Law: Income Tax Ordinance, 2001

Section: 20,20(1),21(a),24,24(3),24(11),32(1),34( 1),34(3),34(11),71,71(2),120,121,122(4)( a),122(5A).133,134(A),177,Clause(102A) ofpartI of Second Schedule

INCOME TAX ORDINANCE, 2001 (XLIX OF 2001) Sections: 20, 20(1), 21(a), 24, 24(3), 24(11), 32(1), 34(1X3), 34(3), 34(11), 71, 71(2), 120, 121, 122(4)(a), 122(5A).133, 134(A) 177 - Clause (102A) of part I of Second Schedule - Pakistan Telecommunication (Re-organization) Act, 1996, Sections: 33(A), 33(B), 57(2)(a)(b) - Universal Service funds Rules, 2006. Rule 10 - SRO No. 390(1)/2001, dated 18.06.2001 - Amendment of assessments - Assessments - Intangible - Alternate dispute resolution - Deductions in computing income chargeable under the head "Income" from business - Deductions not allowed - Method of accounting, accrual basis accounting - Currency conversion - Audit - Submission of Income Tax returns by the applicant - Income declared by applicant found erroneous - Show Cause Notice - Selection of case for audit - Issuance of Show Cause Notice pursuant to submission of reply by applicant - Amendment of assessment by the ACIR - Additions made to fixed assets, activation tax. advertisement expenses and interconnect costs - Appeals filed before CIR(A) and Appellate Tribunal dismissed - Reference to High Court - FACTS Brief and consolidated facts are that M/s Telenor Pakistan (Pvt.) Ltd./applicant submitted its income tax returns for the years 2006, 2008. 2013, 2014 2015, which are treated as assessment orders of Commissioner Inland Revenue (CIR), Islamabad under section 120 of the Income Tax Ordinance, 2001. against which show cause notices have been issued to the applicant alleging therein that the income declared by the applicant is erroneous. Likewise, when the applicant returned losses for the years 2006 and 2008, applicant's case was selected for audit under section 177 of the Ordinance, which ultimately culminated into issuance of show cause notice to the applicant. Pursuant to submission of reply by applicant to the show cause notice, Additional Commissioner Inland Revenue. Islamabad amended the assessment of applicant by making certain additions on various grounds, as such, to the extent of losses returned by the applicant, issues relating to addition to fixed assets, activation tax, advertisement expenses and interconnect costs were decided against the…

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