JUDGMENT

The question of law proposed by the petitioner's counsel is whether the provisions of section 129(1)(a) of the Income Tax Ordinance, 2001 (hereinafter referred to as ‘the Ordinance') permits the Commissioner Inland Revenue Appeals (hereinafter referred to as ‘the Commissioner Appeals') to remand the case, as the mandate of the Commissioner Appeals itself is limited to the extent provided in the aforesaid provisions by way of an amendment brought earlier.2. We have heard the learned counsel for the petitioner and perused the material available on record. The proceedings were initiated by the Additional Commissioner (Audit), Inland Revenue (hereinafter referred to as ‘Assessing Officer'), which culminated into order under section 122(5A) of the Ordinance.3. Respondent being aggrieved of it, filed an appeal before the Commissioner Appeals against the order of the Assessing Officer, which held that the amended assessment order was passed in haste and, consequently, was annulled and t...