MUSTAFA AKHUND vs DCIR, ZONE AEOI, UNIT-4, RANGE-B Ss — 2025 PTD 1264 INLAND REVENUE APPELLATE TRIBUNAL OF PAK

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MUSTAFA AKHUND VS DCIR, ZONE AEOI, UNIT-4, RANGE-B Ss. 111, 116(2), 122 & 122-a---Wealth statement---Concealment of amount in foreign bank account---addition made, assailing of---Submission of the appellant /taxpayer is that after issuance of notice by the Department, it was requested to allow the appellant to revise his wealth statement but same was not considered---Held, that wealth statement cannot be revised after the expiry of five years from the due date of filing of return of income for that tax year, or after issuance of notice the return or wealth statement cannot be revised, therefore, the action of Department is right---appeal, filed by taxpayer, was disposed of. Ss. 111, 116(2), 122 & 176(4)---Wealth statement---Concealment of amount in foreign bank account---Addition made, assailing of---Plea of the appellant (individual taxpayer) is that his late father was a distinguished bureaucrat who, after his stint with the government, served for numerous years in foreign institutions (like Asian Development Bank), however, his father's foreign bank account was revealed to him (appellant) pretty late---Validity---Before the lower forum, appellant statedly failed to produce the relevant documents to substantiate his version with evidence to describe the source and nature of investment in the said bank but before this Appellate Tribunal, the taxpayer has furnished the copies of bank statement of foreign account maintained by his deceased father and other substantial documents, however, to ascertain veracity of its genuineness, it must be scrutinized at the assessment stage to reach at just and fair conclusion---Appellate Tribunal set-aside the impugned order and remanded the case for de novo consideration after providing proper opportunity of hearing to the parties---Appeal was disposed of accordingly. Ss. 111, 116(2), 122 & 176(4)---Wealth statement---Concealment of amount in foreign bank account---Addition made, assailing of---Ground taken by the appellant is that no separate notice under S. 111 of the Income Tax Ordinance, 2001, was issued before making addition---Held, that as only one issue is involved i.e. addition, therefore, independent notice under S. 111 was not required---Appeal, filed by taxpayer, was disposed of.

MUSTAFA AKHUND vs DCIR, ZONE AEOI, UNIT-4, RANGE-B Ss — 2025 PTD 1264 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN

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