ORDER

JAWAID MASOOD TAHIR BHATTI (JUDICIAL MEMBER).-The Department through these appeals has objected to the consolidated impugned order of learned C.I.T. (A) dated 2-1.'--2006 for the assessment years 1993-94, 1996-97, 1997-98 and 1998-99 on the following common ground:-"That the learned C.I.T. (Appeals) was not justified in holding that assessment is deemed to have been rectified under the provisions of subsection (3) read with subsection (1) of section 156 of the Repealed Income-Tax Ordinance, 1979, as there was no mistake apparent from record."2. Mr. Fahimul Haq, learned DR, representing the appellant department, has contended that the taxpayer in this case is a non-resident Romania based company deriving income from wet-lease of aircraft given to Messrs Aero Asia International (Pvt.) Ltd. a resident company.3. The assessments for the years under review were completed under section 62 of the Repealed Income-Tax Ordinance, 1979 subjecting the lease rental receipts to tax @ 4%. According t...