Wednesday, June 9, 2021

Mr. Abdullah Hanif Prop: Jumani Traders; Karachi. Vs Commissioner Inland Revenue, Zone-VI, CRTO, Karachi

APPELLATE  TRIBUNAL  INLAND  REVENUE  (PAKISTAN)
KARACHI BENCH, KARACHI

ITA No.1198/KB/2019
(Tax Year 2015)
ITA No.1199/KB/2019
(Tax Year 2016)
ITA No.1200/KB/2019
(Tax Year 2017)
ITA No.1201/KB/2019
(Tax Year 2018)

Mr. Abdullah Hanif Prop: Jumani Traders;
Karachi.                          …………………………                              Appellant

Versus

The Commissioner Inland Revenue,
Zone-VI, CRTO,
Karachi.                                    …………………………                    Respondent

 

Appellant by          : Mr. Basharat Qureshi & Mr. Taimoor Ahmad Qureshi, Advocates

Respondent by      : Mr. Naveed Dost, DR

Date of hearing     : 09.06.2021

Date of order         : 09.06.2021

M/s Brand Activate (Pvt) Ltd. Vs Commissioner Inland Revenue, Zone-IV, CRTO, Karachi. (2022) 125 TAX 354

  APPELLATE TRIBUNAL INLAND REVENUE (PAKISTAN)

KARACHI BENCH, KARACHI

 

Present:      MR. M.M. AKRAM, J.M.

                   DR. TAUQEER IRTIZA, A.M

 

ITA No.1540/KB/2019

Tax Year 2014

u/s 122(1)

*****                                                 

M/s Brand Activate (Pvt) Ltd.

House No.C-32/5-1, Main Tipu Sultan Road,

KDA Scheme No.1, Karachi                     ………....………………..Appellant

 

Vs

 

Commissioner Inland Revenue,

Zone-IV, CRTO, Karachi.                        ……...…………………Respondent

 

 

 

Appellant by:        Mr. Taimoor Ahmed Qureshi, Advocate

Respondent by:    Mr. Naveed Dost, DR

 

 

 

Date of hearing:   09.06.2021

Date of order:      09.06.2021

 

                 O R D E R

M.M. AKRAM, JUDICIAL MEMBER:        By this order, we intend to dispose of the above-titled appeal filed by the Appellant/Taxpayer challenging the validity of the Order No.69/2019 dated 30.09.2019, passed by the learned Commissioner Inland Revenue (Appeals-III), Karachi, for the tax year 2014, on the grounds as set forth in the memos of appeal.

2.      Brief facts giving rise to the appeal are that the appellant taxpayer is a Private Limited Company. The principal business activity of the company is to provide services in marketing and advertising. Return of income was filed declaring a loss of (Rs.11,367,206/-). Subsequently, the appellant’s case was selected for audit under section 177 of the Income Tax Ordinance, 2001 (“the Ordinance”) by the Commissioner Inland Revenue concerned. Audit proceedings were initiated and IDR/notices followed by reminders were issued from 15.05.2015 to 25.11.2015 which remained un-complied. On account of the appellant’s persistent non-compliance to statutory notices/reminders issued from time to time, the assessing officer ultimately passed the amended order under section 122(1) of the Ordinance whereby a tax demand to the tune of Rs.31,466,590/-was created against the appellant. Aggrieved with the said order, the appellant preferred the appeal before the learned CIR(A) who vide order dated 30.09.2019 confirmed the treatment accorded by the assessing officer. Felt aggrieved, the appellant has assailed the impugned appellate order before this Tribunal on a number of grounds.

3.      This case came up for hearing on 09.06.2021. The learned counsel appearing on behalf of the appellant/taxpayer reiterated the contentions already submitted in the grounds of appeal as set forth in the memo of appeal. On the other hand, the learned DR appearing on behalf of the department has fully supported the impugned order and contended that the learned CIR(A) has passed a speaking order and there is no infirmity in the impugned order.

