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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
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

Narayan Suppliers Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(3), Kolkata

In the result, appeal of the assessee is dismissed

ITA 1077/KOL/2024[2011-2012]Status: DisposedITAT Kolkata08 Sept 2025AY 2011-2012

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri Avijit Ghoshal, ARFor Respondent: Shri Raja Sengputa, CIT-DR
Section 10(38)

company, S, had a paid-up capital of Rs.90 lakhs and was incorporated on January 4, 1989, and was also allotted a permanent account number in September 2001. Thus, it could not be held to be a fictitious person. The reassessment proceedings were not valid and were liable

Kunjan Jagdishchandra Sedani, Jamangar vs. Principal Commissioner of Income Tax, Jamnagar

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

ITA 197/RJT/2025[2015-2016]Status: DisposedITAT Rajkot25 Aug 2025AY 2015-2016

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.197/Rjt/2025 "नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Kunjan Jagdishchandra Sedani Principal Commissioner Of Vs. 18B, Parikunj, Mahavir Society, Income Tax, Jamnagar Room No. 101, 1St Floor Aayakar Bedi Bunder Road, Jamnagar- 361008 Bhavan, Nr. Subhash Bridge, Jamnagar-361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Erips2050H (Assessee) (Respondent) Assessee By : Shri Dushyant Maharshi, Ld. Ar Respondent By : Shri Praveen Verma, Ld. Cit(Dr) Date Of Hearing : 23/06/2025 Date Of Pronouncement : 25/08/2025 आदेश / O R D E R Dr. Arjun Lal Saini, Am By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Dated 21.02.2025 Passed By The Learned Principal Commissioner Of Income-Tax (In Short “Ld Pcit”), Under Section 263 Of The Income-Tax Act, 1961 (Hereinafter Referred To As 'The Act'), For The Assessment Year 2015- 16.Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows: 1. Hon'Ble Pr. Cit, Jamnagar Has Erred In Law & In Facts In Setting-Aside The Order Passed By The Assessing Officer Under Section 147 R W.S. 144B Of The Income-Tax Act, 1961 By Invoking The Provisions Of Section 263 Of The Income-Tax Act, 1961 Even When The Order As Passed By The Assessing Officer Was Neither Erroneous Nor Prejudicial To The Interests Of The Revenue. 2. Hon'Ble Pr. Cit, Jamnagar Erred In Law & In Facts By Setting-Aside The Order Passed By The Assessing Officer Under Section 147 R.W.S. 144B Of The Income-Tax Act, Kunjan Jagdishchandra Sedani

For Appellant: Shri Dushyant Maharshi, Ld. ARFor Respondent: Shri Praveen Verma, Ld. CIT(DR)
Section 147Section 263Section 68Section 69A

furnished detailed reply wherein comprehensive explanations and supporting documents were provided. These submissions included: Kunjan Jagdishchandra Sedani, (a)Complete particulars like Name, Permanent Account Numbers (PANs) and address of the persons from whom unsecured loans were borrowed (Identity); (b)Copy of return of income (credit worthiness); (c )Copy of bank

Vasupujya Filaments, Mumbai vs. DCIT-CC-3, Thane

In the result, all appeals filed by the assessee are allowed

ITA 883/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Aug 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Prabhash Shankar

For Appellant: Ms. Simran Chavan &For Respondent: Shri Vivek Perampurna, CIT-DR
Section 131(1)(d)Section 132Section 143(3)Section 147Section 68Section 69CSection 69D

clear that, in respect of each of the lender companies, a comprehensive suite of evidences has been produced. These comprise copies of their Permanent Account Numbers, acknowledgements of income-tax returns filed, and certificates of incorporation attesting to their legal existence. The assessee has further fortified the record with Memoranda ... namely, identity of the creditors, their financial capacity to advance loans, and the genuineness of the transactions. Specifically, the assessee furnished the Permanent Account Numbers of the lender companies, their certificates of incorporation, acknowledgements of income tax returns, and documents downloaded from the Ministry of Corporate Affairs portal evidencing that

Vasupujya Filaments, Mumbai vs. DCIT-CC-3, Thane

In the result, all appeals filed by the assessee are allowed

ITA 876/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Aug 2025AY 2013-14

Bench: Shri Amit Shukla & Shri Prabhash Shankar

For Appellant: Ms. Simran Chavan &For Respondent: Shri Vivek Perampurna, CIT-DR
Section 131(1)(d)Section 132Section 143(3)Section 147Section 68Section 69CSection 69D

clear that, in respect of each of the lender companies, a comprehensive suite of evidences has been produced. These comprise copies of their Permanent Account Numbers, acknowledgements of income-tax returns filed, and certificates of incorporation attesting to their legal existence. The assessee has further fortified the record with Memoranda ... namely, identity of the creditors, their financial capacity to advance loans, and the genuineness of the transactions. Specifically, the assessee furnished the Permanent Account Numbers of the lender companies, their certificates of incorporation, acknowledgements of income tax returns, and documents downloaded from the Ministry of Corporate Affairs portal evidencing that

