JUDGMENT:

MUHAMMAD JUNAID GHAFFAR, JUSTICE:-In all listed cases the moot question in common is that �Whether the subsidy granted by Federal Government to reimburse losses suffered by the tax-payer is a Capital Receipt or a Revenue Receipt�. Besides this, in some of the assessment years, though arguments have been made by the tax-payers Counsel on a subsidiary question; regarding jurisdiction of the Inspecting Additional Commissioner (�IAC�) to revise the original assessment order under Section 66-A of the repealed Income Tax Ordinance, 1979 (�Ordinance�) however, the question(s) proposed do not clearly spell out such objection, and would require its proper rephrasing at the conclusion of this opinion.2. In this case assessment years involved are 1978-1979, 1979- 1980 1980-1981; wherein, the then Income Tax Appellate Tribunal, at Karachi, (�Tribunal�) vide its common Order dated 14.12.1985 was pleased to decide the controversy in favour of the taxpayer and against the department. The department b...