JUDGMENT

This Reference Application in terms of Section 133 of the Income Tax Ordinance, 2001 (hereinafter referred to as "Ordinance") originates from the order dated 22nd of October, 2024, whereby Commissioner Inland Revenue (Appeals-I), Islamabad (hereinafter referred to as "Commissioner") proceeded to allow the appeal preferred by the respondent No.1 (hereinafter referred to as "respondent") and annul the order dated 24th of June, 2023, passed by the Assistant/Deputy Commissioner, Inland Revenue, Unit VI, Range-II, Cantt Zone, RTO Rawalpindi.2. Facts, in brief, necessary for setting at rest the question canvassed in this reference application are that proceeding were initiated by the applicant-department on the basis of definite information in possession of the Assessing Officer that therespondenthad purchased immovable properties amounting to Rs.33,000,000/- and declared taxable income as Rs.1,253,475/-, which needs verification. Accordingly, a show cause notice under Section 122(9) read wi...