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ORDER MR. MASOOD AKHTAR SHAHEEDI, Accountant Member: Through the titled appeals two separate orders have been challenged at the instance of the department. The first appeal order No. 29, 30 dated 30.04.2013 Lahore, pertaining to tax years 2007 & 2009, has been challenged on common grounds i.e. deletion of addition under the heads "leased assets" and "financial charges"; whereas order No. 03 dated 03.10.2014, pertaining to tax year 2010, has been challenged the deletion of additions under the heads "Advances received from Government of Punjab", "Gratuity" and "Interest income". The same are disposed off through this consolidated order. ITA Nos. 908 & 909/LB/2013: Leased Assets: 2. The learned DR has vehemently opposed the impugned order and supported the assessment order. On the other hand, the learned AR has supported the order passed the learned first appellate authority. He submitted that by using the words "it seems" the Additional Commissioner had confirmed that he was not certain about any erroneousness or prejudice to the interest of revenue and he had been conducting fishing inquiries. Therefore, the CIR(A) has rightly deleted the addition. 3. After hearing the arguments of both the learned representatives of the parties and perusing the record we are of the considered opinion that the learned CIR(A) was justified in deleting the addition under the head "leased assets" because no addition can be made without necessary show cause notice. The action of the CIR(A) being reasonable is hereby upheld. The departmental appeal on this issue is dismissed being without merit. Financial Charges: 4. The DR has strongly opposed the impugned order and supported the assessment order for the reasons recorded therein. The learned AR naturally supported the impugned order. He termed the treatment given by the Addl. Commissioner by submitting that he had used words "it appears that no interest is charged on amounts given to directors". The AR pointed out that all the loans were made out of taxpayer's own funds which position was accepted for tax year 2008. He claimed that all the loans were made from taxpayer's own funds the disallowance made was against the ratio…

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