Assessing officers cannot rely solely on software-generated PAN data; proceedings against merged, deceased entities unjustified, costs reduced

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....The HC held that assessing officers acted on software-generated data without requisite application of mind, initiating proceedings against entities (including a merged bank and deceased/amalgamated persons) based on unverified, potentially erroneous PAN entries, thereby causing high-pitched, avoidable litigation; the Department was found to be treating the software as master rather than a tool and has undertaken corrective measures. The petition was disposed of, administrative proceedings against the AOs reserved, and the previously levied exemplary cost of Rs. 1 crore was reduced: respondent nos.1 and 2 were directed to pay Rs. 10,000 each (total) to the State Legal Services Authority as token costs.....