2020 (10) TMI 754

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....R ABRAHAM, SC JUDGMENT The petitioner, which is stated to be a partnership firm, had applied for, and was issued a PAN, which reflected its status as a company. The petitioner being a firm could not have been issued with the PAN showing its status as a company. But the petitioner firm did not notice this discrepancy till much later, in the year 2005. Immediately thereafter, it applied for and wa....

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....a fresh notice to the petitioner reiterating its earlier demand. It is the case of the petitioner that while it had explained the discrepancy in the PAN, and had reiterated the said submission in the reply to the pre-assessment notice, the respondent proceeded to finalise the assessment ignoring the objections and explanations given by the petitioner. In the writ petition, the petitioner while imp....

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....writ petition, I find that this is a case where the basic issue that comes up for consideration is as to whether the petitioner firm had correctly accounted for the deposits made in its account. The assessing officer in Ext.P6 order states that the claims made by the petitioner could not be accepted in view of the same not being substantiated with proper evidence and due to paucity of time. While ....