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COMMISSIONER INLAND REVENUE, LTO, LAHORE vs EXPO LAHORE (PVT — 2026 PTD 502 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN

Case information

Citation
2026 PTD 502 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN
Year
2026
Reporter
PTD
Parties
COMMISSIONER INLAND REVENUE, LTO, LAHORE vs EXPO LAHORE (PVT
Subject matter
Service
Provisions referred to
S. 15; S. 18; 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, LTO, LAHORE VS EXPO LAHORE (PVT.) LIMITED LAHORE Ss. 15 & 18---Income from property---Scope---Income from event management services---Allegation against the Taxpayer/Company (owned by the Government of Pakistan and Government of Punjab), engaged in providing space in exhibition halls known as Expo Centre, was that the taxpayer had not declared his income under S. 15 of the Income Tax Ordinance, 2001 ('the Ordinance, 2001') as income from property on which tax withheld/paid was minimum tax liability of taxpayer---The Additional Commissioner Inland Revenue treated income of the taxpayer under S. 15 of the Ordinance, 2001 as income from property and apportioned expenses of the taxpayer between the two streams of income from property and event management services under S. 18 of the Ordinance, 2001 as income from business---Commissioner Inland Revenue (Appeals) accepted the appeal of the taxpayer---Validity---Perusal of subsection (2) of S.15 of the Ordinance, 2001 makes it clear that to be owner of land or building is a prerequisite for treating rental receipts as income from property---Therefore, the Additional Commissioner Inland Revenue was not justified in treating income of the taxpayer as income of property ; consequently, he was also not justified in apportioning expenses between the two streams of revenue namely letting out of space and providing of services---Thus, the order of the Additional Commissioner Inland Revenue being illegal and against the facts of the case was rightly vacated by the Commissioner Inland Revenue (Appeals)---Appellate Tribunal Inland Revenue upheld the order of the Commissioner Inland Revenue (Appeals)---Appeals, filed by the Departmental, was dismissed, in circumstances.

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