ARGUMENTS

LTO Karachi, MTO Karachi , CTO Karachi submitted comments vide letters dated 24.06.2022 which have been analyzed and common points are discussed in brief. Preliminary objection regarding bar of jurisdiction has been raised as it is contended that the matter pertains to assessment of income , tax liability for which legal remedy is available.On merit, it has been stated that a standard operating procedure is being followed for returns wherein refund adjustment of previous years has been claimed. In cases where refunds were already eliminated in respective Tax Years due to amended assessments, tax demand is being raised under section 221 of the Ordinance. However, tax demand to the extent of self-adjustment of undetermined refund under section 170(4) of the Ordinance is being raised under section 221 of the Ordinance in view of Honble Supreme Court dated 05.03.2020 in civil petitions 283-L to 286-L of 2018 dated 05.03.2020 wherein it was held that refund would be considered determined on...