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  "title": "Income Tax Ordinance, 2001 (Same as on the official website of FBR dated 31-07-2025)",
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  "text": "45 \r\n \r\n \r\n \r\n \r\n \r\nGOVERNMENT OF PAKISTAN \r\nFEDERAL BOARD OF REVENUE \r\n(REVENUE DIVISION) \r\n…. \r\n \r\n \r\n \r\n  \r\nINCOME TAX MANUAL \r\n \r\nPART I \r\n \r\n  \r\n \r\n \r\nINCOME TAX ORDINANCE, 2001 \r\n \r\n \r\nAMENDED UPTO 31st JULY, 2025 \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\nTABLE OF CONTENTS \r\n \r\nSECTIONS CHAPTER 1 \r\nPRELIMINARY PAGE NO. \r\n1. Short title, extent and commencement 1 \r\n2. Definitions 1 \r\n3. Ordinance to override other laws 31 \r\n CHAPTER II \r\nCHARGE OF TAX \r\n \r\n4. Tax on taxable income 32 \r\n4A. Omitted by Finance Act 2014 33 \r\n4AB. Subject to this Ordinance, a surcharge payable 33 \r\n4B. Super tax for rehabilitation of temporary displaced persons. 33 \r\n4C. Super tax on high earning persons. 34 \r\n5. Tax on dividends 35 \r\n5A. Tax on undistributed Profits. 36 \r\n5AA. Tan on return on investments in Sukuks. 36 \r\n6. Tax on certain payments to non-residents 37 \r\n6A. Tax on payments for digital transactions in e-commerce platforms 38 \r\n7. Tax on shipping and air transport income of a non-resident \r\nperson \r\n38 \r\n7A. Tax on shipping of a resident person. 39 \r\n7B. Tax on profit on debt 39 \r\n7C. Tax on builders 40 \r\n7D. Tax on developers 41 \r\n7E. Tax on deemed income. 41 \r\n7F. Tax on Builders and Developers 43 \r\n8. General provisions relating to taxes imposed under sections 5, 6 \r\nand 7 \r\n44 \r\n CHAPTER III \r\nTAX ON TAXABLE INCOME \r\n \r\n PART I \r\nCOMPUTATION OF TAXABLE INCOME \r\n \r\n9. Taxable income 45 \r\n10. Total income 45 \r\n11. Heads of income 45 \r\n PART II \r\nHEAD OF INCOME \r\nSALARY \r\n \r\n12. Salary 48 \r\n13. Value of perquisites 50 \r\n14. Employee share schemes 54 \r\n PART III \r\nHEAD OF INCOME \r\nINCOME FROM PROPERTY \r\n \r\n15. Income from property 56 \r\n15A. Deductions in computing income chargeable under the head \r\n“Income from Property” \r\n57 \r\n16. Non-adjustable amounts received in relation to buildings. 60 \r\n17. Omitted by the Finance Act, 2006. \r\n \r\n60 \r\n \r\n PART IV \r\nHEAD OF INCOME \r\nINCOME FROM BUSINESS \r\n \r\n Division I \r\nIncome from Business \r\n \r\n18. Income from business 61 \r\n19. Speculation business 63 \r\n Division II \r\n Deductions \r\nGeneral Principles \r\n \r\n20. Deductions in computing income chargeable under the head \r\n“Income from Business” \r\n64 \r\n21. Deductions not allowed 64 \r\n Division III \r\nDeductions \r\nSpecial Provisions \r\n \r\n22. Depreciation 68 \r\n23. Initial allowance 73 \r\n23A. Omitted by the Finance Act, 2021. 74 \r\n23B. Accelerated depreciation to alternate energy projects. 75 \r\n24. Intangibles 75 \r\n25. Pre-commencement expenditure 77 \r\n26. Scientific research expenditure 78 \r\n27. Employee training and facilities 78 \r\n28. Profit on debt, financial costs and lease payments 79 \r\n29. Bad debts 81 \r\n29A Provision regarding consumer loans 82 \r\n30. Profit on non-performing debts of a banking company or \r\ndevelopment finance institution \r\n82 \r\n31. Transfer to participatory reserve  83 \r\n Division IV \r\nTax Accounting \r\n \r\n32. Method of accounting 84 \r\n33. Cash-basis accounting 84 \r\n34. Accrual-basis accounting 84 \r\n35. Stock-in-trade 85 \r\n36. Long-term contracts 87 \r\n PART V \r\nHEAD OF INCOME \r\nCAPITAL GAINS \r\n \r\n37. Capital gains 88 \r\n37A. Capital gain on disposal of securities 92 \r\n38. Deduction of losses in computing the amount chargeable under \r\nthe head “Capital Gains” \r\n94 \r\n \r\n PART VI \r\nHEAD OF INCOME \r\nINCOME FROM OTHER SOURCES \r\n \r\n39. Income from other sources 95 \r\n40. Deductions in computing income chargeable under the head \r\n“Income from Other Sources” \r\n97 \r\n PART VII \r\nEXEMPTIONS AND TAX CONCESSIONS \r\n \r\n41. Agricultural income 99 \r\n42. Diplomatic and United Nations exemptions 100 \r\n43. Foreign government officials 100 \r\n44. Exemptions under international agreements 100 \r\n44A. Exemption under Foreign Investment (Promotion and Protection) \r\nAct, 2022 (XXXV of 2022).  \r\n101 \r\n45. President’s honours 102 \r\n46. Profit on debt 102 \r\n47. Scholarships 103 \r\n48. Support payments under an agreement to live apart 103 \r\n49. Federal Governments, Provincial Government and Local \r\nGovernment \r\n103 \r\n50. Foreign-source income of short-term resident individuals 104 \r\n51. Foreign-source income of returning expatriates 104 \r\n52. Omitted by Finance Ordinance, 2002 104 \r\n53. Exemptions and tax concessions in the Second Schedule 105 \r\n54. Exemptions and tax provisions in other laws 106 \r\n55. Limitation of exemption 107 \r\n PART VIII \r\nLOSSES \r\n \r\n56. Set off of losses 108 \r\n56A. Set off of losses of companies operating hotels. 108 \r\n57. Carry forward of business losses 108 \r\n57A. Set off of business loss consequent to amalgamation 110 \r\n58. Carry forward of speculation business losses 111 \r\n59. Carry forward of capital losses 111 \r\n59A. Limitations on set off and carry forward of losses 112 \r\n59AA. Group Taxation. 113 \r\n59B. Group relief 114 \r\n59C. Omitted by Finance Act, 2022 116 \r\n PART IX \r\nDEDUCTIBLE ALLOWANCES \r\n \r\n60. Zakat 117 \r\n60A. Workers’ Welfare Fund 117 \r\n60B. Workers’ Participation Fund 118 \r\n60C. Omitted by the Finance Act, 2022. 118 \r\n60D. Deductible allowance for education expenses 118 \r\n PART X \r\nTAX CREDITS \r\n \r\n61. Charitable donations 119 \r\n62. Omitted by the Finance Act, 2022. 121 \r\n62A. Omitted by the Finance Act, 2022. 122 \r\n63. Contribution to an Approved Pension Fund. 122 \r\n63A. Tax credit for interest paid on low-cost housing loan. 124 \r\n64. Omitted by Finance Act, 2015. 125 \r\n64A Section re-numbered as 60C 126 \r\n64AB Section re-numbered as 60D 126 \r\n64B. Tax credit for employment generation by manufacturers 126 \r\n64C. Omitted by Finance Act, 2021 127 \r\n64D. Tax credit for point of sale machine 127 \r\n65. Miscellaneous provisions relating to tax credits 128 \r\n65A. Omitted by the Finance Act, 2017 129 \r\n65B. Tax credit for investment 129 \r\n65C. Omitted by the Finance Act, 2021 131 \r\n65D. Omitted by the Finance Act, 2021 131 \r\n65E. Tax credit for industrial undertakings established before the first \r\nday of July, 2011 \r\n132 \r\n65F. Tax credit for certain persons 134 \r\n65G. Tax credit for specified industrial undertakings 135 \r\n65H. Omitted by the Finance Act, 2022. 136 \r\n CHAPTER-IV \r\nCOMMON RULES \r\n \r\n \r\n PART I \r\nGENERAL \r\n \r\n66. Income of joint owners 137 \r\n67. Apportionment of deductions 137 \r\n68. Fair market value 138 \r\n69. Receipt of income 139 \r\n70. Recouped expenditure 139 \r\n71. Currency conversion 139 \r\n72. Cessation of source of income 139 \r\n73. Rules to prevent double derivation and double deductions  140 \r\n PART II \r\nTAX YEAR \r\n \r\n74. Tax year  141 \r\n PART III \r\nASSETS \r\n \r\n75. Disposal and acquisition of assets 143 \r\n75A. Purchase of assets through banking channel 143 \r\n76. Cost 144 \r\n77. Consideration received 146 \r\n78. Non-arm's length transactions 146 \r\n79. Non-recognition rules 147 \r\n  \r\nCHAPTER V \r\nPROVISIONS GOVERNING PERSONS \r\nPART I \r\nCENTRAL CONCEPTS \r\nDivision I \r\nPersons \r\n \r\n80. Person 146 \r\n Division II \r\nResident and Non-resident Persons \r\n \r\n81. Resident and non-resident persons 150 \r\n82. Resident individual 150 \r\n83. Resident company 151 \r\n84. Resident association of persons 151 \r\n Division III \r\nAssociates \r\n \r\n85. Associates 151 \r\n \r\n \r\n \r\n \r\nPART II \r\nINDIVIDUALS \r\nDivision I \r\nTaxation of Individuals \r\n \r\n86. Principle of taxation of individuals 154 \r\n87. Deceased individuals 154 \r\n Division II \r\nProvisions Relating to Averaging \r\n \r\n88. An individual as a member of an association of persons 155 \r\n88A. Omitted by Finance Act, 2014 155 \r\n89. Authors 155 \r\n Division III \r\nIncome Splitting \r\n \r\n90. Transfers of assets 156 \r\n91. Income of a minor child 157 \r\n PART III \r\nASSOCIATIONS OF PERSONS \r\n \r\n92. Principles of taxation of associations of persons 158 \r\n93. Omitted by the Finance Act, 2007. 159 \r\n PART IV \r\nCOMPANIES \r\n \r\n94. Principles of taxation of companies 159 \r\n95. Disposal of business by individual to wholly-owned company 160 \r\n96. Disposal of business by association of persons to wholly-owned \r\ncompany \r\n161 \r\n97. Disposal of asset between wholly-owned companies 163 \r\n97A. Disposal of asset under a scheme of arrangement and \r\nreconstruction. \r\n164 \r\n PART V \r\nCOMMON PROVISIONS APPLICABLE TO ASSOCIATIONS \r\nOF PERSONS AND COMPANIES \r\n \r\n98. Change in control of an entity 166 \r\n PART VA \r\nTAX LIABILITY IN CERTAIN CASES \r\n \r\n98A. Change in the constitution of an association of persons 167 \r\n98B. Discontinuance of business or dissolution of an association of \r\npersons \r\n167 \r\n98C. Succession to business, otherwise than on death 167 \r\n CHAPTER-VI \r\nSPECIAL INDUSTRIES \r\nPART I \r\nINSURANCE BUSINESS \r\n \r\n99. Special provisions relating to insurance business  169 \r\n99A. Special provisions relating to payment of tax through electricity \r\nconnections \r\n169 \r\n99B. Special procedure for small traders and shopkeepers 171 \r\n99C. Special procedure for certain persons 171 \r\n99D. Additional tax on certain income, profits and gains.  171 \r\n PART II \r\nOIL, NATURAL GAS AND OTHER MINERAL DEPOSITS \r\n \r\n100. Special provisions relating to the production of oil and natural \r\ngas, and exploration and extraction of other mineral deposits \r\n173 \r\n100A. Special provisions relating to banking business. 173 \r\n100B. Special provision relating to capital gain tax. 174 \r\n100BA. Special provisions relating to persons not appea ring in active \r\ntaxpayers’ list. \r\n174 \r\n100C. Tax credit for certain persons 175 \r\n100D. Special provisions relating to builders and developers 179 \r\n100E. Special provisions relating to small and medium enterprises 186 \r\n100F Omitted by the Finance Act, 2022 186 \r\n CHAPTER VII \r\nINTERNATIONAL \r\nPART I \r\nGEOGRAPHICAL SOURCE OF INCOME \r\n \r\n101. Geographical source of income 187 \r\n101A Gain on disposal of assets outside Pakistan 194 \r\n \r\n PART II \r\nTAXATION OF FOREIGN-SOURCE INCOME OF RESIDENTS \r\n \r\n102. Foreign source salary of resident individuals 197 \r\n103. Foreign tax credit 197 \r\n104. Foreign losses 198 \r\n PART III \r\nTAXATION OF NON-RESIDENTS \r\n \r\n105. Taxation of a permanent establishment in Pakistan of a non -\r\nresident person \r\n199 \r\n106. Thin capitalization 200 \r\n106A. Restriction on deduction of profit on debt payable to associated \r\nenterprise \r\n202 \r\n PART IV \r\nAGREEMENTS FOR THE AVOIDANCE OF \r\nDOUBLE TAXATION AND \r\n PREVENTION OF FISCAL EVASION \r\n \r\n107. Agreements for the avoidance of double taxation and prevention \r\nof fiscal evasion \r\n205 \r\n CHAPTER VIII \r\nANTI-AVOIDANCE \r\n \r\n108. Transactions between associates 207 \r\n108A. Report from independent chartered accountant or cost and \r\nmanagement accountant \r\n208 \r\n108B. Transactions under dealership arrangements 208 \r\n109. Recharacterisation of income and deductions 209 \r\n109A Controlled foreign company. 210 \r\n110. Salary paid by private companies 212 \r\n111. Unexplained income or assets 212 \r\n112. Liability in respect of certain security transactions 215 \r\n CHAPTER IX \r\nMINIMUM TAX \r\n \r\n113. Minimum tax on the income of certain persons. 214 \r\n113A. Omitted by the Finance Act, 2016 219 \r\n113B. Omitted by the Finance Act, 2016 220 \r\n113C. Alternative Corporate Tax 220 \r\n CHAPTER X \r\nPROCEDURE \r\nPART I \r\nRETURNS \r\n \r\n114. Return of income 221 \r\n114A. Business bank account 230 \r\n114B. Powers to enforce filing of returns. 231 \r\n114C. Restriction on economic transactions by certain persons. 231 \r\n115. Persons not required to furnish a return of income 233 \r\n116. Wealth statement 235 \r\n116A Foreign   income   and   assets   statement 237 \r\n117. Notice of discontinued business 237 \r\n118. Method of furnishing returns and other documents 236 \r\n119. Extension of time for furnishing returns and other documents 240 \r\n PART II \r\nASSESSMENTS \r\n \r\n120. Assessments        242 \r\n120A.  Omitted by Finance Act, 2013 245 \r\n120B.  Restriction of proceedings 245 \r\n121. Best judgment assessment 245 \r\n122. Amendment of assessments 247 \r\n122A. Revision by the Commissioner 251 \r\n122B. Revision by the Chief Commissioner 252 \r\n122C. Omitted by the Finance Act, 2017 252 \r\n122D. Agreed assessment in certain cases 253 \r\n123. Provisional assessment in certain cases 254 \r\n124. Assessment giving effect to an order 254 \r\n124A. Powers of tax authorities to modify orders, etc. 257 \r\n125. Assessment in relation to disputed property 257 \r\n126. Evidence of assessment 257 \r\n PART III \r\nAPPEALS \r\n \r\n126A. Omitted by the Finance Act, 2025 258 \r\n127. Appeal to the Commissioner (Appeals) 258 \r\n128. Procedure in appeal 261 \r\n129. Decision in appeal 261 \r\n130. Appellate Tribunal 263 \r\n131. Appeal to the Appellate Tribunal  267 \r\n132. Disposal of appeals by the Appellate Tribunal 268 \r\n133. Reference to High Court 272 \r\n134. Omitted by Finance Act, 2005 275 \r\n134A. Alternative Dispute Resolution 277 \r\n135. Omitted by the Finance Ordinance, 2002 281 \r\n136. Burden of proof 282 \r\n PART IV \r\nCOLLECTION AND RECOVERY OF TAX \r\n \r\n137. Due date for payment of tax 283 \r\n138. Recovery of tax out of property and through arrest of taxpayer 284 \r\n138A. Recovery of tax by District Officer (Revenue) 286 \r\n138B. Estate in bankruptcy 286 \r\n139. Collection of tax in the case of private companies and \r\nassociations  of persons \r\n286 \r\n140. Recovery of tax from persons holding money on behalf of a \r\ntaxpayer \r\n287 \r\n141. Liquidators 289 \r\n142. Recovery of tax due by non-resident member of an association \r\nof persons \r\n290 \r\n143. Non-resident ship owner or charterer 290 \r\n144. Non-resident aircraft owner or charterer 291 \r\n145. Assessment of persons about to leave Pakistan  292 \r\n146. Recovery of tax from persons assessed in Azad Jammu and \r\nKashmir \r\n293 \r\n146A. Initiation, validity, etc., of recovery proceedings. 293 \r\n146B. Tax arrears settlement incentives scheme 294 \r\n146C. Assistance in the recovery and collection of taxes 294 \r\n146D. Recovery of liability outstanding under other laws.  294 \r\n PART V  \r\nADVANCE TAX AND DEDUCTION OF TAX AT SOURCE \r\nDivision I \r\nAdvance Tax Paid by the Taxpayer \r\n147. Advance tax paid by the taxpayer 296 \r\n147A. Advance tax from provincial sales tax registered person 303 \r\n Division II \r\nAdvance Tax Paid to a Collection Agent \r\n \r\n \r\n148. Imports 304 \r\n148A. omitted through Finance Act, 2020 dated 30th June, 2020 308 \r\n Division III \r\nDeduction of Tax at Source \r\n \r\n149. Salary 308 \r\n150. Dividends 310 \r\n150A omitted by the Finance Act, 2021 310 \r\n151. Profit on debt 310 \r\n151A. Gain arising on disposal of certain debt securities. 311 \r\n152. Payments to non-residents 312 \r\n152A. Omitted by the Finance Act, 2021 320 \r\n153. Payments for goods, services and contracts 320 \r\n153A. Omitted by Finance Act, 2013 328 \r\n153B. Omitted by Finance Act, 2021 328 \r\n154. Exports 328 \r\n154A. Export of Services 330 \r\n155. Rent of immoveable property 331 \r\n156. Prizes and winnings 332 \r\n156A. Petroleum products 333 \r\n156B. Omitted by Finance Act, 2020 333 \r\n157. Omitted by the Finance Ordinance, 2002 334 \r\n158. Time of deduction of tax 334 \r\n Division IV \r\nGeneral Provisions Relating to the Advance Payment of Tax \r\nor the Deduction of Tax at Source \r\n \r\n159. Exemption or lower rate certificate 335 \r\n160. Payment of tax collected or deducted 337 \r\n161. Failure to pay tax collected or deducted 337 \r\n162. Recovery of tax from the person from whom tax was not \r\ncollected or deducted \r\n338 \r\n \r\n163. Recovery of amounts payable under this Division 339 \r\n164. Certificate of collection or deduction of tax 339 \r\n164A. Settlement of transactions liable to Withholding Tax by SWAPS \r\nagents \r\n339 \r\n165. Statements 340 \r\n165A. Furnishing of information by banks 344 \r\n165B. Furnishing of information by financial institutions \r\nincluding banks \r\n345 \r\n165C. Furnishing of information by online marketplace, payment \r\nintermediary and courier service. \r\n346 \r\n166. Priority of tax collected or deducted 346 \r\n167. Indemnity 347 \r\n168. Credit for tax collected or deducted 347 \r\n169. Tax collected or deducted as a final tax 350 \r\n PART VI \r\nREFUNDS \r\n \r\n170. Refunds 354 \r\n170A. Electronic processing and electronic issuance of Refunds by the \r\nBoard \r\n355 \r\n171. Additional payment for delayed refunds  355 \r\n171A. Payment of refund through income tax refund bonds.- 356 \r\n PART VII \r\nREPRESENTATIVES \r\n \r\n172. Representatives 358 \r\n173. Liability and obligations of representatives 360 \r\n PART VIII \r\nRECORDS, INFORMATION COLLECTION AND AUDIT \r\n \r\n174. Records 361 \r\n175. Power to enter and search premises 362 \r\n175A. Real-time access to information and databases 363 \r\n175AA. Exchange of banking and tax information related to high -risk \r\npersons. \r\n364 \r\n175B. National Database and Registration Authority (NADRA) 365 \r\n175C. Posting of officer of Inland Revenue. 366 \r\n176. Notice to obtain information or evidence 366 \r\n177. Audit 369 \r\n178. Assistance to Commissioner 374 \r\n179. Accounts, documents, records and computer-stored information \r\nnot in Urdu  or English language \r\n374 \r\n180. Power to collect information regarding exempt income 374 \r\n PART IX \r\nTAXPAYER’S REGISTRATION  \r\n \r\n181. Taxpayer’s Registration 375 \r\n181A. Active taxpayers’ list 376 \r\n181AA. Compulsory registration in certain cases 376 \r\n181B. Taxpayer card 376 \r\n181C. Displaying of National Tax Number 376 \r\n181D. Business licence scheme 376 \r\n181E. Record of beneficial owners. 