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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

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.30, 113, 120 & 122(5a)---Income from other sources---Dividend---allocation of expenses---Scope---Company deriving income from telecom and broadband services---If the assesse incurs any expenditure for earning of dividend, such expenditure shall be allocated from the dividend income---as a matter of principle only the actual expenses are to be allocated---There is no scope for any estimate of expenditure being made and no notional expenditure can be allocated also for the purpose of earning income unless the facts of the particular case warrant such allocation---Only the actual expenses should be taken into account in reducing the dividend income and not any notional expenditure as has been done in the present case---assessing Officer did not bring on record any evidence with regard to actual expense incurred by the taxpayer in earning dividend income especially after the denial of the taxpayer in respect of expenses incurred---addition made by the assessing Officer was primarily hypothetical and without any evidence, thus, was not sustainable---Impugned order passed by the Commissioner was maintained by the Tribunal---appeal filed by the Department was dismissed, in circumstances.

Other judgments reported in 2024 PTD

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