Law: Income Tax Ordinance, 2001

Section: 120(1A),121,122(1)(5A),176,177,122(5)

Law: Income Tax Ordinance, 1979

Section: 65(2)

(a) Income Tax Ordinance (XLIX of 2001) ---.--- ---.--- -Ss. 120(1A), 121, 122(1)(5A), 176 & 177 ---.--- Amendment of original (deemed) assessment order ---.--- Scope ---.--- Powers of Commissioner to conduct audit of income tax return ---.--- Scope ---.--- When the Commissioner, Inland Revenue, invoked his powers in order to conduct audit or investigation of the income tax affairs of a person, only then the original (deemed) assessment order come under scrutiny with conscious application of mind ---.--- Commissioner by virtue of and in exercise of the powers contained in Ss. 120 (1A), 121, 122 (1)(5A), 176 & 177 of the Income Tax Ordinance, 2001, could initiate the proceedings for investigating the income tax affairs of a person notwithstanding the fact that such return of income by virtue of S. 120(1) of the Ordinance was taken as an assessment made and assessment order issued by the Commissioner ---.--- Deemed assessment order after its amendment with conscious application of mind lost its legal effect in terms of S. 177(10) of the Ordinance. (b) Income Tax Ordinance (XLIX of 2001) ---.--- ---.--- -S. 122(5) ---.--- Income Tax Ordinance (XXXI of 1979) [since repealed], S. 65(2) ---.--- Amendment of original (deemed) assessment order under the Income Tax Ordinance, 2001 and the (repealed) Income Tax Ordinance, 1979 ---.--- Procedure ---.--- Comparison of the provisions of S. 65(2) of the (repealed) Income Tax Ordinance, 1979 and S. 122(5) of the Income Tax Ordinance, 2001 showed that the procedure prescribed for amending an assessment order under the said two Ordinances was not the same ---.--- Difference between the two procedures stated. Central Insurance Co. v. Central Board of Revenue, Islamabad 1983 SCMR 1232 ref. (c) Income Tax Ordinance (XLIX of 2001) ---.--- ---.--- -Ss. 122(5), 122(8) & 176(1)(a) ---.--- 'Definite information" within the meaning of S. 122(5) of the Income Tax Ordinance, 2001 ---.--- Processing "definite information" through use of a scientific or mathematical formula to determine correct tax liability ---.--- Scope ---.--- For the purpose of determining the correct tax liability, any information falling…