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Federal Tax Ombudsman 2012 Income Tax Ordinance (XLIX of 2001)--- ----S.177

2012 PTD 565

Audit---Change of stance during the audit
MUSSADAQ FARHAN CHUGHTAI through Muhammad Ibrahim Chughtai
Appellant
VS
SECRETARY, REVENUE DIVISION, ISLAMABAD
Respondent

Case Laws / Head Notes / Paras

---Audit---Change of stance during the audit---Department, during the audit, shifted its stance and held that the taxpayer had no legitimate resources to finance the purchase of properties---Validity---When Department decided to conduct audit on different lines than what was conveyed to the taxpayer initially, the earlier proceedings should have been first concluded and then a fresh notice issued for the conduct of audit to investigate the taxpayer's sources of investment only---Failure to do so betrayed professional incompetence.