Old PAN used for Reopening Assessment: ITAT dismisses Revenue's Appeal citing cancellation of Old PAN duly Communicated [Read Order]
The tribunal observed that the assessee had submitted all relevant documents confirming the cancellation of the old PAN
![Old PAN used for Reopening Assessment: ITAT dismisses Revenues Appeal citing cancellation of Old PAN duly Communicated [Read Order]](https://www.taxscan.in/wp-content/uploads/2025/03/PAN.jpg "Old PAN used for Reopening Assessment: ITAT dismisses Revenues Appeal citing cancellation of Old PAN duly Communicated [Read Order]")
The Pune Bench of the Income Tax Appellate Tribunal (ITAT) has dismissed the revenue’s appeal against the reopening of assessment based on old pan citing that the cancellation of old pan duly communicated. Shri Agrasen Maharaj Nagari Sahakari Pathsanstha Maryadit (assessee), a cooperative society, had its assessment reopened for AY 2017-18 by the Assessing Officer (AO) under Section 147...
The Pune Bench of the Income Tax Appellate Tribunal (ITAT) has dismissed the revenue’s appeal against the reopening of assessment based on old pan citing that the cancellation of old pan duly communicated.
Shri Agrasen Maharaj Nagari Sahakari Pathsanstha Maryadit (assessee), a cooperative society, had its assessment reopened for AY 2017-18 by the Assessing Officer (AO) under Section 147 of the Act.
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The Assessing Officer initiated reopening was based on PAN AAJCS0457K, despite the fact that the assessee had obtained a new PAN AAMAS4875Q in 2015 and had consistently been filing returns under the new PAN.
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The AO did not accept the assessee’s submission that the old PAN had been cancelled and treated deposits amounting to ₹1.24 crore as unexplained income, passing an order against the outdated PAN.
Aggrieved by the order of AO, the assessee filed an appeal before the Commissioner of Income Tax (Appeals) [CIT(A)]. The CIT(A) observed that the department had been aware of the PAN change.
The CIT(A) also observed that the Pan Change had previously been accepted by the department in assessment years 2015-16 and 2018-19. The CIT(A) held that the reopening of the assessment was not justified.
Aggrieved by the CIT(A)’s decision, the revenue appealed before the ITAT. The counsel for the revenue argued that the relief was granted without giving the AO an opportunity and without adjudicating the additions made.
The two-member bench, comprising Dr. Manish Borad (Accountant Member) and Ms. Astha Chandra (Judicial Member), observed that the department had prior knowledge of the PAN change, and similar contentions were accepted for previous assessment years.
The tribunal also observed that the assessee had submitted all relevant documents confirming the cancellation of the old PAN.
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Therefore, the tribunal upheld the CIT(A)’s order ruling that the reopening of assessment was not in accordance with the provisions of the Income Tax Act. Therefore, the appeal of the revenue was dismissed.
To Read the full text of the Order CLICK HERE
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