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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

Asst.Commissioner of Income Tax (TDS) Cir.2(1), Mumbai. vs. Riya Travel and Tours (India) Pvt.Ltd, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 4193/MUM/2023[2022-2023]Status: DisposedITAT Mumbai04 Mar 2025AY 2022-2023

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Niraj ShethFor Respondent: Shri. R. R. Makwana, Sr. DR
Section 133ASection 194Section 250

sale or services or both during the previous year does not exceed five lakh rupees and such e-commerce participant has furnished his Permanent Account Number or Aadhaar number to the e-commerce operator. 3) Notwithstanding anything contained in Part B of this Chapter, a transaction in respect of which

Asst.Commissioner of Income Tax(TDS)Cir.2(1), Mumbai. vs. Riya Travel and Tours (India) Pvt.Ltd, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 4191/MUM/2023[2022-2023]Status: DisposedITAT Mumbai04 Mar 2025AY 2022-2023

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Niraj ShethFor Respondent: Shri. R. R. Makwana, Sr. DR
Section 133ASection 194Section 250

sale or services or both during the previous year does not exceed five lakh rupees and such e-commerce participant has furnished his Permanent Account Number or Aadhaar number to the e-commerce operator. 3) Notwithstanding anything contained in Part B of this Chapter, a transaction in respect of which

Asst.Commissioner of Income Tax (TDS) Cir.2(1), Mumbai. vs. Riya Travel and Tours (India) Pvt.Ltd, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 4172/MUM/2023[2021-2022]Status: DisposedITAT Mumbai04 Mar 2025AY 2021-2022

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Niraj ShethFor Respondent: Shri. R. R. Makwana, Sr. DR
Section 133ASection 194Section 250

sale or services or both during the previous year does not exceed five lakh rupees and such e-commerce participant has furnished his Permanent Account Number or Aadhaar number to the e-commerce operator. 3) Notwithstanding anything contained in Part B of this Chapter, a transaction in respect of which

Shri Sanjay Dhanraj Jain, Nagpur vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Nagpur

ITA 59/NAG/2022[2017-18]Status: DisposedITAT Nagpur25 Feb 2025AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Shri Sanjay Dhanraj Jain, Nagpur vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Nagpur

ITA 58/NAG/2022[2015-16]Status: DisposedITAT Nagpur25 Feb 2025AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Shri Sanjay Dhanraj Jain, Nagpur vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Nagpur

ITA 57/NAG/2022[2014-15]Status: DisposedITAT Nagpur25 Feb 2025AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Shri Sanjay Dhanraj Jain, Nagpur vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Nagpur

ITA 56/NAG/2022[2013-14]Status: DisposedITAT Nagpur25 Feb 2025AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Shri Sanjay Dhanraj Jain, Nagpur vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Nagpur

ITA 55/NAG/2022[2012-13]Status: DisposedITAT Nagpur25 Feb 2025AY 2012-13
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Shri Sanjay Dhanraj Jain, Nagpur vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Nagpur

ITA 54/NAG/2022[2011-12]Status: DisposedITAT Nagpur25 Feb 2025AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

ITO., Ward-16(1), Hyderabad vs. Phoenix Infraventures and Projects Private Limited, Hyderabad

In the result, the appeal filed by the revenue is dismissed

ITA 867/HYD/2024[2022-23]Status: DisposedITAT Hyderabad24 Feb 2025AY 2022-23

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2022-23 The Income Tax Officer, Vs. Phoenix Infraventures & Projects Private Limited, Ward – 16(1), Hyderabad. Hyderabad. Pan No.Aafcp5499L. (Assessee) (Respondent) Assessee By: Shri R. Mohan Kumar, Advocate Revenue By: Shri B. Bala Krishna, Cit-Dr Date Of Hearing: 24.12.2024 Date Of Pronouncement: 24.02.2025

For Appellant: Shri R. Mohan Kumar, AdvocateFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 139(1)Section 68

Jaipur) dismissing the appeal of Revenue, the Tribunal held that the assessee has furnished complete particulars such as name, address, permanent account numbers, confirmation letters, income tax returns and balance sheet, and all are existing shareholders therefore share application money cannot be assessed as undisclosed income of the assessee

