| Citation(s) |
|---|
| 2026 SLG 1242 2026 SLD 1242 |
I.T.R. no.84/2017
Presented By: (Sardar Ejaz Ishaq Khan) Judge (Babar Sattar) Judge
12.03.2026 Hafiz Muhammad Idris and Syed Farid Bukhari, advocates for the applicant Mr. Riaz Hussain Azam Bopera, advocate for respondents
Pak China Investment Company Limited
VERSUS
Commissioner Inland Revenue, and others
Law: Income Tax Ordinance, 2001
Section:
Law: Banking Companies Ordinance, 1962
Section:
Summary
The High Court partly disposed of the tax reference arising from the Appellate Tribunal Inland Revenue order dated 27.09.2017.
It held that questions already decided in earlier proceedings (STR No. 12/2016) required no fresh adjudication and were remanded to the Assessing Officer for implementation in accordance with that judgment. However, on the main issue, the Court upheld the Tribunal’s finding that certain financial institutions (Khushhali Bank, Tameer Microfinance Bank, Pak Brunei Investment Company, and HBFC) were not “banking companies” under the Income Tax Ordinance, 2001 read with the Banking Companies Ordinance, 1962.
Consequently, withholding tax was held to be correctly applicable, and the reference was decided in favour of the tax department.