Law:

Section:

(a) Income-tax Act (XI of 1922)--- Ss. 10(3-A), (3-B), 10(2) (iv), 10(5) & 13-Assessment--Cost to asses­see-Question involves determination of two questions, firstly, system of accounting regularly adopted by assessee, and secondly, in case of system of accounting being mercantile as to when right .to receive accrued or liability to pay incurred--Liability apportioned to building purchased by assessee, no part of which found tainted with fraud, collusion, inflation, or deflation, being incurred during assessment year in question, held, to be accepted as I-ability incurred irrespective of fact whether whole of it paid during such assessment year or not. Commissioner of Income-tax and Sint. Singari Bai (1945) 13 I T R 225; Cor­poration of Birmingham v. Barnes 19 Tax Cae. 195; C. I. T. v. Poona Electric Supply Co. Ltd. (1946) 14 I T R 622; Cape Brandy Syndicate v. Inland Revenue Commissioner (1921) 1 K B 64; Muhammad Saddiq and 2 others v. Chief Settlement c& Rehabilitation Commissioner and 3 others P L D 1965 S C 123; Haji Ghulam Hussain v. Hamid Hassan Khan and another P L D 1969 Lah. 147; Calcutta .Coal Co. Ltd. v. Commissioner of Income-tax (1959) 37 I T R 1 and Commissioner of Income-tax, Gujrat v. Hides & Leather Products Pvt. Ltd. (1975) 101 1 T R 61 ref. (b) Income-tax Act (XI of 1922)- --- Interpretation of statutes by reference to interpretation of analogous provisions in such legislation in foreign countries.-[Interpretation of statutes]. _ Not much help can be directly obtained in construing a particular provision of Pakistan Income-tax Act, by reference to interpretation of similar, or analogous provisions, in income-tax legislation in England or India. However, on analogous provisions, fundamental concepts and general principles, unaffected by the specialties of either, the authorities may be helpful as guides. North Central Wagon Co. Ltd. v. Fifield (1953) All E R 1009 ref. (c) Income-tax Act (XI of 1922)- Link 1 -- S. 10(3-A)-Cost to assessee, computation of-Assessment of liability-Payment through compensation books-Depreciation allow­ance-Difference in nominal value of compensation book and price paid by assessee for obtaining it-Held, to be…

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