2012 PTD 565

Case Laws / Head Notes / Paras

---Audit---Completion of proceedings---Limitation---Reason-able time---Protracted audit proceedings commenced on 29-6-2007 and concluded on 14-6-2011---Assessment proceedings were required by law to be completed within a "reasonable time'---Federal Board of Revenue had directed that assessment proceedings be finalized within a reasonable time, preferably within three hearings and not more than three notices be issued---Proceedings could not be allowed to be spread out over years with a gap of almost a full year during which time only a single notice was issued by the Department---To keep the taxpayer guessing as to his fate in the audit with no closure in sight was tantamount to maladministration---Protracted delay in bringing judicial proceedings to a close within a reasonable time would ...