377 \r\n  \r\nPART X \r\nPENALTY \r\n \r\n182. Offences and penalties 378 \r\n182A Return not filed within due date. 395 \r\n183. Exemption from penalty and default surcharge 396 \r\n184. Omitted by the Finance Act, 2010. 397 \r\n185. Omitted by the Finance Act, 2010. 397 \r\n186. Omitted by the Finance Act, 2010. 397 \r\n187. Omitted by the Finance Act, 2010. 397 \r\n188. Omitted by the Finance Act, 2010. 398 \r\n189. Omitted by the Finance Act, 2010. 398 \r\n190. Omitted by the Finance Act, 2010. 398 \r\n PART XI \r\nOFFENCES AND PROSECUTIONS \r\n \r\n191. Prosecution for non-compliance with certain statutory obligations 398 \r\n191A. Prosecution for failure to furnish information in return of income. 400 \r\n191B. Prosecution for non-registration 400 \r\n192. Prosecution for false statement in verification 400 \r\n192A. Prosecution for concealment of income. 400 \r\n192B Prosecution for concealment of and offshore assets 401 \r\n193. Prosecution for failure to maintain records 401 \r\n194. Prosecution for improper use of National Tax Number Certificate 401 \r\n195. Prosecution for making false or misleading statements 401 \r\n195A. Prosecution for non-compliance with notice under section \r\n116A.— \r\n402 \r\n195B. Prosecution for enabling offshore tax evasion 402 \r\n196. Prosecution for obstructing an income tax authority 402 \r\n197. Prosecution for disposal of property to prevent attachment 402 \r\n198. Prosecution for unauthorised disclosure of information by a \r\npublic servant \r\n403 \r\n199. Prosecution for abetment 403 \r\n200. Offences by companies and associations of persons 403 \r\n201. Institution of prosecution proceedings without prejudice to other \r\naction \r\n403 \r\n202. Power to compound offences 404 \r\n203. Trial by Special Judge 404 \r\n203A. Appeal against the order of a Special Judge 405 \r\n203B. Power to arrest and prosecute 405 \r\n203C. Procedure to be followed on arrest of a person 406 \r\n203D. Special Judges 408 \r\n203E. Cognizance of offences by Special Judges 408 \r\n203F. Special Judge, etc. to have exclusive jurisdiction 409 \r\n203G. Provisions of Code of Criminal Procedure, 1898, to apply 410 \r\n203H. Transfer of cases 410 \r\n203I. Place of sittings 410 \r\n204. Power to tender immunity from prosecution 410 \r\n PART XII \r\nDEFAULT SURCHARGE \r\n \r\n205. Default surcharge 411 \r\n205A. Reduction in default surcharge, consequential to reduction in tax \r\nor penalty \r\n415 \r\n PART XIII \r\nCIRCULARS \r\n \r\n206. Circulars 415 \r\n206A. Advance ruling 416 \r\n CHAPTER XI \r\nADMINISTRATION \r\nPART I \r\nGENERAL \r\n \r\n207. Income tax authorities 404 \r\n208. Appointment of income tax authorities 419 \r\n209. Jurisdiction of income tax authorities 420 \r\n209A. Uniform 422 \r\n210. Delegation 423 \r\n211. Power or function exercised 424 \r\n212. Authority of approval 424 \r\n213. Guidance to income tax authorities 425 \r\n214. Income tax authorities to follow orders of the Board  425 \r\n214A. Condonation of time limit 425 \r\n214B. Power of the Board to call for records 426 \r\n214C. Selection for audit by the Board 426 \r\n214D. Omitted by the Finance Act, 2018 427 \r\n214E. Inserted by the Finance Supplementary (Amendment) Act, 2018 427 \r\n215. Furnishing of returns, documents etc. 428 \r\n216. Disclosure of information by a public servant 429 \r\n216A. Omitted by the Finance Act, 2022 434 \r\n217. Forms and notices; authentication of documents 435 \r\n218. Service of notices and other documents 435 \r\n219. Tax or refund to be computed to the nearest Rupee 436 \r\n220. Receipts for amounts paid 436 \r\n221. Rectification of mistakes 437 \r\n222. Appointment of expert 437 \r\n222A. Fee and service charges 438 \r\n223. Appearance by authorized representative 438 \r\n224. Proceedings under the Ordinance to be judicial proceedings 440 \r\n225. Proceedings against companies under liquidation 441 \r\n226. Computation of limitation period 441 \r\n227. Bar of suits in Civil Courts 441 \r\n227A. Reward to officers and officials of Inland Revenue 442 \r\n227B. Reward of whistleblowers 442 \r\n227BA. Reward and benefits for certain persons 443 \r\n227C omitted through Finance Act 2019 443 \r\n227D Automated impersonal tax regime 444 \r\n227E E-hearing 444 \r\n PART II \r\nDIRECTORATES-GENERAL  \r\n \r\n228. The Directorate-General of Internal Audit 444 \r\n229. Directorate General of Training and Research 445 \r\n230. Directorate General (Intelligence and Investigation), Inland \r\nRevenue \r\n445 \r\n PART III \r\nDIRECTORATES-GENERAL  \r\n \r\n230A. Directorate-General of Withholding Taxes 446 \r\n230B. Directorate-General of Law 446 \r\n230C. Directorate-General of Research and Development 446 \r\n230D. Directorate-General of Broadening of Tax Base   446 \r\n230E. Directorate-General of Transfer Pricing   447 \r\n230F. Directorate-General of Immovable Property. 448 \r\n230G. Directorate General of Special Initiative 451 \r\n230H. Directorate General of Valuation 452 \r\n230I. Directorate General of Compliance Risk Management 452 \r\n230J. International Centre of Tax Excellence 452 \r\n230K. Tax Fraud Investigation Wing Inland Revenue 454 \r\n231. Omitted by Finance Act, 2005 455 \r\n  \r\nCHAPTER XII \r\nTRANSITIONAL ADVANCE TAX PROVISIONS \r\n \r\n231A. Omitted by the Finance Act, 2021 456 \r\n231AA. Omitted by the Finance Act, 2021 456 \r\n231AB. Advance tax on cash withdrawal 456 \r\n231B. Advance tax on private motor vehicles 457 \r\n231C. Advance tax on foreign domestic workers 459 \r\n232. Omitted by the Finance Ordinance, 2002 459 \r\n233. Brokerage and Commission 460 \r\n233A. Omitted by the Finance Act, 2021 461 \r\n233AA. Omitted by the Finance Act, 2021 461 \r\n234. Tax on motor vehicles 462 \r\n234A. omitted by the Finance Act, 2021 462 \r\n235. Electricity Consumption 463 \r\n235A. omitted by the Finance Act, 2021 464 \r\n235B. omitted through Finance Act, 2020 dated 30th June, 2020 464 \r\n236. Telephone and internet users 465 \r\n236A. Advance tax at the time of sale by auction 466 \r\n236B. Omitted by the Finance Act, 2021 467 \r\n236C. Advance Tax on sale or transfer of immovable Property 467 \r\n236CA. Advance Tax on TV plays and advertisements 469 \r\n236CB. Advance tax on functions and gatherings 470 \r\n236D. Omitted by the Finance Act, 2020  470 \r\n236E Omitted by the Finance Act, 2016 470 \r\n236F. Omitted through Finance Act, 2020  470 \r\n236G. Advance tax on sales to distributors, dealers and wholesalers 471 \r\n236H. Advance tax on sales to retailers 471 \r\n236HA Omitted by the Finance Act, 2021 471 \r\n236I. Omitted by the Finance Act, 2022 472 \r\n236J. Omitted through Finance Act, 2020  472 \r\n236K. Advance tax on purchase or transfer of immovable property 472 \r\n236L. Omitted by the Finance Act, 2021 474 \r\n236M. Omitted by the Finance Act, 2018 474 \r\n236N. Omitted by the Finance Act, 2018 474 \r\n236O. Advance tax under this chapter 475 \r\n236P. omitted by the Finance Act, 2021 475 \r\n236Q. Omitted by the Finance Act, 2022 475 \r\n236R. Omitted through Finance Act, 2020  476 \r\n236S. omitted by the Finance Act, 2021 476 \r\n236T. Omitted by the Finance Act, 2016 476 \r\n236U. omitted through Finance Act, 2020 dated 30th June, 2020 477 \r\n236V. Omitted by the Finance Act, 2021 477 \r\n236W. Omitted through Finance Act, 2019 477 \r\n236X. omitted through Finance Act, 2020 dated 30th June, 2020 477 \r\n236Y Omitted by the Finance Act, 2021 477 \r\n236Y. Advance tax on persons remitting amounts abroad through \r\ncredit or debit or prepaid cards \r\n478 \r\n236Z. Bonus shares issued by companies. 478 \r\n CHAPTER XIII \r\n    MISCELLANEOUS \r\n \r\n237. Power to make rules 480 \r\n237A. Electronic record 481 \r\n237B. Prize schemes to promote tax culture 481 \r\n238. Repeal 481 \r\n239. Savings 482 \r\n239A. Transition to Federal Board of Revenue. 485 \r\n239B. Reference to authorities 485 \r\n240. Removal of difficulties 486 \r\n241. Validation 486 \r\n242. Benefits of repealed provisions 486 \r\n FIRST SCHEDULE \r\nPART I \r\nRATES OF TAX \r\n488 \r\n Division I \r\n \r\n488 \r\n Rates of Tax for Individuals 488 \r\n Rates of Tax for Association of Persons 488 \r\n Division IA 493 \r\n(Omitted by the Finance Act, 2013) \r\n Division IB \r\n(Omitted by the Finance Act, 2012) \r\n494 \r\n Division II \r\nRates of Tax for Companies \r\n494 \r\n Division IIA \r\nRates of Super Tax  \r\n495 \r\n Division IIB \r\nSuper Tax on high earning persons \r\n496 \r\n Division III \r\nRate of Dividend Tax \r\n498 \r\n Division IIIA \r\nRate for Profit on Debt \r\n500 \r\n Division IIIB \r\nRate of Tax on Return on investment in \r\nSukuks received from a special \r\npurpose vehicle \r\n501 \r\n Division IV \r\nRate of Tax on Certain Payments to Non-residents \r\n501 \r\n Division IVA \r\nRate of Tax on Payments for Digital Transactions in  \r\nE-commerce Platforms \r\n501 \r\n Division V \r\nRate of Tax on Shipping or Air Transport Income of a Non-\r\nresident Person \r\n502 \r\n Division VI \r\n(Omitted by the Finance Act, 2013) \r\n502 \r\n Division VIA \r\nIncome from Property \r\n(Omitted by the Finance Act, 2021) \r\n503 \r\n Division VII \r\nCapital Gains on disposal of Securities \r\n506 \r\n Division VIII \r\nCapital Gains on Disposal of Immovable Property \r\n510 \r\n Division VIIIA \r\n Tax on Builders \r\n511 \r\n Division VIIIB \r\n Tax on Developers \r\n512 \r\n Division VIIIC \r\nTax on deemed income \r\n512 \r\n Division IX 512 \r\n Minimum tax under section 113 \r\n PART II \r\nRates of Advance Tax \r\n514 \r\n \r\n \r\n \r\nPART IIA \r\nCollection of Tax from Distributors, Dealers, And \r\nWholesalers \r\nOmitted by the Finance Act, 2014 \r\n517 \r\n Part IIB  \r\nRates of Advance Tax \r\n518 \r\n PART III \r\nDEDUCTION OF TAX AT SOURCE \r\n 519 \r\n Division I \r\nAdvance Tax on Dividend \r\n519 \r\n Division IA \r\nProfit on Debt \r\n521 \r\n Division IB \r\nReturn on Investment in Sukuks \r\n522 \r\n Division II \r\nPayments to non-residents \r\n522 \r\n Division III \r\nPayments for Goods or Services \r\n524 \r\n Division III A \r\n(Omitted by the Finance Act, 2012) \r\n528 \r\n Division IIIAA \r\nGain arising on disposal of certain debt securities  \r\n528 \r\n Division III B \r\n(Omitted by the Finance Act, 2012) \r\n529 \r\n Division IV \r\nExports \r\n529 \r\n Division IVA \r\nExports of Services \r\n529 \r\n Division V \r\nIncome from Property \r\n530 \r\n Division VI \r\nPrizes and Winnings \r\n531 \r\n Division VIA \r\nPetroleum Products \r\n532 \r\n Division VIB \r\nOmitted by the Finance Act, 2021 \r\n532 \r\n Division VII \r\nOmitted by the Finance Act, 2002 \r\n532 \r\n PART IV \r\nDEDUCTION OR COLLECTION OF  \r\nADVANCE TAX \r\n533 \r\n Division I \r\nOmitted by the Finance Act, 2002 \r\n533 \r\n Division II \r\nBrokerage and Commission \r\n533 \r\n Division IIA \r\nOmitted by the Finance Act, 2021 \r\n533 \r\n Division IIB \r\nOmitted by the Finance Act, 2021 \r\n534 \r\n Division III \r\nTax on motor vehicles \r\n534 \r\n Division IV \r\nElectricity Consumption \r\n536 \r\n Division V \r\nTelephone users \r\n538 \r\n Division VI \r\nomitted by the Finance Act, 2021 \r\n540 \r\n Division VIA \r\nomitted by the Finance Act, 2021 \r\n540 \r\n Division VII \r\nAdvance tax on Purchase, Registration and Transfer Motor \r\nVehicles \r\n540 \r\n Division VIII \r\nAdvance tax at the time of sale by auction \r\n543 \r\n Division IX \r\nomitted by the Finance Act, 2021 \r\n543 \r\n Division X \r\nAdvance tax on sale or transfer of \r\nImmovable property \r\n543 \r\n Division XA  \r\nAdvance tax on TV plays and advertisements \r\n544 \r\n Division XI \r\nOmitted through Finance Act, 2020 dated 30th June, 2020 \r\n545 \r\n Division XII \r\nOmitted by the Finance Act, 2016 \r\n545 \r\n Division XIII \r\nOmitted through Finance Act, 2020 dated 30th June, 2020 \r\n546 \r\n Division XIV \r\nAdvance tax on sale to distributors, dealers or wholesalers \r\n546 \r\n Division XV \r\nAdvance tax on sale to retailers \r\n548 \r\n Division XVA \r\nOmitted by the Finance Act, 2021 \r\n548 \r\n Division XVI \r\nOmitted by the Finance Act, 2022 \r\n548 \r\n Division XVII \r\nOmitted through Finance Act, 2020 dated 30th June, 2020 \r\n548 \r\n Division XVIII \r\nAdvance Tax on purchase of immoveable property \r\n549 \r\n Division XIX \r\nOmitted by the Finance Act, 2021 \r\n553 \r\n Division XX \r\nOmitted by the Finance Act, 2021 \r\n553 \r\n Division XXI \r\nOmitted by the Finance Act, 2021 \r\n553 \r\n Division XXII \r\nOmitted by the Finance Act, 2016 \r\n553 \r\n Division XXIII \r\nOmitted by the Finance Act, 2022 \r\n554 \r\n Division XXIV \r\nomitted through Finance Act, 2020 dated 30th June, 2020 \r\n554 \r\n Division XXV \r\nOmitted through Finance Act, 2020 dated 30th June, 2020 \r\n554 \r\n Division XXVI \r\nOmitted by the Finance Act, 2021 \r\n554 \r\n Division XXVII \r\nAdvance tax on amount remitted abroad through credit, \r\ndebit or prepaid cards  \r\n554 \r\n Division XXVII \r\nOmitted by the Finance Act, 2021 \r\n554 \r\n Division XXVII \r\nAdvance tax on amount remitted abroad through credit, \r\ndebit or prepaid cards  \r\n554 \r\n THE SECOND SCHEDULE \r\n EXEMPTIONS AND TAX CONCESSIONS \r\n555 \r\n PART I \r\nEXEMPTIONS FROM TOTAL INCOME \r\n555 \r\n PART II \r\nREDUCTION IN TAX RATES \r\n609 \r\n PART III \r\nREDUCTION IN TAX LIABILITY \r\n624 \r\n PART IV \r\nEXEMPTION FROM SPECIFIC PROVISIONS \r\n631 \r\n THE THIRD SCHEDULE 700 \r\n PART I \r\nDEPRECIATION \r\n700 \r\n PART II \r\nINITIAL ALLOWANCE AND FIRST YEAR ALLOWANCE \r\n702 \r\n PART III \r\nPRE-COMMENCEMENT EXPENDITURE \r\n702 \r\n THE FOURTH SCHEDULE \r\nRULES FOR THE COMPUTATION OF THE PROFITS AND \r\nGAINS OF INSURANCE BUSINESS \r\n703 \r\n     THE FIFTH SCHEDULE                                                                      708 \r\n PART I \r\nRULES FOR THE COMPUTATION OF THE PROFITS AND \r\nGAINS FROM THE EXPLORATION AND PRODUCTION OF \r\nPETROLEUM \r\n708 \r\n PART II \r\nRULES FOR THE COMPUTATION OF THE PROFITS AND \r\nGAINS FROM THE EXPLORATION AND EXTRACTION OF \r\nMINERALS DEPOSITS (OTHER THAN PETROLEUM) \r\n714 \r\nTHE SIXTH SCHEDULE                                                                    717 \r\n PART I \r\nRECOGNIZED PROVIDENT FUNDS \r\n717 \r\n PART II \r\nAPPROVED SUPERANNUATION FUNDS \r\n726 \r\n PART III \r\nAPPROVED GRATUITY FUNDS \r\n730 \r\nTHE SEVENTH SCHEDULE                                                              733 \r\n RULES FOR THE  \r\nCOMPUTATION OF THE PROFITS AND GAINS OF A \r\nBANKING COMPANY AND TAX PAYABLE THEREON \r\n \r\n733 \r\nTHE EIGHTH SCHEDULE                                                                      753 \r\n RULES FOR THE COMPUTATION OF CAPITAL GAINS ON \r\nLISTED SECURITIES \r\n753 \r\n \r\n \r\nTHE NINTH SCHEDULE                                                                       757 \r\n PART I \r\nRULES FOR THE COMPUTATION OF THE PAYABLE ON \r\nPROFITS AND GAINS OF A TRADER FALLING UNDER SUB-\r\nSECTION (1) OF SECTION 99A \r\n757 \r\n PART II \r\nRULES FOR THE COMPUTATION OF THE PAYABLE ON \r\nPROFITS AND GAINS OF A TRADER FALLING UNDER SUB-\r\nSECTION (2) OF SECTION 99A \r\n758 \r\n PART III \r\nGENERAL PROVISIONS FOR THE TRADERS UNDER PART I \r\nAND PART II \r\n758 \r\n \r\n THE TENTH SCHEDULE \r\nRULES FOR PERSONS NOT APPEARING IN THE ACTIVE \r\nTAXPAYERS’ LIST \r\n763 \r\n ELEVENTH SCHEDULE \r\nRULES FOR COMPUTATION OF PROFITS AND GAINS OF \r\nBUILDERS AND DEVELOPERS AND TAX PAYABLE \r\nTHEREON \r\n771 \r\n THE TWELFTH SCHEDULE 777 \r\n THE THIRTEENTH SCHEDULE 797 \r\n FOURTEENTH SCHEDULE \r\nRULES FOR COMPUTATION OF PROFIT AND GAINS FOR \r\nSMALL AND MEDIUM ENTERPRISES \r\n800 \r\n FIFTEENTH SCHEDULE  \r\n THRESHOLD FOR ECONOMIC TRANSACTIONS 802 \r\n  \r\nChapter I – Preliminary__________________________________ \r\n \r\n1 \r\n \r\nF.No.2(1)/2001—Pub.— The following Ordinance promulgated by the President is \r\nhereby  published for general information:— \r\n \r\nAN \r\n \r\nORDINANCE \r\n \r\nTo consolidate and amend the law relating to income tax \r\n \r\n WHEREAS it is expedient to consolidate and amend the law relating to \r\nincome tax and to provide for matters ancillary thereto or connected therewith; \r\n \r\n WHEREAS the President is satisfied that circumstances exist which render \r\nit necessary to take immediate action; \r\n \r\n NOW, THEREFORE, in pursuance of the Proclamation of Emergency of the \r\nfourteenth day of October, 1999, and the Provisional Const itution Order No. 1 of \r\n1999, read with Provisional Constitutional Amendment Order No. 9 of 1999, and \r\nin exercise of all powers enabling him in that behalf, the President of the Islamic \r\nRepublic of Pakistan is pleased to make and promulgate the following \r\nOrdinance:— \r\n \r\nCHAPTER I \r\nPRELIMINARY \r\n \r\n1. Short title, extent and commencement. —(1) This  Ordinance may be \r\ncalled the Income Tax Ordinance, 2001. \r\n \r\n(2) It extends to the whole of Pakistan. \r\n \r\n(3) It shall come into force on such date as the Federal Government may, \r\nby notification in official Gazette, appoint. \r\n \r\n2. Definitions. — In this Ordinance, unless there is anything repugnant in the \r\nsubject or context — \r\n \r\n(1) \"accumulated profits\" in relation to 1[distribution or payment of] a \r\ndividend, 2[include] — \r\n \r\n                                            \r\n*Vide notification S.R.O.381(I)/2002 dated 15.06.2002 the Federal Government appointed the first  day \r\nof July, 2002 on which the Ordinance shall come into force.  \r\n1 Inserted by the Finance Act, 2003. \r\n2 The word “includes” substituted by the Finance Act, 2005. \r\nChapter I – Preliminary__________________________________ \r\n \r\n2 \r\n \r\n(a) any re serve made up wholly or partly of any allowance, \r\ndeduction, or exemption admissible under this Ordinance; -\r\n.9230 \r\n \r\n(b) for the purposes of 1[sub-clauses (a), (b) and (e) of clause (19)”] \r\nall profits of the company including income and gains of a trust \r\nup to the date of such distribution or such payment, as the case \r\nmay be; and \r\n \r\n(c) for the purposes of 2[sub-clause (c) of clause (19)], includes all \r\nprofits of the company including income and gains of a trust up \r\nto the date of its liquidation; \r\n \r\n3[(1A) “active t axpayer’ list” means the list instituted by the Board under \r\nSection 181A and includes such list issued by the Azad Jammu and Kashmir \r\nCentral Board of Revenue or Gilgit-Baltistan Council Board of Revenue;] \r\n    \r\n4[5(1B) “amalgamation” means the merger of one or more banking companies \r\nor non-banking financial institutions, 6[or insurance companies,] 7[or \r\ncompanies owning and managing industrial undertakings] 8[or \r\ncompanies engaged in providing services and not being a trading \r\ncompany or companies] in either case 9[at least one of them] being a \r\npublic company, or a company incorporated under any law, other than \r\n10[Companies Act, 2017 (XIX of 2017)], for the time being in force, (the \r\ncompany or companies which so merge being referred to as the \r\n“amalgamating company” or companies and the company with which \r\nthey merge or which is formed as a result of merger, as the \r\n“amalgamated company”) in such manner that – \r\n \r\n(a) the assets of the amalgamating company or companies \r\nimmediately before the amalgamation become the assets of the \r\namalgamated company by virtue of the amalgamation, \r\notherwise than by purchase of such assets by the amalgamated \r\n                                            \r\n1 Clauses (a), (d) and (e) of sub-section (20) substituted by the Finance Act, 2002. \r\n2 Clause (c) of sub-section (20) substituted by the Finance Act, 2002. \r\n3 Clause 1A inserted through Finance Act, 2019. \r\n4 Inserted by the Finance Act, 2002. \r\n51A renumbered by 1B by the Finance Act, 2019. \r\n6 Inserted by the Finance Act, 2004. \r\n7 Inserted by the Finance Act, 2005. \r\n8Inserted by the Finance Act, 2007. \r\n9 Inserted by the Finance Act, 2005. \r\n10 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \r\n2021. \r\nChapter I – Preliminary__________________________________ \r\n \r\n3 \r\n \r\ncompany or as a result of distribution of such assets to the \r\namalgamated company after the winding up of the \r\namalgamating company or companies; 1[and] \r\n \r\n(b) the liabilities of the amalgamating company or companies \r\nimmediately before the amalgamation become the liabilities of \r\nthe amalgamated company by virtue of the amalgamation 2[.]  \r\n \r\n  3[  ] \r\n \r\n4[(2)  “Appellate Tribunal” means the Appellate Tribunal Inland Revenue \r\nestablished under section 130;] \r\n \r\n(3) “approved gratuity fund” means a gratuity fund approved by the \r\nCommissioner in accordance with Part III of the Sixth Schedule; \r\n \r\n5[(3A)  “Approved Annuity Plan”  means an Annuity Plan approved by  \r\nSecurities and Exchange Commission of Pakistan (SECP) under \r\nVoluntary Pension System Rules, 2005 and offered by a Life \r\nInsurance Company registered with the SECP under Insurance \r\nOrdinance, 2000 (XXXIX of 2000);] \r\n \r\n6[(3B)  “Approved Income Payment Plan” mea ns an Income Payment Plan \r\napproved by Securities and Exchange Commission of Pakistan \r\n(SECP) under Voluntary Pension System Rules, 2005 and offered by \r\na Pension Fund Manager registered with the SECP under Voluntary \r\nPension System Rules, 2005;] \r\n \r\n7[(3C)  “Approved Pension Fund” means Pension Fund approved by \r\nSecurities and Exchange Commission of Pakistan (SECP) under \r\nVoluntary Pension System Rules, 2005, and managed by a Pension \r\n                                            \r\n1 Added by the Finance Act, 2005. \r\n2 The semi-colon and word “and” substituted by the Finance Act, 2005. \r\n3 Clause (c) omitted by the Finance Act, 2005. The omitted clause (c) read as follows: - \r\n“(c) the scheme of amalgamation is approved by the State Bank of Pakistan or by the Securities \r\nand Exchange Commission of Pakistan on or before thirtieth day of June, 2006;” \r\n4 Substituted by the Finance Act, 2010. The substituted provision has been made effective from \r\n05.06.2010 by sub -clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \r\nmade through Finance (Amendment) Ordinance, 2009 which was re -promulgated as Finance \r\n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. Clause (2) before substitution \r\nby the Finance (Amendment) Ordinance, 2009 read as follows: \r\n“(2) “Appellate Tribunal” means the Appellate Tribunal Inland Revenue established under section \r\n130;”.  \r\n5 Inserted by the Finance Act, 2005. \r\n6 Inserted by the Finance Act, 2005. \r\n7 Inserted by the Finance Act, 2005. \r\nChapter I – Preliminary__________________________________ \r\n \r\n4 \r\n \r\nFund Manager registered with the SECP under Voluntary Pension \r\nSystem Rules, 2005;] \r\n \r\n1[(3D)  “Approved Employment Pension or Annuity Scheme” means any \r\nemployment related retirement scheme approved under this \r\nOrdinance, which makes periodical payment to a beneficiary i.e. \r\npension or annuity such as approved superannuation fund, public \r\nsector pension scheme and Employees Old-Age Benefit Scheme;] \r\n \r\n2[(3E)  “Approved Occupational Savings Scheme” means any approved \r\ngratuity fund or recognized provident fund;]  \r\n \r\n(4) “approved superannuation fund” means a superannuation fund, or any \r\npart of a sup erannuation fund, approved by the Commissioner in \r\naccordance with Part II of the Sixth Schedule; \r\n \r\n3[(5)  “assessment” includes 4[provisional assessment,] re-assessment and \r\namended assessment and the cognate expressions shall be \r\nconstrued accordingly;] \r\n \r\n5[(5A)  “assessment year” means assessment year as defined in the repealed \r\nOrdinance;] \r\n \r\n6[(5B) “asset management company” means an asset management \r\ncompany as defined in the Non -Banking Finance Companies and \r\nNotified Entities Regulations, 2007;] \r\n \r\n7[(5C) “assets move” means the transfer of an offshore asset to an \r\nunspecified jurisdiction by or on behalf of a person who owns, \r\n                                            \r\n1Inserted by the Finance Act, 2006. \r\n2Inserted by the Finance Act, 2006 \r\n3 Clause (5) substituted by the Finance Act, 2002. The substituted clause read as follows: \r\n“(5) “assessment” means – \r\n(a) an assessment referred to in section 120; \r\n(b) an assessment raised under section 121; \r\n(c) an amended assessment under section 122; \r\n(d) a demand for an amount due under sections 141, 142, 143 and 144; or  \r\n(e) an assessment of penalty under section 190;”.  \r\n4Inserted by the Finance Act, 2011. \r\n5Inserted by the Finance Act, 2002  \r\n6Clause (5B) substituted by the Finance Act, 2008. The substituted clause (5B) read as follows: \r\n“(5B) “assets management company” means a company registered under the Assets Management \r\ncompanies Rules, 1995;” \r\n7 Clause (5C) inserted by Finance Act, 2019 \r\nChapter I – Preliminary__________________________________ \r\n \r\n5 \r\n \r\npossesses, controls or is the beneficial owner of such offshore assets \r\nfor the purpose of tax evasion;] \r\n \r\n(6) “association of persons” means an association of persons as defined \r\nin section 80; \r\n \r\n(7) “banking company” means a banking company as defined in the \r\nBanking Companies Ordinance, 1962 (LVII of 1962) 1[  ]; \r\n \r\n2[(7A) “beneficial owner” means a natural person who – \r\n(a) ultimately owns or controls a Company or association of persons, \r\nwhether directly or indirectly, through at least twenty five percent \r\nshares or voting rights; or  \r\n \r\n(b) exercise ultimate effective control, through direct or indirect \r\nmeans, over the company or association of persons inc luding \r\ncontrol over the finances or decisions or other affairs of the \r\ncompany or association of persons;] \r\n \r\n3[(8) “Board” means the Central Board of Revenue established under the \r\nCentral Board of Revenue Act, 1924 (IV of 1924), and on the \r\ncommencement of Federal Board of Revenue Act, 2007, the Federal \r\nBoard of Revenue established under section  3 thereof 4[and includes \r\na Member of the Federal Board of Revenue to whom powers of the \r\nBoard have been delegated under section 8 of the Federal Board of \r\nRevenue Act, 2007;]; \r\n \r\n(9) “bonus shares” includes bonus units in a unit trust; \r\n \r\n(10) “business” includes any trade, commerce, manufacture, profession, \r\nvocation or adventure or concern in the nature of trade, commerce, \r\nmanufacture, profession or vocation, but does not include employment; \r\n \r\n5[(10A) “business bank account” means a bank account utilized by the taxpayer  \r\nfor business transaction declared to the Commissioner through original \r\nor modified registration form prescribed under section 181;] \r\n \r\n(11)] “capital asset” means a capital asset as defined in section 37; \r\n \r\n                                            \r\n1 Expression “and includes anybody corporate which transacts the business of banking in Pakistan ” \r\nomitted by the Finance Act, 2025. \r\n2 Clause (7A) Inserted by the Finance Act, 2022. \r\n3Clauses (8), (9), (10) and (11) re -numbered as clauses (9), (10), (11) and (8) respectively by the \r\nFinance Act, 2014. \r\n4 Expression inserted by the Finance Act, 2024. \r\n5 Clause (10A) inserted by the Finance Act, 2021. \r\nChapter I – Preliminary__________________________________ \r\n \r\n6 \r\n \r\n1[(11A) “charitable purpose” includes relief of the poor, education, medical relief \r\nand the advancement of any other object of general public utility;] \r\n \r\n 2[(11B) “Chief Commissioner” means a person appointed a s Chief                    \r\nCommissioner Inland Revenue under section 208 and includes a  \r\n3[Chief Investigator,]  Regional Commissioner of Income Tax and a \r\nDirector-General of Income Tax and Sales Tax;] \r\n \r\n4[(11C) “Collective Investment Scheme” shall have the same meanings as are \r\nassigned under the Non-Banking Finance Companies (Establishment \r\nand Regulation) Rules, 2003;] \r\n \r\n(12) “company” means a company as defined in section 80; \r\n \r\n5[(13)  “Commissioner” means a person appointed as Commissioner Inland \r\nRevenue under section 208 and includes any other authority vested with \r\nall or any of the powers and functions of the Commissioner;] \r\n \r\n6[(13A)  “Commissioner (Appeals)” means a person appointed as Commissioner \r\nInland Revenue (Appeals) under section 208;] \r\n \r\n 7[(13AA) concealment of income includes –  \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2002. \r\n2 Substituted by the Finance Act, 2010. The substituted pro vision has been made effective from \r\n05.06.2010 by sub -clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \r\nmade through Finance (Amendment) Ordinance, 2009 which was re -promulgated as Finance \r\n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. The substituted clause (11B) \r\nread as follows: \r\n“(11B) “Chief Commissioner” means a person appointed as Chief Commissioner Inland  \r\nRevenue under section 208 and includes a Regional Commissioner of Income Tax and \r\na Director-General of Income Tax and Sales Tax.” \r\n3 Expression inserted by the Finance Act, 2024. \r\n4Inserted by the Finance Act, 2011. \r\n5Substituted by the Finance Act, 2010. The substituted provision has been made effective from \r\n05.06.2010 by sub -clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \r\nmade through Finance (Amendment) Ordinance, 2009 which was re -promulgated as Finance \r\n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. The substituted Clause (13) \r\nread as   follows: \r\n“(13)  Commissioner” means a person appointed as Commissioner Inland Revenue under \r\nsection 208, and includes any other authority vested with all or any of the powers and \r\nfunctions of the Commissioner;”. \r\n6Substituted by the Finance Act, 2010. The substituted pr ovision has been made effective from \r\n05.06.2010 by sub -clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \r\nmade through Finance (Amendment) Ordinance, 2009 which was re -promulgated as Finance \r\n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010.  The substituted Clause (13A) \r\nread as follows: \r\n“(13A)  “Commissioner (Appeals)” means a person appointed as Commissioner Inland \r\nRevenue (Appeals) under section 208; \r\n7 New clause (13AA) inserted by the Finance Act, 2021. \r\nChapter I – Preliminary__________________________________ \r\n \r\n7 \r\n \r\n(a) the suppression of any item of receipt liable to tax in whole or in  \r\npart, or failure to disclose income chargeable to tax; \r\n \r\n(b)  claiming any deduction or any expenditure not actually incurred;  \r\n \r\n(c)  any act referred to in sub-section (1) of section 111; and  \r\n \r\n(d) claiming of any income or receipt as exempt which is otherwise     \r\ntaxable.  \r\n \r\nExplanation.- For removal of doubt it is clarified that none of the \r\naforementioned acts would constitute concealment of income \r\nunless it is proved that taxpayer has knowingly and w illfully \r\ncommitted these acts;] \r\n \r\n1[2[(13AB)] “consumer goods ” means goods that are consumed by the end \r\nconsumer rather than used in the production of another good;”] \r\n \r\n3[(13B)  “Contribution to an Approved Pen sion Fund” means contribution as \r\ndefined in rule 2(j) of the Voluntary Pension System Rules, 2005 4[ ];] \r\n \r\n(14) “co-operative society” means a co -operative society registered under \r\nthe Co-operative Societies Act, 1925 (VII of 1925) or under any other \r\nlaw for the time being in force in Pakistan for the registration of co -\r\noperative societies; \r\n \r\n(15) “debt” means any amount owing, including accounts payable and the \r\namounts owing under promissory notes, bills of exchange, \r\ndebentures, securities, bonds or other financial instruments; \r\n \r\n(16) “deductible allowance” means an allowance that is deductible from \r\ntotal income under Part IX of Chapter III; \r\n \r\n(17) “depreciable asset” means a depreciable asset as defined in section 22; \r\n \r\n5[17A. ”Developmental REIT Scheme ” means D evelopmental REIT \r\nScheme as defined under the Real Estate Investment Trust \r\nRegulations, 2015;] \r\n \r\n6[(17B) \"digital means\" means digital payments and financial services \r\nincluding but not limited to — online portals or platforms for digital \r\npayments/receipts; online interbank fund transfer services; online bill \r\n                                            \r\n1Inserted by the Finance Act, 2015 \r\n2 Clause (13AA) re-numbered as clause (13AB) by the Finance Act, 2021. \r\n3 Inserted by the Finance Act, 2005. \r\n4The comma and words “, but not exceeding five hundred thousand rupees in a tax year” omitted by \r\nthe Finance Act, 2006. \r\n5Inserted by the Finance Act, 2015 \r\n6 Clause (17B) Inserted through Finance (Supplementary) Act, 2022. \r\nChapter I – Preliminary__________________________________ \r\n \r\n8 \r\n \r\nor invoice presentment and payment services; over the Counter \r\ndigital payment services or facilities; card payments using Point of \r\nSale terminals, QR codes, mobile devices, ATMs, Kiosk or any other \r\ndigital; payments enabled devices; or any other digital or online \r\npayment modes.] \r\n \r\n1[(17C) “digitally delivered services ” means any service delivered over the \r\ninternet or electronic networks, where the delivery is automated and \r\nrequires minimal or no human intervention including music, audio and \r\nvideo streaming services, cloud services, online software applications \r\nservices, services delivered through online inter -personal interaction \r\ni.e., tele medicines, e -learning etc., online banking services, \r\narchitectural d esign services, research and consultancy reports, \r\naccounting services in the form of digital files or any other online \r\nfacility;] \r\n \r\n(18) “disposal” in relation to an asset, means a disposal as defined in \r\nsection 75; \r\n \r\n2[(18A) “distributor” means a person app ointed by a manufacturer, importer \r\nor any other person for a specified area to purchase goods from him \r\nfor further supply;] \r\n \r\n(19) “dividend” includes — \r\n \r\n(a) any distribution by a company of accumulated profits to its \r\nshareholders, whether capitalised or no t, if such distribution \r\nentails the release by the company to its shareholders of all or \r\nany part of the assets including money of the company; \r\n(b) any distribution by a company, to its shareholders of \r\ndebentures, debenture-stock or deposit certificate in any form, \r\nwhether with or without profit, 3[ ] to the extent to which the \r\ncompany possesses accumulated profits whether capitalised or \r\nnot; \r\n \r\n(c) any distribution made to the shareholders of a company on its \r\nliquidation, to the extent to which the distribut ion is attributable \r\nto the accumulated profits of the company immediately before \r\nits liquidation, whether capitalised or not; \r\n(d) any distribution by a company to its shareholders on the \r\nreduction of its capital, to the extent to which the company \r\n                                            \r\n1 Clause (17C) inserted by the Finance Act, 2025. \r\n2 Clause (18A) Inserted by the Finance Act, 2022. \r\n3 The words  “and any distribution to its shareholders of shares by way of bonus or bonus shares”, \r\nomitted by the Finance Act, 2002 \r\nChapter I – Preliminary__________________________________ \r\n \r\n9 \r\n \r\npossesses accumulated profits, whether such accumulated \r\nprofits have been capitalised or not; 1[  ] \r\n \r\n(e) any payment by a private company 2[as defined in the \r\n3[Companies Act, 2017 (XIX of 2017)] ] or trust of any sum \r\n(whether as representing a part of the assets of the company or \r\ntrust, or otherwise) by way of advance or loan to a shareholder \r\nor any payment by any such company or trust on behalf, or for \r\nthe individual benefit, of any such shareholder, to the extent to \r\nwhich the company or trust, in either case, possess es \r\naccumulated profits;4[or] \r\n \r\n5[(f)  6[remittance of] after tax profit of a branch of a foreign company \r\noperating in Pakistan;] \r\n \r\nbut does not include — \r\n \r\n(i) a distribution made in accordance with 7[sub-clause] (c) \r\nor (d) in respect of any share for full ca sh consideration, \r\nor redemption of debentures or debenture stock, where \r\nthe holder of the share or debenture is not entitled in the \r\nevent of liquidation to participate in the surplus assets; \r\n \r\n(ii) any advance or loan made to a shareholder by a company \r\nin the ordinary course of its