KASB CAPITAL LIMITED, KARACHI versus C.I.R., AUDIT DIVISION-I, R.T.O., KARACHI
Sections 67, 114 (4), 120, 122 (5A), 210, 210 (1A), and 211 Income Tax Ordinance (XXIII of 1979), Sections 59 (1), 62, 63, 65 and 66A Income Tax Rules, 2002, R 13 Deductible Proportional Base Reasoning The taxpayer claimed that the company should conduct money market activities, capital market activities, project finance activities, corporate finance services and general services. Was added for That the overall business plan was prepared for such activities and that the expenses incurred for such trade and consulting fees were not related to income from the exemption / final tax regime source and It was specific to modest tax revenue and did not need to be distributed at all, read with R13 of Income Tax Rules 2002, outside the scope of section 67 of the Income Tax Ordinance 2001. The expenses related to general income and exemption / final tax regime income were presented in all detail before the tax officer and before the appellate authority, but both did not consider the details and evidence in this regard. The Department of Finance received capital (exempt income) that invested in equity. He said there were very few staff in the department but it did a large amount of business. And that business-based expenses could not be allocated, as the Income Tax Department claimed that where taxpayers receive both final tax regime income and ordinary tax regime income or taxable income and exempt income, then that too Should be allowed on. The income included under the final tax regime and the normal tax regime and so on
