 2010- 11. The Assessee Has Raised The Following Grounds Of Appeal: 1. On The Facts & The Circumstances Of The Case & In Law, The Cit(A) Has Erred In Confirming: I) The Disallowance Made U/S.14A Of The Income Tax Act At Rs.7, 06,985/- As Against Disallowance Of Rs.2, 52,536/- As Computed By The Appellant. The Disallowance Made Of Rs.4, 54,449/- May Please Be Deleted.

For Appellant: Sh. Ruturaj GurjarFor Respondent: Sh. B.K. Bagchi, CIT-DR

Section 14Section 14A

every client indicating in the contract note the unique client identity number allotted under any Act referred to in sub-clause (A) and permanent account number allotted under this Act; (ii) "recognised stock exchange" means a recognised stock exchange as referred to in clause (f) of section ... unique client identity number allotted under the Act, rules, regulations or bye-laws referred to in sub-clause (A), unique trade number and permanent account number allotted under this Act; [(iii) "recognised stock exchange" means a recognised stock exchange as referred to in clause (f) of section

ITO 22 (3)(2), Mumbai vs. M/S Sai Everest Builders & Developers, Mumbai

In the result, appeals of revenue for the A

ITA 6490/MUM/2019[2012-13]Status: DisposedITAT Mumbai18 May 2022AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Gagan Goyal

For Appellant: Sh. Hoshang B. Irani, DRFor Respondent: Sh. Prakash Jhunjhunwala

Section 133ASection 143(1)Section 148Section 68

though amount was received by account payee cheque and most of creditors were assessed to Income Tax Act and had even provided their permanent account number but on desire of AO of producing said parties, none of parties were able ‘to prove source of amount advanced to assessee Thus

ITO 22 (3)(2), Mumbai vs. M/S Sai Everest Builders & Developers, Mumbai

In the result, appeals of revenue for the A

ITA 6489/MUM/2019[2011-12]Status: DisposedITAT Mumbai18 May 2022AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Gagan Goyal

For Appellant: Sh. Hoshang B. Irani, DRFor Respondent: Sh. Prakash Jhunjhunwala

Section 133ASection 143(1)Section 148Section 68

though amount was received by account payee cheque and most of creditors were assessed to Income Tax Act and had even provided their permanent account number but on desire of AO of producing said parties, none of parties were able ‘to prove source of amount advanced to assessee Thus

ACIT 22(3), Mumbai vs. Sai Everest Builders $ Developers, Mumbai

In the result, appeals of revenue for the A

ITA 4105/MUM/2019[2013-14]Status: DisposedITAT Mumbai18 May 2022AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Gagan Goyal

For Appellant: Sh. Hoshang B. Irani, DRFor Respondent: Sh. Prakash Jhunjhunwala

Section 133ASection 143(1)Section 148Section 68

though amount was received by account payee cheque and most of creditors were assessed to Income Tax Act and had even provided their permanent account number but on desire of AO of producing said parties, none of parties were able ‘to prove source of amount advanced to assessee Thus

ITO-22(3)(2), Mumbai vs. Sai Everest Builders & Developers, Mumbai

In the result, appeals of revenue for the A

ITA 4096/MUM/2019[2014-15]Status: DisposedITAT Mumbai18 May 2022AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Gagan Goyal

For Appellant: Sh. Hoshang B. Irani, DRFor Respondent: Sh. Prakash Jhunjhunwala

Section 133ASection 143(1)Section 148Section 68

though amount was received by account payee cheque and most of creditors were assessed to Income Tax Act and had even provided their permanent account number but on desire of AO of producing said parties, none of parties were able ‘to prove source of amount advanced to assessee Thus

M/S. Infosys Bpo Limited, Bangalore vs. The Deputy Commissioner of Income Tax, International Taxation, Circle-1(1), Bangalore

In the result, the appeal is allowed in favour of the assessee

ITA 988/BANG/2017[2016-17]Status: DisposedITAT Bangalore17 May 2022AY 2016-17

Bench: Shri N V Vasudevan & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Priyadarshi Mishra, Addl.CIT(DR)(ITAT)

Section 195Section 195ASection 206ASection 248Section 9Section 9(1)(vi)

deducted at higher rate under section 206AA was not applicable when the payments were made to non-residents in the absence of Permanent Account Number. On this, the CIT(A) relied on the decision of the coordinate bench of the Tribunal in the case of Bosch ... next issue for consideration is the deduction of tax at source at higher rate under section 206AA in the absence of Permanent Account Number not being applicable to payments made to non- residents by the assessee. We notice that the CIT(A) himself has quoted Page

