WORLDCALL TELECOM LTD. vs THE COMMISSIONER OF INCOME TAX, LARGE DIVISION, LARGE TAXPAYER UNIT, NABHA ROAD, LAH

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WORLDCALL TELECOM LTD. VS THE COMMISSIONER OF INCOME TAX, LARGE DIVISION, LARGE TAXPAYER UNIT, NABHA ROAD, LAHORE. Ss.153, 160 & 236(1)(b)---Advance payment of tax---Essence---Different types---"Deduction" and "collection"---Legal framework elaborated---The advance payment of tax takes one of two forms: deduction or collection---Two types of possibilities are envisaged under the Chapter: a transaction or simply a point of interaction---The difference between the two is that in a transactional situation some payment is invariably being made in relation to which there is advance payment of tax, whereas in the latter some point of interaction, usually with some State authority or agency, is selected for such payment, the interaction itself not necessarily envisaging any payment---In a transactional situation there can be either deduction or collection---Thus, it may be that "A" has to make payment to "B" and the relevant provision provides that while doing so "A" has to deduct a certain specified amount and pay it into the State treasury, or it may be that "B" has to make payment to "A" and the relevant provision provides that while doing so "B" has also to make an additional payment of a certain specified amount which "A" is then required to pay into the State treasury---In the other type of situation, i.e. a point of interaction, there is only collection where the agency or authority interacting is required to collect from "B" a certain specified amount which it then has to deposit into the State treasury---In all cases it must be remembered that what is being deducted or collected is payment of tax in advance---Another principle follows that the referent taxpayer must be identified or identifiable when advance tax is deducted or collected---It must also be remembered that severely adverse consequences follow for the person who is liable to deduct or collect advance tax under provisions of Chapter XII but fails to do so.

WORLDCALL TELECOM LTD. vs THE COMMISSIONER OF INCOME TAX, LARGE DIVISION, LARGE TAXPAYER UNIT, NABHA ROAD, LAHORE — 2026 SCMR 663 SUPREME-COURT

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