Appellate Tribunal Inland Revenue
2025
THLN 858
2025 PTD 1264
Laws Cited
Income Tax Ordinance, 2001
Sections
111, 116(2), 122 & 176(4), 122A,

MUSTAFA AKHUND

VS

DCIR, ZONE AEOI, UNIT-4, RANGE-B

Petitioner(s) by: Faiz Ahmed for Applicant.
Respondent(s) by: Imran Falak Sher,
Present: Aijaz Ahmed Khan and Fakhar-ul-Zaman Akhtar, Members
ORDER

Above captioned appeal has been filed by the appellant/taxpayer against the impugned order dated 29.06.2024, passed by the Deputy Commissioner-IR, Zone AEOI, Unit-4, Range-B. Karachi, on the following grounds:-"1) That the Order of the learned DCIR is bad in law and on facts.2) That the Order of learned DCIR is illegal, ultra vires, void and without any justification.3) That the learned DCIR had, without considering the various documents filed by the AR of the taxpayer went on to erroneously hold in paragraph 4 of the impugned order "that the taxpayer failed to prove any explanation or money trail of the foreign asset in light of documentary evidence".4) That the impugned order is riddled with contradictory statements as on the one hand it reflects acknowledgment of the fact that the source of the concerned asset emanated from the investment made by the late father of the taxpayer during his employment abroad. However, the connections to the confronted bank account to the aforementione...