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MESSRS CRESCENT INVESTMENT BANK LTD. versus INCOME TAX APPELLATE TRIBUNAL


Sections 15, 22, 23 (1) (xviii), 27, 28 and II Schedule, Part I, CL 116 The sale of shares of an investment banking company in connection with expenses related to the increase in capital generated by the sale of shares. In the absence of such sales accounts, the claim for capital gains for capital gains was that when operating a comprehensive business, its entire income would be eligible for business income and could not be divided into sub-trades. Nor can the costs be divided against different heads. The income paid under section 15 of the Income Tax Ordinance, 1979, was mutually exclusive capital gain, which could be assessed under section 27 of the Income Tax Ordinance, 1979 and could not be integrated into commercial income under section 22. Assessed under section 22 of the Income Tax Ordinance, 1979 cannot be taken advantage of exemption under section 27 read with section 28 of this ordinance. If an individual or corporate entity engages in more than one type of business, this will not result in income from various sources. The ACCC cannot take advantage of its failure to maintain a record of the transaction. And in the absence of receiving money, such income distribution will increase the amount of small income claimed. In the case of a bank / investment company, the concept of comprehensive business cannot be extended to the benefits of capital.

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