MESSRS PAKISTAN INDUSTRIAL CREDIT AND INVESTMENT CORPORATION LTD. versus COMMISSIONER OF INCOME TAX
Sections 32 and 66 maintain two diagnostic simultaneous accounting systems when re-opening the assessment by examining the accuracy of the Additional Commissioner, where the assessment was made on a basis that was inaccurate with the law and was subject to the assessee's tax liability. The risk may be even higher than that determined by the Assessing Officer. The Commissioner could always reopen the assessment revenue, in the present case it was found that the SCCC was not legally entitled to benefit from the two accounting systems and could be liable to pay interest tax on the whole account. In such cases the Commissioner cannot be denied the option to reopen the assessment.
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