COMMISSIONER INLAND REVENUE, SIALKOT vs AIR SIAL LIMITED, SIALKOT Ss

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COMMISSIONER INLAND REVENUE, SIALKOT VS AIR SIAL LIMITED, SIALKOT Ss.18, 25, 39(1)(c) & 133---Reference---Profit on debt---Deposit of surplus funds---Pre-commencement expenditure---authorities claimed that income from pre-commencement expenses was lawfully disallowed and amortized---authorities further claimed that income on account of profit on debt was not income from business---Validity---Primary object and purpose of respondent / taxpayer company was to carry on and operate air transport service and not to derive any profit on debt as required under S. 18(2) of Income Tax Ordinance, 2001---For the purpose to achieve such object respondent / taxpayer company was authorized to invest surplus money of the company in shares, stocks or securities of any company, debentures, debenture stocks or in any investments, short term and long term participation, term finance certificates or any other government or semi-government securities---Respondent / taxpayer company was specifically not allowed to indulge in non-banking finance business, banking or an investment company or any such business---Respondent / taxpayer company was incorporated on 06-06-2016 though certificate of commencement of business was issued on 26-08-2016, however, date of actual commencement of business was 20-12-2020, when first sales tax return was filed---Profit in question accrued on surplus money from year 2017 to 2020 and was before commencement of respondent's / taxpayer's company business---Profit on surplus fund amount to income from other sources and expenses were covered under the head of pre-commencement expenses under S. 25(5) of Income Tax Ordinance, 2001---assessing Officer lawfully disallowed and amortized expenses against interest on income under the relevant provision of Income Tax Ordinance, 2001---Reference was disposed of accordingly. Citation Name: 2025 PTD 1149 LAHORE-HIGH-COURT-LAHOREBookmark this Case COMMISSIONER INLAND REVENUE, SIALKOT VS AIR SIAL LIMITED, SIALKOT S. 25(5)---Word "including"---Scope---Word "include" is normally used as expression of enlargement and implies that something also falls within the word which was beyond its general organic meaning in the interpretation clauses in order to enlarge the meaning of the words or phrases occurring in the body of the statute.

COMMISSIONER INLAND REVENUE, SIALKOT vs AIR SIAL LIMITED, SIALKOT Ss — 2025 PTD 1149 LAHORE-HIGH-COURT-LAHORE

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