Law: Income Tax Ordinance, 2001

Section: 21(c),122(5)

Law: Income Tax Ordinance, 2001

Section: 21(c),122(5)

Income Tax Ordinance, 2001 (XLIX of 2001) - Section 21(c) & 122(5) - Amendment of assessment - Management Consultancy Services - Deduction not allowed - Addition u/s 21(c) made by A.O. confirmed by CIR(A) - Validity - Whether addition u/s 21(c) has wrongly has been wrongly been made which is ordered to be deleted as addition made does not come under ambit of section 21(c) and is also not maintainable as same was not specifically confronted to appellant and has been made without referring any definite any definite information - Held yes. Addition under section 21(c) of the Income Tax Ordinance, 2001. He however, could not substantiate that expenses claimed on account of stationery & office supplies, repair & maintenance, selling expenses & other expenses attract the provision of section 21(c) of Income Tax Ordinance 2001. We have heard the learned Representatives from both the sides and have also perused the impugned orders of the officers below, case law referred and the available record of the case. After hearing both the parties and perusing the assessment record available before us and considering the arguments and case laws referred supra, we are of the view that addition under section 21(c) of Income Tax Ordinance 2001 has wrongly been made which is ordered to be deleted as the addition made do not come under the ambit of section 21(c) of Income Tax Ordinance 2001. The addition under section 21(0) of Income Tax Ordinance 2001 is also not maintainable as the same was not specifically confronted to the appellant and has been made without referring any definite information. In this regard, reliance is placed on the decisions of the Hon'ble High Courts reported as (2013) 107 Tax 41 (H.C. Lah)=2013 PTD 884 (Lahore High Court), (2010) 101 Tax 293 (Sindh High Court) and decision of this Tribunal dated 23-01-2010 in ITA No.1468/LB/2009 discussed above. Hence orders of the authorities below are hereby cancelled. Cases referred to: (2013) 107 Tax 41 (HC. Lah) and (2010) 101 Tax 293 (H.C. Kar.) ORDER The Order was passed by Javaid Masood Tahir Bhatti, Chairman - Through this Appeal the Appellant/Taxpayer Company has objected against the impugned order…

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