Law:

Section:

(a) Income Tax Ordinance (XLIX of 2001)--- ----S.122 (SA)---Amendment of assessment---Profit and loss expenses---Markup/interest recovered by the taxpayer from its associated undertakings against the loans provided to them out of borrowed funds---Addition---Taxpayer contended that finance cost was the net amount of mark up expense after deducting the amount of markup recovered from the associated undertakings---Validity---Taxation of markup income which had already been taxed through adjustment with total mark up would tantamount to double taxation---Perusal of audited accounts showed that profit before taxation had remained the same even showing the gross amount of markup expense and markup income (i.e. markup recovered from associated undertakings)---Inspecting Additional Commissioner had accepted the same treatment/adjustment of markup made by another associated company of the group---Addition made on account of markup income recovered by the taxpayer from associated undertakings was deleted in toto. (b) Income Tax Ordinance (XLIX of 2001)--- ----S.122 (SA)---Amendment of assessment---Profit and loss expenses---Loss on sale of shares of listed companies---Addition---Taxpayer contended that capital loss on disposal of shares of public limited companies claimed under the head "administrative" expenses had been voluntarily added back while computing the taxable income; and loss on sales of share was a capital loss but since the gain from sales of shares was exempt from tax, such loss could not be carried forward and adjusted against any capital gain of the subsequent years; and had rightly been added back as inadmissible expenses that included the loss of shares---Department contended that taxpayer had not disclosed the sale of shares in the audited accounts as normal sale, the addition made was correct and should be maintained---Taxpayer contended that disposal of shares of listed companies was not a normal business sale of the taxpayer rather it was a disposal of asset, the difference between the sale proceeds and cost of such was taken to profit and loss account under head 'administrative expenses', which was voluntarily added back in the accounting profit…

Deprecated: trim(): Passing null to parameter #1 ($string) of type string is deprecated in /home/digixyei/sldsystempk.com/view/master-layout/view_case.php on line 492