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" AMENDMENT OF ASSESSMENT AMENDMENT OF ASSESSMENT   [A BRIEF STUDY OF SECTION 122 OF THE INCOME TAX ORDINANCE, 2001 AND SECTIONS 65 & 66A OF THE REPEALED INCOME TAX ORDINANCE, 1979]   By Muhammad Shahid Baig, Advocate High Court, Lahore   The basic function of the legislature is to make laws and judiciary is responsible to understand, comprehend and interpret the law. It is the judiciary who while exercising the power of judicial review gathers the intention of the legislature contained in any law to apply it in its true perspective. This process of interpretation takes years to comprehend the laws. The judiciary took almost two decades to comprehend the earlier law on the subject i.e. sections 65 & 66A. These remedial provisions remained in vogue for more than'20 years and there has been a veritable war between the Taxpayers and Tax Collectors about the invocation and interpretation of these penal provisions of the Fiscal Statute. Now a new chapter has been opened by repealing the old law and enacting a new theory with various amendments through insertion of section 122 of the Income Tax Ordinance, 2001.   The subsection (1) of section 122 of the Income Tax Ordinance, 2001 empowers the Commissioner to amend an assessment order treated as issued under section 120 or 121 of the new law or the assessment order issued under sections 59, 59A, 62, 63 or 65 of the old law by making necessary alterations or additions. Although this provision authorizes the Commissioner to amend an assessment but there are certain prerequisites to invoke this provision which are provided in the subsequent subsections. As per this subsection, the basic requirement is that an assessment order sought to be amended should have been treated as issued under section 120 or…