2025 (4) TMI 82

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.... u/s.147 r.w.s.144 r.w.s.144B of the Act. 2. Briefly stated, the facts of the case are that the assessee is a Cooperative Society registered under the Maharashtra Cooperative Societies Act, 1960. The assessee is engaged in the business of accepting deposits and providing credit facilities to its members. Based on the information available in ITBA module that the assessee inter alia made Time deposit of Rs.12.00 lakh and cash deposit of Rs.1.10 crore with Lonavala Sahakari Bank Maryadit, the case was reopened by way of issuance of notice u/s.148 of the Act. The assessee in response to notice u/s.142(1) of the act, the assessee stated that there are two PAN number. PAN Number AAMAS4518Q is in respect of Bhagwan Shree Agrasen Nagari Sahakari ....

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....s already filed the return of income for the same AY 2017-18 with new PAN AAMAS4875Q. The appellant had also intimated to the AO that they have obtained the new PAN in April of 2015 for want of change of 4th character being AOP and not as the company. The appellant assessee further submitted before the AO that both the PAN numbers belong to the appellant assessee and due to change of PAN from the year 2015, regular return of income for AY 2017-18 is filed with new PAN. The appellant further claims that the cash credits on which addition is made are already accounted for in the regular books of accounts, are part of income declared in the ROI filed in the regular course. The assessing officer without considering the submissions made by the a....

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....nt was already made against that ROI for the same AY and informed reason for change of PAN, I am of the opinion that reopening of assessment proceedings u/s 147 in the name of old PAN AAJCS0457K is not in accordance with the provisions of the Act. Hence, the grounds of appellant, in this regard are hereby allowed." 4. Now the Revenue is in appeal before us that ld.CIT(A) erred in giving relief to the assessee without providing an opportunity to the AO and without adjudicating the additions made by the Assessing Officer. 5. We have heard both the sides and perused the record placed before us. We find the ld.CIT(A) gave relief to the assessee on verifying the PAN data of the assessee and information of change in the PAN is in the knowledge....