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TMI Blog2024 (11) TMI 322X X X X Extracts X X X X X X X X Extracts X X X X ..... . M. Thirumalesh., counsel for the respondents has appeared through video conferencing. 2. The short facts are these: The petitioner is an Urban Credit Society which was earlier registered under the Karnataka Co-op. Societies Act, 1959. The petitioner had obtained a PAN Card bearing No. AADFS9937M for the Society. The petitioner later got itself converted into Shree Vijayalaxmi Urban Credit Souhard Sahakari Ltd., as per the Karnataka Souhard Act, 1997. Because of the conversion of the Society under Souhard Act, the petitioner obtained a new PAN Card bearing No. AAEAS0544G. Thereafter, the petitioner stopped filing its income tax returns under the old PAN Card as it had surrendered the same to the ITO, Hubli on receipt of the new PAN card. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h transactions in its bank account during the reassessment year 2015-16 and the second respondent has reasons to believe that income chargeable to tax has escaped reassessment and the same requires to be brought to tax. Subsequently, 142 (1) notices were issued and finally, a show cause notice was issued under Section 144 of the Act on 22.02.2022. The petitioner contends that the first respondent without properly considering the records and also without considering the fact that the petitioner Society had already surrendered the old PAN Card long back in the year 2012, went ahead and passed reassessment order under Section 144 of the Act on 20.03.2022 and issued demand notice under Section 156 of the Act. Consequently, penalty proceedings w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n is devoid of merits and the same may be dismissed. 4. Heard the contentions and perused the Writ papers with care. 5. The order passed under Section 147 R/w Section 144 R/w Section 144B of the Income Tax Act, 1961 is furnished along with the Writ Petition and the same is marked as Annexure-H. A perusal of the same reveals that it's an ex-parte order. The order is passed for the Assessment Year 2015-16 by mentioning the PAN bearing No. AADFS9937M, which according to the petitioner is an old PAN number. Suffice it to note that the department has issued a notice to the PAN which is available in their record. However, the petitioner contends that the notice was issued by mentioning the old PAN number, it could not give reply to the notice. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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