MESSRS SHADMAN COTTON MILLS LTD. THROUGH DIRECTOR versus COMMISSIONER OF INCOME TAX, COMPANIES-I, KARACHI AND 2 OTHERS
Sections 66A and 156 the scope of amendment and correction of the evaluation order where the assessment order was made in accordance with the prevailing theory of law and consistent practice of the Department, but subsequently due to the interpretation of the law by the appellate or superior court Has been changed. Conviction of wrongdoing will not be disclosed on record, but an amendment decision by the jurisdiction of the amendment under section 66A of the Income Tax Ordinance, 1979, shall be erroneous by the Assessing Officer under section 156 of the Ordinance 1979. This decision error will be corrected. The order for review of the order was not available to them under the Income Tax Ordinance, 1979, where the prevailing theory of law was not applied / implemented due to the appellate judgment or interpretation by the superior courts. Which was assessed by the Assigning Officer intentionally or due to ignorance or as a result of ignorance, then an incident of error which appears on the record correction was made in accordance with the principles of Section 156 Income Tax Ordinance, 1979.
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