9911796707
TMI Blog2023 (2) TMI 1229X X X X Extracts X X X X X X X X Extracts X X X X ..... h carried out under the new permanent account number- HELD THAT:- As dispute has arisen on account of the confusion in respect of the permanent account numbers, which was changed in the year 2011. For this reason, this court deems it appropriate that the matter has to be reconsidered by the Assessing Officer further by affording an opportunity to the petitioner to produce necessary documents in support of its claim. This court also makes it clear that nothing is expressed on the merits of the claim of either of the parties and for the purpose of affording an opportunity to the petitioner to substantiate its claim, the matter is remanded to the first respondent. For these reasons the impugned orders are set aside. Since, the petitioner ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the petitioner-society was required to obtain permanent account number under the status of association of persons. After having realised this, the petitioner had applied for a permanent account number under the status of association of persons and the same was granted to the petitioner way back in the year 2011. 5. The contention of the petitioner is that after new permanent account number is assigned to the petitioner-society, the petitioner-society has submitted the Income-tax return under the said permanent account number and all the transactions carried out by the petitioner-society is duly reflected in the Income-tax returns filed under the new permanent account number. 6. The respondents have sought for reassessment of the inc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sel for the petitioner would further submit that he has got all the records to show that all the transactions carried out by the petitioner subsequent to obtaining a new permanent account number have been duly reflected in the returns submitted by the petitioner. 11. The learned counsel for the petitioner would also place reliance on the judgments of the High Court of Calcutta in M. A. T. No. 1943 of 2022 with I. A. No. CAN 1 of 2022, in the case of Shree Ramkirshna Sishu Tirtha v. ITO [2023] 457 ITR 729 (Cal), and in W. P. A. No. 17644 of 2022, in the case of Shakuntala Sales Incorporation v. Asst. CIT and would submit that the scope of remand is very much available in a matter like this. This court has considered the above said two jud ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
