PAKISTAN MOBILE COMMUNICATIONS LTD. versus COMMISSIONER OF INCOME TAX AUDIT DIVISION
Amendments to Sections 122 and 210 Constitution of Pakistan (1973), Article 199 Constitutional Application, Commissioner's powers to amend assessment Evaluate under subsection (1) and (4) of section 122 of Income Tax Ordinance 2001 Scope of the Commissioner, the Commissioner was authorized to amend and further amend the Review Orders under section 122 (5A) of the Income Tax Ordinance 2001; the Commissioner had the power to make a modification, which the Additional Commissioner Was canceled under the law governing the inspection of powers. Under subsection (5A) or (5B) of section 122 of the Income Tax Ordinance 2001, the returns were usable based on the date already available and other documents related to the jurisdiction of the withdrawal. However, if the Commissioner will consider the date available on the basis that the Assessment Order was incorrect and prejudicial to the interest of the Revenue, however, if the Commissioner may obtain some additional information from an audit or by some other means, he or she may be subject to income tax. You may exercise your powers under section 122 (1) of section 122 of the Ordinance 2001, so that the ordinance issued under section 120 of the Ordinance Modify the Order or be approved under Section 121 of the Ordinance. Since the powers under section 122 (5A) of the Income Tax Ordinance were exercisable on the basis of the material already available, if the order was passed against it, the appeal and the appellate order would come into the field, the theory of integration applicable. Will be. However, the powers under Sections (1) and (4) of Section 122 of the Income Tax Ordinance 2001 cannot be amended, even in the presence of an Appellate Order, if the Commissioner obtains accurate information, he / she will be required to comply with the law.
