Sections 177, 122 (1) and 122 (5) CBR Circular C No. 1 (1) Section (ITAS) / 2004 dated 11 6 2004 CBR Circular C No. 1 (1) Section (ITA) S) / 2004 Date 28 7 2004 Audit tax year, 2003 Selection of case for audit despite the fact that the taxpayers had revised the return in the circular / letter of the Central Board of Revenue Assessment. The Commissioner is not eligible to select the matter as stated in the circular / letter. Article 11 of 2004 The Department claimed that these privileges were available to non-corporate taxpayers because there were no such privileges available to corporate taxpayers. Excluding matters from the list of selected cases by the Federal Board of Revenue. Two circulars / letters were issued under the same reference number. For the audit of the tax year, 2003, the subsequent circular / letter did not dispose of the earlier circular should be rational conclusion, dealing with the issues covered by one of the circular / letter corporate taxpayers accordingly. Who modified the retiree. Once the taxpayer acknowledged the return as per the letters issued by the Federal Board of Revenue and the subsequent proceedings / orders were declared invalid, the Audit Commissioner had no mandate to select the matter. Under Section 122 (1) / 122 (5) of the Income Tax Ordinance 2001, the revised Order of the Law and the orders of the First Appellate Authority were vacated because the jurisdiction to take the audit and to amend the amended order were all Illegal revised returns were filed by taxpayer to have valid assessment order
Related judgments — Income Tax Appellate Tribunal Pakistan, 2010