Deputy Commissioner of Income Tax, Delhi vs. M/S. Shrish Enterprises Private Limited, Delhi

ITA 5315/DEL/2024[2018-19]Status: DisposedITAT Delhi21 Aug 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandradcit, Room No. 225E, Cr Vs. M/S Shrish Enterprise Building, 2Nd Floor, Private Limited, Hall No. Ip Estate, 3 & 4, M-27/2, Badli New Delhi - 110002 Industrial Estate, Badli, Delhi – 110042 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafcs0684N Appellant .. Respondent

For Appellant: Sh. Nitin Gulati, Adv. &For Respondent: Sh. Manish Gupta, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 68

Court held that where the assessee has provided sufficient indication(s) including by way of permanent account number, to highlight the identity of the share applicants and produced affidavits of directors of the companies along with bank details of share applicants, then it would be a valid discharge

Mr. Chandrakant Deshmukh, Pune vs. ITO Ward 3(3), Pune

In the result, appeal of the Assessee is dismissed as withdrawn

ITA 984/PUN/2025[2020-21]Status: DisposedITAT Pune08 Aug 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.984/Pun/2025 िनधा"रण वष" / Assessment Year: 2020-21 Mr.Chandrakant Deshmukh, V The Commissioner Of 46/2, B/2 Jog Hospital, Pune S Income Tax Paud Road, Pune – 411038. Appeals[Nfac]. Maharashtra. Pan: Aasfa0485F Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Ajay D. Kulkarni – Addl.Cit(Dr) Date Of Hearing 07/08/2025 Date Of Pronouncement 08/08/2025

Section 143(3)Section 250Section 37

filling withdrawl in my capacity as Self and I am also competent to make this withdrawl of appeal I am holding permanent account number ADKPN9403H And I further declare that the critical assumptions specified above are true & correct.” 2.2 It is also observed that in the Appeal Memo, Mr.Chandrakant Deshmukh

DCIT Central Circle-8(1), Mumbai vs. Shivshankar Ramswaroop Sharma, Mumbai

ITA 2731/MUM/2025[2015-16]Status: DisposedITAT Mumbai08 Aug 2025AY 2015-16
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

DCIT Central Circle-8(1), Mumbai vs. Shivshankar Ramswaroop Sharma, Mumbai

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

ITA 2730/MUM/2025[2014-15]Status: DisposedITAT Mumbai08 Aug 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

DCIT, Central Circle-8(1), Mumbai vs. Shivshankar Ramswaroop Sharma, Mumbai

ITA 2729/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Aug 2025AY 2013-14
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

DCIT, Central Circle-8(1), Mumbai vs. Shivshankar Ramswaroop Sharma, Mumbai

In the result, all the appeals filed by the revenue are

ITA 2728/MUM/2025[2012-13]Status: DisposedITAT Mumbai08 Aug 2025AY 2012-13
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shri Shiv Shankar Sharma, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are

ITA 2684/MUM/2025[2015-16]Status: DisposedITAT Mumbai08 Aug 2025AY 2015-16
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shri Shiv Shankar Sharma, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are

ITA 2683/MUM/2025[2014-15]Status: DisposedITAT Mumbai08 Aug 2025AY 2014-15
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shri Shiv Shankar Sharma, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

ITA 2682/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Aug 2025AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shri Shiv Shankar Sharma, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are

ITA 2681/MUM/2025[2012-13]Status: DisposedITAT Mumbai08 Aug 2025AY 2012-13
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shiv Shankar Sharma, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are

ITA 2164/MUM/2025[2021-22]Status: DisposedITAT Mumbai08 Aug 2025AY 2021-22
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shiv Shankar Sharma, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are

ITA 2163/MUM/2025[2020-21]Status: DisposedITAT Mumbai08 Aug 2025AY 2020-21
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shiv Shankar Sharma, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

ITA 2162/MUM/2025[2019-20]Status: DisposedITAT Mumbai08 Aug 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shiv Shankar Sharma, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

ITA 2161/MUM/2025[2018-19]Status: DisposedITAT Mumbai08 Aug 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shiv Shankar Sharma, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are

ITA 2160/MUM/2025[2017-18]Status: DisposedITAT Mumbai08 Aug 2025AY 2017-18
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly

Shiv Shankar Sharma, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, all the appeals filed by the revenue are

ITA 2159/MUM/2025[2016-17]Status: DisposedITAT Mumbai08 Aug 2025AY 2016-17
Section 132Section 132(4)Section 143(3)

lenders in question is duly established. The assessee has placed on record confirmations from each of the lenders, along with their respective Permanent Account Numbers, and copies of their income tax returns. To demonstrate the genuineness of the transactions, the assessee has also produced copies of bank statements, which clearly