JUDGMENT:

RAHEEL KAMRAN, JUSTICE:---In this reference application under Section 133(1) of the Income Tax Ordinance, 2001 (�Ordinance�), the following questions of law have been proposed for our opinion which are asserted to have arisen from the order dated 06.04.2022 passed by the Appellate Tribunal Inland Revenue, Multan Bench, Multan (�Tribunal�) in I.T.A. No. 150/MB of 2022:-1. Whether the Appellate Tribunal has erred in law to cancel the orders of authorities below by holding that issuance of audit report and its confrontation to the appellant is mandatory without appreciating that audit proceedings in this case were initiated before substitution of subsection (6) and insertion of subsection (6A) in section 177 of the Income Tax Ordinance, 2001 through Finance Act, 2019?�2. Whether on the facts and circumstances of the case the Appellate Tribunal was justified to ignore that for tax year 2017 the issuance of audit report was not required by law as the provisions of subsection (6) and subsect...