Lova Impex (P.) Ltd. v. ITO (2025) 238 TTJ 1049 (Hyd.)(Trib.)

S. 249: Appeal-Commissioner (Appeals)-Form of appeal and limitation-Condonation of delay-Two PANs allotted to assessee-Proceedings initiated under old PAN-Sufficient cause established-Delay was condoned-Matter remanded. [S. 147, 148A, 144, 249(3)]

The assessee-company had inadvertently been allotted two PANs, one in the status of a firm and another in the status of a company. Returns of income were filed under the new PAN, whereas reassessment proceedings were initiated under the old PAN on the basis of information received from the DGFT. Since the assessee was unaware of the proceedings under the old PAN, it could not file appeals within the prescribed time. The Tribunal held that the existence of two PANs constituted sufficient and reasonable cause for the delay in filing the appeals. The delay was condoned, and the matter was restored to the Assessing Officer to verify whether the transactions reported by the DGFT under the old PAN had already been accounted for by the assessee in its books of account. (AY. 2015-16,2017-18.) 

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