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NISHAT CHUNIAN LTD. vs COMMISSIONER INLAND REVENUE, LTU, LAHORE Ss — 2025 PTD 1448 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN

Case information

Citation
2025 PTD 1448 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN
Year
2025
Reporter
PTD
Parties
NISHAT CHUNIAN LTD. vs COMMISSIONER INLAND REVENUE, LTU, LAHORE Ss
Subject matter
Tax & Customs
Provisions referred to
S. 108

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

NISHAT CHUNIAN LTD. VS COMMISSIONER INLAND REVENUE, LTU, LAHORE Ss. 20(1), 85 & 108 ---Income Tax Rules, 2002, R. 23---Income from business---Deductions, dis-allowance of---Transactions between associates---Arm's length---Scope---Inadmissible financial charges---Scope---Commissioner Inland Revenue (Appeals) upheld the impugned disallowance by observing that the taxpayer could not rebut the calculation/basis established by the officer and that the taxpayer had not given any calculation to establish that the interest offered for tax at Rs.28,905,058/- was not at arm's length transaction within terms of S. 108 of the Ordinance 2001---Summary of calculation of mark-up submitted by appellant / taxpayer indicates that loan to subsidiary company vary from date to date but assessment order depicts that the Assessing Officer misconceived the calculation of mark up of short term borrowing as per record submitted by the appellant / taxpayer---Appellate Tribunal Inland Revenue set-aside the impugned order and remanded the matter back to the Assessing Officer for reappraisal and decision while directing taxpayer /appellant to submit the complete summary of calculation of mark up to the Assessing Officer to reach out a just conclusion---Appeal, filed by Taxpayer, was disposed of accordingly.

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