← All Phrases

“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

Bombay Tyres, Mumbai vs. Income Tax Officer -15(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2393/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Oct 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18 Bombay Tyres Vs Income-Tax Officer, 23, Arenja Corner, -15(1)(1), Sector-17, Vashi, Mumbai Navi Mumbai – 400703 [Pan: Aagcb1604E] Appellant Respondent Present For: Assessee : Shri Tanzil Padvekar & Shri Gopal Sharma, Advocates Revenue : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 06.08.2025 Date Of Pronouncement : 29.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2023-24/1057354062(1), Dated 26.10.2023 Passed Against The Assessment Order By National Faceless Assessment Centre, Delhi U/S.144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 28.06.2019 For Ay 2017-18. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. Considering The Facts & Circumstances Of The Case & In Law, The National Faceless Appeal Centre (Nfac) Has Erred In Confirming The Order U/S. 144 R.W.S. 144A Dated 28Th June, 2019 Passed By The Assessing Officer Without Appreciating The Merits Of The Case.

For Appellant: Shri Tanzil Padvekar and Shri Gopal Sharma, AdvocatesFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 144Section 250Section 44ASection 69A

cash in the bank account of the assessee, whereby 3 Bombay Tyres AY 2017-18 it is alleged that one of the permanent account number (PAN) i.e., AAGCB1604E does not pertains to the assessee but to a non-existent entity. 3. There is a delay of 460 days noted

DCIT, Central Circle - 4(4), Kolkata vs. M/S. Evernewcommodeal Pvt. Ltd., Kolkata

In the result, ITA No.1535/Kol/2025 of the revenue is dismissed

ITA 1536/KOL/2025[2019-20]Status: DisposedITAT Kolkata10 Oct 2025AY 2019-20

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1535 & 1536/Kol/2025 Assessment Years: 2018-19 & 2019-20 Dcit, Central Circle-4(4), Kolkata.…………………………….…….……Appellant Vs. M/S Evernewcommodeal Pvt. Ltd..……………….………...……...…..…..Respondent 11, Pollock Street, Kol- 1. [Pan: Aabce9293P] Appearances By: Shri Altaf Hossain, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Manish Tiwari, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2019-20 Against Separate Orders Both Dated 25.04.2025 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.1535/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.1535/Kol/2025 - Brief Facts Of The Case Are That U/S 2. 139(1) Of The Act On 10-10-2019 Declaring A Total Income At Rs. 10,02,960/-. The Same Was Processed U/S 143(1) Of The Act. Later, A Search & Seizure Operation U/S 132 Of The Act Was Conducted At "Ladhuram Toshniwal Group" On 08-03-2022 As A Part Of "Jain Group" Of Concerns/ Persons At Various Places & Simultaneously, Business

Section 127Section 132Section 133ASection 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 2Section 250

discharged the onus by placing (i) confirmation letters of the cash creditors; (ii) their affidavits; (iii) their full addresses and GIR numbers and permanent account numbers. It has found that the assessee's burden stood discharged and so, no addition to his total income on account of cash credit ... Officer to assessee. 16. In the case before us, the appellant by producing the loan- confirmation-certificates signed by the creditors, disclosing their permanent account numbers and address and further indicating that the loan was taken by account payee cheques, no doubt, prima facie, discharged the initial burden and those

DCIT, Central Circle - 4(4), Kolkata vs. M/S. Evernewcommodeal Pvt. Ltd., Kolkata

