Bhavna Steel v. ITO [2023] 152 taxmann.com 218 / 454 ITR 670/ 335 CTR 1074 (Bom)(HC)

S. 148 : Reassessment-Notice-Two Permanent Account Numbers —Earlier Permanent Account Number was abended – Notices issued in earlier Permanent Account Number not responded – [ 144, 147, 148, 156, 271B, 271F, 274, Art. 226]

Held that in view of the peculiar facts, the petitioner-firm, having two PANs issued in its name (one in status as a company), filed its audited returns and paid taxes on correct PAN but since they had not taken any steps to cancel or surrender wrong PAN nor respondent had fulfilled its duties diligently by indicating in their reply to petition whether or not petitioner had filed any return of income on wrong PAN since issued, impugned notice under section 148 was t quashed and respondent was to be directed to cancel wrong PAN in accordance with law and reassess petitioner, if required. (AY. 2015-16, 2016-17)