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Sections 128, 161, 165, 221 and 131 reduce the levy of taxes, so that it is not permissible for the Commissioner to assume that the taxpayers were not provided adequate opportunity. Secondly, the Commissioner was not authorized to exclude tax collection under section 161 of the Income Tax Ordinance 2001, advertising costs, payment for local purchase, tax collection, advance tax collection, order under commission Directive to Accept Section 221 of the Income Tax Ordinance 2001 and acceptance of additional evidence of reconciliation etc. It was not adhered to in accordance with the legitimate principle of Audi UltraPrem, as the taxpayers provided sufficient evidence, which was not considered by the Assessing Officer during the currency of the appeal, the taxpayers requested by the department. To correct which request was rejected and the taxpayers said, the order did not provide the taxpayers with a proper opportunity to specify their status and the taxpayer would not be able to do so without issuing appropriate show cause notices. It was estimated that the exact intentions of the examiner in relation to this estimate were explained. The default Plea exact amount was announced, giving the taxpayers ample opportunity, in which case the commissioner's order to exclude the entire amount in advertising costs was justified because taxpayers must already accompany the correction application. The department's appeal was rejected on the grounds that the details were submitted. Accepting additional evidence of reconciliation, the Assessing Officer had stated in his order that if the details were provided, the order would be corrected despite the fact that the details were provided.

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