C.I.R. (LD), L.T.U., KARACHI versus PAKISTAN REFINERY LIMITED
Sections 67 and 122 (5A) Income Tax Ordinance (XXXI of 1979), Schedule I: Part IV Income Tax Rules, 2002, Rr 13 and 231 Income Tax Rules, 1982, R 216 Sec R 392 (I) / 2009 dated 19 5 2009 Section RO 58 (I) / 2010 Dates 2 1 2010 Obtaining Deductions Reasonable basis Oil Refinery Exports Local sales taxpayers say that in the present case, the nature of the activity, namely the activity of crude oil processing and reference. Will be. On the input of the material and its output. Directly or indirectly distributed costs with respect to the volume of activity, this result should be the basis for the distribution of all direct and indirect costs. That this would be a reasonable basis in the context of price limitation on the free sale of goods and exports in the local market. Section 67 of the Income Tax Ordinance 2001 required the distribution of deductions for ordinary expenses and such distribution should be made on a proper basis, taking into account the nature and size of the appropriate activities. Although the turnover basis for the deduction of deductions was mentioned in R13 (3) of the Income Tax Rules 2002, the taxpayer would also adopt a different basis if one were reasonable. The acquisition of this business was based on general expenditures, which consist primarily of costs other than raw materials, for which a reasonable basis could not be determined. Also, sub-rule 13 (3) of the Income Tax Rules 2002 did not apply for the acquisition of raw material prices. Where there was a reasonably close basis for allocating costs. And in turn, for the purposes of distributing the deductions, the price of crude oil was divided in proportion to the quantity sold while the department