M/S. Infosys Bpo Limited, Bangalore vs. The Deputy Commissioner of Income Tax, International Taxation, Circle-1(1), Bangalore

In the result, the appeal is allowed in favour of the assessee

ITA 987/BANG/2017[2016-17]Status: DisposedITAT Bangalore17 May 2022AY 2016-17

Bench: Shri N V Vasudevan & Shri Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri

Section 195Section 195ASection 206ASection 248Section 9Section 9(1)(vi)

deducted at higher rate under section 206AA was not applicable when the payments were made to non-residents in the absence of Permanent Account Number. On this, the CIT(A) relied on the decision of the coordinate bench of the Tribunal in the case of Bosch

M/S. Goldman Sachs Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, International Taxation, Circle- 1(1), Bangalore

In the result, the appeal filed by the assessee for all the years under consideration stands allowed

ITA 369/BANG/2020[2014-15]Status: PendingITAT Bangalore29 Apr 2022AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(It)A Nos. 362 To 369 & 338 To 345/Bang/2020 Assessment Years : 2011-12 To 2014-15 & 2015-16 To 2018-19 M/S. Goldman Sachs Services Pvt. Ltd., The Deputy Wing A, Wing B & Commissioner Of Ground Floor To 6Th Floor Income Tax, Of Wing C, International Helios Business Park, Taxation, 150 Outer Ring, Vs. Circle 1 (1), Kadubeesanahalli, Bangalore. Bangalore – 560 103. Pan:Aaccg2435N Appellant Respondent Assessee By : Shri Sharath Rao, Ca : Dr. Manjunath Karkihalli, Revenue By Cit Dr Date Of Hearing : 09-03-2022 Date Of Pronouncement : 29-04-2022 Order Per Beena Pillaipresent Appeals Are Filed By The Assessee Against Following Orders, Passed By The Ld. Dcit, International Taxation, Circle – 1(1), Bangalore Independently, Under Section 201(1) & 201(1A) Of The Act, For The Assessment Years Under Consideration As Under:

For Appellant: Shri Sharath Rao, CA

Section 192(1)Section 195Section 201Section 201(1)

designation, division and brief description of the duties performed by such employees. It was also submitted that such expatriate employees held valid permanent account number in India and were assessed to tax in Page 4 of 45 IT(IT)A Nos. 362 to 369 & 338 to 345/Bang/2020 India. The assessee

“permanent account number”

Leading authorities on permanent account number

Judgments citing permanent account number

DCIT Cir -4(2) (1), Mumbai vs. M/S. Goddress Pharmaceuticals P.Ltd, Mumbai

DCIT CC 8(1), Mumbai vs. Shri. Suresh Gurubuxsing Wadhwa, Navi Mumbai

DCIT, CC- 8 (1), Mumbai vs. Surinder Anantram Sabhlok, Mumbai

DCIT, Cir - 4(2)(1), Mumbai vs. M/S.Ohm Stock Broker P. Ltd., Mumbai

Gujarat Goods Service, Mumbai vs. ITO-17(1)(5), Mumbai

Mrs. Spureet Kaur Nagi, Mumbai vs. ACIT CC 20, Mumbai

Mrs. Spureet Kaur Nagi, Mumbai vs. ACIT CC-20, Mumbai

Mrs. Spureet Nagi, Mumbai vs. ACIT CC-20, Mumbai

Mrs. Spureet Nagi, Mumbai vs. ACIT CC-20, Mumbai

Mrs. Spureet Nagi, Mumbai vs. ACIT CC-20, Mumbai

Mrs. Supreet Kaur Nagi, Mumbai vs. ACIT CC 20, Mumbai

Mrs. Supreet Kaur Nagi, Mumbai vs. ACIT CC 20, Mumbai

Hinduja Finance Ltd., Mumbai vs. DCIT, Range -7(1)(2) (Earlier DCIT 6(1)), Mumbai

ITO 22 (3)(2), Mumbai vs. M/S Sai Everest Builders & Developers, Mumbai

ITO 22 (3)(2), Mumbai vs. M/S Sai Everest Builders & Developers, Mumbai

ACIT 22(3), Mumbai vs. Sai Everest Builders $ Developers, Mumbai

ITO-22(3)(2), Mumbai vs. Sai Everest Builders & Developers, Mumbai

M/S. Infosys Bpo Limited, Bangalore vs. The Deputy Commissioner of Income Tax, International Taxation, Circle-1(1), Bangalore

M/S. Infosys Bpo Limited, Bangalore vs. The Deputy Commissioner of Income Tax, International Taxation, Circle-1(1), Bangalore

M/S. Goldman Sachs Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, International Taxation, Circle- 1(1), Bangalore