4.      We have heard the arguments put forth by the learned representative of both sides and have carefully gone through the available record. After due consideration, we find that the submissions made by the learned AR for the appellant carry substantial weight. The heart of the controversy, involved in the instant appeal revolved around the interpretation of section 177 of the Ordinance. Admitted facts, briefly, are that the case of the appellant was selected for audit under section 177 of the Ordinance by the concerned Commissioner Inland Revenue and for conducting an audit the case was assigned to the Assessing Officer. In consequence thereof, the audit proceedings were initiated by the Assessing Officer and accordingly, called upon through notice to the appellant to produce the books of accounts and related documents in support of its declared version for the purpose of conducting an audit under section 177. The record shows that numerous opportunities were provided to the appellant but all in vain and admittedly the appellant did not provide the books of accounts and required documents. Now the following question arises for determination by this Tribunal:-

Whether the proceedings should have been finalized under section 122 or 121(1)(d) of the Ordinance where admittedly the taxpayer did not produce the books of accounts and related documents to the Assessing Officer for the purpose of an audit under section 177 of the Ordinance?

To answer the question, it would be advantageous to reproduce hereunder the relevant provisions of law:-

177. Audit:- (1) The Commissioner may call for any record or documents including books of accounts maintained under this Ordinance or any other law for the time being in force for conducting audit of the income tax affairs of the person and where such record or documents have been kept on electronic data, the person shall allow access to the Commissioner or the officer authorized by the Commissioner for use of machine and software on which such data is kept and the Commissioner or the officer may have access to the required information and data and duly attested hard copies of such information or data for the purpose of investigation and proceedings under this Ordinance in respect of such person or any other person: - 

           Provided that--

(a)      the Commissioner may, after recording reasons in writing call for record or documents including books of accounts of the taxpayer; and

(b)      the reasons shall be communicated to the taxpayer while calling record or documents including books of accounts of the taxpayer:  

Provided further that the Commissioner shall not call for record or documents of the taxpayer after expiry of six years from the end of the tax year to which they relate.                                     

(2) After obtaining the record of a person under sub-section(1) or where necessary record is not maintained, the Commissioner shall conduct an audit of the income tax affairs (including examination of accounts and records, enquiry into expenditure, assets and liabilities) of that person or any other person and may call for such other information and documents as he may deem appropriate. 

(3) Omitted.

(4) Omitted.

(5) Omitted. 

(6)      After completion of the audit the Commissioner shall, after obtaining taxpayer's explanation on all the issues raised in the audit, issue an audit report containing audit observations and findings. 

(6A) After issuing the audit report, the Commissioner may, if considered necessary, amend the assessment under subsection (1) or sub-section (4) of section 122, as the case may be, after providing an opportunity of being heard to the taxpayer under sub-section (9) of section 122. 

(7) …………………………….

(8) …………………………….

(9) …………………………….

(10) Notwithstanding anything contained in sub-sections (2) and (6) where a person fails to produce before the Commissioner or a firm of Chartered Accountants or a firm of Cost and Management Accountants appointed by the Board or the Commissioner under sub-section (8) to conduct an audit, any accounts, documents and records, required to be maintained under section174 or any other relevant document, electronically kept record, electronic machine or any other evidence that may be required by the Commissioner or the firm of Chartered Accountants or the firm of Cost and Management Accountants for the purpose of audit or determination of income and tax due thereon, the Commissioner may proceed to make best judgment assessment under section 121 of this Ordinance and the assessment treated to have been made on the basis of return or revised return filed by the taxpayer shall be of no legal effect.    

 

(11) ……………………………

(12) ……………………………

(13) …………………………..

(14) …….............................

(15) ………………………….

(16) …………………………. 

(17) ………………………….

 

Section 114. Return of income.- (1) Subject to this Ordinance, the following persons are required to furnish a return of income for a tax year, namely:-    

                    ……………..……………

(1A)    …………………………..

(2)      …………………………..                

           (2A)  ………………………….. 

(3)      ………………………….. 

(4)      ………………………….. 

(5)      ………………………….. 

(6)      ………………………….. 

(6A)    If a taxpayer files a revised return voluntarily alongwith deposit of the amount of tax short paid or amount of tax sought to be evaded along with the default surcharge, whenever it comes to his notice, before receipt of notice under sections 177 or sub-section (9) of 122, no penalty shall be recovered from him: 

Provided that in case the taxpayer deposits the amount of tax as pointed out by the Commissioner during the audit or before the issuance of notice under sub-section (9) of section 122, he shall deposit the amount of tax sought to be evaded, the default surcharge and twenty-five per cent of the penalties leviable under the Ordinance along with the revised return:

Provided further that in case the taxpayer revises the return after the issuance of a show-cause notice under sub-section (9) of section 122, he shall deposit the amount of tax sought to be evaded, default surcharge and fifty per cent of the leviable penalties under the Ordinance along with the revised return and thereafter, the show cause notice shall stand abated. 

