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Inland Revenue Appellate Tribunal 2021 Income Tax Ordinance of 2001

2021 PTD 1223

Unexplained income or assets
MUHAMMAD YOUNAS
Appellant
VS
THE COMMISSIONER INLAND REVENUE, SIALKOT
Respondent

Case Laws / Head Notes / Paras

Amendment of assessments---Mandatory show-cause notice and opportunity for taxpayer to file reply to same---Credit entries in Bank accounts(s) of taxpayer---Computation of “net income’ / “total income” chargeable to tax---Obligation of Departmental officer to issue notice to taxpayer under S.122(5) of Income Tax Ordinance, 2001 specifying relevant clause of S.122(5) sought to be invoked with clarity---Scope---Section 111(1)(d) of Income Tax Ordinance, 2001 did not warrant taxation of whole of the credit entries/ deposits in a Bank account maintained by taxpayer by treating same to be “net income” chargeable to taxpayer; and only such part of total Bank deposits was chargeable to tax which could be termed as “total income”---Such credit entrie...