Section 12 (18) Gift of Income Bonds, which is considered to be deposited or originated in Pakistan, further said that the gift of the Prize Bond was in accordance with the provisions of Islamic law. And Islamic law, being a special law, will not eliminate the violation of section 12 (18) of the Income Tax Ordinance 1979. And section 12 (18) of the Income Tax Ordinance 1979 deals with the advancement of loans, gifts, and cash, so the gift of a Prize Bond does not fall under this section because the prize bonds were not considered cash in the terms. ? The first appellate authority dismissed the addition of the provisions of section 12 (18) of the Income Tax Ordinance, 1979, with the observation that the award bonds do not fall within the scope of section 12 (18) of the Income Tax Ordinance 1979. The department's position was that the prize bonds were equal to cash, which meant that according to the department's view, even prize bonds were not cash in section 12 (18) of the Income Tax Ordinance, a loan transaction was required in 1979 or Advance or gift by cross-check on bank or through a banking channel which was only possible in respect of cash transactions and not the words used in section 12 (18) of Income Tax Ordinance, 1979 on other. The items could not be stretched to include items, even if they could have easily converted the First Appellate Authority to cash that the Income Tax Ordinance of 1979 Such prize bonds do not fall within the scope of section 12 (18). The appellate tribunal upheld it and the order was upheld