Law: Income Tax Ordinance, 2001

Section: 177(4),122(1)/(5)

(a) Income Tax Ordinance (XLIX of 2001)--- ----Ss. 177 (4) & 122(1)/(5)---FBR letter C. No. 4(7S)ITP/2009 dated 9-1-2010---Audit---Tax Year 2008---Federal Board of Revenue directed the field formation that random audit selection of cases for tax year 2008 had been held for Audit of Corporate cases and cases of AOP's and the cases of audit on any other basis for tax year 2008 may be closed, however, cases with proof or evidence of gross irregularities may be intimated to the Board for guidelines as to further necessary action. (b) Income Tax Ordinance (XLIX of 2001)--- ----Ss. 177 (4) & 122(1)/(5)---FBR letter C. No. 4(7S)ITP/2009 dated 9-1-2010---Audit---Tax year 2008---Taxpayer contended that selection of the case was totally unlawful and unwarranted as the Federal Board of Revenue had directed the Department to close the audit proceedings initiated in respect of tax year 2008 but the department had not complied with the directions---Validity---Case was selected for audit on 20-1-2009 and proceedings were finalized on 30-4-2009, much before that Board's circular through which instructions to the field formation were conveyed that cases of Corporate cases and cases of AOPs had been selected through random ballot for tax year 2008 for audit and the cases of audit on any other basis for tax year 2008 may be closed---Board's instructions would apply to cases of audit of cases selected on the basis other than random ballot for tax year 2008 in which proceedings were pending on the date instruction was received from the Board---Proceedings in such cases could be closed where proceedings were pending on the date, Board Circular was received but this was not the situation in the present case because the Taxation Officer had already finalized the proceedings on 30-4-2009 before Board instructions were communicated on 9-1-2010 and the---Taxpayer contended that appeal was the continuation of assessment proceedings and the policy laid down by the Board was applicable to its case; and Supreme Court had directed to follow the policy guidelines in letter and spirit and exclusion of individual cases was not justified as the same tantamount to discrimination which the…

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