The Taxpayertaxpayer in this case is an AOP filed return of income for the tax year 2020, declaring Salessales at Rs. 650,000,000/-. The taxpayer is running a Flourflour mill under the Namename & Stylestyle of M/S INAYAT CHEEMA Flour Mills, Daska Road, Sambrial Distt. Sialkot engaged in the business of the purchase of Wheatwheat and Salethe sale of Flourflour and other different products as a result of Grindinggrinding the Wheatwheat. Notice U/S 161(1) (A) was issued on 9-12-2022 and sent, but never served upon the taxpayer. Later on, reminders were issued U/S 161(1)(A) but never served upon the taxpayer. Ultimately the ex-partee order u/s 161(1) was passed dated 03-05-2023 but served on 15-6-2023. The taxpayer has purchased total wheat amounting to Rs. 627,317,978/- for the tax period 01-07-2019 to 30-06-2020, from exempt sources & all other expenses which are below threshold limit and not subject to deduction of Withholding Tax u/s 153(1)(b) as per SRO 586. In a nutshell, the treatment given by the department to the taxpayer is not only illegal but also against the norms of justice which is liable to be canceled.

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