           (7)    ……………………………

 

          121. Best judgment assessment.— (1) Where a person fails to

          (ab)    ……………..

(b)      …………….. or

(c)      …………….. or

(d)      produce before the Commissioner, or a special audit panel appointed under sub-section (11) of section 177 or any person employed by a firm of chartered accountants or a firm of cost and management accountants under section 177, accounts, documents and records required to be maintained under section 174, or any other relevant document or evidence that may be required by him for the purpose of making assessment of income and determination of tax due thereon, the Commissioner may, based on any available information or material and to the best of his judgment, make an assessment of the taxable income or income of the person and the tax due thereon and the assessment, if any, treated to have been made on the basis of return or revised return filed by the taxpayer shall be of no legal effect.

(2)      …………..

(3)      ………….

 

122. Amendment of assessments.— (1) Subject to this section, the Commissioner may amend an assessment order treated as issued under section 120 or issued under section 121 by making such alterations or additions as the Commissioner considers necessary.

(2)     ……………

(3)     …………..

(4)     …………..

(4A)   …………..

(5)     An assessment order in respect of tax year, or an assessment year, shall only be amended under subsection (1) and an amended assessment for that year shall only be further amended under sub-section (4) where on the basis of audit or on the basis of definite information the Commissioner is satisfied that —

(i)       any income chargeable to tax has escaped assessment; or

(ii)      total income has been under-assessed, or assessed at too low a rate, or has been the subject of excessive relief or refund; or

(iii)     any amount under a head of income has been mis-classified.

          (5A)    …………

          (5AA)  ………..

          ………………………….” (Emphasis supplied) 

It can be seen from the combined reading of the above provisions of law that after selection of the case for audit under section 177, the audit shall be conducted as per procedure given in section 177 of the Ordinance. Under sub-section (5) of section 177, the Commissioner shall conduct an audit of income tax affairs, call for records or documents including books of accounts maintained under the Ordinance for conducting an audit of income tax affairs of the taxpayer. After obtaining the record of a taxpayer under subsection (5) of section 177, the Commissioner shall conduct an audit of the income tax affairs of the taxpayer. After completion of the audit, the Commissioner under subsection (6) of section 177 shall after obtaining the taxpayer’s explanation on all the issues raised in the audit, issue an audit report. After issuance of the audit report, the Commissioner may proceed if he considered it necessary to amend the assessment order under section 122 of the Ordinance. The language of sub-section (6) of section 177 is express, explicit, and mandatory to the effect that the Commissioner proceeds to amend the deemed assessment only after obtaining the taxpayer’s explanation on all the issues raised in the Audit Report. Hence it is very clear that no proceedings for amendment of deemed assessment can be initiated without obtaining the taxpayer’s explanation on the Audit Observations.  This view is fortified by the judgment reported as Nestle Pakistan Limited etc. Vs. The Federal Board of Revenue etc, (2017 PTD 686) which says that –

“Selection for audit cannot and should not be allowed to be used for raising revenue simpliciter, without conducting any audit and preparation of Audit Report. It is reiterated that an audit, necessarily, is administrative in nature, which starts by selection for audit and ends on the issuance of an “Audit Report” after seeking an explanation from the taxpayer.  Issuance of “Audit Report” is the sine qua non for to maintain separation between administrative and judicial powers, as envisaged in Article 175 (3) of the Constitution of 1973.”

It is further held in the said judgment that:-

“Audit, being administrative proceedings, shall complete on the issuance of Audit Report.  If an audit is not completed within the given time frame, the selection shall be deemed to have been dropped. After issuance of Audit Report; adjudication proceedings shall be carried out by some other taxation officer to satisfy the command of the Constitution under Article 10A.” 

It has very clearly and authoritatively held in the judgment supra that the Audit Officer should issue an audit report before stepping towards amendment of an already completed assessment order. The above judgment was subsequently upheld by the Honorable Division Bench of Lahore High Court in the ICA No.338 of 2017 through an order dated 18-07-2017. The Honorable Division Bench, while discussing the matter of the audit report, has annunciated the legal procedure in the following words;

“However, in doing so it is vital that due process is followed and the basic requirements of the FTS are not ignored. In terms of Section 177 of the Ordinance read with Section 25 of the Act and Section 46 of the 2005 Act, the Commissioner can call for the record or documents for conducting the audit of the income tax affairs of the person provided that he gives reasons in writing and the reasons must be communicated to the Taxpayer. Under Section 177(6) of the Ordinance the Commissioner can seek an explanation from the Taxpayer on the issues raised during the audit and only if satisfied that the explanation is unsatisfactory, may proceed to amend the assessment under Section 122 of the Ordinance.” 

