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The assessment of the liability of persons failing to pay the tax deduction of sections 52 and 86 should be the year 1993 94, the order should have been by 1997 1997 98, but the taxation officer correctly passed the order on 29 6 2000. The order was passed on 29 6 2000, which was subject to limitations, it was made after a period of four years but the order was illegal and illegal but such legal fact was not accepted by the First Appellate Authority. , Even otherwise, on merit, the details of all the payments filed by the assessee, most of which were less than Rs 25,000 but the Assessing Officer Failure to consider the fact that the first appellate authority's order was vacated and the order passed by the taxation officer under section 52/86 of the Income Tax Ordinance 1979. The appellate tribunal upheld the law, allowing it to move beyond the limits provided under the Miscellaneous application, as well as allowing appeals filed by the SC.

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