Law: Income Tax Ordinance, 2001

Section: 2(12),18(2),32,33,34,80(1)(b),100A

Law: Public Debt, Act, 1944

Section: 29

Law: Income Tax Ordinance, 1979

Section: 17(1)(a),17(1),23(1)(x),24(i),32

(a) Income Tax Ordinance (XXXI of 1979)--- ----S. 17(1)(a)---Expression 'Receivable'---Connotation---Expression 'receivable' cannot be construed as involving actual receipt of income---Under international accounting standards 'receivable' is distinct from actual receipt of income. (b) Interpretation of statutes--- ----Taxing/fiscal statute---Intendment---Court, in case of taxing statute has to look to clear words since there is no question of any intendment---No presumption or equity about tax---Nothing can be read or implied in taxing statute---Statute has to be read as a whole in order to discover legislative intent---Provisions of a fiscal statute are required to be interpreted literally and equity or presumption are alien thereto---If a provision of a taxing statute can have two reasonable explanations, then one which is favourable to taxpayer has to be accepted---Any ambiguity is required to be resolved in favour of taxpayer---Redundancy cannot be attributed to lawmaker---Every word and part of statute has to be given meaning and effect---Presumption is that legislature has used every word in a context and for a purpose---Statute has to be read as a whole and intention of legislature has to be discovered by paying attention to what has been said. (c) Words and phrases--- ----"Entitled"---Defined. Burton's Legal Thesaurus, Fifth Edition; Cambridge Dictionary Tenth Edition; Black's Law Dictionary Ninth Edition; Concise Oxford English Dictionary Twelfth Edition and Words and Phrases Paramount Edition Volume 14B rel. (d) Income Tax Ordinance (XLIX of 2001)--- ----Ss. 2(12), 33, 34, & 80(1)(b)---Banking company---Status---Accounting on cash/accrual basis---Scope---Each individual Bank is a company within meaning of expression 'company' under S.2(12) read with S.80(1)(b) of Income Tax Ordinance, 2001---Mandatory for Banks to account for chargeability to tax under head 'income from business' on accrual basis---Distinction between "accounting on cash basis" or "accrual basis" is explained under Ss. 33 & 34 of Income Tax Ordinance, 2001 respectively which is in consonance with…