TAX YEAR 2016

GROUNDS OF APPEAL
UNDER SECTION 127 AGAINST ORDER ISSUED U/S 122(5A)
OF THE INCOME TAX ORDINANCE, 2001

1. That the order passed by the learned Additional Commissioner Inland Revenue Range
01, Zone-06 (Add. CIR) u/s 122(5A) is bad in law and against the facts of the case.

2. That the proceedings initiated by the learned Add. CIR u/s 122(5A) was based on
assumption and surmises and tantamounts to fishy and roving inquiry, which is beyond
the mandate of section 122(5A) and without jurisdiction, hence order passed is
erroneous, illegal and liable to be annulled.

3. Without prejudice to ground no. 2 above, that the learned Add. CIR failed to adjudicate
on our legal objection raised on the application of section 21(l) of the Ordinance,
therefore; the order passed by the learned Add. CIR is not a speaking order, hence;
erroneous, illegal and need to be annulled.

4. Without prejudice to ground no. 2 and 3 above, that the disallowance of cash withdrawal
from bank u/s 21(l) is not warranted under law, hence the Add. CIR miserably failed to
understand the spirit of section 21(l), therefore addition made is erroneous, illegal and
against the true spirit of section 21(l), hence liable to be annulled.

5. Without prejudice to ground no. 2, 3 and 4 above, that the learned ACIR issued show
cause notice in a summary manner without confronting the specific
transaction(s), hence beyond the mandate of section 21(l), therefore addition
made is erroneous, illegal and needs to be annulled as held in a similar cases of
ATIR cited as (2013) 108 TAX 35 and 2010 PTD 96 and High Court case cited as
1984 PTD 218.

6. That the appellant craves permission to alter, amend and to add any new ground
of appeal at the time of hearing

7. That the relief, as found due, may kindly be allowed to the appellant.

APPELLANT
 TAX YEAR 2016

GROUNDS OF APPEAL
UNDER SECTION 127 AGAINST ORDER ISSUED U/S 122(5A)
OF THE INCOME TAX ORDINANCE, 2001

1. That the order passed by the learned Additional Commissioner Inland Revenue Range
01, Zone-06 (Add. CIR) u/s 122(5A) is bad in law and against the facts of the case.

2. That the proceedings initiated by the learned Add. CIR u/s 122(5A) was based on
assumption and surmises and tantamounts to fishy and roving inquiry, which is beyond
the mandate of section 122(5A) and without jurisdiction, hence order passed is
erroneous, illegal and liable to be annulled.

3. Without prejudice to ground no. 2 above, that the learned Add. CIR failed to adjudicate
on our legal objection raised on the application of section 21(l) of the Ordinance,
therefore; the order passed by the learned Add. CIR is not a speaking order, hence;
erroneous, illegal and need to be annulled.

4. Without prejudice to ground no. 2 and 3 above, that the disallowance of cash withdrawal
from bank u/s 21(l) is not warranted under law, hence the Add. CIR miserably failed to
understand the spirit of section 21(l), therefore addition made is erroneous, illegal and
against the true spirit of section 21(l), hence liable to be annulled.

5. Without prejudice to ground no. 2, 3 and 4 above, that the learned ACIR issued show
cause notice in a summary manner without confronting the specific
transaction(s), hence beyond the mandate of section 21(l), therefore addition
made is erroneous, illegal and needs to be annulled as held in a similar cases of
ATIR cited as (2013) 108 TAX 35 and 2010 PTD 96 and High Court case cited as
1984 PTD 218.

6. That the appellant craves permission to alter, amend and to add any new ground
of appeal at the time of hearing

7. That the relief, as found due, may kindly be allowed to the appellant.