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ORDER CH. SHAHID IQBAL DHILLON (JUDICIAL MEMBER). The titled appeal preferred at the instance of the taxpayer is directed against order passed by the learned Commissioner Inland Revenue (Appeals-ll), Lahore dated 14.12.2015. 2. Facts of the case, in brief, are that the return filed by the Taxpayer, an AOP deriving income from running a steel Mills, declaring income at Rs.66,99,704/- was firstly treated as deemed order in terms of Section 120 of the Income Tax Ordinance, 2001. Subsequently, the case was selected for audit u/s 177 of the Ordinance and intimation in this regard was sent to the taxpayer accordingly. Thereafter, the Officer of Inland Revenue (OIR) issued notice u/s 177(1) followed by show cause notice firstly u/s 121(1)(d) and secondly u/s 122(9) of the Ordinance. In response to the said notices, the learned A.R of the taxpayer submitted reply alongwith certain documents which was considered unsatisfactory and consequently order u/s 122(1)/(5) of the Ordinance was passed on 31.07.2015 determining income at Rs.54,18,15,969/-. 3. Being aggrieved, the taxpayer preferred first appeal on the following grounds:- i. That the impugned order is wholly void, unlawful and untenable in the eyes of law having been passed after lapse of period of limitation of 5 years. The taxpayer was subject to law as it stood on 30.06.2009 and not to the law that came into force on 01.07.2009. ii. That the addition u/s 174(2) to the tune of Rs.29,89,09,624/- on account undocumented purchases was unjustified. The Assessing Officer acted in lump-sum manner by disallowing the purchase without making out any specific instances or substituting his allegation with evidence that purchases were liable to be disallowed. iii. That the addition u/s 174(2) on account of manufacturing expenses to the tune of Rs.1,19,42,655/- holding as undocumented was justified without any specific stances or substituted his allegations with evidence that expenditure was inadmissible. iv. That addition u/s 174(2) to the tune of Rs.5,89,20,541/- on adhoc estimate basis on account of P&L Account expenses was unjustified, harsh and arbitrary, thus not maintainable under the law as the Assessing Officer…

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