Law: Income Tax Ordinance, 2001

Section: 21(c),21(l),120,122(1)(5)

Assessment order u/s 120 of the Income Ordinance 2001 ORDER This appeal has been filed by the taxpayer against the impugned order dated 02-10-2014 recorded by the Learned CIR (Appeals-II), Lahore, wherein partial relief has been granted which is found inadequate by the taxpayer. 2. Through the miscellaneous application the applicant company sought permission to revise its grounds of appeal taken in ITA No. 238/LB/2015 (Tax year 2012). Since the revised grounds taken by the applicant company raise vital issues which are necessary for consideration by this Tribunal for the dispensation of justice, the applicant is allowed to plead its case on the basis of revised grounds of appeal. 3. Brief facts of the case are that the taxpayer, a private limited company derives income from courier services. The taxpayer Filed its return declaring income of Rs. 6,300,362/- which was deemed to be an assessment order u/s 120 of the Income Ordinance 2001. The case of the taxpayer was selected for audit through computer random ballot In this regard the taxation officer sent intimation to the taxpayer requiring for books of accounts consisting of cash book, ledgers alongwith other relevant details/documents/invoices. After sought adjournments from time to time the taxpayer submitted written reply which was considered and found to be unsatisfactory by the taxation officer She therefore, amended the assessment order u/s 122(1)(5) of the Income Ordinance, 2001 and determined the income of the taxpayer at Rs. 157,181,751/-. In appeal, the learned CIR(Appeals), thereafter deleted and curtailed the certain additions upto 70% under the heads Packing Expenses/Printing & Stationery, Repair & Maintenance, Telephone & Telex and upheld the additions under the heads Rent, Rates & Taxes, Miscellaneous Expenses i.e. Head Office Expenses/Loss on Disposal of Assets/Postage & Booking, and Selling Expenses. This has brought the taxpayer in further appeal before this forum. 4. The learned AR has vehemently challenged the orders of the authorities below and has argued that the taxation officer has made an addition u/s 21(c) of the Income Tax Ordinance, 2001. He has further argued…

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