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ABDUL AZIZ MUHAMMAD versus COMMISSIONER OF INCOME TAX


Sections 23 and 136 (2) Non-repudiation of bad credit Applicant for reference to the High Court had invested money in the joint venture and stated that the joint venture had informed him that on 31 12 4 1974 Profit will decrease in the period ending. The applicant, however, said that for the year of the review, the applicant was never paid for the benefit through a joint venture. The applicant claimed as bad loans under section 23 (1) of the Income Tax Ordinance 1979 as the creditors allegedly cheated him and were of no avail. The Income Tax Officer did not allow the claim of the denialist because the applicant claimed that there was bad debt as the order of the Income Tax Officer was upheld by the CIT. Held that the alleged bad debt was capitalist in nature, the Income Tax Appellate Tribunal dismissed the applicant's appeal and refused to answer the questions involved in the case as it was fully practiced in his opinion. Was. Detection of facts and no questions related to the law were included The applicant referred to the High Court under Section 136 (2) of the Income Tax Ordinance 1979, which sought the opinion of the applicant's counsel on these questions, Even a bad debt allowance is concerned under Section 23 (1) (X) of the Income Tax Ordinance 1979, thus there is no difference between the category of bad debt and big debt in income tax, bad debt by the Income Tax Officer. Absence and dismissal of appeal by the Income Tax Appellate Tribunal on the basis that the petitioner

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