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ORDER This appeal has been filed by the taxpayer against order dated 11-05-2015 passed by the learned CIR (Appeals-I), Islamabad on the grounds set forth in the memo of appeal. Brief facts of the case are that the taxpayer is a Private Ltd company derives incomes from business of running a flour mill. For the financial year 2009 it filed its return declaring income. The case was selected for audit u/s 177 of the Income Tax Ordinance, 2001. After holding proceedings and issuance of show cause notice Dated 10.03.2015 the assessment has been made at balance income at Rs. 117,439,087/-. In first appeal the learned CIT has remanded the case back for reframing the assessment. However no guideline having been provided, the taxpayer, has come in appeal before this Tribunal. The taxpayers has argued the addition of Rs.310,966,659 u/s 21(L) of I/Tax Ordinance 2001, by firstly referring sections 18, 19 and 20 then referred S.21 which reads as follows:- SEC(21). Deductions not allowed.- Except as otherwise provided in this Ordinance, no deduction shall be allowed in computing the income of a person under the head "Income from Business" for - 21-(L) any expenditure for a transaction, paid or payable under a single account head which, in aggregate, exceeds fifty thousand rupees, made other than by a crossed cheque drawn on a bank or by crossed bank draft or crossed pay order or any other crossed banking instrument showing transfer of amount from the business bank account of the taxpayer: Provided that online transfer of payment from the business account of the payer to the business account of payee as well as payments through credit card shall be treated as transactions through the banking channel, subject to the condition that such transactions are verifiable from the bank statements of the respective payer and the payee: Provided further that this clause shall not apply in the case of- (a) expenditures not exceeding ten thousand rupees; (b) expenditures on account of - (i) utility bills; (ii) freight charges; (iii) travel fare; (iv) postage; and (v) payment of taxes, duties, fee, fines or any other statutory obligation; (vi) any salary paid or payable exceeding fifteen…

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