66. Limitation for assessment in certain cases.-

(1)   Notwithstanding anything contained in section 64 and sub-section (3) of section 65 where in consequence of, or to give effect to, any finding or direction contained in any order made under this Chapter or Chapter VIII, XIII or XIV or any order made by any High Court or the Supreme Court of Pakistan in exercise of its original or appellate jurisdiction,-

(a)    an assessment is to be made on any firm or a partner of any firm; or

(b)    an assessment is to be made on the assessee or any other person; or

(c)    an assessment has been set aside, in full or in part, by an order under section 132 or section 135 and no appeal is filed under section 134 against such order or no appeal filed under section 136 in respect thereof, as the case may be,

such assessment may be made at any time within two years in any case to which clause (a) or clause (b) applies, and within one year in any case to which clause (c) applies, from the end of the financial year in which such order is received by the Deputy Commissioner.

(2)   Where, by any such order, as is referred to in sub-section (1), any income is excluded-

(i)     from the total Income of the assessee for any year and held to be the income of another year;

(ii)    from the total income of one person and held to be the income of another persons,

the assessment of such income as income of another income year or of another person, as the case may be, shall, for the purposes of the said subsection, be deemed to be an assessment made in consequence of, or to give effect to, a finding or direction contained in such order.

(3)   Notwithstanding anything contained in this Ordinance, where the ownership of any property the income from which is chargeable under this Ordinance is in dispute in any Civil Court in Pakistan, the assessment on any person in respect of such income may be made at any time within one year of the end of the financial year in which the decision of such Court is brought, or otherwise comes, to the notice of the Deputy Commissioner.

66A. Powers of Inspecting Additional Commissioner to revise Deputy Commissioner's order.-

(1)   The Inspecting Additional Commissioner may call for and examine the record of any proceedings under this Ordinance, and if he considers that any order passed therein by the Deputy Commissioner is erroneous in so far as it is prejudicial to the interests of revenue, he may, after giving the assessee an opportunity of being heard and after making, or causing to be made, such enquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment to be made.

(1A) The provisions of sub-section (1) shall, in like manner, apply,-

(a)   where an appeal has been filed under sections 129, 134 and 137, or an appeal has been filed under section 136, against an order passed by the Deputy Commissioner; and

(b)   where an appeal referred to in clause (a) has been decided, in respect of any point or issue which was not the subject matter of such appeal.

(2)   No order under sub-section (1) shall be made after the expiry of four years from the date of the order sought to be revised.

Explanation.-For the purpose of this section, an order prejudicial to the interests of revenue shall include an order passed without lawful jurisdiction.