1. SUMMARY OF CASE: In the matter before this Court, Advocate Hamid, the appellant, challenges the assessment order passed by the Deputy Commissioner of Income Tax for the tax year 2025, asserting that the assessment is arbitrary, excessive, and without legal basis. Advocate Hamid contends that the assessment, which includes a deemed income of PKR 50 million and an additional PKR 30 million as "unknown sources of income," is unsupported by evidence and violates the principles of natural justice. Advocate Abbas, the respondent, defends the assessment, arguing that it is legally sound, based on the failure of the appellant to disclose all sources of income and to reconcile company expenses with declared income. 2. EVALUATION OF APPELLANT'S CASE (ADVOCATE HAMID): Advocate Hamid presents a compelling argument that the assessment order lacks legal basis and violates the principles of natural justice. The appellant emphasizes the absence of proper notice and opportunity to be heard, the failure to consider documentary evidence, and the arbitrary addition of income without supporting evidence. Advocate Hamid also references the Supreme Court's precedent in Commissioner of Income Tax v. Syed Ahmad Hussain (2002 SCMR 1954), which underscores the necessity of tangible evidence for ex-parte assessments. 3. EVALUATION OF RESPONDENT'S CASE (ADVOCATE ABBAS): Advocate Abbas argues that the assessment order is justified based on the appellant's failure to disclose all sources of income and to reconcile company expenses with declared income. The respondent highlights the legal provisions under Section 111 of the Income Tax Ordinance, 2001, which shift the burden of proof to the taxpayer in cases of unexplained credits. Advocate Abbas also cites the Supreme Court's holding in Commissioner of Income Tax v. Muhammad Rafiq (2005 SCMR 1254), which supports the respondent's position that the burden of proving the source of income lies with the taxpayer. 4. STATUTORY APPLICATION: The Income Tax Ordinance, 2001, provides the legal framework for assessing income tax. Section 62 allows for ex-parte assessments, but they must be based on available records and established principles of natural justice. Section 111 deems income from undisclosed sources when the burden of proof is upon the taxpayer. Section 170 mandates assessments to be made on the basis of available records. The Supreme Court's precedents in Commissioner of Income Tax v. Syed Ahmad Hussain and Commissioner of Income Tax v. Muhammad Rafiq emphasize the necessity of tangible evidence for assessments and the burden of proof on the taxpayer. 5. FINAL VERDICT & ORDER: The appeal is PARTLY ALLOWED. The Court finds that the Deputy Commissioner of Income Tax erred in adding PKR 30 million as "unknown sources of income" without proper evidence. However, the Court also acknowledges that the Deputy Commissioner acted within the legal framework provided by Section 62 of the Income Tax Ordinance, 2001, and the Supreme Court's precedents. The Court remands the matter back to the Deputy Commissioner for a fresh assessment, ensuring that the appellant is given proper notice and opportunity to be heard, and that the assessment is based on available records and established principles of natural justice. The Court also directs the Deputy Commissioner to provide substantial evidence for the deemed income of PKR 50 million and the additional PKR 30 million. The appeal is PARTLY DISMISSED insofar as the addition of PKR 30 million as "unknown sources of income" is concerned.