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Inland Revenue Appellate Tribunal 2022 Income Tax Ordinance, 2001

2022 PTD 1895

Conducting of audit proceeding is just a process
THE COMMISSIONER INLAND REVENUE, ZONE-I, RTO-II, KARACHI
Appellant
VS
M/S. A.O. CLINIC, KARACHI
Respondent

Case Laws / Head Notes / Paras

Audit Amendment of assessment. Procedure. Scope selection for audit or even conducting and audit does not mean modification of assessment. Selection for audit and thereafter conducting of audit proceeding is just a process. Assessing officer, before invoking the provisions of S.122, Income Tax Ordinance, 2001, has to frame charge sheet/audit observation/audit report and the same ought to be communicated to the taxpayer for rebuttal and the explanation/reply/assertion/contention/objection of taxpayer must be obtained and considered. Assessment order can only be amended by acquiring jurisdiction and fulfilling all the requirements of subsections (1) and (5) of S. 122, Income Tax Ordinance, 2001. Mere (firstly) issuance of notice under S.122(9), Income Tax Ordinance, 2001, read with S.122(1),...