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PAN, KYC & Identity

You have ended up with two PANs. Here is how to give one up

Common, fixable, and the advice you will find elsewhere is now out of date.

One PAN was issued years ago, often while you were still in India or as a student, and a second came later, perhaps through an employer, a bank, or an application you thought had never gone through. Now your TDS is landing against one and your filings run on the other, a refund has stalled, or a bank has asked which one is real. You have also read that there is a penalty, which is the part that worries people most.
Last reviewed: 15 September 20267 min readReviewed by Preetesh Maloo, CA

The short answer

Tell your Jurisdictional Assessing Officer, in writing, which PAN you use and which one should be deactivated. That is the route the Income Tax Department itself sets out, and as of 1 April 2026 it is effectively the only one: the prescribed correction form, PAN CR-01, no longer carries the field that used to be used for surrendering a duplicate. Keep the PAN your filings and TDS actually run on, not automatically the older one. The penalty for holding two is 10,000 rupees under Section 272B, but the officer may impose it rather than must, you are entitled to be heard first, and Section 273B bars it entirely where you show reasonable cause.

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Why two PANs is a problem worth fixing now

The bar is explicit. Section 139A(7) says that a person who has already been allotted a permanent account number "shall not apply, obtain or possess another" one. The Income-tax Act 2025 carries the same rule forward at Section 262(8).

The practical damage usually arrives before any penalty does. Your TDS credits split across two numbers, so the tax deducted on your NRO interest sits against a PAN your return never mentions and the credit simply does not appear. Refunds stall. Your AIS and Form 26AS each tell half the story. A bank or a registrar asks for KYC and gets a mismatch. None of that resolves itself, and each year you leave it adds another set of records to reconcile later.

The advice everywhere else is now out of date

Until recently the answer was to fill in the PAN change or correction form and list the unwanted PANs in the item provided for it. That item existed, it was headed "Mention other Permanent Account Numbers (PANs) inadvertently allotted to you", and it is what almost every article still tells you to use.

It is no longer the prescribed form. With effect from 1 April 2026, an order of the Director General of Income-tax (Systems), issued under Rule 158(12) of the Income-tax Rules 2026 read with Section 262(4) of the Income-tax Act 2025, prescribes two forms and only two: PAN CR-01 for an individual and PAN CR-02 for everyone else.

We read PAN CR-01. It has ten numbered items, covering name, gender, date of birth, address, passport number, foreign tax identification number, contact details, parents' names, and the documents you are attaching. There is no field for a duplicate PAN anywhere on it.

So if you follow the instructions you find elsewhere, you will reach the form and find nothing to fill in.

What actually works: the Assessing Officer route

The Department's own position is the one to follow. Its PAN 2.0 FAQ puts the obligation on you and names the office: a person holding more than one PAN "is obliged to bring it to notice of Jurisdictional Assessing officer and get the additional PAN deleted/de-activated".

So the request goes to your Jurisdictional Assessing Officer, in writing. It should identify both PANs, say plainly which one you use and which should be deactivated, and enclose copies of both cards along with proof of identity. If you are abroad, this is correspondence rather than a counter visit, and it can be run by someone acting for you in India.

Your jurisdiction is shown on the income-tax portal under your profile, and it can be reached through the portal's grievance facility as well as by post. If you do not know which officer holds your file, that is the first thing to establish, because a letter to the wrong ward simply sits there.

Which PAN to keep, and why the usual answer is wrong

You will be told to keep the older one. There is no rule that says so, in the Act, in the Rules, or in any departmental instruction we could find.

What the official instructions actually key on is use. The Department's own correction instructions say the PAN to be cancelled must not be the one "currently used" and that the one currently used goes at the top of the form. So the test is which number your filing history, your TDS credits and your bank and demat records are actually attached to.

Usually that is the older PAN, which is why the shorthand survives. Not always. If you left India, stopped filing on the first PAN for a decade, and everything since has run on the second, keeping the first because it is older gives you the harder migration and no benefit. Work out where the history sits before you decide, because reversing this choice afterwards is far more work than making it correctly.

The penalty, in proportion

Section 272B is where the 10,000 rupee figure comes from. Three things about it are usually left out.

It is discretionary. The section says the Assessing Officer "may direct" that the person pay the penalty, not that they shall.

You are entitled to be heard. No penalty order can be passed unless you have been given an opportunity of being heard on it.

And there is a statutory defence. Section 273B names Section 272B expressly and provides that no penalty shall be imposable if you prove there was reasonable cause for the failure. A second PAN issued by an employer without your knowledge, or an application you believed had lapsed, is the kind of fact that goes to reasonable cause.

Under the Income-tax Act 2025 the penalty provision is renumbered, and the amount is reported as unchanged. Voluntarily coming forward is not what creates the exposure. Holding two PANs is.

