ORDER

The titled appeal filed by the taxpayer is directed against the appellate order dated 07-04-2023 passed by Commissioner Inland Revenue (Appeals-VIII), Lahore.2. Brief facts of the case are that the appellant taxpayer was registered in Pakistan on 6th April, 2011 under the Societies Registration Act XXI of 1860 as a non-profit-organization ("NPO"). The primary function of the Foundation is to relieve suffering caused by natural disasters, to save lives and protect livelihoods, to reduce chronic hunger and to establish centres for providing food and shelters to the disabled and poor people with suitable training to enable them to stand on their own, financially and economically. Tax return for the year in question was filed, declaring a surplus of Rs.695,221. The learned assessing officer, initiated proceedings based on definite information in terms of Section 122(8) of the Income Tax Ordinance, 2001 ("the Ordinance"). A show cause notice was issued on 14.05.2022 under Section 122(9) rea...