Law: Income Tax Ordinance, 2001

Section: 21(c),21(l),21(m),111,111(1)(a),111(1)(d ),122(1),122(9),159,174(2),177,177(1),22 1

ORDER: CH. MUHAMMAD TARIQUE (ACCOUNTANT MEMBER):---.--- These miscellaneous applications, preferred at the behest of the applicant-taxpayer, seek recall/rectification of the ATIR's order passed in the taxpayer appeal bearing ITA No. 992/LB/2023 dated 29.03.2023. Learned counsel appearing on behalf of the taxpayer has sought recalling the said order simply by reiterating the following grounds of the miscellaneous applications, which read as under: "1. That the appellant is small Private Limited Company having NTN No. 2975597-2 and STRN 0801320001937. 2. That the nature of business of appellant is manufacturing of paper cones supplying to various Textile mills in the country. 3. That the return for the period under consideration filed and declared income at Rs 3,200,557/-. 4. That the return of the appellant was selected u/s 177(1) of the Income Tax Ordinance, 2001. 5. That the selection of appellant case for audit u/s 177 by learned of the Income Tax Ordinance, 2001 by Commissioner Inland Revenue, Corporate Zone, RTO, Faisalabad is totally against law and unjustified as no parametric for selection of audit which are basic ingredients for selection of audit u/s 177 are communicated/confronted to the appellant. 6. That the notice u/s 122(9) of the Income Tax Ordinance, 2001 was issued by the Deputy Commissioner Inland Revenue, Faisalabad. Unit-03, Corporate Zone, RTO, Faisalabad. 7. The proper reply along-with documentary evidence to above referred show case notice u/s 122(9) was submitted. 8. That the Officer framed order u/s 122(1) and determined tax recoverable at Rs 21,554,704/- under various heads of accounts. 9. That the appellant filed an appeal before the Commissioner Inland Revenue (Appeal-1), RTO Faisalabad. 10. That the Commissioner Inland Revenue (Appeals-1), RTO, Faisalabad dismissed the appellant's appeal without considering the facts / grounds of appeal of the appellant. 11. That the appellant filed an appeal before the Hon'ble ATIR, Lahore Bench, Lahore as on 14.02.2023 which decided vide ITA No. 992/LB/2023 dated 29.03.2023. The copy Appellate Tribunal Inland Revenue, Lahore Bench, Lahore order received as on 24.05.2023. 12. That the appellant…

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