Kai Balkrishna R. Gawade Mandai Vyapari Premises Sahakari Sanstha Maryadit v. ITO (2023)457 ITR 41 /153 taxmann.com 97 (Bom)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cancellation of old Permanent Account Number card and obtaining of New Permanent Account Number card-Intimated to Income-Tax Authorities-Notice referring to old Permanent Account Number card-Notice is not valid-Obiter : The Income-tax authorities ought to prominently display the steps for cancellation of a permanent account number on their website apart from sending a link for cancellation in the covering letter when a permanent account number is provided to an assessee. [S. 147, 148 148A(b) 148A(d), Art. 226].

Allowing the petition the Court held, that it was the duty of the Income-tax Officer to have examined and verified the contentions of the assessee in respect of cancellation of the old permanent account number and the returns filed under the new permanent account number before the issuance of the order and the notice. The order under section 148A and notice under section 148 of the Income-tax Act, 1961, were not valid.

Obiter : The Income-tax authorities ought to prominently display the steps for cancellation of a permanent account number on their website apart from sending a link for cancellation in the covering letter when a permanent account number is provided to an assessee.(AY.2019-20)