The Lahore High Court (LHC) has significantly restricted the Federal Board of Revenue's (FBR) authority to amend deemed tax assessments, specifically under Section 122(5A) of the Income Tax Ordinance, 2001. This ruling, reported by ProPakistani and Dawn, emphasizes that the section cannot be used for 'roving or fishing inquiries' or speculative revenue recovery. The judgment arose from a case involving the Commissioner Inland Revenue versus Sajid Hussain Gondal, where the court ruled that the FBR's actions were unlawful. Justice Mirza Viqas Rauf and Justice Jawad Hassan clarified that Section 122(5A) is revisional and can only be invoked when an assessment is both erroneous and prejudicial to revenue. They stressed that mere suspicion or perceived revenue loss does not meet the statutory threshold, stating, 'The revisional jurisdiction under Section 122(5A) is not a licence for roving or fishing inquiries.' The court's decision underscores the need for clear and demonstrable errors to justify revisiting assessments.