business, where the lending \r\nof money is a substantial part of the business of the \r\ncompany; 8[ ]  \r\n \r\n(iii) any dividend paid by a company which is set off by the \r\ncompany against the whole or any part of any sum \r\npreviously paid by it and treated as a dividend within the \r\nmeaning of 9[sub-clause] (e) to the extent to which it is so \r\nset off;10[and] \r\n                                            \r\n1The word ‘or’ omitted by Finance Act, 2008. \r\n2 Inserted by the Finance Act, 2003. \r\n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \r\n2021. \r\n4The word ‘or’ added by the Finance Act, 2008. \r\n5Inserted by the Finance Act, 2008. \r\n6The word “any” substituted by the Finance Act, 2009. \r\n7 Substituted for “clause” by the Finance Act, 2002 \r\n8The word “and” omitted by the Finance Act, 2009. \r\n9 The word  “clause” substituted by the Finance Act, 2002 \r\n10The word “and” inserted by the Finance Act, 2009. \r\nChapter I – Preliminary__________________________________ \r\n \r\n10 \r\n \r\n \r\n1[(iv)  remittance of after tax profit by a branch of Petroleum  \r\nExploration and Production (E&P) foreign company, \r\noperating in Pakistan.] \r\n \r\n2[(19A) “Eligible Person”, for the purpose of Voluntary Pension System Rules, \r\n2005, means an individual Pakistani who 3[holds] a valid National Tax \r\nNumber4[or Computerized National Identity Card 5[or National Identity \r\nCard for Overseas Pakistanis]  issued by t he National Database and \r\nRegistration Authority] 6[ ]7[:]] \r\n \r\n8[Provided that the total tax credit available for the contribution made to \r\napproved employment pension or annuity scheme and approved \r\npension fund under Voluntary Pension System Rules, 2005, should not \r\nexceed the limit prescribed or specified in section 63.] \r\n \r\n9[(19AA) “e-commerce” means sale or purchase of goods and services \r\nconducted over computer networks by methods specifically designed \r\nfor the purpose of receiving or placing of orders either t hrough \r\nwebsites, mobile applications or online marketplace having digital \r\nordering features by using either mobile phone, iPad, Tablet or \r\nautomated computer-to-computer ordering system;] \r\n \r\n10[(19B)  The expressions “addressee”, “automated”, “electronic”, “el ectronic \r\nsignature”, “information”, “information system”, “originator” and \r\n“transaction”,  shall have the same meanings as are assigned to them \r\nin the Electronic Transactions Ordinance, 2002 (LI of 2002);] \r\n \r\n11[(19C)  “electronic record” includes the content s of communications, \r\ntransactions and procedures under this Ordinance, including \r\nattachments, annexes, enclosures, accounts, returns, statements, \r\ncertificates, applications, forms, receipts, acknowledgements, notices, \r\n                                            \r\n1Added by the Finance Act, 2009. \r\n2 Inserted by the Finance Act, 2005. \r\n3 The words “has obtained” substituted by the Finance Act, 2007. \r\n4 Inserted by the Finance Act, 2007. \r\n5Inserted by the Finance Act, 2008.  \r\n6The words “ but does not include an individual who is entitled to benefit under any other approved \r\nemployment pension or annuity scheme” omitted by the Finance Act, 2006. \r\n7The semicolon substituted by the Finance Act, 2006. \r\n8Inserted by the Finance Act, 2006. \r\n9 Clause (19AA) inserted by the Finance Act, 2025. \r\n10 Inserted by the Finance Act, 2008. \r\n11New clause (19C) inserted by Finance Act, 2008. \r\nChapter I – Preliminary__________________________________ \r\n \r\n11 \r\n \r\norders, judgments, approvals, notifica tions, circulars, rulings, \r\ndocuments and any other information associated with such \r\ncommunications, transactions and procedures, created, sent, \r\nforwarded, replied to, transmitted, distributed, broadcast, stored, held, \r\ncopied, downloaded, displayed, viewed,  read, or printed, by one or \r\nseveral electronic resources and any other information in electronic \r\nform;] \r\n \r\n1[(19D) “electronic resource” includes telecommunication systems, transmission \r\ndevices, electronic video or audio equipment, encoding or decoding \r\nequipment, input, output or connecting devices, data processing or \r\nstorage systems, computer systems, servers, networks and related \r\ncomputer programs, applications and software including databases, \r\ndata warehouses and web portals as may be prescribed by the Board \r\nfrom time to time, for the purpose of creating electronic record;] \r\n \r\n2[(19E)  “telecommunication system” includes a system for the conveyance, \r\nthrough the agency of electric, magnetic, electro -magnetic, electro -\r\nchemical or electro -mechanical energy, of speech, music and other \r\nsounds, visual images and signals serving for the impartation of any \r\nmatter otherwise than in the form of sounds or visual images and also \r\nincludes real time online sharing of any matter in manner and mode \r\nas may be prescribed by the Board from time to time.] \r\n \r\n(20) “employee” means any individual engaged in employment; \r\n \r\n(21) “employer” means any person who engages and remunerates an \r\nemployee; \r\n \r\n(22) “employment” includes – \r\n \r\n(a) a directorship or any other office involved in the management of \r\na company; \r\n \r\n(b) a position entitling the holder to a fixed or ascertainable \r\nremuneration; or \r\n \r\n(c) the holding or acting in any public office; \r\n \r\n3[(22A) “fast moving consumer goods ” means consumer goods which are \r\nsupplied in retail marketing as per d aily de mand of a \r\nconsumer4[excluding durable goods]. \r\n                                            \r\n1Inserted by the Finance Act, 2008. \r\n2Inserted by the Finance Act, 2008. \r\n3Inserted by the Finance Act 2015 \r\n4Inserted by the Finance Act 2017 \r\nChapter I – Preliminary__________________________________ \r\n \r\n12 \r\n \r\n \r\n1[(22AA) “fair market value” means value as provided in section 68;] \r\n \r\n2[(22B)  ”fee for offshore digital services” means any consideration for providing \r\nor rendering services by a non-resident person for online advertising \r\nincluding digital advertising space, designing, creating, hosting or \r\nmaintenance of websites, digital or cyber space for websites, \r\nadvertising, e-mails, online computing, blogs, online content and online \r\ndata, providing any facility or service for uploading, storing or \r\ndistribution of digital content including digital text, digital audio or digital \r\nvideo, online collection or processing of data re lated to users in  \r\nPakistan, any facility for online sale of goods or services or any other \r\nonline facility.] \r\n \r\n 3[(22C) “FBR Refund Settlement Company Limited” means the company with this \r\nname as incorporated under the Companies Act, 2017 (XIX of 2017), for \r\nthe purposes of settlement of income tax refund claims including payment \r\nby way of issuing refund bonds under section 171A;]  \r\n(23) “fee for technical services” means any consideration, whether \r\nperiodical or lump sum, for the rendering of any managerial, technical \r\nor consultancy services including the services of technical or other \r\npersonnel, but does not include — \r\n \r\n(a) consideration for services rendered in relation to a construction, \r\nassembly or like project undertaken by the recipient; or \r\n \r\n(b) consideration which would be income of the recipient \r\nchargeable under the head “Salary”; \r\n \r\n4[  ] \r\n \r\n(24) “financial institution” means an institution 5[as defined] under the \r\n6[Companies Act, 2017 (XIX of 2017)] ] 7[  ]; \r\n \r\n                                            \r\n1 Clause (22AA) Inserted by the Finance Act, 2022. \r\n2Inserted by the Finance Act 2018 \r\n3Clause (22C) Inserted by the Finance Act 2019  \r\n4Omitted by Finance Act 2019. The Omitted clause read as follow: \r\n(23A) “filer” means a taxpayer whose name appears in the active taxpayers’ list issued by the Board \r\n4[or Azad Jammu and Kashmir Council Board of Revenue or Gilgit-Baltistan Council Board of \r\nRevenue] from time to time or is holder of a taxpayer’s card; \r\n \r\n5 The word “notified” substituted by the Finance Act, 2005. \r\n6 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \r\n7 The words “by the Federal Government in the official Gazette as a financial institution” omitted by the \r\nFinance Act, 2003. \r\nChapter I – Preliminary__________________________________ \r\n \r\n13 \r\n \r\n(25) “finance society” includes a co-operative society which accepts money \r\non deposit or otherwise for the purposes of advancing loans or making \r\ninvestments in the ordinary course of business; \r\n \r\n(26) “firm” means a firm as defined in section 80; \r\n(27) “foreign-source income” means foreign -source income as defined in \r\nsub-section (16) of section 101. \r\n \r\n1[(27A) “greenfield industrial undertaking” means – \r\n \r\n(a) a new industrial undertaking which is – \r\n \r\n(i) setup on land which has not previously been utilized for any \r\ncommercial, industrial or manufacturing activity and is free from \r\nconstraints imposed by any prior work; \r\n \r\n(ii) built without demolishing, revamping, re novating, upgrading, \r\nremodeling or modifying any existing structure, facility or plant; \r\n(iii) not formed by the splitting up or reconstitution of an undertaking \r\nalready in existence or by transfer of machinery, plant or building \r\nfrom an undertaking established i n Pakistan prior to \r\ncommencement of the new business and is not part of an \r\nexpansion project; \r\n \r\n(iv) using any process or technology that has not earlier been used \r\nin Pakistan and is so approved by the Engineering Development \r\nBoard; and  \r\n \r\n(b) is approved by the Comm issioner on an application made in the \r\nprescribed form and manner, accompanied by the prescribed \r\ndocuments and, such other documents as may be required by the \r\nCommissioner: \r\n \r\nProvided that this definition shall be applicable from the 1st July, 2019 \r\nand onwards.]  \r\n \r\n(28) “House Building Finance Corporation” means the Corporation \r\nconstituted under the House Building Finance Corporation Act, 1952 \r\n(XVIII of 1952); \r\n \r\n                                            \r\n1  New clause (27A) inserted through Tax Laws (Second Amendment) Ordinance 2019 dated 26th \r\nDecember, 2019 \r\nChapter I – Preliminary__________________________________ \r\n \r\n14 \r\n \r\n1[(28A)  “imputable income” in relation to an amount subject to final tax means \r\nthe income which wo uld have resulted in the same tax, had this \r\namount not been subject to final tax;”] \r\n \r\n2[(29) “income” includes any amount chargeable to tax under this Ordinance, \r\nany amount subject to collection 3[or deduction] of tax under section \r\n148, 4[150, 152(1), 153, 154, 156, 156A, 233, 5[  ] ] 6[,] sub-section (5) \r\nof section 234  7[, section 236Z] 8[ ] 9[and] 10[any amount treated as \r\nincome under any provision of this Ordinance] and any loss of \r\nincome11[ ]; \r\n \r\n12[(29A) “income year” means income year as defined in the repe aled \r\nOrdinance;] \r\n \r\n13[(29B)  “Individual Pension Account” means an account maintained by an \r\neligible person with a Pension Fund Manager approved under the \r\nVoluntary Pension System Rules, 2005;] \r\n \r\n 14[(29C) “Industrial undertaking” means — \r\n                                            \r\n1Inserted by the Finance Act, 2015 \r\n2 Clause (29) substituted by the Finance Act, 2002. The substituted clause read as follows:  \r\n “(29) “income” includes any amount chargeable to tax under this Ordinance, any amount subject to \r\ncollection of tax under Division II of Part V of Chapter X, sub -section (5) of 234 Division III of \r\nChapter XII, and any loss of income;”  \r\n3 Inserted by the Finance Act, 2003. \r\n4 The figures, commas and word “153, 154 and 156,” substituted by the Finance Act, 2005. \r\n5 The expression “233A,” omitted by the Finance Act, 2021. \r\n6 The word “and” substituted by a comma by the Finance Act, 2014. \r\n7 The expression “, section 236Z” inserted by the Finance Act, 2023. \r\n8The word and figure “and 236M” substituted by a comma by the Finance Act, 2015 \r\n9The expression “, 236M and 236N,” substituted by the Finance Act, 2018 \r\n10 Inserted by the Finance Act, 2003. \r\n11Omitted by the Finance Act, 2014. The omitted text read as follows:  \r\n“but does not include, in case of a shareholder of a company, the amount representing the face \r\nvalue of any bonus share or the amount of any bonus declared, issued or paid by the company to  \r\nthe shareholders with a view to increasing its paid up share capital.” \r\n12 Inserted by the Finance Act, 2002. \r\n13 Inserted by the Finance Act, 2005. \r\n14Clause (29C) substituted by the Finance Act, 2010. The substituted clause (29C) read as follows:- \r\n “(29C) “Industrial undertaking” means – \r\n(a) an undertaking which is set up in Pakistan and which employs, (i) ten or more persons in \r\nPakistan and involves the use of electrical energy or any other form of energy which is \r\nmechanically transmitted and is not generated by human or animal energy; or (ii) twenty or more \r\npersons in Pakistan and does not involve the use of electrical energy or any other form of energy \r\nwhich is mechanically transmitted and is not generated by human or animal energy and which is \r\nengaged in,- \r\n (i) the manufacture of goods or materials or the subjection of goods or materials to any \r\nprocess which substantially changes their original condition; \r\nChapter I – Preliminary__________________________________ \r\n \r\n15 \r\n \r\n \r\n(a) an undertaking w hich is set up in Pakistan and which \r\nemploys,— \r\n \r\n(i) ten or more persons in Pakistan and involves the use \r\nof electrical energy or any other form of energy which is \r\nmechanically transmitted and is not generated by \r\nhuman or animal energy; or \r\n \r\n(ii) twenty or more perso ns in Pakistan and does not \r\ninvolve the use of electrical energy or any other form of \r\nenergy which is mechanically transmitted and is not \r\ngenerated by human or animal energy: \r\n \r\nand which is engaged in,— \r\n \r\n(i) the manufacture of goods or materials or the subjection \r\nof goods or materials to any process which substantially \r\nchanges their original condition; or  \r\n \r\n(ii) ship-building; or \r\n(iii) generation, conversion, transmission or distribution of \r\nelectrical energy, or the supply of hydraulic power; or \r\n \r\n(iv) the working of any mine, oil-well or any other source of \r\nmineral deposits; 1[  ] \r\n \r\n2[(aa) from the 1st day of May, 2020, a person directly involved in the \r\nconstruction of buildings, roads, bridges and other such \r\nstructures or the development of land, to the extent and for the \r\npurpose of import of plant and machinery to be utilized in such \r\nactivity, subject to such conditions as may be notified by the \r\nBoard; \r\n \r\n(ab) from the first day of July, 2020 a resident company engaged in \r\nthe hotel business in Pakistan;] 3[and] \r\n \r\n 4[  ]    ] \r\n                                            \r\n(ii) ship-building;  \r\n(iii)  generation, conversion, transmission or distribution of electrical energy, or the supply \r\nof hydraulic power; or \r\n(iv)  the working of any mine, oil-well or any other source of mineral deposits; and \r\n(b) any other industrial undertaking which the Board may by notification in the official Gazette, \r\nspecify;”. \r\n1 The word “and” omitted through Finance Act, 2020 dated 30.06.2020. \r\n2 New sub-clauses inserted through Finance Act, 2020 dated 30th June, 2020. \r\n3 The word “and” added by the Finance Act, 2021. \r\n4 Sub-clause (b) omitted by the Finance Act, 2021. Earlier this sub -clause was omitted t hrough Tax \r\nLaws (Second Amendment) Ordinance, 2021. The omitted sub-clause read as follows: \r\nChapter I – Preliminary__________________________________ \r\n \r\n16 \r\n \r\n \r\n 1[(c) telecommunication companies operating under the license of \r\nPakistan Telecommunication Authority (PTA).;] \r\n \r\n(30) “intangible” means an intangible as defined in section 24; \r\n \r\n2[(30A) “integrated enterpris e” means a person integrated with the Board \r\nthrough approve d fiscal electronic device and software, and who \r\nfulfills obligations and requirements for integration as may be \r\nprescribed;] \r\n \r\n3[4[(30AA)] “investment company” means an investment company as defined in \r\nthe Non -Banking Finance Companies (Establishment and \r\nRegulation) Rules, 2003;] \r\n \r\n5[6[(30AB)] KIBOR means Karachi Inter Bank Offered Rate prevalent on the  \r\nfirst day of each quarter of the financial year;] \r\n \r\n7[(30AC) “Iris” means a web based computer programme for operation and \r\nmanagement of Inland Revenue taxes and laws administered by the \r\nBoard;] \r\n \r\n8[(30AD)   Information Technology (IT) services include  9[but not limited to ] \r\nsoftware development, software maintenance, system integration, \r\nweb design, web development, web hosting and network design; \r\nand  \r\n \r\n(30AE)        IT enabled services include 10[but not limited to] inbound or outbound \r\ncall centres, medical transcription, remote monitoring, graphics \r\ndesign, accounting services, Human Resource (HR) services, \r\ntelemedicine centers, data entry operations, cloud compu ting \r\n                                            \r\n“(b)  any other industrial undertaking which the Board may by notification in the official gazette, \r\nspecify.” \r\n1 Clause (c) added by the Finance Act, 2021. \r\n2 New sub-clause (30A) inserted through Finance Act, 2020 dated 30th June, 2020 \r\n3 Clause (30A) substituted  by the Finance Act, 2008. The substituted clause (30A) read as follows: \r\n“ (30A) “investment company” means a company registered under the Investment Companies and \r\nInvestment Advisors Rules, 1971;” \r\n4 Clause (30A) renumbered as clause (30AA)  through Finance Act, 2020 dated 30th June, 2020 \r\n5Inserted by the Finance Act, 2009. \r\n6 Clause (30AA) renumbered as (30AB) through Finance Act, 2020 dated 30th June, 2020 \r\n7 New clause (30AC) inserted through Finance Act, 2020 dated 30th June,2020 \r\n8 Clauses (30AD) and (30AE) inserted by the Finance Act, 2021. \r\n9 Inserted by the Finance Act, 2022. \r\n10 Inserted by the Finance Act, 2022. \r\nChapter I – Preliminary__________________________________ \r\n \r\n17 \r\n \r\nservices, data storage services, locally produced television \r\nprograms and insurance claims processing;] \r\n \r\n1[(30B)  “leasing company” means a leasing company as defined in the Non-\r\nBanking Finance Companies and Notified Entities Regulation, 2007;] \r\n \r\n2[(30C)  “liaison office” means a place of business acting for the principal, head \r\noffice or any entity of which it is a part, and \r\n \r\n(a) its activities do not result in deriving income in Pakistan; and \r\n \r\n(b) maintains itself out of any amount remitted from outside \r\nPakistan received through normal banking channels. \r\n \r\nExplanation,—  It is clarified that— \r\n \r\n(i) a place of business shall not be treated as liaison office if \r\nit engages in -  \r\n \r\n(a) commercial activities;  \r\n(b) trading or industrial activities; or \r\n(c) the negotiation and conclusion of contracts; \r\n \r\n(ii) the activities shall be treated to be commercial activities, if \r\nthese include— \r\n \r\n(a) providing after sales services for goods or services; \r\nor \r\n \r\n(b) marketing or promoting pharmaceutical and medical \r\nproducts or services; \r\n \r\n(iii) subject to clau se (i), a place of business shall be treated \r\nas a liaison office, if it undertakes activities of— \r\n \r\n(a) an exploratory or preparatory nature, to investigate \r\nthe possibilities of trading with, or in, Pakistan; \r\n \r\n(b) exploring the possibility of joint collaboration an d \r\nexport promotion; \r\n \r\n                                            \r\n1Clause (30B) substituted by the Finance Act, 2008. The substituted clause (30B) read as follows: \r\n“ (30B) “leasing company” means a company licensed under the Leasing Companies (Establishment \r\nand Regulation) Rules, 2000; \r\n2Inserted by the Finance Act, 2017. \r\nChapter I – Preliminary__________________________________ \r\n \r\n18 \r\n \r\n(c) promoting  products where such products are yet to \r\nbe supplied to, or sold in, Pakistan; \r\n \r\n(d) promoting technical and financial collaborations \r\nbetween  its principal and taxpayers in Pakistan;  or \r\n \r\n(e) provision of technical advice and assistance.] \r\n \r\n(31) “liquidation” in relation to a company, includes the termination of a \r\ntrust; \r\n \r\n1[(31A) “Local Government” shall have the same meaning for respective \r\nprovisions and Islamabad Capital Territory as contained in the \r\nBalochistan Local Government Act,2010 (V of 2010), the Khyber \r\nPakhtunkhwa Local Government Act, 2013 (XXVIII of 2013), the Sindh \r\nLocal Government Act, 2013 (XLII of 2013), the Islamabad Capital \r\nTerritory Local Gover nment Act, 201 5 (X of 201 5) and  the Punjab \r\nLocal Government Act, 2019(XIII of 2019)] \r\n(32) “member” in relation to an association of persons, includes a partner \r\nin a firm; \r\n \r\n(33) “minor child” means an individual who is under the age of eighteen \r\nyears at the end of a tax year; \r\n \r\n(34) “modaraba” means a modaraba as defined in the Modaraba Companies \r\nand Modarabas (Floatation and Control) Ordinance, 1980 (XXXI of \r\n1980); \r\n \r\n(35) “modaraba certificate” means a modaraba certificate as defined in the \r\nModaraba Companies and Modarabas (Floatation and Control) \r\nOrdinance, 1980 (XXXI of 1980); \r\n \r\n2[(35A) “Mutual Fund” means a mutual fund 3[registered or approved by the \r\nSecurities and Exchange Commission of Pakistan];] \r\n \r\n                                            \r\n1 Clause (31A) is substituted through Finance Act 2020 dated 30th June, 2020 the substituted  clause \r\nread as follows: “(31A) “Local Government” shall have the same meaning as defined in the \r\nPunjab Local Government Ordinance, 2001 (XIII of 2001), the Sindh Local Government Ordinance, \r\n2001 (XXVII of 20 01), the NWFP Local Government Ordinance, 2001 (XIV of 2001) and the \r\nBalochistan Local Government Ordinance, 2001 (XVIII of 2001);” \r\n2 Inserted by the Finance Act, 2002 \r\n3 The  words “set up by the Investment Corporation of Pakistan or by an investment compa ny” \r\nsubstituted by the Finance Act, 2003. \r\nChapter I – Preliminary__________________________________ \r\n \r\n19 \r\n \r\n1[(35AA)  “NCCPL” means National Clearing Company of Pakistan Limited, \r\nwhich is a company incorporated under the 2[Companies Act, 2017 \r\n(XIX of 2017)] and licensed as “Clearing House” by the Securities and \r\nExchange Commission of Pakistan ,3[or any subsidiary of NCCPL \r\nnotified by the Board for the purpose of this clause] \r\n \r\n4[(35B) “non-banking finance company” means an NBFC as defined in the \r\nNon-Banking Finance Companies (Establishment and Regulation) \r\nRules, 2003;] \r\n \r\n5[  ] \r\n \r\n6[(36)  “non-profit organization” means any person other than an individual, \r\nwhich is — \r\n \r\n(a) established for religious, educational, charitable, welfare  \r\n7[purposes for general  public], or for the promotion of an \r\namateur sport 8[excluding recreational clubs where the joining \r\nfee for membership exceeds one million for any class of new \r\nmembers]; \r\n \r\n(b) formed and registered  9[by or]  under any law as a non -profit \r\norganization; \r\n \r\n(c) approved by the Commissioner for specified period, on an \r\napplication made by such person in the prescribed form and \r\nmanner, accompanied by the prescribed documents and, on \r\n                                            \r\n1Inserted by the Finance Act, 2012. \r\n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \r\n3Inserted by the Finance Act, 2017 \r\n4Clause (35B) substituted by the Finance Act, 2008. The substituted clause (35B) read as follows: \r\n“ (35B) “non-banking finance company” means an institution notified under the Non-Banking Finance \r\nCompanies (Establishment and Regulation) Rules, 2003.” \r\n5Omitted by Finance Act, 2019. Omitted clause read as follow:  \r\n(35C)“non-filer” means a person who is not a filer;  \r\n6 Clause (36) substituted by the Finance Act, 2002. The substituted clause (36) read as follows: \r\n“(36) “non-profit organization” means any person – \r\n(a) established for religious, charitable  or educational purposes, or for the \r\npromotion of amateur sport; \r\n(b) which is registered under any law as a non-profit organization and in respect of \r\nwhich the Commissioner has issued a ruling certifying that the person is a non-\r\nprofit organization for the purposes of this Ordinance; and \r\n(c) none of the income or assets of the person confers, or may confer a private \r\nbenefit on any other person”;. \r\n7 The expressions “or development purposes” substituted through Finance Act,2020 dated 30th June, \r\n2020 \r\n8 Words inserted by Finance Act, 2025. \r\n9 Words “by or” inserted through Finance Act, 2020 dated 30th June, 2020 \r\nChapter I – Preliminary__________________________________ \r\n \r\n20 \r\n \r\nrequisition, such other documents as may be required by the \r\nCommissioner; \r\nand none of the assets of such person confers, or may confer, \r\na private benefit to any other person;] \r\n \r\n(37) “non-resident person” means a non -resident person as defined in \r\nSection 81; \r\n \r\n(38) “non-resident taxpayer” means a taxpayer who is a non -resident \r\nperson; \r\n \r\n 1[(38A) “Officer of Inland Revenue” means any Additional Commissioner \r\nInland Revenue, Deputy Commissioner Inland Revenue, Assistant \r\nCommissioner Inland Revenue, Inland Revenue Officer, Inland \r\nRevenue Audit Officer ,2[District Taxation Officer Inland Revenue, \r\nAssistant Director Audit ,]or any other officer however designated or \r\nappointed by the Board for the purposes of this Ordinance;] \r\n \r\n 3[(38AA) “offshore asset” in relation to a person, includes any movable or \r\nimmovable asset held, any gain, profit, or income de rived, or any \r\nexpenditure incurred outside Pakistan; \r\n \r\n (38AB) “offshore evader” means a person who owns, possesses, controls, or \r\nis the beneficial owner of an offshore asset and does not declare, or \r\nunder declares or provides inaccurate particulars of such asset to the \r\nCommissioners.; \r\n \r\n (38AC) “offshore enabler” includes any person who, enables, assists, or \r\nadvises any person to plan, design, arrange or manage a transaction \r\nor declaration relating to an offshore asset, which has resulted or may \r\nresult in tax evasion;] \r\n \r\n4[(38B) “online marketplace” means an information technology platform run \r\nby e -commerce entity over an electronic network that acts as a \r\n                                            \r\n1Substituted by the Finance Act, 2010. The substituted provision has been made effective from \r\n05.06.2010 by sub -clause (77) of clause 8 of the Finance Ac t, 2010. Earlier the substitution was \r\nmade through Finance (Amendment) Ordinance, 2009 which was re -promulgated as Finance \r\n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. The substituted clause (38A) \r\nread as follows: \r\n“(38A)  “Officer of  Inland Revenue” means any Additional  Commissioner Inland Revenue,  \r\nDeputy Commissioner Inland Revenue, Assistant Commissioner Inland Revenue, \r\nInland Revenue Officer, Special Officer Inland Revenue or any other officer however \r\ndesignated or appointed by the Board for the purposes of this Ordinance.” \r\n2Inserted by the Finance Act, 2017 \r\n3New clauses (38AA), (38AB) & (38AC) inserted by Finance Act, 2019  \r\n4Inserted by the Finance Act, 2017 \r\nChapter I – Preliminary__________________________________ \r\n \r\n21 \r\n \r\nfacilitator in transactions that occur between a buyer and a seller 1[and \r\nincludes “online interfaces ” that facilitate, for a fee, the direct \r\ninteraction between multiple buyers and multiple sellers via digital \r\norders for supply of goods and services, with or without the platform \r\ntaking economic ownership of the goods or providing or rendering the \r\nservices that are being sold.];] \r\n \r\n(39) “Originator” means Originator as defined in the Asset Backed \r\nSecuritization Rules, 1999; \r\n \r\n(40) “Pakistan-source income” means Pakistan-source income as defined \r\nin section 101; \r\n \r\n2[(40A)  “Pension Fund Manager” means an asset manag ement company \r\nregistered under the Non -Banking Finance Companies \r\n(Establishment and Regulations) Rules, 2003, or a life insurance \r\ncompany registered under Insurance Ordinance, 2000 (XXXIX of \r\n2000), duly authorized by the Securities and Exchange Commission \r\nof Pakistan and approved under the Voluntary Pension System Rules, \r\n2005, to manage the Approved Pension Fund;] \r\n \r\n(41) “permanent establishment” in relation to a person, means a 3[  ] 4[  ] \r\nplace of business through which the business of the person is wholly  \r\nor partly carried on, and includes –  \r\n \r\n(a) a place of management, branch, office, factory or workshop, \r\n5[premises for soliciting orders, warehouse, permanent sales \r\nexhibition or sales outlet,] other than a liaison office except \r\nwhere the office engages in  the negotiation of contracts (other \r\nthan contracts of purchase); \r\n \r\n(b) a mine, oil or gas well, quarry or any other place of extraction of \r\nnatural resources; \r\n \r\n6[(ba) an agricultural, pastoral or forestry property;] \r\n \r\n7[(bb) virtual business presence in Pakistan  including any business \r\nwhere transactions are conducted through internet or any other \r\n                                            \r\n1 Expression inserted by the Finance Act, 2025. \r\n2 Inserted by the Finance Act, 2005. \r\n3 The word “fixed” inserted by the Finance Act, 2006. \r\n4 The word “fixed” omitted by the Finance Act, 2023. \r\n5 Inserted by the Finance Act, 2003. \r\n6 Inserted by the Finance Act, 2003. \r\n7 The sub-clause (bb) inserted by the Finance Act, 2023. \r\nChapter I – Preliminary__________________________________ \r\n \r\n22 \r\n \r\nelectronic medium, with or without having any physical \r\npresence;] \r\n \r\n(c) a building site, a construction, assembly or installation project or \r\nsupervisory activities 1[connected] with such site or project 2[but \r\nonly where such site, project and its 3[connected] supervisory \r\nactivities continue for a period or periods aggregating more than \r\nninety days within any twelve-months period] ; \r\n \r\n(d) the furnishing of services, includin g consultancy services, by \r\nany person through employees or other personnel 4[or entity ] \r\nengaged by the person for such purpose 5[  ]; \r\n \r\n(e) a person  acting  in  Pakistan  on   behalf   of   the   person \r\n(hereinafter referred to as the “agent  6[”),] other t han an agent \r\nof independent status acting in the ordinary course of business \r\nas such, if the agent – \r\n \r\n7[(i)  has and habitually exercises an authority to c onclude                      \r\ncontracts on behalf of t he other person or habitually \r\nconcludes contracts or habitually plays the principal role \r\nleading to the conclusion of contracts that are routinely \r\nconcluded without material modification by the person \r\nand these contracts are─ \r\n \r\n (a) in the name of the person; or \r\n (b) for the transfer of the ownership of or for the     \r\ngranting of the right to use property owned by that \r\nenterprise or that the enterprise has the right to use; \r\nor \r\n \r\n(c) for the provision of services by that person; or”] \r\n  \r\n                                            \r\n1 The word “connect” substituted by the Finance Act, 2010. \r\n2 Inserted by the Finance Act, 2006. \r\n3 The word “connect” substituted by the Finance Act, 2010. \r\n4  Words inserted by the Finance Act, 2023. \r\n5 The words “, but only where activities of that nature continue for the same or a connected project \r\nwithin Pakistan for a period or periods aggregating more than ninety days within any twelve -month \r\nperiod” omitted by the Finance Act, 2003. \r\n6 Comma  substituted by the Finance Act, 2002 \r\n7Paragraph (i) substituted by Finance Act 2018, the substituted Paragraph (i) is read as under: \r\n“has and habitually exercises an authority to conclude contracts on behalf of the other person;” \r\nChapter I – Preliminary__________________________________ \r\n \r\n23 \r\n \r\n(ii)  has no such authority, but habitually maintains a stock-in-\r\ntrade or other merchandise from which the agent regularly \r\ndelivers goods or merchandise on behalf of the other \r\nperson; or \r\n \r\n1[Explanation.—For removal of doubt, it is clarified that an \r\nagent of independent status acting in the ordinary course \r\nof business does not include a person acting exclusively \r\nor almost exclusively on behalf of the person to which it \r\nis an associate; or ”;] \r\n \r\n(f) any substantial equipment installed, or other asset or property \r\ncapable of activity giving rise to income; \r\n \r\n2[(g)  a 3[  ] place of business that is used or maintained by a person if \r\nthe person or  an associate of a person carries on business at \r\nthat place or at another place in Pakistan and ─ \r\n \r\n(i) that place or other place  constitutes a permanent \r\nestablishment of the person or  an associate of the person \r\nunder this sub-clause; or \r\n(ii)  business carried on by the person or an associate of the \r\nperson at the same place or at more than one place \r\nconstitute complementary functions that are part of  a \r\ncohesive business operation. \r\n \r\nExplanation.