In the result, ITA No.1535/Kol/2025 of the revenue is dismissed

ITA 1535/KOL/2025[2018-19]Status: DisposedITAT Kolkata10 Oct 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1535 & 1536/Kol/2025 Assessment Years: 2018-19 & 2019-20 Dcit, Central Circle-4(4), Kolkata.…………………………….…….……Appellant Vs. M/S Evernewcommodeal Pvt. Ltd..……………….………...……...…..…..Respondent 11, Pollock Street, Kol- 1. [Pan: Aabce9293P] Appearances By: Shri Altaf Hossain, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Manish Tiwari, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2019-20 Against Separate Orders Both Dated 25.04.2025 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.1535/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.1535/Kol/2025 - Brief Facts Of The Case Are That U/S 2. 139(1) Of The Act On 10-10-2019 Declaring A Total Income At Rs. 10,02,960/-. The Same Was Processed U/S 143(1) Of The Act. Later, A Search & Seizure Operation U/S 132 Of The Act Was Conducted At "Ladhuram Toshniwal Group" On 08-03-2022 As A Part Of "Jain Group" Of Concerns/ Persons At Various Places & Simultaneously, Business

Section 127Section 132Section 133ASection 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 2Section 250

discharged the onus by placing (i) confirmation letters of the cash creditors; (ii) their affidavits; (iii) their full addresses and GIR numbers and permanent account numbers. It has found that the assessee's burden stood discharged and so, no addition to his total income on account of cash credit ... Officer to assessee. 16. In the case before us, the appellant by producing the loan- confirmation-certificates signed by the creditors, disclosing their permanent account numbers and address and further indicating that the loan was taken by account payee cheques, no doubt, prima facie, discharged the initial burden and those

Nafees Ahmad, Gonda vs. ITO Ward-52(1), Delhi

In the result, appeal of the assessee is allowed

ITA 4046/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Sept 2025AY 2017-18

Bench: Shri Mahavir Singhasstt. Year : 2017-18 Nafees Ahmad, Vs. Ito-52(1), New Delhi/ Nfac, 115/21, Rakabganj, Kotwali Nagar, Delhi Gonda, Uttar Pradesh-271001 (Pan: Aiopa0771A) (Appellant) (Respondent) Appellant By : Sh. Prashant Kumar Verma, Adv. Respondent By : Sh. Manoj Kumar, Sr. Dr. Date Of Hearing 03.09.2025 Date Of Pronouncement 12.09.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi Dated 18.11.2024 Pertaining To Assessment Year 2017-18. The Solitary Issue Argued By The Ld. Ar Is Relating To Challenging The Notice U/S. 148 Of The Act Dated 27.3.2021 Issued By The Ito, Ward- 52(1), Delhi Is Without Jurisdiction & Is Void Ab Initio & Consequently The Reassessment Is Also Void Ab Initio. 2. Heard Both The Sides & Perused The Records. 3. Brief Facts Of The Case Are That Assessee Is An Individual & Filed His Original Return Of Income For The Ay 2017-18 Declaring Total Income Of Rs. 2,60,450/-. Thereafter, The Assessee Filed Revised Return Of Income Declaring Taxable Income Of Rs. 3,12,480/-. As Per The Financial Transactions Reported In The Its, Assessee Has Deposited Cash Amounting To Rs. 18,29,000/- With Indian Overseas Bank At Gonda

For Appellant: Sh. Prashant Kumar Verma, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 115BSection 142(1)Section 147Section 148Section 69A

known. Coming to merits of contention, it is noticed that notice us 148 was issued by ITO, W-52(1), Delhi. However, PAN (Permanent Account Number) card can have an address that is different from the jurisdiction of the income tax assessment. The PAN card reflects the address provided during

Priti Prajyot Potphode, Palghar vs. Income Tax Officer Ward 3, Palghar

In the result, appeal of the assessee is allowed for statistical purposes, in terms of our aforesaid observations

