Wrong allotment of two PANs cannot set assessee as non-filer for one PAN as return filed via other PAN

Samreen Shafi Chattabal Channa Mohalla Vs ITO (ITAT Amritsar)

ITAT Amritsar held that because of wrong allotment of two PANs, assessee cannot be set as a non-filer or undeclared of tax in the return of one PAN as income duly declared via other PAN. Matter remanded back.

Facts- The assessee is possessing two Permanent Account Numbers (PAN) bearing number AHCPS0377H (‘old PAN’) and bearing number EAHPS5244B (‘new PAN’).

The assessee filed the return in the old PAN, AHCPS0377H for the impugned assessment year. In the HDFC Bank the assessee submitted the new PAN, number EAHPS5244AB. Accordingly, the ld. AO got the information and completed the assessment on basis of the new PAN, u/s 144 and the addition was determined on 8% net profit u/s 44AD related to deposit Rs.12,20,26,670/- which works out to Rs.97,62,133/- and amount of Rs.1,90,15,570/- deposited cash in bank account during the demonetisation. Accordingly, the addition was confirmed amount to Rs.97,62,133/- and Rs.1,90,15,570/- which works out the total amount of Rs.2,87,77,703/- U/s 69 of the Act.

Aggrieved assessee filed an appeal before the ld. CIT(A). The ld. CIT(A) upheld the order of the ld. AO. Being aggrieved, the present appeal is filed by the assessee.

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