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I.T.A. NO.59/IB OF 2004, DECIDED ON 17TH FEBRUARY, 2006. versus I.T.A. NO.59/IB OF 2004, DECIDED ON 17TH FEBRUARY, 2006.

The Department, which allowed the approval of Sections 65 and 62 additional assessments, argued that the First Appellate Authority was not justified in vacating an order approved under section 65/62 of the Income Tax Ordinance 1979 because the Inspection Additional Commissioner only allowed ` That was not possible. Alternative to `Approval a 'required under section 65 of the Income Tax Ordinance, 1979, the Examining Additional Commissioner's article / title contains the words" Approval "while the body of the letter allows the word used Is. The Commissioner gave the approval along with the approval of both the `` Examining the Commissioner using the word 'permission' to initiate proceedings to reopen the assessment of SCCC pursuant to section 65 of the Income Tax Ordinance 1979 Was actually approved. In fact, `approval 'is equivalent to, and regardless of the word used, the intention is to have the law permanently fulfilled by the inspecting additional commissioner acting on his jurisdiction. The consent of the Commissioner for the purposes of section 65 of the Income Tax Ordinance 1979 was not allowed to be treated and it was sufficient to understand that the jurisdiction to reopen a case was exercised at the discretion of the Additional Commissioner. Was clear and in the body of the letter issued by the inspector Additional Commissioner instead of `Approval ' The use of the word permission was clearly explained. No material significance has been clearly used for the letter title in the case of the case. immigration advocate from Gharo lawyer