Law:

Section:

ORDER: The titled appeal preferred at the instance of the taxpayer is directed against the order passed by the learned Commissioner Inland Revenue (Appeals-III) Lahore on 27.09.2015. 2 Facts of the case, in brief, are that the taxpayer filed return for the tax year under review declaring income at Rs.50,601,531/- which was taken as deemed order in terms of Section 120(1) of the Income Tax Ordinance, 2001. Subsequently, the Additional Commissioner examined the assessment record and found that the deemed assessment was erroneous as well as prejudicial to the interest of revenue in terms of section 122(5A) of the Ordinance for the following reasons- i. "As per Sr. No.3 of Annex-E you have declared the PTR income Rs.31,862,493/- whereas actual PTR income in view of provisions contained in section 67 of the Income Tax Ordinance, 2001 read with Rule 13 of the Income Tax Rules, 2002 is as under:- PTR sales declared Rs. 180,991,040/- total sales Rs.921,768,291/- x net profit Rs. 103,781,635/- = to 20,377,730/-. The difference comes to Rs. 11,484,763/- which needs to be added in your income. ii. You have the opening stock for the tax year, 2013 at Rs. 109,479,721/- whereas closing stock for the tax year, 2012 was Rs. 125,047,261/-. As such you have suppressed an amount of Rs.16,468,240/- which attracts action u/s 111(1)(d) of the Income Tax Ordinance, 2001." Accordingly, the Additional Commissioner issued show cause notice u/s 122(9) read with section 122(5A) of the Ordinance requiring explanation of the appellant. Reply submitted by the appellant was found unsatisfactory. Therefore, the Additional CIR amended the assessment in the following manner:- Income declared for tax year 2013 ------------ 50,601,631/- Addition u/s 111(1)(d) of the Income Tax Ordinance, 2001 ---------- 16,468,240/- Addition u/s 67 of the Income Tax Ordinance, 2001-----------11,484,763/- Total income ---------------- 78,554,634/- Less WWF @ 2% ------------- 1,571,092/- Balance -------------- 76,983,542/- Less WPPF -------------- 4,721,771/- Balance taxable income -------------- 72,261,771/- 3. Being aggrieved the taxpayer filed appeal before the learned CIR(A) on the following grounds:- i. The…

Deprecated: trim(): Passing null to parameter #1 ($string) of type string is deprecated in /home/digixyei/sldsystempk.com/view/master-layout/view_case.php on line 492