NOBLE (PVT.) LTD. THROUGH MANAGER FINANCE AND ADMINISTRATION versus FEDERAL BOARD OF REVENUE THROUGH CHAIRMAN
Returns to sections 120, 122 and 177 were finalized under section 1220 (1) of the Income Tax Ordinance 2001, amended under section 122 (5A) of the Income Tax Ordinance 2001, under 5 177 of the Income Tax Ordinance. After a detailed investigation of such matter by the Commissioner for Audit. 2001, for the same reasons on which it was processed under section 122 (5A), the validity of the case selection process for audit once the Section 122 of the Ordinance Case is selected for audit. 5A) was different from the method adopted for modifying the order under. For the Assessment Order as amended under Section 122 of the Ordinance, either to confirm the approved order or to take action to amend it, subject to a strong audit and discrepancy in the record, on a case by case basis audit. Should be identified in favor of. The modification of the order, assuming that the return will be converted into an Assessment Order, cannot be relied upon in the Income Tax Ordinance, 2001 did not restrict the selection of the matter for audit. Its section 177, if it has already been dealt with under section 122 for the same tax year, the selection of the case for the total audit under section 177 of this ordinance and the proceedings under section 122, have different actions. , There is no restriction for starting both operations for the same tax year. Matter points The Commissioner had the power to select cases before the issuance of section 120 (1A) of the Ordinance, thus, section 120 (1A) had the precedent effect. The unwanted order was legal and the principles of jurisdiction With
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