Law: Income Tax Ordinance, 2001

Section: 21(c),22,23,23(1),29,34(3),122(5A),100A, 122(5A),129,148,148(1),148(7),156A,169,1 69(2)

Law: Income Tax Rules, 2002

Section: 1(c)6ofSeventhSchedule

INCOME TAX ORDINANCE, 2001 (XLIX OF 2001)---Sections: 21(c), 122(5A) , 129 - Amendment of assessments - Deductions not allowed - Decision in appeal - Disallowance of rent and interest expenses - Upholding addition and deletion of balance addition by CIR(A) - Appeal against - Sections: 21(c), 34(3) , 122(5A), 100A, 122(5A), 129, 148(1), 148(7), 156A, 169 , 169(2) Rule 6 of Seventh Schedule - Amendment of assessments - Tax collected or deducted as a final tax - Banking Company - Imported ATMs, switches, routers and servers - Tax collected u/s 148 - Claim of the Bank for adjustment of amount against normal tax liability denied by the assessing officer and treated the same to be final tax in terms of section 148(7) - treatment meted out by the assessing officer upheld in appeal by the CIR(A) in appeal - Validity - Section: 122(5A) - Amendment of assessments - Additions on account of:- (i) Reversal of provision against NPLs, (ii) Reversal of provision for diminution in value of investment and (iii) Reversal of provision against other assets - Deletion of additions by the appellate authority in appeal, holding that same had already been offered to tax by taxpayer, thus additions resulted into double taxation of the same amount - Challenge to be Department - Sections: 22, 23, 23(1), 122(5A) , 153(1)(c) - Amendment of assessments - initial allowance - Depreciation - Payments for goods, services and contracts - Banking Company - Disallowance of initial allowance on building by the assessing officer - First Appellate Authority held that subject additions made in buildings in the form of newly Constructed / renovated branches duly qualify for deduction u/s 23 - Challenge to - Sections: 29, 122(5A) , Rule 1(c) of the Seventh Schedule of ordinance - Amendment of assessments - Bad debts - Disallowance of adjustment of bad debts by the assessing officer - First appellate authority allowed the deduction - Validity - Appeal against - FACTS The subject cross appeals, preferred by the taxpayer and the department, impugn the appellate order dated 22-11-2017 passed by the learned first appellate authority (hereinafter referred to as the ‘CIR(A)’) under section 129 of the Income Tax…

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