JUDGMENT

The applicant / department has filed instant Reference under Section 133 of Income TaxOrdinance, 2001 (the Ordinance) against the order dated 24.07.2023 passed by Appellate Tribunal Inland Revenue Pakistan Karachi Bench, whereby, appeal filed by the respondent No.1 (Taxpayer) was accepted and the order passed by the Deputy Commissioner Inland Revenue (DCIR) and order of the Commissioner Inland Revenue, appeal was set aside.2. Facts of the case are that the taxpayer had filed return of income for tax year 2018 on30.11.2018, declaring agricultural income at Rs.31,840,200/- as exempt of tax on account of being agricultural income. The deemed income in term of Section 120(1) of the Ordinance was found erroneous/prejudicial to the interest of revenue warranting amendment under Section 122(5A) of the Ordinance, a show-cause notice dated 18.01.2021 under Section 122 (9) of the Ordinance for the tax year 2018 was issued against taxpayer for compliance on 27.01.2021. In response the taxpayer fa...