Madavalasu Ramsamy Anandanaryanan Vs ITO (Madras High Court)
Petitioner approached the Madras High Court challenging an Income Tax demand notice dated 11.09.2025 issued for the Assessment Year 2018-19. The said demand had been raised under PAN ACBPA4671J, which, according to the Petitioner, was a PAN obtained by mistake and subsequently deactivated.
Petitioner clarified that his active PAN is ADXPA1508K, under which he is regularly assessed. Petitioner submitted that the Income Tax Department was well aware of this fact, since even for the Assessment Year 2017-18, in an order dated 07.09.2021, the Department itself had recorded that:
“The assessee has deposited cash amounting to Rs.24,69,060/- in bank during the period 09.11.2016 to 30.12.2016 which was reported in the ITS for PAN ACBPA4671J, pursuant to which 144 proceedings were initiated for PAN ACBPA4671J, later found to be deactivated PAN of the assessee, whereas the active PAN of the assessee is ADXPA1508K.”
Despite this earlier acknowledgment, a fresh demand notice for AY 2018-19 was again issued on the deactivated PAN, leading to the present writ petition.
Petitioner’s Submissions
The learned counsel for the Petitioner, argued that:
- No assessment order corresponding to the impugned demand was ever served on the Petitioner.
- The Department could not have raised any lawful demand on a non-existent or deactivated PAN, particularly when it had already recognized the correct active PAN in its prior proceedings.
- Hence, the demand notice dated 11.09.2025 is invalid in law & liable to be quashed.
Respondents’ Submissions
