| Citation(s) |
|---|
| 2025 SLG 1868 2025 SLD 1868 |
ITA No. 1634/KB/2024
AUTHOR(S): MR. AIJAZ AHMED KHAN, MEMBER AND MR. SAJJAD AKBAR KHAN, MEMBER
Date of hearing: 20.03.2025. Date of order: 09.05.2025 Applicant by: Mr. Muhammad, ACA.
Respondent by: Mr. Majid Ali, DR.
M/S SHANGHAI ELECTRIC POWER TRANSMISSION & DISTRIBUTION ENGINEERING COMPANY LIMITED, KARACHI......APPELLANT
VS
THE ASSISTANT/DEPUTY COMMISSIONER INLAND REVENUE, ZONE-I, MTO, KARACHI......RESPONDENT Applicant by: Mr. Muhammad, ACA.
Law: Income Tax Ordinance, 2001
Section: 32(2),120,153(1)(b) ,153(1)(c) ,161,161(1),161(1A),176,182(1)(15)205
Law: Sales Tax Act, 1990
Section: 44(4)
SUMMARY:
The appellant, a branch of a Chinese company executing infrastructure works for K-Electric Ltd., challenged an order passed under Sections 161 and 205 of the Income Tax Ordinance,
2001, alleging non-deduction of tax. The order was passed by the ADCIR, Zone-I, MTO, Karachi. The taxpayer contended that it had complied with the withholding tax requirements, and any differences were due to the accrual-based accounting system vis-Ã vis withholding on payment basis. Reconciliations and documentary evidence including audited accounts and withholding statements were submitted during appellate proceedings.