TaxTMI 
TaxTMI 
2026 (1) TMI 1262
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....hereby initiating proceedings for reassessment of the petitioner's income for the assessment year 2019-20. 3. The case of the petitioner is that it is a Co-operative Society carrying on banking business was initially operating under Permanent Account No. (PAN) - AAGFB4500N. Subsequently, the petitioner applied for and was issued a new PAN being AABAB6253G. After obtaining the new PAN, the petitioner has been conducting its transactions under the new PAN itself. It is the petitioner's case that the petitioner has informed its respective bankers about the fact that the petitioner has obtained a new PAN but while all the other banks had updated the petitioner's new PAN in the Bank's database pertaining to the petitioner, only IDBI Bank upda....
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....e income tax return filed under the new PAN, was accepted by the Assessing Officer. 6. Subsequently, another notice dated March 31, 2025 under Section 148A(1) of the said Act of 1961 was issued to the petitioner asking the petitioner to show-cause as to why the petitioner's income for the assessment year 2019-20 shall not be reassessed. The petitioner replied thereto on April 15, 2025 and indicated to the Assessing Officer that the petitioner was ready to provide any further detail that may be required by the Assessing Officer. Thereafter, on May 8, 2025 the petitioner furnished answers to queries raised by the respondents/revenue authorities and once again stressed that the petitioner would provide further details, if required. 7. Ul....
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....thout affording an opportunity to the petitioner to produce the same. 10. Mr. Mazumder submits that if the said documents had been called for, the petitioner would have willingly produced the same and the matter could have been resolved. 11. Mr. Dudhoria, learned advocate appearing for the respondents/revenue authorities submits that the order impugned has been rightly passed inasmuch as the petitioner has not produced the relevant documents. It is further submitted that since two PANs are active, it was incumbent on the petitioner to take steps to deactivate one of the two PANs and since the petitioner has not done so the order impugned is valid. 12. Mr. Mazumder, learned advocate appearing for the petitioner, submits, in reply, t....
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....d that the petitioner did not produce balance-sheet and profit and loss accounts to reconcile its claim without giving the petitioner one more opportunity to produce such balance-sheet and profit and loss accounts. Since it appears that the Assessing Officer has not given proper opportunity to the petitioner despite the petitioner's willingness, therefore for ends of justice the petitioner should be granted one more opportunity to produce all relevant documents before the Assessing Officer including the balance-sheet and the profit and loss accounts. In such view of the matter, the order impugned dated June 25, 2025 as well as the consequential notice for the assessment year 2019-20 under Section 148 dated June 25, 2025 are set aside. 16....