Law: Income Tax Ordinance, 2001

Section: 111,120(1),122,122(5),122(9),122(1)(4),1 74,177,177(6),177(10),236M

Law: Income Tax Rules, 2002

Section: 5(a),5(d)

INCOME TAX ORDINANCE, 2001 (XLIX OF 2001)---Sections: 111, 120(1), 121, 122, 122(5), 122(9), 122(1)(4), 174, 177, 177(6), 177(10), 236M - Income Tax Rules: 2002, Rule: 5(a) to 5(d) - Unexplained income or assets - Assessments - Amendment of assessments - Audit - Selection of case for audit by the Commissioner of Inland Revenue in terms of Section 177 of the Ordinance - Show Cause Notice issued u/s 122(9) and amendment order issued u/s 122(5) — Adverse Inferences were drawn by the Taxpayer which were assailed before CIR(A),. who accorded partial relief - Challenge to - (i) Ground of appeal No. 2 - Additions not confronted in the Audit Report. (ii) Ground No. 3 - Bonus income u/s 236M of Ordinance, (iii) Ground No. 4 - Additions u/s 111 of the Ordinance. (iv) Ground of Appeal No. 5 - Additions u/s 111 of the Ordinance. (v) Grounds of Appeal No. 6,7 - Additions u/s 174 of the Ordinance. FACTS Briefly, the relevant facts are that the appellant Hied return of income for tax year 2017, which constituted deemed assessment u/s 120(1) of the Ordinance. Subsequently, the appellants case was selected for audit by the concerned Commissioner Inland Revenue in terms of section 177 of the Ordinance on 30-03-2018. The audit report was issued on 12-10- 2018 and, after obtaining appellants explanations thereon, the show-cause notice was issued on 07-12-2018, which finally culminated into amendment order under section 122(5) of the Ordinance on 31-12-2018 from which adverse inferences were drawn against the treatment meted out by the taxpayer which were assailed before the learned first appellate authority who, vide impugned order accorded partial relief to the taxpayer. Through this appeal the taxpayer challenges the order of the first appellate authority to the extent the amendment order has been upheld on the grounds furnished with the appeal memo. It is an undisputed fact that some additions in taxable income were not confronted to appellant company in the form of the audit report issued on 12-10-2018, after conclusion of audit. However additions in respect of these issues were made vide amendment order dated 31-12- 2018 after confronting the same. When the said legal…

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