The above judgments were subsequently upheld by the Hon’ble Supreme Court in the case titled CIR Vs Allah Din Steel & Re-rolling Mills (2018 PTD 1444) wherein it observed as follows:- 

“16. A perusal of the statutory landscape makes it clear that the provisions of sections 177 and 214C of the Ordinance; section 25 of the Act, 1990, and section 46 of the Act, 2005 provide a mechanism and roadmap which is required to be followed by the Taxation Officer/Auditor. In terms of section 177 of the Ordinance, the Commissioner can call for the record or documents for conducting the audit of the tax affairs of a person, provided he furnishes reasons to do so. Such reasons must be communicated to the Taxpayer. He can also seek explanations from the Taxpayer on issues raised during the audit in terms of section 177 of the Ordinance. It is only if he is convinced that the explanation furnished by the Taxpayers is not satisfactory, he may proceed to amend the assessment under section 122 of the Ordinance, after giving the Taxpayer an opportunity to defend him. We are therefore of the view that the statutory framework together with the overarching umbrella of constitutional guarantees furnish adequate and sufficient safeguards to the Taxpayer where there is a possibility of overstepping by the Tax authorities.”   

It is quite obvious from the judgments referred above that the department is under legal and statutory obligation, prior to further proceed for the amendment process contemplates under section 122 of the Ordinance to obtain explanation/clarifications on all the issues raised during the audit from the taxpayer which in the instant case was not done. After the judgment of the Hon’ble Supreme Court cited above, the provision of sub-section (6) was amended and a new sub-section (6A) of section 177 was inserted through the Finance Act, 2019 which expressly mandates that after completion of the audit, the Commissioner shall after obtaining taxpayer’s explanation on all the issues raised in the audit, issue an audit report. After issuance of the audit report, the Commissioner may proceed if he considered it necessary to amend the assessment order under sections 122(1) read with 122(5) of the Ordinance.

5.      Similarly, the first proviso to sub-section (6A) of section 114 of the Ordinance gives safeguard, privilege, and the waiver of penalty to the extent of 75% to the taxpayer if he deposits the amount of tax as pointed out by the Commissioner during the audit proceedings or before the issuance of notice under sub-section (9) of section 122 along with default surcharge and twenty-five percent of the penalties leviable under the Ordinance along with the revised return. If such an opportunity during the audit proceedings or before the issuance of notice under section 122(9) of the Ordinance is not given to the taxpayer, it would be seriously deprived of its statutory right enshrined in the said proviso which is not permissible under any canon of interpretation. It is a settled principle of interpretation of the statutes that each and every word appearing in a section is to be given effect to and no word is to be rendered or surplus. So was held by the Apex Court in the cases of (i) In the matter of Reference by the President of Pakistan under Article 162 of the Constitution of Islamic Republic of Pakistan PLD 1957 SC (Pak.) 219, (ii) Muhammadi Steamship Company Ltd Vs CIT, (Central) Karachi (PLD 1966 SC 828), (iii) M/s V. N. Lakhani and Company vs M. V. Lakatoi Express and 2 others (PLD 1994 SC 894) and (iv) Director General Intelligence and Investigation FBR Vs Sher Andaz and 20 Others (2010 SCMR 1746).

6.      Simultaneously, sub-section (10) of section 177 of the Ordinance has an overriding effect, contemplates that where a person fails to produce before the Commissioner any accounts, documents, and records, required to be maintained under section 174 or any other relevant document, electronically kept a record, electronic machine or any other evidence that may be required by the Commissioner for the purpose of an audit or determination of income and tax due thereon, the Commissioner may proceed to make best judgment assessment under section 121 of this Ordinance and the assessment treated to have been made on the basis of return or revised return filed by the taxpayer shall be of no legal effect.

