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" AMENDMENT, RECTIFICATION AND REVISION OF AMENDMENT, RECTIFICATION AND REVISION OF ASSESSMENT   By Zahid-Ur-Rehman, Chartered Accountant, Peshawar   In a recent judgment reported as 2005 PTD 1621, the Honorable Lahore High Court Lahore on the issue of amendment of orders under section 122 of the Income Tax Ordinance, 2001, passed under the provision of repealed Income tax Ordinance, 1979, prior to 1-7-2002, held as under:   "A comparison of the relevant section of the repealed law and section 123 of the present law shows a difference. Whereas, under sections 65 & 66A of the previous Ordinance, a lower grade official could re-open the assessment, whereas, the new law has totally vested the powers in the Commissioner. Its section 122 (2) reveals that the amendment to be made within the period prescribed is confined to a taxpayer. The taxpayer is defined in section 2 (66) of the Ordinance and is confined to an assessee who can be assessed income tax under the new Ordinance, whereas, the petitioners-assessee could only be assessed under the previous Ordinance and not the present Ordinance."   In the above judgment the Honourable Court has focused on the wording Tax Payer used in the aforesaid section and defined in section 2(66) of the Ordinance, which according to the honourable Court, is only confined to an assessee, who can be assessed under the new Ordinance.   The reading of section 122 of Income Tax Ordinance, 2001, beside the wording Tax Payer also reveals some other issues in relation to assessment order passed under the provisions of repealed Ordinance 1979, prior to 1-7-2002, i.e. the date of implementation of the new Ordinance, which I have tried to explain as under:   Under the provisions of subsection (1) of section…
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