Hcc Cp Pl Jv, Hyderabad vs. Income Tax Officer, Ward-14(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1005/HYD/2024[2018-19]Status: DisposedITAT Hyderabad24 Feb 2025AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2018-19 Hcc Cp Pl Jv, Vs. The Income Tax Officer, Ward –14(1), Hyderabad. Hyderabad. Pan : Aaaah5541G. (Assessee) (Respondent) Assessee By: Shri Gvn Hari, Advocate (Appeared Through Hybrid Mode) Revenue By: Shri Srinath Sadanala, Sr.Dr Date Of Hearing: 06.02.2025 Date Of Pronouncement: 24.02.2025

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Shri Srinath Sadanala, Sr.DR
Section 194CSection 199Section 238Section 238(1)

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

Hilton Commodities Pvt. Ltd., Kolkata vs. ITO, Ward-5(3), Kolkata

In the result, the appeal of the revenue is dismissed

ITA 676/KOL/2024[2009-10]Status: DisposedITAT Kolkata24 Feb 2025AY 2009-10

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Hilton Commodities Pvt. Ltd. Ito, Ward 5(3) 9/12, Lal Bazar Street, Aaykar Bhavan, P-7, Mercantile Building, Block-B, Chowringhee Square, Vs. 3Rd Floor, No.10, Kolkata-700069, West Bengal Kolkata-700001, West Bengal (Appellant) (Respondent) Pan No. Aacch1011P Assessee By : Shri Soumitra Choudhury, Ar Revenue By : Shri S Datta, Cit Dr Date Of Hearing: 08.01.2025 Date Of Pronouncement : 24.02.2025

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri S Datta, CIT DR
Section 131Section 143(1)Section 143(2)Section 144Section 147Section 148Section 14ASection 263Section 68

Assessing Officer to assessee. 16. In the case before us, the appellant by producing the loan- confirmationcertificates 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

Sri. D. K Shivakumar, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

ITA 1064/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Feb 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

For Appellant: S/ShriFor Respondent: Shri.Y. V. Raviraj, Sr. Standing Counsel
Section 132(4)Section 143(2)Section 250Section 292CSection 69ASection 69B

appellant. The Hon’ble CIT(A) has erred in not holding that the assessment order 7. is bad in law as the Permanent Account Number on the Order does not belong to the Appellant. The Hon’ble CIT(A) failed to appreciate that the statutory presumption 8. u/s. 292C

Smt. Meenakshi Mittal, Jagraon vs. ITO, Ward-1, Jagraon

In the result, the appeal of the assessee is partly allowed

ITA 1132/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh19 Feb 2025AY 2010-11
For Respondent: Shri S.K. Mukhi, Advocate
Section 142(1)Section 148

year under reference, as such no Return of Income was filed earlier. 3. It is further submitted that the Assessee's Permanent Account Number in the name of Smt. Meenakshi Garg at Jagraon was not used by the Appellant after her marriage on 21.01.2007 with Sh. Kunj Bihari Garg ... Garg and ter address had also changed from Jagraon to Ludhiana, as mentioned herein above. The Appellant was advised to apply for new Permanent Account Number as her name and address had changed. The Appellant applied for new Permanent Account Number in the name of Meenakshi Garg with residential address

Murugan Oil Corporation, Salem vs. DCIT Circle 1(1), Salem

In the result the appeal of the assessee is allowed

ITA 1501/CHNY/2024[2017-18]Status: DisposedITAT Chennai17 Feb 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं/.Ita No.: 1501/Chny/2024 िनधा"रणवष" / Assessment Year: 2017-18

For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Smt. Samantha Mullamudi
Section 142(1)Section 143(1)Section 143(3)Section 194CSection 194C(6)Section 194C(7)Section 40Section 80I

owns ten or less goods carriages at any time during the previous year and furnishes a declaration to that effect along with] his permanent account number, to the person paying or crediting such sum.” Therefore, the total payment of Rs. 7,01,94,373/- made to 12 parties as Transport

Assistant Commissioner of Income Tax, Circle - 7(1), Kolkata, Aayakar Bhawan vs. Ugraya Foods and Feeds Private Limited, Jalpaiguri

