Law: Income Tax Ordinance, 1979

Section: 66A,62

Income Tax Ordinance (XXXI of 1979)----S. 66-A---Powers of Inspecting Additional Commissioner to revise Deputy Commissioners order ---Limitation---Assessee had contended that assessment orders were made on 4-5-1994 and 29-6-1996 respectively and notice under S.66-A of the Income Tax Ordinance, 1979 was issued on 20-6-2002 and orders passed thereafter were barred by limitation as no action under S.66-A of the Income Tax Ordinance, 1979 could be taken in respect of an order made more than four years prior to its proposed revision---Department pleaded that original assessment orders were subject-matter of appeal and appeal effected the orders of First Appellate Authority even on 30-6-1998 and therefore, Inspecting Additional Commissioners order were not hit by limitation ---Validity--¬Mistake allegedly made by the Assessing Officer was never a subject ¬matter of appeal before First Appellate Authority and limitation, in circumstances, had to start from the date of original assessment under S.62 of the Income Tax Ordinance, 1979---Original assessment orders to which the issues involved were the subject-matter of mistake, if any, having been made on 4-5-1994 and 29-6-1996 could not be revised beyond four years from these dates as had been done by the Inspecting Additional Commissioner vide his undated orders passed consequent upon his notice, dated 20-6-2003---Orders having been made beyond limitation were not maintainable in the eye of law and were cancelled by the Appellate Tribunal---Original assessments flamed under S.62 of the Income Tax Ordinance, 1979 and modified in appeals stood restored. (1999) 79 Tax 273 (Trib.); (2000) 78 Tax 230 (Trib.); I.T.As. Nos. 78 and 79/KB of 1998-99; 2002 PTD 570 and 2000 PTD 207 ref. ORDER MUHAMMAD AKHTAR NAZAR MIAN (ACCOUNTANT MEMBER).---These two appeals by the appellants company are directed against orders math by the learned IAC for the assessment years 1992-93 and 1993-94 under section 66A of the Income Tax Ordinance, 1979 (hereinafter called the Ordinance). Both the learned representatives have been heard and the orders of the authorities below perused. 2. The facts so far as relevant for disposal of these appeals are…

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