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I.T.AS. NOS. 837-838/KB, 814-815/KB AND 986/KB OF 2003; DECIDED ON 8TH NOVEMBER, 2004. versus I.T.AS. NOS. 837-838/KB, 814-815/KB AND 986/KB OF 2003; DECIDED ON 8TH NOVEMBER, 2004.


Section 122 (5A) Notice of Proposal for Action under Section 122 of the Income Tax Ordinance in Section RO663 (I) / 2002, Section 142 of the Income Tax Ordinance (1979). Amendment; 2001 was issued by the Tax Officer on 12 9 2002 and the reason for initiating proceedings was that the earlier orders issued under section 62 of the Income Tax Ordinance 1979 were invalid and the interests of the Income Tax. Were biased towards. Assisi asserts that in accordance with the provisions of the law, Section 122 of the Income Tax Ordinance, 1979, the Commissioner was not given any authority to amend the assessment made under section 62 of the Income Tax Ordinance 1979 because it was therefore invalid and It was prudent to take an interest in income tax. At the time, the current legality law did not give the jurisdiction of the Additional Commissioner, acting as a taxation officer, as the sub-section (5A) of section 122 of the Income Tax Ordinance 2001 was enacted. On the basis of the day the notices were issued, proposing action under Section 122 of the Income Tax Ordinance 2001, on the basis of the day on which the notice was issued, it was wrong to amend the review and prejudice in the interest of income, The commissioner was not available accordingly. Relevant, the text of the relevant notice to the provisions of the law shows that the proceedings were initiated by the assuming officer until recording the order under section 122 of the Income Tax Ordinance 2001, which was well approved before registration. had gone. Sub-section (5A) of Section 122 of the Income Tax Ordinance, 166 200 by the Finance Act 2003, lacks jurisdiction over all orders made by the 1001 Taxation Officer in the law

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