Sections 85, 80 (2) (a), 92, 93 and 122 (9) assessing the change in the status of sole proprietorship in the association were considered the "Association of Persons" on the issue in which the investor Partner (Skousie's husband) made the purchase. Other affiliates and its contribution to the business to expand existing infrastructure, the value of the place explained the investment partner's interest in investing in the business ownership. The business's bank account revealed that it was claimed to be handing over money to a partner. And the investor partner is using the positive cash flow of the business for personal investments and commitments, without accidentally fulfilling any obligation to obtain a loan, not just the extent of its authority. Neither established nor controlled the assets of the business. But, as well as being a business partner / member, Assisi confirmed that by treating her husband as a partner under Section 85 of the Income Tax Ordinance 2001, the diagnostic officer was able to reach out to them. Failing to identify any such transaction, it was concluded that the same was the case for tax avoidance. And the change in the status of sole proprietorship in a compromised association of persons in charge of the personal without any solid and credible evidence did not justify the tax officer's action. And Section 85 of the Income Tax Ordinance 2001 had to enforce the anti-avoidance provisions of the Legislature and it had not authorized the Department to change the status of taxpayers / assets.