The NRI-specific part

If one of your PANs has gone inoperative, that is a separate problem riding alongside this one, and it bites harder.

An inoperative PAN means refunds are not issued, no interest is paid on them for that period, and tax is deducted at the higher rate under Section 206AA, which generally works out at 20 percent. That is the rate people run into on NRO interest and on a property sale.

The relief is that a non-resident is not required to link PAN with Aadhaar at all. The exempt categories published by the Department cover a non-resident under the Act and a person who is not a citizen of India. Where a PAN has gone inoperative anyway, it is usually because the Department's record still shows you as resident, and the fix is to tell your Assessing Officer your residential status and evidence it, which is the same correspondence as the duplicate-PAN request and can go in the same letter.

One thing that catches people: an inoperative PAN is not a dead PAN. You can still file a return on it.

What's involved

What the CA actually does

  1. 1

    Work out which PAN your record actually sits on

    We pull the filing history, the Form 26AS and the AIS for both numbers and establish which one carries the credits and the returns, rather than assuming the older one wins.

  2. 2

    Draft the request and find the right officer

    The letter to your Jurisdictional Assessing Officer identifying both PANs, with the documents that support it, addressed to the ward that actually holds your file.

  3. 3

    Put the reasonable-cause position on the record

    Where a penalty is raised, Section 273B is a statutory defence and it turns on the facts of how the second PAN came about. Those facts are worth setting out at the start rather than after an order.

  4. 4

    Clean up what the split PAN broke

    Credits sitting against the wrong number, a refund that never arrived, a bank or demat KYC showing the PAN you are giving up. This is usually the longer half of the job.

What to have ready

Documents you'll typically need

  • Copies of both PAN cards, or the numbers if a card is lost
  • Proof of identity and address
  • Your income-tax portal login, to confirm the jurisdiction and pull both records
  • Any correspondence or notice that referred to either PAN
  • Bank and demat records showing which PAN each is registered against

References on this page

  • Income-tax Act 1961, Section 139A(7)
  • Income-tax Act 2025, Section 262(8)
  • Section 272B and Section 273B
  • CBDT PAN 2.0 FAQ, Question 11
  • DGIT(Systems) order prescribing PAN CR-01, effective 1 April 2026

Frequently asked questions

Common questions

There is no longer a form field for it. From 1 April 2026 the prescribed correction forms are PAN CR-01 for individuals and PAN CR-02 for others, and neither carries the duplicate-PAN item the old form had. The route now is a written request to your Jurisdictional Assessing Officer, which is what the Department's own PAN 2.0 FAQ directs.

Not automatically. Section 272B says the Assessing Officer may direct the penalty, no order can be passed without giving you an opportunity of being heard, and Section 273B bars it altogether if you show reasonable cause. A PAN issued by an employer without your knowledge is the kind of circumstance that goes to reasonable cause.

Keep the one your filings, TDS credits and bank records actually run on. That is the test the official instructions use, which refer to the PAN currently used. It is often the older one, but not always, and there is no rule that the older one wins.

Yes. It is correspondence with your Assessing Officer, not a counter visit, and it can be handled by someone acting for you in India. The income-tax portal also has a grievance facility you can use from anywhere.

No. The Department's published exempt categories include a non-resident under the Act and a person who is not a citizen of India. If your PAN has gone inoperative anyway, it is usually because the record still shows you as resident, and that is corrected by informing your Assessing Officer of your residential status.

It is deactivated on the Department's records. The number is not reassigned to anyone else, and the history attached to it does not disappear, which is why the clean-up of credits sitting against it matters as much as the deactivation itself.

The exceptions that change the answer

Where the general rule stops applying to you

Every rule below has a carve-out, a cut-off date or a condition that flips the answer. These are the ones that decide real cases.

Inoperative PAN: what breaks

Right now: TDS at 20% or higher under s.206AA, refunds withheld, and no interest on the withheld refund

Where it works differently

The holder is an NRI
NRIs are EXEMPT from Aadhaar linking. PANs have nonetheless been made inoperative in bulk where the department's records still show resident status.
The fix is to get the residential status updated with the jurisdictional AO, not to obtain an Aadhaar.
A refund is pending
It is withheld while the PAN is inoperative, and no s.244A interest accrues for that period.
Rule 114AAA.

Commonly got wrong

  • An NRI must link Aadhaar to keep their PAN operative. NRIs are exempt. The problem is a stale residential status on the department's record.NRIs are exempt from Aadhaar linking. If your PAN shows inoperative, get your residential status corrected with the AO. Do not apply for an Aadhaar.

Two PANs and not sure which one to give up?

Send us both numbers. A practising CA will work out which one your record actually sits on, draft the request to your Assessing Officer, and sort out the credits stranded on the other. Free call, no obligation.

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