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Section 170, 120 and 153 of the Refund Carriage Contractor First Appellate Authority found that the contractor of the carriage was included in the definition of services rendered and thus charged under the Income Tax Ordinance, under section 170 of the Income Tax Ordinance 2001 With the exception of The issue was not included in discussing the nature of the business of the assessee, as well as the power to dissolve the matter, whether it was a hypothetical income matter, nor the Enforcement Wing having the authority to Determining the status of the vehicle contractor and its entire assessment as well as its appeal was illegal. It was permissible for the entire appellate authority to revoke the order but not because it mentioned in its order that there was some discrimination in regard to different vehicle contractors. Neither can be commended nor the approved department was instructed to issue a refund within 45 days till further action is initiated against it till the service of the present order.

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