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Section 184 and 122 CBR Circular No. 2, CBR Circular No. 6 (II) dated 6/7/561 of 1959, dated 17 6 1975 amended by some additions to the difference in the penalty for concealing income limit At the time of purchase, the first appellate authority retained such an increase, according to the sales tax return provided by the reviewer and the false accounts of the return, accounts / income / purchases, This was equal to 100% of the tax levied. Such conviction was removed by the First Appellate Authority with the observation that after 11 months interval, the imposition of a fine was not legally enforceable after an unlawful delay which was lawful and lasting. The department claimed that the penalty was to be removed. The delay was unfair and illegal as the Constitution did not draw a time limit for seeking Section 184 of the Income Tax Ordinance, 20. The period of 01 and 11 months could not be determined as the illegal delay officer was fined only on the basis of the assessment, which the appellate authority had earlier directed the Central Board of Revenue to complete. Was released. The action was taken within three months after the assessment, but the penalty proceedings were initiated after about a year, which was inappropriate, and the Appellate Tribunal rejected the circumstances. top advocates from Tarnol lawyer