7.      In the instant case, it is an admitted fact that the appellant failed to produce the books of accounts and related records for the purpose of an audit before the Assessing Officer, therefore, there was no occasion for him to conduct an audit, prepare an audit report and call for an explanation thereon from the appellant as required under sub-sections (6) and (6A) of section 177 of the Ordinance respectively. Thus, the only recourse available to the assessing officer was to pass an ex-parte order under section 121(1)(d) of the Ordinance on the basis of available information and record. When the provision of sub-section (10) of section 177 is read with section 121(1)(d) in a juxtaposition, it is made clear that the assessment, if any, is treated to have been made on the basis of return or revised return filed by the taxpayer shall be of no legal effect. It is settled law that in order to arrive at the correct conclusion a scheme of law is to be examined in its totality. Reference may be placed on the judgment titled as M/s Bilz (Pvt.) Ltd Vs DCIR, Multan and another 2002 PTD 1(SC). It is also well-settled law that when the law requires an act to be done in a particular manner, it had to be done in that manner alone. Reliance is placed on the case titled IAC Income Tax Vs Micro Pak (Pvt,) Ltd and others, 2002 PTD 877(SC).

Therefore, keeping in view the above discussion, the answer to the question is that the Assessing Officer has to pass an order only under section 121(1)(d) of the Ordinance where the taxpayer fails to provide the books of accounts and related record for the purpose of an audit before the Assessing Officer, the assessment, if any, treated to have been made on the basis of return or revised return filed by the taxpayer shall be of no legal effect.

8.      Notwithstanding the aforesaid, further we have noted that the record available before us shows that while assuming the jurisdiction under section 122 of the Ordinance, the mandatory notice under section 122(5) has not been issued to the appellant which is a sine qua none for assuming the jurisdiction under the said section. The basic amended order passed by the ACIR is silent about the issuance of notice under the provisions of sub-section (5) of section 122 ibid.  For the purpose of invoking jurisdiction under section 122(1) read with 122(5) of the Ordinance, the following conditions are to be satisfied:-

(a)     There should be definite information acquired from an audit or otherwise or information received as defined in subsection (8) of section 122;

(b)     An income chargeable to tax has escaped the assessment; or

(c)     Total income has been under-assessed, or assessed at too low a rate, or has been the subject to excessive relief or refund; or

(d)     Any amount under a head of income has been misclassified. 

Sub-sections (1), (3), (4), and (5) of section 122 are to be read together and not in isolation or distinctly, or separately. Thus, an assessment order or revised assessment order issued or taken/treated as issued can be amended by invoking original jurisdiction under sub-section (5) of section 122, on fulfillment of conditions specified therein, and on no other ground. Reliance may be placed on the judgment of the Hon’ble Sindh High Court titled as Fauji Oil Terminal and Distribution Company Ltd., Karachi Vs Additional Commissioner/Taxation Officer-A, Audit Division, Karachi and 2 others, (2006 PTD 734). As stated above, the impugned amended order is silent about the issuance of notice under the provision of sub-section (5) of section 122 and even does not show under which clause of sub-section (5) the case of the appellant falls. On this score alone, the proceedings are void ab-initio, uncalled for, and cannot be sustained in the eyes of law. Reliance may be placed on the judgment reported as 2007 PTD 2601 wherein it was observed that:-

“16. The upshot of the above discussion, therefore, is obvious. The jurisdiction, in this case, could only be acquired by the Taxation Officer after receiving information from the audit department by the issuance of a notice under section 122(5). Since said notice have not properly been issued for acquiring jurisdiction over this case, one cannot agree with the department that the subsequent proceedings are justified.”

Similarly in another case reported as 2008 PTD 1549 observed as follows:-

“While perusal of the order passed by the Taxation Officer under section 122(1) of the Income Tax Ordinance, 2001, I have found that he has nowhere mentioned that which assessment order is being amended and the additions have been made on the basis of assessment for the years, 2001-2002 and 2002-2003, without any reference to the assessment order regarding tax year, 2003. I have further noted that the order has been passed by the Taxation Officer under section 122(1) and notice in this regard has been sent to the assessee as mentioned in the amended order under section 122(9) and nowhere in that order, subsections (5) or (5)(a) of section 122 has been mentioned.

In view of these legal infirmities, I am of the view that the learned CIT(A) has upheld the amended order and has not considered the fact that the Taxation Officer has not mentioned in the order which the order is going to be amended. The impugned order of the learned CIT(A) is, therefore, vacated and the amended order passed by the Taxation Officer being illegal is annulled.” (Emphasis supplied) 

