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ORDER Through this appeal the taxpayer has objected to the impugned order of the learned CIR (A) dated 27.04.2015 for the tax year 2013 on the following grounds:- "A. That the impugned order is bad in Law, against the facts as well as against the statutory provisions of Income Tax ordinance 2001 B. That the order of the Respondent no. 1 is without jurisdiction. The BTB HQ having no any jurisdiction against registered taxpayers who have filed their Income Tax Returns. The Appellant filed his Income Tax Returns for the lax years 2008 to 2013 before issuance of show cause notice. C. That FBR Notification no C. No. 57 (2) Jurisdiction/2011-Vol-V dated 1st August, 2013 vividly stated that "the commissioner IR (BTB) RTO, shall exercise the powers and functions mentioned in the notification in respect of all persons jailing in the jurisdiction of RTO Rawalpindi, who are potential taxpayers LIABLE TO FURNISH THEIR RETURNS of income and have been identified on the basis of information collected for BROADENING OF TAX BASE. (Copy attached) D. That as per aforesaid notification the jurisdiction of powers of sections 122 & 122C of the Income Tax Ordinance, 2001 is only available to Respondent BTB department after enforcement of Income Tax Returns of potential taxpayers who are liable for furnishing of Income Tax Return, whereas Appellant is registered taxpayer vide NTN 3267869-0 since from 04.03.2009. E. That Respondent No. 2 was not at all justified to confirm the addition on account of commission earned @ 5%. It is open secret that real estate dealers charged maximum 1% commission and said l % is not their net Income due to deduction of allowable admin expenses. F. That the order passed by the Respondent No. 1 and upheld by the Respondent No. 2 is without any definite information, which is mandatory under the law. The Respondent No. 1 deliberately ignored to mention the sub-section (5) of Section 122 of the Ordinance, 2001 due to reason that he has no any definite information for amendment of original assessment. G. That Respondent No. 2 was not at all justified to confirm addition under section 111 (1) (d) (ii) of TTO, 2001 on account of so called suppressed receipts…

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