In the result, the appeal of the revenue is dismissed

ITA 1341/KOL/2024[2020-2021]Status: DisposedITAT Kolkata13 Feb 2025AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.1341/Kol/2024 Assessment Year: 2020-21 Acit, Circle-7(1), Kolkata……...………………...…….………....Appellant Vs. Ugraya Foods & Feeds Pvt. Ltd……............................…..…..... Respondent 12A, Dabgram Industrial Centre, Fulbari, Near Krishna Weight Bridge. [Pan: Aaacy8901B] Appearances By: Shri P. N. Barnwal, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Amit Agarwal, Advocate, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 02, 2025 Date Of Pronouncing The Order : February 13, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Revenue Against The Order Dated 26.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 111 Days In Filing The Present Appeal. The Revenue Filed Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause & Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2020-21 By Declaring Total Income Of Rs.23,48,56,350/-. The Case Of The Assessee Was Selected For Scrutiny Under Cass With Specific Reasons Being Substantial Unexplained Loans

Section 142(1)Section 14ASection 250Section 68

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

Careleavers Inner Circle Forum, Jaipur vs. Commissioner of Income Tax (Exemption), Jaipur

ITA 903/JPR/2024[2024-2025]Status: DisposedITAT Jaipur11 Feb 2025AY 2024-2025

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Pankaj Sancheti, CAFor Respondent: Sh. Sanjay Dhariwal, CIT-DR
Section 11Section 12Section 12ASection 8Section 80G

code 4A having commenced activities on 01-04-2022, and also that no income or part thereof the CARELEAVERS INNER CIRCLE FORUM having permanent account number (PAN) AAJCC9402A has been excluded from the total income on account of applicability of sub-clause (iv)or sub-clause (v) or sub-clause

M/S. Vision Millenium Exports P. Ltd, Mumbai vs. DCIT, Central Circle- 7(2), Mumbai

In the result, the appeal

ITA 1645/MUM/2020[2015-16]Status: DisposedITAT Mumbai10 Feb 2025AY 2015-16

Bench: BEFORESHRI SANDEEP GOSAIN (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Abhishek Khandelwal,ARFor Respondent: Ms. Neena Jeph, (CIT DR)
Section 143(3)

contract note, the unique client identity rules, regulations rules, regulations or bye-laws,unique trade number and permanent account unique trade number and permanent account number allotted number allotted under this Act.In the present case,the self In the present case,the self-serving contract notes were serving contract notes

Deputy Commissioner of Income Tax Circle 3(1), Visakhapatnam vs. Ramakrishna Nukala, Visakhapatnam

ITA 412/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam04 Feb 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri S. Balakrishnan

For Appellant: Shri GVN Hari, ARFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 143Section 69ASection 80Section 80I

आयकर अपीलीय अधिकरण, विशाखापटणम पीठ में IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM “DIVISION BENCH”, VISAKHAPATNAM BEFORE SHRI LALIET KUMAR

Ivy Comptech Private Limited, Hyderabad vs. DCIT., Circle 2(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 908/HYD/2024[2020-21]Status: DisposedITAT Hyderabad04 Feb 2025AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2020-21 Ivy Competech Private Limited, Vs. The Deputy Commissioner Of Income Tax, Hyderabad. Circle 2(1), Hyderabad. Pan : Aaac18884K. (Appellant) (Respondent) Assessee By: Shri Nageswara Rao, Advocate. Revenue By: Ms. M. Narmada, Cit-Dr Date Of Hearing: 20.01.2025 (Hybrid Hearing) Date Of Pronouncement: 04.02.2025

For Appellant: Shri Nageswara Rao, AdvocateFor Respondent: Ms. M. Narmada, CIT-DR
Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 92C

copy of the DRP directions, the said document is visible to the AO of the Faceless Assessment Unit ("FAU") having jurisdiction over the permanent account number of the assessee concerned. Thus, both the affiants agree that the Dispute Resolution Panel directions once uploaded on the Income-tax Business Application portal ... automatically visible to the Faceless Assessing Officer, if any assessment work item is pending related to a particular permanent account number. Admittedly assessment proceedings of the petitioner were pending. Thus, undoubtedly the Dispute Resolution Panel directions uploaded on the Income-tax Business Application portal were readily and clearly visible