Law: Income Tax Ordinance, 2001

Section: 122

Income Tax Ordinance (XLIX of 2001)---S. 122---Amendment of assessment---Order passed under Income Tax Ordinance, 1979---Original assessments for the assessment years 1996-97 to 1998-99 were completed under S.60 of (repealed) Income Tax Ordinance, 1979---Said original assessments were amended by invocation of provisions of S.122 of Income Tax Ordinance, 2001---On filing appeal by the taxpayer, Commissioner (Appeals)/Appellate Authority cancelled said amended order---Order of Appellate Authority was upheld by the Tribunal holding that provisions of S.122 of Income Tax Ordinance, 2001, did not have any retrospective effect---No order under subsection (1) of S.66 of repealed Income Tax Ordinance, 1979 would be made after expiry of four years from the date of order sought to be revised---Impugned order passed beyond the period of four years time, was liable to be struck down and was annulled, by Appellate Tribunal, in circumstances. 2005 PTD 1621; Messrs Eli Lilly Pakistan (Pvt.) Ltd.'s case 2009 PTD 1392; 2009 PTD 1392; 2011 PTD (Trib.) 2362; 2012 PTD 964; 1981 PTD 210; 2008 PTD (Trib.) 1641 and 2007 PTD (Trib.) 1203 ref 2011 PTD (Trib.) 2362 rel. ORDER M.B. TAHIR, ACCOUNTANT MEMBER.---The titled appeals preferred at the instance of the taxpayer are directed against the consolidated order of learned Additional Commissioner Inland Revenue, Lahore passed on 29-6-2011. Facts in brief are that the original assessments for the assessment years 1996-1997 to 1998-1999 were completed under section 60 of the Income Tax Ordinance, 1979. Subsequently, on scrutiny of record the Assessing Officer observed that the appellant had claimed expenses under the head leased rental in all the years under consideration but had not furnished any details thereof and not declared any leased assets in its balance sheet. Accordingly the appellant was called on to explain the position. The reply furnished by the assessee did not find favour, therefore, original assessments were amended by invocation of provisions of section 122 of the Income Tax Ordinance, 2001. The taxpayer filed appeals and the learned CIT(A) vide its order dated 6-11-2004 cancelled the amended order. The department filed…

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