Law: Income Tax Ordinance, 2001

Section: 21,21(a),21(c),29,32,39(3),39(4),67,111( 1),111(1)(a),111(1)(b),113(2)(c),120,122 ,122(5A),153,153(2),177,Clause(45)(b) ofPartIVtotheSecond Schedule

Law: Customs Act, 1969

Section: 139

Law: Income Tax Rules, 2001

Section: 13

Law: Income Tax Ordinance, 1979

Section: 34,35,65,66A,80C,80D

(a) Income Tax Ordinance (XLIX of 2001)-- --S. 122(5-A)--Amendment of assessment--Mandatory requirements were that there should be some illegality in the existing order, and apparent loss of revenue must exist to proceed under S.122(5-A) of Income Tax Ordinance, 2001--Enquiry had to be in accordance with two requirements and sense of enquiry would not be in respect of calling of information--First show-cause notice was defective having no definite material to establish the co-existence of erroneousness and prejudice--Assessing authority, had asked for documents I record and showed its intention or the estimation of bifurcating or apportioning the "Normal Tax Regime" or "Final Tax Regime" expenditures, disallowing the expenses on his volition--Said action was based on assumption, which was not allowable in proceedings under S. 122(5-A) of Income Tax Ordinance, 2001--Such action of Assessing Officer was ab initio illegal as there was no proper basis for invoking provisions of S.122(5-A) of Income Tax Ordinance, 2001--Amended assessment order as well as the order of appellate authority below, was cancelled, in circumstances. (2016) 113 Tax 53 (Trib.) and 2014 PTD (Trib.) 1101 rel. (b) Income Tax Ordinance (XLIX of 2001)-- --S. 32--Method of accounting "Double-entry accounting System "-- Scope--Taxpayer used "double-entry accounting system", which was based on the accounting equation and required that every business transaction be recorded in at least two accounts; in addition, it required that the total debts recorded for each transaction equal the total credits recorded--Double-entry accounting system also had specific rules of debt and credit for recording transactions in the accounts--Foreign trade debts, were advance receipts of the future revenues and were receivable in the financial year--Receivables were usually a significant portion of the total current assets--Receivable was recorded as a debt to accounts receivable--All receivables that were expected to be realized in cash within a year or more, were reported in the current assets section of the balance sheet--Current assets were normally reported in the order of their liquidity beginning with cash and…

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