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Sections 65, 148 and 59 (1) of the Additional Assessment resume the assessment on the basis that Assisi had imported a new material consignment and, therefore, needed to clarify its sources of investment. The investigating officer investigated the collection of evidence under Section 148 of the Income Tax Ordinance, 1979 and also provided an opportunity to examine the witness after issuing a notice under section 65 of the Income Tax Ordinance, 1979. Without such action, such proceedings were not permitted under the law as may be issued only after completion of the said notice, if such inquiry would have resulted in accurate information under section 65 of the Income Tax Ordinance 1979, The original documents could not be discarded without verification or else the record that was made to reopen the evaluation And this was only the case can not be made based on local assessment and the current record for the reopening. The Assessing Officer reviewed its foregoing proceedings and held that the lenders' data were fictitious, which was subsequently investigated under section 148 of the Income Tax Ordinance 1979, which was subsequently considered. Legal provisions of the Assessing Officer's action were not supported The assessment order was irreversible which was canceled / canceled by the appellate tribunal.

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