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FARA AGRO (PVT.) LTD., GUJRANWALA versus C.I.R., (LEGAL DIVISION) RTO, GUJRANWALA


The amendment of the Commissioner's Income Tax (Appeals), which had been examined by his order in the first period of Articles 122 (5A) and 131, not only invalidated this order on legal grounds, but he also got the right. That it is not sustainable on the face of facts. The taxpayer representative who said that the original order had expired and was merged in the appeal order was correct. The legal process for the department was to file an appeal because the first appellate order was not challenged, which is why they were final. Had taken shape and demanded the transfer of provisions. Section 122 (5A) of the Income Tax Ordinance, 2001 was not sustainable where the appellate authority offered its finding on a particular issue, the original order was not present and the appellate order was merged in the present case. Income Taxes (Appeals) have already considered the issue of debt forgiveness and integrate a deemed order into the Appellate Order and Tax Tax proceedings. There was no substantial improvement under Section 122 (5A) of the Income Tax Ordinance, 2001, after the Commissioner integrated the Income Tax (Appeal) order, the Higher Authority for the Commissioner Income Tax (Appeals) filed under Section 122 (5A). Can take action under The proceedings under section 122 (5A) of the Income Tax Ordinance, 2001, were of modal nature, not executed by the first appellate authority in addition to the subordinate authority order approved by the tax officer. Could go In the eyes of the law the following two orders of the authorities were vacated and the appeal preferred by the taxpayers was accepted \ r \ n

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