Wrong PAN, Wrong 26AS, Wrong Addition: Hyper-Technical Dismissal Set Aside

Sikha Rani De Vs ITO (ITAT Kolkata) ITAT Kolkata held that denial of justice on hyper-technical grounds cannot be sustained where assessee’s appeal was dismissed solely due to inordinate delay without examining merits. In the present case, CPC made an adjustment u/s 143(1) by adding ₹14.43 lakh based on Form 26AS, though assessee neither received such income nor claimed corresponding TDS. Assessee contended that due to wrong PAN linkage, receipts belonging to a company were wrongly reflected in her Form 26AS, while she had only rental income. Tribunal noted that assessee had been diligentl...