Summary: (a) Income Tax Ordinance, 2001----S. 124---Effect of appellate order---Remand for re-examination of specified facts---Scope---Assessing officer, after remand by Commissioner Inland Revenue (Appeals), made an addition of Rs.1,247,002,763 towards amount payable to related parties while invoking S. 20(1), on grounds not disclosed in the earlier show-cause notice---Commissioner (Appeals) had set aside the addition and remanded the matter only to re-examine whether the expenses claimed had been added to taxable income of the respondent during a subsequent year under S. 34(5) and, if such amount had been offered for taxation, directed that no disallowance could be made in the current year---Held, that once a matter or issue is remanded by the Commissioner (Appeals) for re-examination of certain facts only, the assessing officer is bound by such directions and cannot go beyond the mandate given in the appellate order, particularly while giving effect to such order under S. 124---Appellate proceedings are continuation of original proceedings; the original order merges into the appellate order, and the assessing officer is bound to give effect to the appellate order in its letter and spirit, without creating fresh grounds other than those disclosed in the show-cause notice issued under original assessment proceedings---S. 124 was not to be misconstrued with proceedings after remand for de novo assessment under S. 122(5A)---Explanation of the respondent that the unpaid amount had been offered to tax under S. 34(5) in Tax Year 2016, and that a portion pertained to sale of imported hardware taxable under the final tax regime and was never claimed as an expense, was in line with the order of the Commissioner (Appeals) and had been satisfactorily explained---Assessing officer did not assign valid reasons for not accepting that explanation. (b) Income Tax Ordinance, 2001----Ss. 124 & 122(5A)---Reference jurisdiction---Findings of fact of Appellate Tribunal Inland Revenue---Scope---Matter primarily related to findings of fact recorded by the Appellate Tribunal Inland Revenue, duly approved by the High Court---Finding of facts recorded by the Tribunal, unless found to be perverse or contrary to the record, cannot be disturbed by the High Court while exercising reference jurisdiction or even by the Supreme Court---Legal position relating to scope of S. 124 had been rightly interpreted by the Tribunal and the High Court, and no exception could be drawn---Counsel for the department failed to establish that the concurrent finding of facts was either perverse or contrary to the record. Disposition: Civil petitions dismissed in limine and leave refused. (C.P.L.A. Nos.534 and 535 of 2026, Supreme Court of Pakistan, order dated 15.10.2026; Munib Akhtar and Aqeel Ahmed Abbasi, JJ. Approved for reporting.)