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ORDER This appeal has been filed at the instance of the taxpayer against the impugned appellate order dated 06.2013 recorded by the learned CIR(A) Lahore for the tax year 2009. 2. Brief facts, leading to the disposal of present appeal as per order of the learned CIR(A) are that return was filed declaring income at Rs. 2,538,972/- which was deemed to be an assessment order in terms of section 120(1) of the Ordinance Subsequently, the tax affairs of the appellant were selected for audit u/s 177 of the Ordinance by the commissioner Inland Revenue. In order to complete audit proceedings various notices u/s 176 05.10.2011 claimed that its case falls under the category of presumptive tax regime and income is subject to deduction of tax u/s 153(1)(c) of the Ordinance, therefore, proceedings initiated should be dropped. This contention of the taxpayer was not accepted by the assessing officer as the taxpayer had itself declared income under normal regime (showing sales, cost of sales, GP rate etc. and claiming P & L expenses) as well as final tax regime on account of supply of goods. Since the taxpayer failed to make compliance of statutory notices and failed to produce books of account as well as detail of purchases, expenses claimed under various heads of P & L account etc. therefore, the assessing officer issued specific notice u/s 121 conveying intention to disallow entire purchases and profit & loss account expenses u/s 174(2) of the Ordinance. No reply was furnished on the due date of hearing. Therefore, the assessing officer framed assessment u/s 121 of the ordinance in the following manner:- Income declared 2,538,972 Addition u/s 174 under the head P&L Exp. 3,388,408 Addition u/s 174 under the head purchases 241,260,704 __________________________________________________ Total amended income 247,188,084 Taxation officer except on the addition of entire purchases u/s 174(2) and directed the assessing officer to verify purchases from the record of sales tax returns and recomputed the disallowance u/s 174(2) of the Income Tax Ordinance, 2001. Feeling dissatisfied against the treatment meted out by the learned CIR(Appeals) the taxpayer has come up in…

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