Law: Income Tax Ordinance, 1979

Section: 65,59(1),59

Income Tax Ordinance (XXXI of 1979)--- ----Ss.65 & 59---Re-opening of assessment---Change of opinion---Valuation of property---Information which was received subsequent to the framing of assessment, was not available at the relevant time and neither any enquiry was made on the point of valuation of property purchased by the assessee nor any occasion arose for conscious application of mind by the Assessing Officer---Issuance of notice under S.65 of the Income Tax Ordinance, 1979 to the assessee, held, was not the result of change of opinion, in circumstances and hence justified. C.I.T. v. Jennings Private School 1993 SCMR 96; M/s. Arafat Woollen Mills Limited v. I.T.O. 1990 SCMR 697; Edulji Dinshaw Limited v. I.T.O. PLD 1990 SC 399 = 1990 PTD 155; M/s. Crescent Art Fabric Ltd. v. CIT 1988 PD 857; Shadman International (Pvt.) Limited v. I.T.O. 1991 PTD 387.; Jaison International (Pvt.) Ltd. v. I.T.O. 1989 PTD 1141; Republic Motors Limited v I.T.O. 1990 PTD 889; Car Tunes v. I.T.O. PLD 1989 Kar. 337; I.T.O. v. Panama (Pvt.) Ltd. (1974) 97 ITR 210; M/s. Ramzan & Sons v. I.T.O. 1991 PTD 503 and 1991 PTD (Trib.) 639 ref. ORDER MUHAMMAD MUJIBULLAH SIDDIQUI, (CHAIRMAN).--- The above appeal at the instance of assessee is directed against the order, dated 22-5-1988 by the learned C.I.T.(A), Zone-IV, Karachi in I.T.A. No.CIT(A)/Z-IV of 1983-84/relating to the assessment year 1983-84. 2. Heard Mr. Arshad Siraj, learned counsel for the appellant and Mr. Misri Ladhai, learned representative for the department. 3. The first objection raised on behalf of the appellant is that the assessing officer was not justified in reopening the assessment under section 65. His contention is that it is a case of mere change of opinion and, therefore, the re-assessment proceedings have been initiated without jurisdiction. 4. The relevant facts as gleaned from the orders of the learned two officers below and the facts narrated by the learned counsel for the appellant are that the appellant is a private limited company which filed return of total income for the assessment year 1983-84 under self-assessment scheme in accordance with Circular No.8, dated June 26, 1983 containing…

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