Reassessment on disputed Form 26AS income was remanded for limited verification of the correct assessee identity and source attribution.

Reassessment based on Form 26AS entries and PAN-linked information was found to rest on mistaken factual inputs, because the record did not conclusively establish whether the transactions belonged to the assessee or to another person whose PAN had been used. The Tribunal held that the source attribution of the income required verification and confined the enquiry to whether the Form 26AS income had already been declared in the return or reflected in the books of the successor company. The matter was therefore remanded to the Assessing Officer for limited verification, and the assessee obtained relief to that extent.

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Issues: Whether the reassessment and resulting additions required to be sustained or the matter should be remanded for verification of the correct assessee identity and the income reflected in Form 26AS.

Analysis: The assessee contended that the reopening was founded on incorrect PAN particulars and information pertaining to another person, while the revenue maintained that the PAN and banking trail showed continued existence of the assessee and utilisation of the account. On the material available, the Tribunal found that the reopening was triggered on mistaken factual inputs and that the source attribution of the transactions required verification. It noted that the record did not conclusively establish whether the Form 26AS entries belonged to the assessee or to the individual whose PAN had been used, and considered it appropriate to confine the enquiry to whether the income shown in Form 26AS had already been declared in the return or in the books of the successor company.

Conclusion: The matter was remanded to the Assessing Officer for limited verification, and the assessee succeeded to that extent.

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