Bombay High Court
CANVAS SHOE CO GOA PVT LTDversusUNION OF INDIA AND ORS
- Decided
- Disposal
- Disposed off as Withdrawn
Holding
The petition was disposed of as withdrawn, with liberty to the petitioner to re‑file the writ before the Bombay High Court at Goa.
Summary
Canvas Shoe Co. (Goa) Pvt. Ltd. filed a writ petition in the Bombay High Court seeking a mandamus directing the Revenue to correct the fourth character of its Permanent Account Number (PAN) from "F" (Firm) to "C" (Company) and to carry forward its tax data. The petitioner argued that the PAN status was erroneous as the entity is a company, while the respondent Revenue counsel highlighted that the assessing officer is located in Goa, implying the appropriate forum is the Bombay High Court at Goa. The petitioner contended that although its registered office shifted to Mumbai in 2021, it continues to be assessed by the Goa jurisdiction. The Court examined the jurisdictional issue and concluded that the petitioner may approach the Bombay High Court at Goa for the relief. Rather than transferring the petition, the Court allowed the petitioner to withdraw the present petition and re‑file it before the appropriate bench. The petition was consequently disposed of as withdrawn, with liberty to file afresh, and no order as to costs was made.
Issues considered
- Whether the Bombay High Court at Mumbai has jurisdiction to entertain a writ petition filed by a taxpayer assessed by the jurisdictional assessing officer in Goa
- Whether the petitioner is entitled to a mandamus directing correction of the fourth character of its PAN
Subjects
- PAN correction
- jurisdiction
- writ of mandamus
- High Court
- Bombay High Court
- Goa jurisdiction
- tax assessment
Judgment
2026:BHC-AS:39809-DB
3-WP-12361-2026.doc
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CIVIL APPELLATE JURISDICTION
WRIT PETITION NO. 12361 OF 2026
Canvas Shoe Co. (Goa) Pvt. Ltd. .. Petitioner
Versus
Union of India and Ors. .. Respondents
Adv. Krishna Pratap Singh, i/b EJ Law LLP, for the Petitioner.
Adv. Akhileshwar Sharma, for the Respondent-Revenue.
CORAM: B. P. COLABAWALLA &
FARHAN P. DUBASH, JJ.
DATE: SEPTEMBER 29, 2026
P. C.
1. The above Writ Petition is filed seeking a writ of mandamus to
the Respondents for correction/amendment of the existing Permanent
Account Number (for short “PAN”) of the Petitioner in the manner that the
4th character of the PAN, which is "F", is to be replaced with the letter "C",
and all existing data along with the business loss as reflected in the Income-
tax Return is to be carried forward to the corrected PAN data.
2. This relief is sought on the basis that in the PAN the 4th
character depicts the status of the Assessee. “F” depicts the status as "Firm",
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“P” depicts the status as “Individual” and “C” depicts the status as
“Company”. Despite the Petitioner being a Company, the 4th character in the
PAN of the Petitioner is reflected as “F” instead of “C”. It is on this basis that
a correction is sought in the PAN of the Petitioner.
3. Mr. Sharma, the learned Counsel appearing on behalf of the
Revenue, pointed out that the Jurisdictional Assessing Officer of the
Petitioner is situated in Goa and hence the present Petition ought to be filed
in the High Court of Bombay at Goa.
4. The learned Advocate appearing on behalf of the Petitioner
stated that originally the Petitioner had its registered office in Goa, but in
2021 the same was shifted to Mumbai. However, the Petitioner is still being
assessed by the Jurisdictional Assessing Officer in Goa.
5. Considering these circumstances, we are of the view that the
Petitioner is at liberty to approach the High Court of Bombay at Goa for
seeking the reliefs sought in the present Petition. Rather than transferring
this Writ Petition to the High Court of Bombay at Goa, which would take
some time, we are of the view that the Petitioner can be allowed to withdraw
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the above Writ Petition with liberty to file it afresh before the High Court of
Bombay at Goa.
6. In these circumstances, the above Writ Petition is disposed of as
withdrawn with liberty to the Petitioner to approach the High Court of
Bombay at Goa to seek the same reliefs that are sought in the above Writ
Petition. No order as to costs.
7. This order will be digitally signed by the Private Secretary/
Personal Assistant of this Court. All concerned will act on production by fax
or email of a digitally signed copy of this order.
[FARHAN P. DUBASH, J.] [B. P. COLABAWALLA, J.]
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SEPTEMBER 29, 2026
Darshan Patil
Signed by: Darshan Patil
Designation: PA To Honourable Judge
Date: 30/09/2026 15:42:43
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