Discrepancies in Date of Birth and Address Details on Duplicate PANs Prompt Court to Seek Verification and Explanation for Deactivation of One PAN
In a significant judgment delivered on September 29, 2026, the Delhi High Court (Division Bench) addressed a dispute concerning the issuance of two Permanent Account Numbers (PANs) allegedly held by Neeraj Kukreja. The petitioner, Neeraj Kukreja, contended that he possessed only one PAN (AANPK4217G) and denied having applied for or used the second PAN (AISPK7844C), which was implicated in an income tax reassessment proceeding.
The Income Tax Department opposed this claim, highlighting striking similarities in the particulars of both PAN cards, such as the same name and father's name, to argue that both PANs belonged to the petitioner. The Department also relied on the fact that the petitioner had received notices under Section 147 of the Income Tax Act and was aware of the assessment order related to the second PAN.
Upon examination of the details, the Court observed that while there were similarities in the names and parental details on both PANs, there were notable dissimilarities, including a difference in the year of birth (1975 vs. 1974) and variations in the residential addresses. The Court expressed difficulty in understanding how two PAN cards could have been issued to one individual with almost identical but conflicting details, especially in the absence of proper proof of date of birth at the time of issuance.
To resolve the issue, the Court directed the Income Tax Department to produce comprehensive original records related to both PANs. This includes theriginal PAN application forms, supporting documents submitted during issuance, contact details such as mobile number or email used for verification, and a 360-degree profile encompassing all related information for both PANs. Furthermore, the Court ordered the Assessing Officer to submit reasons for the deactivation of the second PAN (AISPK7844C) during the Assessment Year 2018-2019, along with any application filed for such deactivation.
The Court listed the matter for further hearing on October 15, 2026, emphasizing the need for thorough verification to ensure no misuse or error occurred in the issuance of multiple PAN cards to a single individual. This judgment underscores the importance of stringent verification processes by the Income Tax Department in issuing PANs to avoid duplication and potential tax evasion.
Bottom Line:
Income Tax - Dispute regarding alleged second PAN card and reassessment proceedings - Where petitioner denied having applied for or used second PAN, and Department relied on similarity of particulars in both PANs, Court found both similarities and dissimilarities in records and questioned how two PAN cards could be issued to one person without proper proof of date of birth - Department directed to produce original PAN application records, supporting documents, verification details, 360 degree profile, and reasons for deactivation of one PAN.
Statutory provision(s):
Income Tax Act, 1961 - Section 147 (Reassessment Proceedings)
Neeraj Kukreja v. Income Tax Officer, (Delhi)(DB) : Law Finder Doc Id # 2990707
