Mere allotment of PAN would not make allottee a Separate Entity

Section 139A of the Act pertains to permanent account number. Sub­section (1) of section 139A provides various categories of persons who are required to pay tax or for some other reason required to furnish return of income, would apply to the Assessing Officer for allotment of a PAN. Under sub- section(1B), the Central Government may for the purpose of collecting any information which may be useful for or relevant to the purposes of the Act, may by notification require any class or classes of persons who shall apply to the Assessing Officer for the allotment of the PAN.Under sub­section (2), the Assessing Officer having regard to the nature of transactions as may be prescribed, may also allot a PAN to any other person following the prescribed procedure. Sub­section (3) of section 139A provides that any person not falling under sub­section (1) or sub­section (2), may also apply to the Assessing Officer for allotment of PAN, upon which, the Assessing Officer shall allot the same.

It can thus be seen that mere allotment of PAN under section 139A of the Act would not make the allottee necessarily a separate entity for the purpose of assessment of tax. The statute recognizes certain eventualities where quite outside the requirement of payment of tax and for filing return of income, the Assessing Officer may allot a PAN to individual.