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CITIBANK N. A., KARACHI versus COMMISSIONER OF INCOME-TAX, COMPANIES-1, KARACHI

Income Tax Rules 1982 R 20 Income Tax Ordinance (XXXI of 1979), Section 24 (e) Overview of deductions for head office of a multinational non-residential banking company Non-residential real estate expenses and allowance of these expenses Income tax discrimination And in Scope 20 (1) of the Rules, 1982, two conditions were considered for deduction: the first average head office expense; and the second the actual head office expenditure incurred by the Income Tax Rules, 1982 R2 (2). ), The average costs described in the first situation will be allowed, while in the second case the costs mentioned in section 24 (e) will also be allowed. ) The Income Tax Ordinance, 1979, will allow the Assessing Officer to do two exercises to determine the extent to which the Non-Resident Assessment will be allowed where the original head of his business / profession affiliated in Pakistan. Office expenses were low. Above average costs, then actual expenditures will be allowed and for this purpose, the expenditure incurred in a particular foreign currency will be calculated first and then changed the same amount in Pakistan currency under Income Tax Ordinance 1979. Where the actual costs will be. If the expenditure was charged by the Assisi above the average expenditure, then the Assisi would be allowed the average expenditure as stated in R 20 (2) of I. Income Tax Rules, 1982 and in this case, expenditures in foreign currency would be negligible because the assessment under the Income Tax Ordinance, 1979 would have allowed expenditure in the case of Pakistan currency. famous supreme court advocate from Haveli Kahuta lawyer