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Section 22, (50 ()), R 86 and 4 144 Section RA No. 8 368 (I) / ated 94 Date 6 30 199 199 4 19944 Liability for tax deduction or failure to pay source million Issuance of notice under section 4144 of tax deduction on capital by less than Income Tax Ordinance, 1979, instead of notice under section 52 of Income Tax Ordinance 1979, the accuracy of the first appellate authority finding the legal issue Income Tax Ordinance 1979 Instead of issuing a notice under section 144 of the section. 52 of the Income Tax Ordinance, 1979, was legally enforceable and the matter was set aside for consideration de novo. Putting this case aside was to give the Assamming Officer an opportunity to meet his shortcomings that were not valid in his view. The law-first appellate authority made a mistake in law, putting the case aside rather than canceling it in one place. It is conceded that Assessie's capital was less than $ 5 million for all years under appeal. ee was not responsible for deduction of tax under section 50 (4) of the Income Tax Ordinance, 1979 under section RO No. 368 (I) / 94 dated 30 6 1994, otherwise, section 52 of the Income Tax Ordinance 1979 Cannot be under any obligation. Section 222 of the Income Tax Ordinance was imposed without notice, 1979 the Assigning Officer was obliged to adhere to such mandatory conditions, and all subsequent acts of failure to do so would be rendered and his The first appellate authority's vacancy and vacant order was later dismissed. Appellate Tribunal Cases Under Section 52/86 of Income Tax Ordinance 1979 patent advocate from Hasilpur lawyer