9.      For the foregoing reasons, both the orders passed by the lower authorities are annulled being void ab-initio and without jurisdiction. It is an immutable principle of law that defective assumption/exercise of jurisdiction by the authorities is incurable. Reliance may be placed on Director General Intelligence and Investigation FBR Vs Sher Andaz and 20 Others (2010 SCMR 1746), Director General Intelligence and Investigation and others Vs M/s AL-Faiz Industries (Pvt.) Limited and others PTCL 2008 CL 337(S.C) and Collector, Sahiwal and 2 others Vs Muhammad Akhtar (1971 SCMR 681). In all these judgments it was held by the Hon’ble Supreme Court of Pakistan that:-

i)       Where an essential feature of assumption of jurisdiction is contravened or the forum exercises power not vested in it or exceeds authority beyond the limit prescribed by law the judgment is rendered coram non-judice and inoperative (2002 SCMR 122).

ii)      If a mandatory condition for the exercise of jurisdiction before a Court, Tribunal, or Authority is not fulfilled, then the entire proceedings which follow become illegal and suffer from want of jurisdiction. Any order passed in continuation of these proceedings in appeal or revisions equally suffer from illegality and are without jurisdiction (2008 SCMR 240)”

Since we have decided the appeal on a legal issue, therefore, there is no need to dilate upon the other grounds of appeal which relates to the merits of the case. 

10.    The appeal of the appellant is accepted in the manner stated above and the orders passed by the authorities below are annulled.

11.    This order consists of (13) pages and each page bears my signature.

                

                                                                                        Sd/-
                                                                                        (M. M. AKRAM)
                                                                                    JUDICIAL MEMBER
                     Sd/-
    (DR. TAUQEER IRTIZA)
    ACCOUNTANT MEMBER

         

CERTIFICATE U/S 5 OF THE LAW REPORT ACT 

                   This case is fit for reporting as it settles the principles highlighted above.

 

 -Sd-
(M. M. AKRAM)
JUDICIAL MEMBER
 

M/s Quetta Electric Supply Company Limited Vs Commissioner Inland Revenue, Zone-1, Karachi (UP HELD BY HON'BLE HIGH COURT QUETTA BENCH)

 

APPELLATE TRIBUNAL INLAND REVENUE OF PAKISTAN

KARACHI BENCH KARACHI

 

Present:      MR. M.M.AKRAM, J.M.

                    DR. TAUQEER IRTIZA, A.M.          

                     

STA NO.362/KB/2018

(Tax Periods July 2015 to June 2016)

*******

M/s Quetta Electric Supply Company Limited,

(QESCO), Head Office,

Zarghoon Road, Quetta.                       ………………………………….Applicant 

 

                                                  V e r s u s

 Commissioner Inland Revenue,

Zone-I, LTU, Karachi,          .…………………………………………………..Respondent

Applicant by         : Mr. Muhammad Munib & Mr. Kamran Rizvi, Adv.

Respondent by     : Sardar Abdul Rab, DR

Date of hearing    : 09-06-2021

Date of order       : 09-06-2021

 

Monday, June 7, 2021

M/s ICI Pakistan Limited, Karachi Vs The Commissioner Inland Revenue, LTO, Karachi

 APPELLATE TRIBUNAL INLAND REVENUE OF PAKISTAN

KARACHI BENCH KARACHI

 

Present:      MR. M.M.AKRAM, J.M.

                   MR. HABIBULLAH KHAN, A.M.             

 

ITA No. 336/KB/2018

(Assessment year 2002-2003)

******

 

M/s ICI Pakistan Limited,

Karachi………………………………                                                 Appellant

 

V e r s u s

 

The Commissioner Inland Revenue, LTO,

Karachi…………..………………….                                                Respondent

 

Appellant by           : Mr. Asim Zulfiqar Ali, FCA, and

                                 Ms. Asra Rauf, FCA

                                                              

Respondent by       :  Mr. Fouz Khalid, Addl. CIR /DR

 

Date of hearing      :  17.03.2021

Date of Order       :  07.06.2021

Wednesday, June 2, 2021

M/s Nutrico Pakistan (Pvt) Ltd., Karachi Vs CIR, Zone-I, LTU-II, Karachi

 
APPELATE TRIBUNAL INLAND REVENUE,
KARACHI BENCH, KARACHI
 
ITA No.953/KB/2018
(Tax Year 2015)
 
M/s Nutrico Pakistan (Pvt) Ltd.,
34-A-1, P.E.C.H.S. Shahrah-e-Faisal
Block-6, Karachi                                                               …..…Appellant
Versus
CIR, Zone-I, LTU-II, Karachi.                                           …Respondent
 
Appellant by:                  Mrs. Asra Rauf, FCA
Respondent by:               Mr. Tariq Tunio, DR
 
Date of hearing:             02.06.2021
Date of order:                02.06.2021