2025 (7) TMI 604

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....ade against the Impugned Assessment Order dated 29.09.2023 passed by the 2nd respondent and consequential order dated 24.09.2024 passed by the 1st respondent, pertaining to the assessment year 2018-19. 3. The learned counsel for the petitioner would submit that, in the present case, originally return was filed on 17.02.2019 for the assessment year 2018-19. Earlier, the petitioner had one PAN Number, which was wrongly issued under the status of "Non Juridical Person". Subsequently, the petitioner applied for another PAN Number, which was rightly issued under the status of "Society". Due to change of PAN Number, the petitioner was not aware of the notices issued in the Old PAN Number and therefore, the petitioner did not file any reply to ....

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....ner is ready to deposit the amount of cost which is to be fixed by this Court, the prayer sought for by the petitioner may be considered with heavy cost. 7. I have given due consideration to the submissions made on either side and perused the materials available on record. 8. In the present case, the petition under Section 264 was rejected for the reason that, the petitioner had failed to file any reply or produce any documentary evidences to demonstrate the case before the Assessing Officer. The reason given by the petitioner for not participating in the assessment proceedings was because of change in the name of the Management. According to the petitioner, due to change in the name of the management of the society, the notices were ....