Cash deposits already declared under another PAN could not be taxed again as the same receipts were disclosed in return.

Cash deposits in a bank account linked to one PAN could not be added again where the same receipts were already reflected in the return filed under the assessee's other PAN. The factual finding was that the deposits had been disclosed in the AOP return, and the assessing authority had not verified that position before making the addition. The Tribunal accepted that the receipts were the same and that double taxation was impermissible on these facts, so the additions were deleted.

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Issues: Whether the additions made on account of cash deposits in the IDBI bank account linked to one PAN could be sustained when the same deposits were already reflected in the return filed under the assessee's other PAN.

Analysis: The assessee had obtained two PANs, one linked to the bank account and another used for filing returns. The cash deposits in the bank account were already disclosed in the return filed with reference to the PAN of the AOP. The lower appellate authority found that the assessing authority failed to verify this factual position and that the same receipts could not be taxed again merely because they were traced to the PAN linked with the bank account. The Tribunal agreed that the additions represented the same receipts already declared in the return.

Conclusion: The additions could not be sustained and were rightly deleted.

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