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I.T.AS. NOS.1393/LB AND 1409/LB OF 2010, DECIDED ON 30TH MARCH, 2012 versus


Sections 21 (c), 120, 122 (4) [as amended by the Finance Act, 2009], 122 (5A), 127 and 131 amended the assessment of taxpayer disclosing net income 2, 652,643, which was assessed in accordance with the terms of section 120 (1) of the Income Tax Ordinance, 2001, which states that the original diagnostic order was amended by the Additional Commissioner and the income was determined to be 3,167. , At Rs 143, from which the taxpayer's appeal against the amendment order was partially accepted by the Commissioner (Appeal). Prior to the amendment of section 122 (4) of the Income Tax Ordinance 2001, the validity of the action under section 122 (5A) of the Income Tax Ordinance was confirmed, the time limit for modification of this assessment order was five The year was the filing of returns, while the amendment, after amending section 122 (4) of the Income Tax Ordinance 2001, extended the period limit, long after the original evaluation order was approved. This was not applicable to the case of the taxpayers as well, which is why in submitting the Income Tax Return 30 2004 12 2004, a rightful right was made to the point of limitation in favor of the taxpayer's law as assessed. Appeal filed by taxpayers on the first day of application and not later in the Legislature, the amended assessment order was timely bound and approved after a five-year ban. The tribunal's appeal was accepted, while the court's appeal was dismissed.

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