ITA 4058/MUM/2025[2014-2015]Status: DisposedITAT Mumbai10 Sept 2025AY 2014-2015

Bench: Shri Amit Shukla & Shri. Arun Khodpiaआयकर अपील सं./Ita No. 4058/Mum/2025 (निर्धारण वर्ा / Assessment Year: 2014-15) Priti Prajyot Potphode V/S. Income Tax Officer Umber Pada Wadare, बिधम Ward 3 Safale, Palghar 401102 Amba Wadi, Palghar, Maharashtra, Thane 401404 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No: Ajhpm9841M Appellant/अपीलधथी .. Respondent/प्रनिवधदी निर्धाररिी की ओर से /Assessee By: Shri Tanmay Phadke-Advocate रधजस्व की ओर से /Revenue By: Shri. Virabhadra Mahajan, (Sr Dr) सुिवधई की िधरीख / Date Of Hearing 09.09.2025 घोर्णध की िधरीख/Date Of Pronouncement 10.09.2025 आदेश / O R D E R Per Arun Khodpia, Am:- This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 26.08.2024 For The Assessment Year 2014-15, Which In Turn Arises From The Order U/S. 143(3) Of The Income-Tax Act Passed By Assessing Officer, Nfac, Delhi, Dated 26.03.2021. 2. The Grounds Of Appeal Raised By The Assessee Are Extracted As Under: “1. On The Facts & Circumstances Of The Case & In Law, The National Faceless Appeal Centre/Commissioner Of Income Tax (Appeals) ["The Learned Commissioner (Appeals)] Erred In Deciding The Appeal Ex-Parte In Violation Of The Principle Of Natural Justice. Thus, The Order Dated 26.08.2024 May Be Set Aside & The Matter May Be Restored Back To The File Of The Learned Commissioner (Appeals).

For Appellant: Shri Tanmay Phadke-AdvocateFor Respondent: Shri. Virabhadra Mahajan, (SR
Section 133(6)Section 143(3)Section 250

that the same business was carried out in the name of private limited company floated by the assessee w.e.f. 01/10/2013 and that the Permanent Account Number(PAN) for the private limited company was not intimated properly to all the clients of the assessee. Hence, certain income had been reflected

DCIT, Circle- 19(1), Delhi vs. Paramount Propbuild Pvt. Ltd., Delhi

In the result, the appeal of the Revenue is dismissed

ITA 2027/DEL/2025[2017-18]Status: DisposedITAT Delhi10 Sept 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwaldcit, Paramount Propbuild Pvt. Circle-19(1), Ltd. Delhi. Vs. 208, 2Nd Floor, Sikka Mansion, Lsc, Savita Vihar, New Delhi-110092. Pan:Aadcp522P (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv. & Shri Somil Aggarwal, Adv. Department By Shri Pradumna Kumar Singh, Sr. Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 03.09.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Revenue Against The Order Of Commissioner Of Income Tax (Appeals), 29, Delhi In Appeal No. Cit(A), Delhi-7/10457/2019- 20 Dated 24.01.2025 U/S 250 Of The Income Tax Act, 1961 Arising Out Of Order Passed U/S 143(3) Dated 08.04.2021 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Company & E-Filed Its Return Of Income On 21.11.2018 Declaring Total Income At Rs.2,80,29,572/-. The Case Of The Assessee Was Taken Up For Scrutiny & The Assessment Was Completed Wherein Disallowance Of Rs. 3,23,93,370/- Was Made Towards The Interest Paid On Funds Borrowed From Two Entities Namely M/S Sarvottam Securities Pvt. Ltd. & M/S Upaj Leasing Finance Company Ltd. By Holding That The Loan Taken From These Two Companies As Bogus. The Ld. Cit(A) Deleted The Disallowance So Made By Observing That Loans Taken From These Two Companies On Which The Interest Paid Is Disallowed In The Year Under Appeal Was Not Disputed By The Revenue Nor Held As Bogus In The Year When They

Section 143(3)Section 148Section 148ASection 250Section 263

filed statement of account of these lender companies showing the amount received through banking channels and also claimed that their complete address and permanent account number (PAN) details were submitted during the relevant assessment proceedings of the assessment year 2016-17. 6.4 Thereafter, PCIT, Delhi-7 initiated the proceedings