Anathi Hanumegowda Vijay Kumar Vs ITO (ITAT Bangalore)
Wrong PAN, Wrong Addition: ITAT Deletes ₹2.35 Crore Addition Made on Area Manager for Company’s Bank Account Transactions
The Bangalore ITAT granted relief to an employee of Manappuram Finance Ltd. after finding that cash deposits of ₹2.35 crore were wrongly attributed to him merely because the bank had reported his PAN in the Statement of Financial Transactions (SFT), even though the bank account belonged to the company.
The assessee was treated as a non-filer and reassessment proceedings were initiated based on information that ₹2.35 crore had been deposited in a bank account linked to his PAN. Since the Assessing Officer was not satisfied with the explanation regarding the source of deposits, the entire amount was added as income in a reassessment completed under sections 147 and 144. The CIT(A) confirmed the addition.
Before the Tribunal, the assessee explained that he was an Area Manager of Manappuram Finance Ltd. and that the bank account in question belonged to the company. Under an internal resolution, area managers were authorised to operate company bank accounts as joint signatories, and their PAN details were furnished to the bank only for operational purposes. The assessee produced a certificate from Federal Bank admitting that the SFT had been incorrectly reported using the PAN of the area manager instead of the PAN of Manappuram Finance Ltd. The bank further confirmed that all transactions in the account belonged to the company and not to the assessee.
