PAK LAW GPT — Pakistan Case Law AI justice scale emblemPAK LAW GPTCase law · Urdu & English

COMMISSIONER INLAND REVENUE, LTU, LAHORE vs WORLD CALL TELECOM LTD — 2024 PTD 358 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN

Case information

Citation
2024 PTD 358 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN
Year
2024
Reporter
PTD
Parties
COMMISSIONER INLAND REVENUE, LTU, LAHORE vs WORLD CALL TELECOM LTD
Subject matter
Tax & Customs
Provisions referred to
Income Tax Ordinance

Fields are extracted from the reported citation and judgment text. Where a detail is not stated in the record, it is not shown.

Judgment text as reported

COMMISSIONER INLAND REVENUE, LTU, LAHORE VS WORLD CALL TELECOM LTD. Ss.15, 15-a, 16, 67, 120 & 122(5a)---Income Tax Rules, 2002, R.13---Income from property---allocation of expenses---Scope---Company deriving income from telecom and broadband services---Officer Inland Revenue allocated the taxpayer/company expenses relatable to rental income which order was deleted by the Commissioner (appeal) accepting claim of the taxpayer that properties were rented out in previous years incurring some negligible / immaterial charges not warranting any need to allocate the expenditure to the income---Department assailed order passed by the Commissioner (appeal) before the appellate Tribunal Inland Revenue ('Tribunal')---Validity---according to the Commissioner, allocation of expenses to property income was against the provisions of section of the Income Tax Ordinance, 2001 as well as R. 13 of the Income Tax Rules, 2002---There was no justification in the assessing Officer's stance to allocate expenses from rented property---There was no tangible evidence before the assessing Officer to show that the allocated expenses were specifically incurred from earning income---Tribunal maintained that expenses prorated by the OIR had no relevance with the earning of property income---appeal filed by the Department was dismissed, in circumstances.

Other judgments reported in 2024 PTD

Back to the case-law library · Search Pakistani case law in Urdu or English