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I.T.A. NO. 1557/LB OF 2000, DECIDED ON 18TH APRIL, 2002. versus I.T.A. NO. 1557/LB OF 2000, DECIDED ON 18TH APRIL, 2002.


Income Tax Ordinance 1979 Section 12 (18) considered the Income Share Deposit money as debt bond amount treated as share deposit amount and was not shown as claim or debt in the balance sheet but in fact. I think it could be a loan, the provisions contained in section 12 (18) of the Income Tax Ordinance, 1979, were not attracted in such a way that any law should be displeased with the wrong impression or the use of wrong terms. Cannot be allowed because it is equivalent to allowing perpetual fraud on it. With the exception of the law where two interpretations were equally possible, one had to adopt the theme that the tax law had to be understood in the sense that the letter law was used and expressed. It has been noted that the terms can be used as balance deposit amount in the balance sheet. Do not substitute such a loan because the express loan was always characterized to be repaid or repaid after a certain period or, in some cases, indefinitely with section 12 (18) of the Income Tax Ordinance, 1979. Or without time restriction was not drawn where the assessee claimed or showed the share deposit amount in the balance sheet, unless contracted by the Department with irrelevant evidence.

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