Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee.

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....Duplicate PAN allocation is in issue where an assessee maintains that only one PAN was held, that no application was made for the other PAN, and that it was never used for any transaction, including the transaction underlying an assessment. The Department was required to produce original records for both PANs, including verification details and profiles, and to provide the reasons and any relevant application concerning deactivation of one PAN. The focus is on verifying the origin, use and deactivation basis of the alleged duplicate PAN before proceeding on the assessment-related transaction.....