— For the removal of doubt, it is clarified that ─  \r\n \r\n(A) the term ”cohesive business operation” includes an overall \r\narrangement for the supply of goods, installation, \r\nconstruction, assembly,  commission, guarantees or \r\nsupervisory activities and  all or principal activities are  \r\nundertaken or performed either by  the person or the  \r\nassociates of the person; and \r\n \r\n(B)  supply of goods include the goods imported in the name of \r\nthe associate or any other person, whether or not the title to \r\nthe goods passes outside Pakistan.] \r\n \r\n(42) “person” means a person as defined in section 80; \r\n \r\n                                            \r\n1Added by the Finance Act, 2018 \r\n2Added by the Finance Act, 2018 \r\n3 The word “fixed” omitted by the Finance Act, 2023. \r\nChapter I – Preliminary__________________________________ \r\n \r\n24 \r\n \r\n1[(42A) “PMEX” means Pakistan Mercantile Exchange  Limited a futures  \r\ncommodity exchange company  incorporated under the 2[Companies \r\nAct, 2017 (XIX of 2017)] and is licensed and regulated by the  \r\nSecurities and Exchange Commission of Pakistan;”] \r\n \r\n(43) “pre-commencement expenditure” means a pre -commencement \r\nexpenditure as defined in section 25; \r\n \r\n(44) “prescribed” means prescribed by rules made under this Ordinance; \r\n \r\n3[(44A) “principal officer” used with reference to a company or association of \r\npersons includes –  \r\n \r\n(a) a director, a manager, secretary, agent, accountant or any \r\nsimilar officer; and \r\n \r\n(b) any person conne cted with the management or administration \r\nof the company or association of persons upon whom the \r\nCommissioner has served a notice of treating him as the \r\nprincipal officer thereof;] \r\n \r\n(45) “private company” means a company that is not a public company; \r\n 4[  ] \r\n \r\n 5[  ] \r\n \r\n(46) “profit on a debt” 6[whether payable or receivable, means] — \r\n(a) any profit, yield, interest, discount, premium or other amount 7[,] \r\nowing under a debt, other than a return of capital; or \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2015. \r\n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \r\n2021. \r\n3 Inserted by the Finance Act, 2003. \r\n4Clause (45A) omitted by the Finance Act, 2008. The omitted clause (45A) read as follows: \r\n“ (45A) “Private Equity and Venture Capital Fund” means a fund registered with the Securities \r\nand Exchange Commission of Pakistan under the Private Equity and Venture Capital Fund Rules, \r\n2007;” \r\n5Clause (45B) omitted by the Finance Act, 2008. The omitted clause (45B) read as follows: \r\n“(45B) “Private Equity and Venture Capital Fund Management Company” means a company \r\nlicensed by the Securities and Exchange Commission of Pakistan under the Private Equity and \r\nVenture Capital Fund Rules, 2007;” \r\n6 The word “means” substituted by the Finance Act, 2003. \r\n7 Comma inserted by the Finance Act, 2002. \r\nChapter I – Preliminary__________________________________ \r\n \r\n25 \r\n \r\n(b) any service fee or other charge in respect of a debt, including \r\nany fee or charge incurred in respect of a credit facility which \r\nhas not been utilized; \r\n \r\n(47) “public company” means — \r\n \r\n(a) a company in which not less than fifty per cent of the shares are \r\nheld by the Federal Government 1[or Provincial Government];  \r\n \r\n2[(ab) a company in which 3[not less than fifty per cent of the] shares \r\nare held by a foreign Government, or a foreign company owned \r\nby a foreign Government 4[;]] \r\n \r\n(b) a company whose shares were traded on a registered stock \r\nexchange in Pakistan at any time in the tax year and which \r\nremained listed on that exchange 5[ ] at the end of that year; or \r\n \r\n6[(c)  a unit trust whose units are widely available to the public and \r\nany other trust as defined in the Trusts Act, 1882 (II of 1882);] \r\n7[(47A)  “REIT Scheme” means a REIT Scheme as defined in the Real Estate \r\nInvestment Trust Regulations, 2015;”] \r\n \r\n \r\n \r\n8[(47B) “Real Estate Investment Trust Management Company 9[RMC]means \r\n10[RMC] as defined under the Real Estate In vestment Trust \r\nRegulations, 11[2015];] \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2 Inserted by the Finance Act, 2003. \r\n3 Inserted by the Finance Act, 2005. \r\n4 The full stop substituted by the Finance Act, 2005. \r\n5 The words “and was on the Central Depository System,” omitted by the Finance Act, 2002. \r\n6 Clause (c) substituted by the Finance Act, 2003. The substituted clause (c) read as follows:  \r\n   “(c) a unit trust whose units are widely available to the public and any other public trust;” \r\n7Clause (47A) substituted by the Finance Act, 2015. The substituted clause read as follows: \r\n“(47A)  “Real Estate Investment Trust (REIT) Scheme” means a REIT Scheme as defined in the \r\nReal Estate Investment Trust Regulations, 2008; \r\n8Clause (47B) substituted by the Finance Act, 2008. The substituted clause (47B) read as follows: \r\n “(47B) “Real Estate Investment Trust Management Company” means a company licensed by the \r\nSecurity and Exchange Commission of Pakistan under the Real Estate Investment Trust Rules, \r\n2006.” \r\n9Inserted by the Finance Act, 2015. \r\n10Inserted by the Finance Act, 2015. \r\n11 The figure “2008” substituted by the Finance Act, 2015. \r\nChapter I – Preliminary__________________________________ \r\n \r\n26 \r\n \r\n1[(47C) “Rental REIT Scheme” means a Rental REIT Scheme as defined  \r\n  under the Real Estate Investment Trust Regulations, 2015;”] \r\n \r\n(48) “recognised provident fund” means a provident fund recognised by the \r\nCommissioner in accordance with Part I of the Sixth Schedule;  \r\n \r\n 2[ ] \r\n \r\n(49) “rent” means rent as defined in sub -section (2) of section 15 and \r\nincludes an amount treated as rent under section 16; \r\n \r\n3[(49A)  “repealed Ordinance” means Income Tax Ordinance, 1979 (XXXI of \r\n1979);] \r\n \r\n(50) “resident company” means a resi dent company as defined in section \r\n83; \r\n \r\n(51) “resident individual” means a resident individual as defined in section \r\n82; \r\n \r\n(52) “resident person” means a resident person as defined in section 81;  \r\n \r\n(53) “resident taxpayer” means a taxpayer who is a resident person; \r\n(54) 4[“royalty”]means any amount paid or payable, however described or \r\ncomputed, whether periodical or a lump sum, as consideration for — \r\n \r\n(a) the use of, or right to use any patent, invention, design or model, \r\nsecret formula or process, trademar k or other like property or \r\nright; \r\n \r\n(b) the use of, or right to use any copyright of a literary, artistic or \r\nscientific work, including films or video tapes for use in \r\nconnection with television or tapes in connection with radio \r\nbroadcasting, but shall not  include consideration for the sale, \r\ndistribution or exhibition of cinematograph films; \r\n \r\n(c)  the receipt of, or right to receive, any visual images or sounds, \r\nor both, transmitted by satellite, cable, optic fibre or similar \r\n                                            \r\n1Inserted by the Finance Act, 2015. \r\n2Clause (48A) omitted  by the Finance Act, 2010. The omitted clause (48A) read as follows: \r\n“(48)  “Regional Commissioner” means a person appointed as a Regional Commissioner of Income \r\nTax under section 208 and includes a Director-General of Income Tax and Sales Tax.” \r\n3 Inserted by the Finance Act, 2002 \r\n4 The word “royalties” substituted by the Finance Act, 2002. \r\nChapter I – Preliminary__________________________________ \r\n \r\n27 \r\n \r\ntechnology in connection with t elevision, radio or internet \r\nbroadcasting; \r\n \r\n(d)  the supply of any technical, industrial, commercial or scientific \r\nknowledge, experience or skill; \r\n \r\n(e) the use of or right to use any industrial, commercial or scientific \r\nequipment; \r\n \r\n(f) the supply of any as sistance that is ancillary and subsidiary to,  \r\nand is furnished as a means of enabling the application or \r\nenjoyment of, any such property or right as mentioned in 1[sub-\r\nclauses] (a) through (e); 2[and] \r\n \r\n(g) the disposal of any property or right referred to in 3[sub-clauses] \r\n(a) through (e); \r\n \r\n(55) “salary” means salary as defined in section 12; \r\n \r\n(56) “Schedule” means a Schedule to this Ordinance; \r\n \r\n(57) “securitization” means securitization as defined in the Asset Backed \r\nSecuritization Rules, 1999; \r\n(58) “share” in relation to a company, includes a modaraba certificate and \r\nthe interest of a beneficiary in a trust (including units in a trust); \r\n \r\n(59) “shareholder” in relation to a company, includes a modaraba \r\ncertificate holder, 4[a unit holder of a unit trust] a nd a beneficiary of a \r\ntrust; \r\n \r\n5[(59A) “small and medium enterprise” means a person who is engaged in  \r\nmanufacturing as defined in clause (iv) of sub -section (7) of section \r\n153 of the Ordinance and his business turnover in a tax year does \r\nnot exceed two hundred and fifty million rupees:  \r\n \r\nProvided that if annual business turnover of a small and medium \r\nenterprise exceeds two hundred and fifty million rupees, it shall not \r\n                                            \r\n1 The word “clauses” substituted by the Finance Act, 2002. \r\n2 Added by the Finance Act,  2005. \r\n3 The word “clauses” substituted by the Finance Act, 2002 \r\n4 Inserted for “, a unit holder of a unit trust” by the Finance Act, 2002 \r\n5 New clause (59A) inserted by the Finance Act, 2021. \r\nChapter I – Preliminary__________________________________ \r\n \r\n28 \r\n \r\nqualify as small and medium enterprise in the tax year in which \r\nannual turnover exceeds that turnover or any subsequent tax year.] \r\n \r\n1[2[(59AB)] “Small Company” means a company registered on or after the first             \r\nday of July, 2005, under the 3[Companies Act, 2017 (XIX of 2017)], \r\nwhich,— \r\n \r\n(i)  has paid up capital plus undistributed rese rves not \r\nexceeding 4[fifty]million rupees; \r\n \r\n5[(ia) has employees not exceeding two hundred and fifty any \r\ntime during the year;]  \r\n \r\n(ii)  has annual turnover not exceeding two hundred 6[and \r\nfifty] million rupees; 7[  ] \r\n \r\n(iii) is not formed by the splitting up or t he reconstitution of \r\ncompany already in existence;] 8[and] \r\n \r\n9[(iv)    is not a small and medium enterprise as defined in clause \r\n(59A);] \r\n \r\n10[(59B) “Special Judge” means the Special Judge appointed under section  \r\n203;] \r\n \r\n(60) “Special Purpose Vehicle” means a Special Purpose Vehicle as \r\ndefined in the Asset Backed Securitization Rules, 1999; \r\n \r\n11[(60A)  “specified jurisdiction” means any jurisdiction which has committed to \r\nautomatically exchange information under the Common Reporting \r\nStandard with Pakistan;]  \r\n \r\n(61) “speculation business” means a speculation business as defined in \r\nsection 19; \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2005. \r\n2 Clause (59A) re-numbered as clause (59AB) by the Finance ACT, 2021. \r\n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \r\n2021. \r\n4The word “twenty-five” substituted by the Finance Act, 2015 \r\n5Inserted by the Finance Act, 2007. \r\n6Inserted by the Finance Act, 2007. \r\n7 The word “and “ omitted by the Finance Act, 2021. \r\n8 The word “and “ added by the Finance Act, 2021. \r\n9 New sub-clause (iv) added by the Finance Act, 2021. \r\n10Inserted by the Finance Act, 2014. \r\n11(60A)Inserted by the Finance Act, 2019 \r\nChapter I – Preliminary__________________________________ \r\n \r\n29 \r\n \r\n1[(61A)  “stock fund” means a collective investment scheme or a mutual fund \r\nwhere the invest ible funds are invested  by way of equity shares in \r\ncompanies, to the extent of more  than seventy per cent of the \r\ninvestment;] \r\n \r\n(62) “stock-in-trade” means stock-in-trade as defined in section 35; \r\n \r\n2[(62A) “startup” means,— \r\n \r\n(i) a business of a resident individual, AOP or a company that \r\ncommenced on or after first day of July, 2012 and the pe rson \r\nis engaged in or intends to offer technology driven products or \r\nservices to any sector of the economy provided that the person \r\nis registered with and duly certified by the Pakistan Software \r\nExport Board (PSEB) and has turnover of less than one \r\nhundred million in each of the last five tax years; or \r\n \r\n(ii) any business  of a person or class of persons, subject to the \r\nconditions as the 3[Board with the approval of Federal Minister-\r\nin-charge] may, by notification in the official Gazette, specify.;] \r\n \r\n4[(62B) “Syn chronized Withholding Administration and Payment System \r\nagent” or “SWAPS agent” means any person or class of persons \r\nnotified by Board to collect or deduct withholding taxes through \r\nSynchronized Withholding Administration and Payment System;] \r\n(63) “tax” me ans any tax imposed under Chapter II, and includes any \r\npenalty, fee or other charge or any sum or amount leviable or payable \r\nunder this Ordinance; \r\n \r\n(64) “taxable income” means taxable income as defined in section 9; \r\n \r\n5[   ] \r\n \r\n(66) “taxpayer” means any perso n who derives an amount chargeable to \r\ntax under this Ordinance, and includes — \r\n \r\n                                            \r\n1Inserted by the Finance Act,  2014.. \r\n2Inserted by the Finance Act, 2017 \r\n3 The words “Federal Government” substituted by the Finance Act, 2021.  \r\n4 Inserted by the Finance Act, 2022. \r\n5Clause (65) omitted by the Finance Act, 2010. The omitted Clause (65) read as follows: \r\n“(65)  “taxation officer” means any Additional Commissioner of Income Tax, Deputy \r\nCommissioner of Income Tax, Assistant Commissioner of Income Tax, Income Tax \r\nOfficer, Special Officer or any other officer however designated appointed by the Board \r\nfor the purposes of this Ordinance;” \r\nChapter I – Preliminary__________________________________ \r\n \r\n30 \r\n \r\n(a) any representative of a person who derives an amount \r\nchargeable to tax under this Ordinance; \r\n \r\n(b) any person who is required to deduct or collect tax under Part V \r\nof Chapter X 1[and Chapter XII;] or \r\n \r\n(b) any person required to furnish a return of income or pay tax \r\nunder this Ordinance; \r\n2[(66A) “tax invoice” means an invoice as prescribed under the Income Tax \r\nRules, 2002;] \r\n \r\n(67) “tax treaty” means an agreement referred to in section 107; \r\n \r\n(68) “tax year” means the tax year as defined in sub-section (1) of section 74 \r\nand, in relation to a person, includes a special year or a transitional year \r\nthat the person is permitted to use under section 74; \r\n(69) “total income” means total income as defined in section 10; \r\n \r\n(70) “trust” means a “trust” as defined in section 80; \r\n \r\n3[(70A)  “turnover” means turnover as defined in sub-section (3) of section 113;] \r\n(71) “underlying ownership” means an underlying ownership as defined in \r\nsection 98;  \r\n(72) “units” means units in a unit trust;  \r\n(73) “unit trust” means a unit trust as defined in section 80; and \r\n4[(73A) “unspecified jurisdiction” means a jurisdiction which i s not a specified \r\njurisdictions.] \r\n \r\n5[(74) “Venture Capital Company” and “Venture Capital Fund” shall have the \r\nsame meanings as are assigned to them under the 6[Non-Banking \r\nFinance 7[Companies] (Establishment and Regulation) Rules, 2003]; \r\n \r\n8[(75)  “whistleblower” means whistleblower as defined in section 227B;”] \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2002 \r\n2 Inserted by the Finance Act, 2022. \r\n3Inserted by the Finance Act, 2009. \r\n4(73A) inserted through Finance Act, 2019. \r\n5 Added by Finance Act, 2002 \r\n6 The words, brackets, comma and figure “Venture Capital Company and Venture Capital Fund \r\nRules, 2001” substituted by the Finance Act, 2004. \r\n7 The word “Company” substituted by the Finance Act, 2005. \r\n8 Inserted by the Finance Act, 2015. \r\nChapter I – Preliminary__________________________________ \r\n \r\n31 \r\n \r\n3. Ordinance to override other laws.—The provisions of this Ordinance shall \r\napply notwithstanding anything to the contrary contained in any other law for the \r\ntime being in force.\r\nChapter II – Charge of Tax_______________________________ \r\n \r\n32 \r\nCHAPTER II \r\nCHARGE OF TAX \r\n \r\n4. Tax on taxable income.— (1)  Subject to this Ordinance, income tax shall \r\nbe imposed for each tax year, at the rate or rates specified in 1[Division I 2[ ] or II] \r\nof Part I of the First Schedule, as the case may be, on every person who has \r\ntaxable income for the year. \r\n \r\n (2) The income tax payable by a taxpayer for a tax year shall be computed \r\nby applying the rate or rates of tax applicable to the taxpayer under this Ordinance \r\nto the taxable income of the taxpayer for the year, and from the resulting amount \r\nshall be subtracted any tax credits allowed to the taxpayer for the year.  \r\n \r\n (3) Where a taxpayer is allowed more than one tax credit for a tax year, \r\nthe credits shall be applied in the following order – \r\n \r\n(a) any foreign tax credit allowed under section 103; then \r\n(b) any tax credit allowed under Part X of Chapter III; and then \r\n(c) any tax credit allowed under sections 3[  ] 147 and 168. \r\n \r\n (4) Certain classes of income (including the income of certain classes of \r\npersons) may be subject to – \r\n \r\n(a) separate taxation as provided 4[under this chapter]; or \r\n \r\n(b) collection of tax under Division II of Part V of Chapter X or \r\ndeduction of tax under Division III of Part V of Chapter X as a \r\nfinal tax on the income 5[of] the person. \r\n \r\n (5) Income referred to in sub -section (4) shall be subject to tax as \r\nprovided for 6[under this chapter], or Part V of Chapter X, as the case may be, and \r\nshall not be included in the computation of taxable income in accordance with \r\nsection 8 or 169, as the case may be. \r\n \r\n                                            \r\n1The words and letters “Division I or II” substituted by the Finance Act, 2010. \r\n2The expression “IB” omitted through Finance Act, 2020 dated 30th June, 2020 \r\n3 The figure and comma “140,” omitted by the Finance Act, 2003. \r\n4 The expression “in sections 5, 6 and 7” substituted by the Finance Act, 2022. \r\n5The word “or” substituted by the Finance Act, 2010. \r\n6 The expression “in sections 5, 6 and 7” substituted by the Finance Act, 2022. \r\nChapter II – Charge of Tax__________________________ \r\n \r\n33 \r\n \r\n1[(6)  Where, by virtue of any provision of this Ordinance, income tax is to \r\nbe deducted at source or col lected or paid in advance, it shall, as the case may \r\nbe, be so deducted, collected or paid, accordingly 2[.] ] \r\n3[  ]  \r\n \r\n4[(4AB) Subject to this Ordinance, a surcharge shall be payable by every individual \r\nand association of persons at the rate of ten percent  of the income tax imposed \r\nunder Division I of Part I of the First Schedule where the taxable income exceeds \r\nrupees ten million 5[: \r\n  \r\n Provided that in case of an individual deriving income chargeable under \r\nthe head “Salary”, a surcharge shall be payable a t the rate of nine percent of the \r\nincome tax imposed under Division I of Part I of the First Schedule where the \r\ntaxable income exceeds rupees ten million in a tax year.] \r\n \r\n6[4B. Super tax for rehabilitation of temporarily displaced persons.― (1) A \r\nsuper tax shall be imposed for rehabilitation of temporarily displaced persons, for \r\ntax years 2015 7[and onwards], at the rates specified in Division IIA of Part I of the \r\nFirst Schedule, on income of every person specified in the said Division. \r\n \r\n(2)  For the purposes of this section, “income” shall be the sum of the \r\nfollowing:— \r\n \r\n(i)  profit on debt, dividend, capital gains, brokerage and \r\ncommission; \r\n \r\n                                            \r\n1 Added by the Finance Act,  2003. \r\n2 The semicolon substituted by the Finance Act, 2005. \r\n3Omitted by the Finance Act, 2014. Section 4A was added by Income Tax (Amendment) Ordinance, \r\ndated 30.05.2011. Earlier the identical section 4 A was added by Income Tax (Amendment) \r\nOrdinance, dated 16.03.2011. The omitted section 4A read as follows: — \r\n“4A Surcharge. — (1) Subject to this Ordinance, a surcharge shall be payable by every taxpayer at \r\nthe rate of fifteen per cent of the income tax payable under this Ordinance including the tax payable \r\nunder Part V of Chapter X of Chapter XIII, as the case may be, for the period commencing from the \r\npromulgation of this Ordinance, till the 30th June, 2011. \r\n (2)  Surcharge shall be paid, collected, educated and deposited at the same time and in the \r\nsame manner as the tax is paid, collected, deducted and deposited under this Ordinance including \r\nChapter X or XII as the case may be: \r\nProvided that this surcharge shall not be payable for the tax year 2010 and prior tax years \r\nand shall be applicable, subject to the provisions of sub -section (1), for the tax year 2011 \r\nonly.” \r\n4 Section (4AB) inserted by the Finance Act, 2024. \r\n5 Full stop substituted by semi-colon and a new proviso added by the Finance Act, 2025.   \r\n6Inserted by the Finance Act, 2015. \r\n7The “expression” “to 2020” substituted by “and onwards” through Finance Supplementary (Second \r\nAmendment) Act, 2019. \r\n \r\nChapter II – Charge of Tax__________________________ \r\n \r\n34 \r\n \r\n(ii)  taxable income 1[(other than brought forward depreciation and \r\nbrought forward  business losses)]  under section (9) of this \r\nOrdinance, if not included in clause (i); \r\n \r\n(iii)  imputable income as defined in clause (28A) of section 2 \r\nexcluding amounts specified in clause (i); and \r\n \r\n(iv) income computed , 2[other than brought forward depre ciation, \r\nbrought forward amortization and brought forward business \r\nlossess] under Fourth, Fifth, Seventh and Eighth Schedules. \r\n \r\n(3)  The super tax payable under sub -section (1) shall be paid, collected \r\nand deposited on the date and in the manner as specifi ed in sub -section (1) of \r\nsection 137 and all provisions of Chapter X of the Ordinance shall apply. \r\n \r\n(4)  Where the super tax is not paid by a person liable to pay it, the  \r\nCommissioner shall by an order in writing, determine the super tax payable, and \r\nshall serve upon the person, a notice of demand specifying the super tax payable \r\nand within the time specified under section 137 of the Ordinance. \r\n \r\n(5) Where the super tax is not paid by a person liable to pay it, the \r\nCommissioner shall recover the super tax p ayable under subsection (1) and the \r\nprovisions of Part IV,X, XI and XII of Chapter X and Part I of Chapter XI of the \r\nOrdinance shall, so far as may be, apply to the collection of super tax as these \r\napply to the collection of tax under the Ordinance. \r\n \r\n(6) The Board may, by notification in the official Gazette, make  rules for \r\ncarrying out the purposes of this section.] \r\n \r\n3[4C. Super tax on high earning persons.― (1) A super tax shall be imposed for \r\ntax year 2022 and onwards at the rates specified in Division IIB of Part I of the First \r\nSchedule, on income of every person: \r\n \r\nProvided that this section shall not apply to a banking company for tax \r\nyear 2022. \r\n \r\n(2) For the purposes of this section, “income” shall be the sum of the \r\nfollowing:— \r\n  \r\n(i) profit on debt, dividend, capital gains, brokerage and commission; \r\n(ii) taxable income (other than brought forward depreciation and \r\nbrought forward business losses) under section 9 of the Ordinance, \r\nexcluding amounts specified in clause (i); \r\n                                            \r\n1Inserted by the Finance Act, 2016. \r\n2Inserted by the Finance Act, 2019.   \r\n3 Inserted by the Finance Act, 2022. \r\nChapter II – Charge of Tax__________________________ \r\n \r\n35 \r\n \r\n \r\n(iii) imputable income as defined in clause (28A) of section 2 excluding \r\namounts specified in clause (i); and  \r\n \r\n(iv) income computed, other than brought forward depreciation, \r\nbrought forward amortization and brought forward business losses \r\nunder Fourth, Fifth 1[, Seventh and Eighth] Schedules. \r\n \r\n(3) The tax payable under sub -section (1) shall be paid, collected and \r\ndeposited on the date and in the manner as specified in sub-section (1) of section \r\n137 and all provisions of Chapter X of the Ordinance shall apply. \r\n \r\n(4) Where the tax is not paid by a person liable to pay it,  the \r\nCommissioner shall by an order in writing, determine the tax payable, and shall \r\nserve upon the person, a notice of demand specifying the tax payable and within \r\nthe time specified under section 137 of the Ordinance. \r\n \r\n(5) Where the tax is not paid by a pers on liable to pay it, the \r\nCommissioner shall recover the tax payable under sub -section (1) and the \r\nprovisions of Part IV, X, XI and XII of Chapter X and Part I of Chapter XI of the \r\nOrdinance shall, so far as may be, apply to the collection of tax as these apply to \r\nthe collection of tax under the Ordinance. \r\n \r\n2[(5A) The provisions of section 147 shall apply on tax payable under this \r\nsection.] \r\n \r\n(6) The Board may, by notification in the official Gazette, make rules for \r\ncarrying out the purposes of this section.] \r\n \r\n5. Tax on dividends.— (1)  Subject to this Ordinance, a tax shall be imposed, \r\nat the rate specified in Division III of Part I of the First Schedule, on every person \r\nwho receives a dividend from a 3[  ] company 4[or treated as dividend under clause \r\n(19) of section 2]. \r\n (2) The tax imposed under sub -section (1) on a person who receives a \r\ndividend shall be computed by applying the relevant rate of tax to the gross amount \r\nof the dividend. \r\n \r\n (3) This section shall not apply to a dividend that is exempt from tax under \r\nthis Ordinance. \r\n \r\n                                            \r\n1  The words “and Seventh” substituted by the Finance Act, 2023. \r\n2  The sub-section (5A) inserted by the Finance Act, 2023. \r\n3The word “resident” omitted by the Finance Act, 2003. \r\n4Inserted by the Finance Act, 2009. \r\nChapter II – Charge of Tax__________________________ \r\n \r\n36 \r\n \r\n1[5A.  Tax on undistributed profits.—(1) For tax 2[years 2017 to 2019], a tax shall \r\nbe imposed at the rate of 3[five] percent of its accounting profit before tax on every \r\npublic company, other than a scheduled bank or a modaraba, that derives profit \r\nfor a tax year but does not distribute at least 4[twenty] percent of its after tax  \r\nprofits within six months of the end of the tax year through cash 5[ ]: \r\n \r\nProvided that for tax year 2017, bonus shares or cash dividends may \r\nbe distributed b efore the due date mentioned in sub -section (2) of section \r\n118, for filing of a return. \r\n \r\n(2) The provisions of sub-section (1) shall not apply to— \r\n \r\n(a) a company qualifying for exemption under clause (132) of Part \r\nI of the Second Schedule; and \r\n \r\n(b) a company in which not less than fifty percent shares are held \r\nby the Government.] \r\n \r\n6[5AA. Tax on return on investments in sukuks.—(1) Subject to this Ordinance, \r\na tax shall be imposed, at the rate specified in Division IIIB of Part I of the First \r\n                                            \r\n1 section 5A substituted by the Finance Act, 2017. The substituted section read as follows:- \r\n“5A. Tax on undistributed reserves .—(1) Subject to this Ordinance, a tax shall be imposed at the \r\nrate of ten percent, on every public company other than a scheduled bank or a modaraba, that derives \r\nprofits for a tax year but does not distribute cash dividends within six months of the end of the said tax \r\nyear or distributes dividends to such an extent that its reserves, after such distribution, are in excess of \r\nhundred percent of its paid up capital, so much of its reserves as exceed hundred per cent of its paid \r\nup capital shall be treated as income of the said company: \r\nProvided that for tax year 2015, cash dividends may be distributed before the due date \r\nmentioned in sub-section (2) of section 118, for filing of return for tax year 2015. \r\n(2) The provisions of sub-section (1) shall not apply to— \r\n(a) a public company which distributes profit equal to either forty per cent of its after tax \r\nprofits or fifty per cent of its paid up capital, whichever is  less, within six months of \r\nthe end of the tax year; \r\n(a) a company qualifying for exemption under clause (132) of Part I of the Second \r\nSchedule; and \r\n(b) a company in which not less than fifty percent shares are held by the Government. \r\n(3) For the purpose of this section, ‘reserve‘ includes amounts setaside out of revenue or other \r\nsurpluses excluding capital reserves, share premium reserves and reserves required to be \r\ncreated under any law, rules or regulations.”] \r\n2 The “expression” “year 2017 and onwards” substituted by “years 2017 to 2019” through Finance \r\nSupplementary (Second Amendment) Act, 2019 \r\n5The word “seven and half” substituted by the Finance Act, 2018 \r\n4The word “forty” substituted by the Finance Act, 2018 \r\n \r\n5The word “or bonus shares” omitted by the Finance Act, 2018 \r\n6Inserted by the Presidential Order No. F.2(1)/2016-Pub dated 31.08.2016.  \r\nChapter II – Charge of Tax__________________________ \r\n \r\n37 \r\n \r\nSchedule, on every person who receives a return on investment in sukuks from a \r\nspecial purpose vehicle1[, or a company]. \r\n \r\n(2) The tax imposed under sub -section (1) on a person who receives a \r\nreturn on investment in sukuks shall be computed by applying the relevant rate of \r\ntax to the gross amount of the return on investment in sukuks. \r\n \r\n(3)     This section shall not apply to a return on investment in sukuks that is \r\nexempt from tax under this Ordinance.”] \r\n \r\n6. Tax on certain payments to non -residents.— (1) Subject to this \r\nOrdinance, a tax shall be imposed, at the rate specified in Division IV of Part I of \r\nthe First Schedule, on every non -resident person who receives any Pakistan -\r\nsource royalty  2[, fee for offshore  digital services  3[, fee for money transfer \r\noperations, card network services, payment gateway services, interbank financial \r\ntelecommunication services] ] or fee for technical services. \r\n \r\n (2) The tax imposed under sub-section (1) on a non-resident person shall \r\nbe computed by applying the relevant rate of tax to the gross 4[amounts of receipts \r\nmentioned in sub-section (1)]. \r\n \r\n (3) This section shall not apply to — \r\n \r\n(a) any royalty where the property or right giving rise to the royalty \r\nis effectively connected with a permanent establishment in \r\nPakistan of the non-resident person; \r\n \r\n(b) any fee 5[  ] where the services giving rise to the fee are \r\nrendered through a permanent establishment in Pakistan of the \r\nnon-resident person; or \r\n \r\n(c) any royalty or fee for technical services that is exempt from tax \r\nunder this Ordinance. \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2017 \r\n2Inserted by the Finance Act, 2018 \r\n3 The expression inserted by the Finance Act, 2022. \r\n4 The expression “amount of the royalty 4[,free for offshore digital services]  or fee for technical \r\nservices” substituted by the Finance Act, 2022. \r\n5 The expression “for technical services 5[or fee for offshore digital services” omitted by the Finance \r\nAct, 2022. \r\nChapter II – Charge of Tax__________________________ \r\n \r\n38 \r\n \r\n (4) Any Pakistani -source royalty 1[ 2[or fee] received by a non -resident \r\nperson to which this section does not apply by virtue of clause (a) or (b) of sub -\r\nsection (3) shall be treated as income from business attributable to the permanent \r\nestablishment in Pakistan of the person.  \r\n \r\n3[6A. Tax on payments for digital transactions in e-commerce platforms.– (1) \r\nSubject to this Ordinance, a tax shall be imposed, at the rate specified in Division \r\nIVA of Part I of the First Schedule, on every person who receives pay ment for \r\nsupply of digitally ordered goods or services which are delivered from within \r\nPakistan using locally operated online platforms including online marketplace or \r\nwebsites:  \r\n \r\nProvided that the export proceeds subjected to withholding under section \r\n154 and 154A shall not fall within the ambit of this section.  \r\n \r\n(2) The tax imposed under sub -section (1) shall be computed by applying \r\nthe relevant rate of tax to the gross amounts of receipts mentioned in sub -section \r\n(1).] \r\n \r\n7. Tax on shipping and air transp ort income of a non -resident person.— \r\n(1)  Subject to this Ordinance, a tax shall be imposed, at the rate specified in \r\nDivision V of Part I of the First Schedule, on every non-resident person carrying on \r\nthe business of operating ships or aircraft s as the owner or charterer thereof in \r\nrespect of – \r\n \r\n(a) the gross amount received or receivable (whether in or out of \r\nPakistan) for the carriage of passengers, livestock, mail or \r\ngoods embarked in Pakistan; and \r\n \r\n(b) the gross amount received or receivable in Pakis tan for the \r\ncarriage of passengers, livestock, mail or goods embarked \r\noutside Pakistan. \r\n \r\n (2) The tax imposed under sub-section (1) on a non-resident person shall \r\nbe computed by applying the relevant rate of tax to the gross amount referred to \r\nin sub-section (1). \r\n \r\n (3) This section shall not apply to any amounts exempt from tax under \r\nthis Ordinance. \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2018 \r\n2 The expression “, fee for offshore digital services] or fee for technical services” substituted by the \r\nFinance Act, 2022. \r\n3 Section 6A inserted by the Finance Act, 2025. \r\nChapter II – Charge of Tax__________________________ \r\n \r\n39 \r\n \r\n1[7A. Tax on shipping of a resident person. —(1) In the case of  any resident  \r\nperson engaged in the business of shipping, a presumptive  income tax shall be \r\ncharged in the following manner, namely:— \r\n \r\n(a) ships and all floating crafts including tugs, dredgers, survey \r\nvessels and other specialized craft purchased or bare -boat \r\nchartered and flying Pakistan flag shall pay tonnage tax of an \r\namount equivalent to one US $ per  gross registered tonnage \r\nper annum; 2[  ]  \r\n \r\n(b)  ships, vessels and all floating crafts including tugs, dredgers,  \r\nsurvey vessels and other specialized craft not registered in  \r\nPakistan and hired under any charter other than bare -boat \r\ncharter shall pay tonnage tax of an amount equivalent to fifteen \r\nUS cents per ton of gross registered tonnage per  chartered \r\nvoyage provided that such tax shall not exceed  one US $ per \r\nton of gross registered tonnage per annum: \r\n \r\nExplanation.—For the purpose of this section, the  \r\nexpression “equivalent amount” means the rupee equivalent of a \r\nUS dollar according to the exchange rate prevalent on the first day \r\nof December in the case of a company and the  first day of \r\nSeptember in other cases in the relevant assessment year 3[;and \r\n   \r\n(c) A Pakistan resident ship owning company registered with the \r\nSecurities and Exchange Commission of Pakistan after the 15th \r\nday of November, 2019 and having its own sea worthy vessel \r\nregistered under Pakistan Flag shall pay tonnage tax of an \r\namount equiv alent to seventy five US Cents per ton of gross \r\nregistered tonnage per annum.]   \r\n \r\n (2) The provisions of this section shall not be applicable after the \r\n30thJune, 4[2030].”] \r\n \r\n5[7B.  Tax on profit on debt. —(1) Subject to this Ordinance, a tax  shall be \r\nimposed, at the rate specified in Division IIIA of Part I of the First  Schedule, on \r\nevery person, other than a company, who receives a profit on debt from any person \r\nmentioned in clauses (a) to (d) of sub-section (1)of section 151. \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2015 \r\n2The word “and” omitted through Finance Act, 2020 dated 30th June, 2020 \r\n3 Full stop at the end substituted by semi-colon and  the word “and” thereafter new clause “(c)” shall \r\nbe added namely through Finance Act, 2020 dated 30th June, 2020   \r\n4 The word 2020 substituted by 2030 through Finance Act 2020 dated 30th June, 2020  \r\n5Inserted by the Finance Act, 2015 \r\nChapter II – Charge of Tax__________________________ \r\n \r\n40 \r\n \r\n(2)  The tax imposed under su b-section (1) on a person, other than a  \r\ncompany, who receives a profit on debt shall be computed by applying the relevant \r\nrate of tax to the gross amount of the profit on debt. \r\n \r\n1[(3) This section shall not apply to a profit on debt that – \r\n \r\n (a) is exempt from tax under this Ordinance; or \r\n \r\n (b) exceeds 2[five] million Rupees.] \r\n \r\n3[7C. Tax on builders. — (1)  Subject to this Ordinance, a tax shall be imposed \r\non the profits and gains of a person deriving income from the business of \r\nconstruction and sale of resi dential, commercial or other buildings at the rates \r\nspecified in Division VIIIA of Part I of the First Schedule. \r\n \r\n(2) The tax imposed under sub-section (1) shall be computed by applying \r\nthe relevant rate of tax to the area of the residential, commercial or  other building \r\nbeing constructed for sale. \r\n \r\n(3) The Board may prescribe: \r\n \r\n(a) the mode and manner for payment and collection of tax under this \r\nsection; \r\n \r\n(b) the authorities granting approval for computation and payment plan \r\nof tax; and \r\n \r\n(c) responsibilities and powers of the authorities approving, suspending \r\nand cancelling no objection certificate to sell and the matters \r\nconnected and ancillary thereto. \r\n \r\n4[(4) This section shall apply to projects undertaken for construction and \r\nsale of residential and commercial buildings initiated and approved.─ \r\n \r\n(a) during tax year 2017 only; \r\n(b) for which payment under rule 13S of the Income Tax Rules, 2002 has \r\nbeen made by the developer during tax year 2017; and \r\n                                            \r\n1Sub clause 3 of 7B substituted by Finance Act, 2019, substituted clause read as follow:                   \r\n“(3) This section shall not apply to a profit on debt that is exempt from tax under this Ordinance.” \r\n2 The words “thirty six” substituted by the Finance Act, 2021. \r\n3 Inserted by the Finance Act, 2016. \r\n4Section 4 substituted by the Finance Act, 2017. The substituted section read as follows: \r\n“This section shall apply to business or projects undertaken for  construction and sale of residential, \r\ncommercial or other buildings initiated and approved after the 1st July, 2016.”] \r\nChapter II – Charge of Tax__________________________ \r\n \r\n41 \r\n \r\n(c)     the Chief Commissioner has issued online schedule of advance tax \r\ninstallments to be paid by the developer in accordance with rule 13U \r\nof the Income Tax Rules, 2002.] \r\n \r\n1[7D. Tax on developers.