Failure to pay taxpayers by default to the taxpayers received by Section 161 and 128 (5) taxpayers, by default the company was considered a taxpayer because the company failed to deduct the required tax under the heads: Local Raw Materials, Salary & Wages, Store / Spare, Repair and Maintenance, Other, Travel / Leasing, Communication, Repair and Maintenance, Professional Compensation and Sales Expenses. Taxpayers said that the notes issued were never presented to the taxpayers. And the officer who determined the expenditure of various officers was simply estimated which was not lawful. And no reasonable opportunity was provided for the matter to be considered under law. And the taxpayer submitted the required information / documents First Appellate Authority retained the Assessing Officer's previous action and refused to enjoy the documentary evidence presented by the taxpayers under section 128 (5) of the Income Tax Ordinance, Assessment accuracy of 2001 was issued by the officer under section 161 of the Income Tax Ordinance 2001, based on the amount of money in the accounts of the company and failed to be involved in the proceedings to present its case to the taxpayers in any way; The appropriate opportunity, considered under, was not given. The taxpayer should prove that the payment under various expenses was mostly below the holding tax threshold and that the tax was properly deducted / deposited where the taxpayer was required and the taxpayer had Such documentary evidence was available for necessary examination / verification / complete examination