Punjab National Bank Vs ITO (ITAT Chandigarh)
The case of Punjab National Bank vs. ITO (ITAT Chandigarh) involved an appeal by the bank against an order from the Assessing Officer (AO) for the Assessment Year (AY) 2016-17. The AO had raised a demand of ₹7,48,060 against the bank, holding it to be an “assessee-in-default” for not deducting Tax Deducted at Source (TDS) under Section 194A of the Income Tax Act. The AO’s primary observation was that the Form 15G/15H submitted by the bank lacked complete particulars.
The bank appealed this decision to the Additional/Joint Commissioner of Income Tax (Appeals), or CIT(A), but the demand was confirmed. Subsequently, the bank filed an appeal with the Income Tax Appellate Tribunal (ITAT). The ITAT noted a 23-day delay in filing the appeal, which it condoned.
During the ITAT proceedings, the bank furnished copies of the Form 15G/15H with all the requisite details filled in. The ITAT also found that similar demands were raised against the bank for previous assessment years (AY 2013-14 and 2014-15). In those cases, the CIT(A) had considered similar documents and deleted the demand. The ITAT observed that the documents provided for the 2016-17 assessment year were identical to those accepted in the previous years but had not been considered by the CIT(A) in this instance.
