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ITAS.NOS.1374/KB OF 1992-93 AND 1796/KB OF 1993-94, DECIDED ON 14TH SEPTEMBER, 1994. versus ITAS.NOS.1374/KB OF 1992-93 AND 1796/KB OF 1993-94, DECIDED ON 14TH SEPTEMBER, 1994.


Additional Taxes with Income Tax Ordinance 1979 Sections 79 and 62 Non-Residential Principal Income Tax Officers discussed at length in this assessment order that Assissee made less profit than ordinary profits by purchasing raw materials from its parent company at a higher price. It was disclosed that the raw material in the open market was earned at a very low cost and that Assisi was not compelled to buy the said goods from any particular source, beyond any doubt between the non-resident and the non-resident. A business relationship and close contact was established with. The officer, while determining the amount of the profits which he deemed to have accumulated the assessee, provided the assessee with an opportunity to explain the various points under Section 62, Income Tax Ordinance 1979 and the Income Tax Officer. The occasion provided a suitable opportunity. Under section 62 of the Income Tax Ordinance, 1979, the contents of the notice issued under the Income Tax Ordinance were allowed to be interpreted and the explanation presented by the Assisi was included in the order which was assessed and irrelevant. The points regarding the business relationship between the Income Tax Officer were discussed in the Assessment Order and a close relationship between the Non-Resident and the Assisi was sought by the Income-tax Officer and the general profits made in view of the raw material prices. Could also be acquired by the company on the Income TA under Section 79, Income Tax Ordinance, 1979 The officer had worked. Income Tax Commissioner, which was examined in the Income Tax Commissioner, on the basis of the rate available to him in the case of an importer's parallel case,

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