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ORDER Nazir Ahmad, (Judicial Member): The titled further appeal filed at the instance of the taxpayer has been directed against the appellate order dated 10.09.2015 recorded by CIR (Appeals-III), Rawalpindi. 2. The facts in brief leading to the instant appeal are that the taxpayer, an individual, deriving income from sanitary store filed return for the year under consideration declaring income at Rs.308,680/-, which was treated to be an assessment order in terms of section 120 of the Income Tax Ordinance, 2001 (hereinafter called 'the Ordinance'). Subsequently, the case was selected for audit. Audit proceedings were initiated by way of issuance of statutory notices including notice u/s 122(9) of the Ordinance requiring the taxpayer to provide certain documents alongwith books of accounts, which were not provided for proper scrutiny of the same. Resultantly, the proceedings culminated in passing of assessment order u/s 121(1)(d) of the Ordinance dated 17.03.2015 wherein total income of the taxpayer was worked out at Rs. 1,768,839/-. Feeling aggrieved, the taxpayer preferred appeal before CIR (Appeals-III), Rawalpindi, which was partially accepted as under:- i) Addition made out of cost of sales @ 50% was restricted to 20%. ii) P&L Add Backs amounting to Rs.57,729/- were confirmed. - Still discontented with the treatment meted out by the first appellate authority, the taxpayer has come up in further appeal before this Tribunal. 3. The learned counsel appearing on behalf of the taxpayer has termed the relief allowed by the first appellate authority in respect of addition made out of cost of sales to be inadequate on the plea that while making addition @ 50%, the taxation officer has disallowed the purchases whereas the sales have been accepted by him. He has criticized that the method adopted by the taxation officer is against the accounting principle as without purchases how the sales can be…

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