COMMISSIONER INLAND REVENUE, LAHORE vs COCA COLA PAKISTAN LIMITED, LAHORE — 2026 SCMR 130 SUPREME-COURT

Case information

Citation: 2026 SCMR 130 SUPREME-COURT
Court: Supreme Court of Pakistan
Year: 2026
Reporter: SCMR
Parties: COMMISSIONER INLAND REVENUE, LAHORE vs COCA COLA PAKISTAN LIMITED, LAHORE
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, LAHORE VS COCA COLA PAKISTAN LIMITED, LAHORE. Ss.21(c) & 153---Income Tax Ordinance, 2001---Rebate granted by taxpayer to customer for exclusive sale of products---Whether withholding tax attracted. Department treated rebate as payment for advertising services. Held: Section 153(1)(b) requires actual payment from person liable to deduct tax to recipient. In present case rebate was merely notional and no actual payment moved from taxpayer to customer. Therefore, provision had no application. Department's claim failed at inception. Leave to appeal refused and petition dismissed.

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