BEFORE THE COMMISSIONER INLAND REVENUE

(APPEALS-III), RAWALPINDI.

In the matter of appeal of

Mr. Jazib Hussain, Kahuta ,Pakistan .
CNIC # 35404-3763855-9
Tax year 2015

VS

Assistant /Deputy Commissioner (Audit)

Inland Revenue ,,Unit-V,I-Zone City,
RTO Rawalpindi.

Commissioner (Audit)
Inland Revenue ,,Unit-V,I-Zone City,
RTO Rawalpindi.

APPEAL AGAINST ORDER PASSED UNDER SECTION 122(1) OF

THE INCOME TAX ORDINANCE, 2001 .DATED 24TH ,MARCH, 2021.
RECEIVED CERTIFIED TRUE COPIES ON 29TH-JULY-2021’

1. That the order passed by the Learned Assistant / Deputy

Commissioner Inland Revenue (Audit ) ,Unit-V,Range I, Zone-

City, Regional Tax Office, Rawalpindi (hereinafter referred to as

the “A/DCIR”) issued under section 122(1) of the Income Tax

Ordinance, 2001 dated 24th, March, 2021 (hereinafter referred to as

the “impugned order”) in respect of Tax Year 2015 is bad in law and

against the facts of the case.

2. That the order passed by the Learned DCIR is completely non-

speaking as he has failed to give any Opportunity of being heard to

the appellant.The Appellant was condemned unheard .Therefore

Assessment Order U/S 122(1) of the Income Tax Ordinance 2001 is

unjustifiable and illegal.

 3 That the Appellant was not served with any letter by the learned A/

DCIR Intimating him about Selection of his case for Audit U/S 214C

for Tax Year 2015 which is prerequisite initiate an Audit Proceeding .

4. That no notice to call for record/Information U/S 176/177 was

served upon the Appellant for the sake of Audit .Therefore

Assessment Made U/S 122(1) of the ITO 2001 is unjustified and

Illegal.

5. That the DCIR Passing the impugned Order disallowing in arbitrary

manner, the gift declared in return (received from my mother

amounting Rs. 1,050,000/- into the Head of ‘ Other Sources Income”

U/S 39 (3) without knowing real facts of the case or Obtaining any

Definite Information regarding the Transaction is being in violation

of Principle of Natural justice is not sustainable in law.

7. That it is well settled Law , that the limitation starts running from

the date of Service of Notice to the Appellant ,the Appellant received

his true certified copy of impugned order against the payment of

prescribed Fee Rs. 200/ on 29-07-2019. (Chilean is Attached

herewith).

8. That the appellant craves the right to add, amend, modify or delete

any ground(s) of appeal at the time of hearing.

In view of the circumstances narrated above, it is most respectfully

prayed that by allowing the instant appeal, due relief as is admissible

 under the law and warranted by the facts of the case may graciously be

allowed to the appellant.

( Appallant )