—(1)  Subject to this Ordinance, a tax shall be imposed \r\non the profits and gains of a person deriving income from the business of \r\ndevelopment and sale of residential, commercial or other plots at the rates \r\nspecified in Division VIIIB of Part I of the First Schedule. \r\n \r\n(2) The tax imposed under sub-section (1) shall be computed by applying \r\nthe relevant rate of tax to the area of the residential , commercial or other plots for \r\nsale. \r\n \r\n(3) The Board may prescribe: \r\n \r\n(a) the mode and manner for payment and collection of tax under \r\nthis section; \r\n(b) the authorities granting approval for computation and payment \r\nplan of tax; and \r\n(c) responsibilities and powers of the  authorities approving, \r\nsuspending and cancelling no objection certificate to sell and the \r\nmatters connected and ancillary thereto. \r\n2[(4) This section shall apply to projects undertaken for development and \r\nsale of residential and commercial plots initiated and approved.─ \r\n \r\n(a) during tax year 2017 only; \r\n \r\n(b) for which payment under rule 13S of the Income Tax Rules, 2002 has \r\nbeen made by the developer during tax year 2017; and \r\n \r\n(c) the Chief Commissioner has issued online schedule of advance tax \r\ninstallments to be paid by the developer in accordance with rule 13ZB \r\nof the Income Tax Rules, 2002.”; \r\n \r\n3[7E. Tax on deemed income.- (1) For tax year 2022 and onwards, a tax shall \r\nbe imposed at the rates specified in Division VIIIC of Part -I of the First Schedule \r\non the income specified in this section. \r\n \r\n(2) A resident person shall be treated to have derived, as income \r\nchargeable to tax under this section, an amount equal to five percent of the fair \r\n                                            \r\n1 Inserted by the Finance Act, 2016. \r\n2Section 4 substituted by the Finance Act, 2017. The substituted section read as follows: \r\n“This section shall apply to projects undertaken for development and sale of residential, \r\ncommercial or other plots initiated and approved after the 1st July, 2016.” \r\n3 Section 7E inserted by the Finance Act, 2022. \r\nChapter II – Charge of Tax__________________________ \r\n \r\n42 \r\n \r\nmarket value of capital assets situated in Pakistan held on the last day of tax year \r\nexcluding the following, namely:– \r\n \r\n(a) one capital asset owned by the resident person; \r\n \r\n(b) self-owned business premises from where the business is \r\ncarried out by the persons appearing on the active taxpayers’ \r\nlist at any time during the year; \r\n \r\n(c) self-owned agriculture land where agriculture activity is carried \r\nout by person excluding farmhouse and land annexed thereto; \r\n \r\n(d) capital asset allotted to – \r\n \r\n(i) a Shaheed or dependents of a shaheed belonging to \r\nPakistan Armed Forces; \r\n(ii) a person or dependents of the person who dies while in the \r\nservice of Pakistan armed forces or Federal or provincial \r\ngovernment;  \r\n \r\n(iii) a war wounded person while in service of Pakistan armed \r\nforces or Federal or provincial government; and \r\n \r\n(iv) an ex-serviceman and serving personal of armed forces or \r\nex-employees or serving personnel of Federal and \r\nprovincial governments, being original allottees of the \r\ncapital asset duly certified by the allotment authority; \r\n \r\n(e) any property from which income is chargeable to tax under the \r\nOrdinance and tax leviable is paid thereon; \r\n \r\n(f) capital asset in the first tax year of acquisition where tax under \r\nsection 236K has been paid; \r\n \r\n(g) where the fair market value of the capital assets in aggregate \r\nexcluding the capital assets mentioned in clauses (a), (b), (c), \r\n(d), (e) and (f) does not exceed Rupees twenty-five million; \r\n \r\n(h) capital assets owned by a provincial government or a local \r\ngovernment; or \r\n \r\n(i) capital assets owned by a local authority, a development \r\nauthority, builders and developers for land development and \r\nconstruction, subje ct to the condition that such persons are \r\nChapter II – Charge of Tax__________________________ \r\n \r\n43 \r\n \r\nregistered with Directorate General of Designated Non -\r\nFinancial Businesses and Professions 1[: \r\n \r\nProvided that the exclusions mentioned at clauses (a), (e), (f) \r\nand (g) of this sub -section shall not apply in case of  a person not \r\nappearing in the active taxpayers’ list, other than persons covered in \r\nrule 2 of the Tenth Schedule.]  \r\n \r\n(3) The Federal Government may include or exclude any person or \r\nproperty for the purpose of this section. \r\n  \r\n(4) In this section– \r\n \r\n(a) “capital asset” means property of any kind held by a person, \r\nwhether or not connected with a business, but does not include \r\n– \r\n(i) any stock -in-trade, consumable stores or raw materials \r\nheld for the purpose of business; \r\n(ii) any shares, stocks or securities; \r\n(iii) any property with respect to which the person is entitled \r\nto a depreciation deduction under section 22 or \r\namortization deduction under section 24; or \r\n(iv) any movable asset not mentioned in clauses (i), (ii) or (iii); \r\n \r\n(b) “farmhouse” means a house constructed on a total minimum \r\narea of 2000 square yards with a minimum covered area of 5000 \r\nsquare feet used as a single dwelling unit with or without an \r\nannex: \r\n \r\n  Provided that where t here are more than one dwelling \r\nunits in a compound and the average area of the compound is \r\nmore than 2000 square yards for a dwelling unit, each one of \r\nsuch dwelling units shall be treated as a separate farmhouse. \r\n \r\n2[7F. Tax on builders and developers. – (1) A tax shall be imposed at the rate \r\nspecified in Division I or II of Part -I of the First S chedule on the taxable profit of \r\nevery person deriving income from the business of – \r\n \r\n(a)  construction and sale of residential, commercial or other buildings;  \r\n \r\n(b)  development and sale of residential commercial or other plots; or  \r\n \r\n(c)  activities as mentioned in (a) and (b) above.  \r\n                                            \r\n1  The full stop substituted with colon and new proviso added by the Finance Act, 2023. \r\n2 Section 7F inserted by the Finance Act, 2024. \r\nChapter II – Charge of Tax__________________________ \r\n \r\n44 \r\n \r\n \r\n(2) For the purpose of this section, taxable profit shall be –  \r\n \r\n(a) ten percent of gross receipts in respect of activities specified in clause \r\n(a) of sub-section (1);  \r\n \r\n(b)  fifteen percent of gross receipts in respect of activities specified in \r\nclause (b) of sub-section (1); and  \r\n \r\n(c)  twelve percent of gross receipts in respect of activities specified in \r\nclause (c) of sub-section (1).  \r\n \r\nExplanation.- For the removal of doubt, it is clarified that the provisions of \r\nthis section shall only apply in respect of income accruing from gross receipts from \r\nactivities specified in sub -section (1) and shall not be applicable to income or \r\nincomes from any other source or under any head of income. \r\n \r\n(3) Where a taxpayer, while explainin g the nature and source of the \r\namount credited or the investment  made, money or valuable article owned or the \r\nfunds from which the expenditure was made, takes into account any source of \r\nincome which is subject to tax under this section, the taxpayer shall not be allowed \r\nto take credit of any sum as is in excess of taxable profit: \r\n \r\nProvided that where taxable income under section 9 is more than the taxable \r\nprofit under this section, taxpayer shall be entitled to take credit of such taxable \r\nincome subject to the payment of tax at the rate specified in Division I or II of Part-\r\nI of First Schedule.  \r\n \r\n(4) The provisions of this section shall not apply to a builder or developer \r\nestablished by an Act of the Parliament or a Provincial Assembly or by a \r\nPresidential Order and who is engaged in activities for the benefit of its employees \r\nor otherwise including activities for the planning and development of and for \r\nproviding and regulating housing and ancillary facilities in  a specified or notified \r\narea.] \r\n \r\n8. General provisions relating to taxes im posed under sections 1[ 2[ 3[5, \r\n5A, 5AA, 6,  6A,] 7, 7A, 7B and 7E ]. – (1) Subject to this Ordinance, the tax \r\nimposed under Sections 4[ 5[5, 5A, 5AA, 6, 6A,] 7, 7A, 7B and 7E] shall be a final \r\ntax on the amount in respect of which the tax is imposed and— \r\n \r\n                                            \r\n1 The expression “5, 6 and 7” substituted by the Finance Act, 2021.  \r\n2 The expression “5, 5AA, 6, 7, 7A and 7B” substituted by the Finance Act, 2022. \r\n3 The expression “5, 5AA, 6,” substituted by the Finance Act, 2025. \r\n4 The expression  ”5, 4[ ] 4[ ] 4[“, 5AA”] 6, 7, 7A 4[and 7B]”” substituted by the Finance Act, 2022. \r\n5 The expression “5, 5AA, 6,” substituted by the Finance Act, 2025. \r\nChapter II – Charge of Tax__________________________ \r\n \r\n45 \r\n \r\n(a) such amount shall not be chargeable to tax under any head of \r\nincome in computing the taxable income of the person who \r\nderives it for any tax year; \r\n \r\n(b) no deduction shall be allowable under this Ordinance for any \r\nexpenditure incurred in deriving the amount;  \r\n \r\n(c) the amount shall not be reduced by — \r\n \r\n(i) any deductible allowance; or \r\n \r\n(ii) the set off of any loss; \r\n \r\n(d) the tax payable by a person under  1[section] 2[5, 5A, 5AA, 6, \r\n6A,] 7, 3[7A, 7B and 7E] shall not be reduced by any tax credits \r\nallowed under this Ordinance; and \r\n(e) the liability of a person under  4[section] 5, 6 5[, 6A]   or 7 shall \r\nbe discharged to the extent that — \r\n \r\n(i) in the case of shipping and air transport income, the tax \r\nhas been paid in accordance with section 143 or 144, as \r\nthe case may be; or \r\n \r\n(ii) in any other case, the tax payable has been deducted at \r\nsource under Division III of Part V of Chapter X 6[.] \r\n \r\n    7[  ] \r\n                                            \r\n1The word “sections” substituted by the word “section”by the Finance Act, 2014. \r\n2 The expression “5, 2[5A,2[“, 5AA”] 6,” substituted by the Finance Act, 2025. \r\n3 The expression “7A and 7B” substituted by the Finance Act, 2022. \r\n4The word “sections” substituted by the word “section”by the Finance Act, 2014. \r\n5 The expression inserted by the Finance Act, 2025. \r\n6 Colon substituted by the Finance Act, 2013. \r\n7 Proviso omitted by the Finance Act, 2013. The omitted proviso read as follows:  \r\n  “Provided that the provision of this section shall not apply to dividend received by a company.” \r\nChapter III – Tax on Taxable Income_______________________ \r\n \r\n46 \r\nCHAPTER III \r\nTAX ON TAXABLE INCOME \r\n \r\nPART I \r\nCOMPUTATION OF TAXABLE INCOME \r\n \r\n9. Taxable income.—The taxable income of a person for a tax year shall be \r\nthe total income 1[under clause (a) of section 10] of the person for the year reduced \r\n(but not below zero) by the total of any deductible allowances under Part IX of this \r\nChapter of the person for the year. \r\n \r\n10. Total Income.— The total income of a person for a tax year shall be the \r\nsum of the 2[—] \r\n \r\n  3[(a)  person’s income under all heads of income for the year; and] \r\n \r\n4[(b)  person’s income exempt from tax under any of the provisions of \r\nthis Ordinance.] \r\n \r\n11. Heads of income.— (1)  For the purposes of the imposition of tax and the \r\ncomputation of total income, all income shall be classified under the following \r\nheads, namely: — \r\n \r\n(a) Salary; \r\n \r\n5[(b) Income from Property;] \r\n \r\n6[(c)  Income from Business;] \r\n \r\n7[(d)  Capital Gains; and] \r\n \r\n8[(e)  Income from Other Sources.] \r\n                                            \r\n1Inserted by the Finance Act, 2012. \r\n2The words “person’s income under each of the heads of income for the year” substituted by the \r\nFinance Act, 2012. \r\n3Inserted by the Finance Act, 2012. \r\n4Inserted by the Finance Act, 2012. \r\n5 Clause (b) substituted by the Finance Act, 2002. The substituted clause (b) read as follows: \r\n “(b) income from property;” \r\n6 Clause (c) substituted by the Finance Act, 2002. The substituted clause (c) read as follows: \r\n  “(c) income from business;”  \r\n7 Clause (d) substituted by the Finance Act, 2002. The substituted clause (d) read as follows: \r\n  “(d) capital gains; and” \r\n8 Clause (e) substituted by the Finance Act, 2002. The substituted clause (e) read as follows: \r\n  “(e) income from other sources.” \r\n \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n47 \r\n \r\n (2) Subject to this Ordinance, the income of a person under a head of \r\nincome for a tax year shall be the total of the amounts derived by the person in \r\nthat year that are chargeable to tax un der the head as reduced by the total \r\ndeductions, if any, allowed under this Ordinance to the person for the year under \r\nthat head.  \r\n \r\n (3) Subject to this Ordinance, where the total deductions allowed under \r\nthis Ordinance to a person for a tax year under a head of income exceed the total \r\nof the amounts derived by the person in that year that are chargeable to tax under \r\nthat head, the person shall be treated as sustaining a loss for that head for that \r\nyear of an amount equal to the excess.  \r\n \r\n (4) A loss for a head of income for a tax year shall be dealt with in \r\naccordance with Part VIII of this Chapter. \r\n \r\n (5) The income of a resident person under a head of income shall be \r\ncomputed by taking into account amounts that are Pakistan -source income and \r\namounts that are foreign-source income. \r\n \r\n (6) The income of a non-resident person under a head of income shall be \r\ncomputed by taking into account only amounts that are Pakistan-source income. \r\n \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n48 \r\n \r\nPART II \r\nHEAD OF INCOME: SALARY \r\n \r\n12. Salary.— (1)  Any salary received by an employee in a tax year, other than \r\nsalary that is exempt from tax under this Ordinance, shall be chargeable to tax in \r\nthat year under the head “Salary”. \r\n \r\n (2) Salary means any amount received by an employee from any \r\nemployment, whether of a revenue or capital nature, including — \r\n \r\n(a) any pay, wages or other remuneration provided to an employee, \r\nincluding leave pay, payment in lieu of leave, overtime payment, \r\nbonus, commission, fees, gratuity or work condition \r\nsupplements (such as for unpleasant or dangerous  working \r\nconditions)1[;] \r\n \r\n2[  ] \r\n \r\n(b) any perquisite, whether convertible to money or not; \r\n \r\n(c) the amount of any allowance provided by an employer to an \r\nemployee including a cost of living, subsistence, rent, utilities, \r\neducation, entertainment or travel a llowance, but shall not \r\ninclude any allowance solely expended in the performance of \r\nthe employee’s duties of employment. \r\n  \r\n 3[Explanation.– For removal of doubt, it is clarified that the \r\nallowance solely expended in the performance of employee’s \r\nduty does not include –  \r\n \r\n(i) allowance which is paid in monthly salary on fixed basis or \r\npercentage of salary; or  \r\n \r\n(ii) allowance which is not wholly, exclusively, necessarily or \r\nactually spent on behalf of the employer;] \r\n \r\n(d) the amount of any expenditure incurre d by an employee that is \r\npaid or reimbursed by the employer, other than expenditure \r\nincurred on behalf of the employer in the performance of the \r\nemployee’s duties of employment;  \r\n \r\n                                            \r\n1Semi-colon substituted by the Finance Act, 2015. \r\n2 Omitted by the Finance Act, 2015. The omitted proviso read as follows:-   \r\nProvided that any bonus paid or payable to corporate employees receiving salary income of \r\none million rupees or more (excluding bonus) in tax year 2010, shall be chargeable to tax at the rate \r\nprovided in paragraph (2) of Division I of Part I of the First Schedule; \r\n3 Explanation added by the Finance Act, 2021. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n49 \r\n \r\n(e) the amount of any profits in lieu of, or in addition to, salary or \r\nwages, including any amount received — \r\n \r\n  (i) as consideration for a person’s agreement to enter into an \r\nemployment relationship; \r\n \r\n (ii) as consideration for an employee’s agreement to any \r\nconditions of employment or any changes to the \r\nemployee’s conditions of employment; \r\n \r\n(iii) on termination of employment, whether paid voluntarily or \r\nunder an agreement, including any compensation for \r\nredundancy or loss of employment and golden handshake \r\npayments;  \r\n(iv) from a provident or other fund, to the extent to which the  \r\namount is not a repayment of contributions made by the \r\nemployee to the fund in respect of which the employee \r\nwas not entitled to a deduction; and \r\n \r\n(v) as consideration for an employee’s agreement to a \r\nrestrictive covenant in respect of any past, present o r \r\nprospective employment; \r\n \r\n(f) any pension or annuity, or any supplement to a pension or \r\nannuity; and \r\n \r\n(g) any amount chargeable to tax as “Salary” under section 14. \r\n \r\n 1[(2A) In case of pension under clause (f) of sub-section (2),—  \r\n \r\n(i) the pension shall be charged to tax as a final tax at the rates \r\nspecified in the proviso to clause (2) of Division I of Part I of the \r\nFirst Schedule where the amount received by an individual from \r\na former employer for a tax year exceeds ten million rupees and \r\nthe individual who has attained the age of seventy years shall \r\nnot be charged to tax on pension income; and  \r\n \r\n(ii) the pension of an individual who continues to work for former \r\nemployer or its associate shall be charged to tax at the rates \r\nspecified under clause (1) or  (2) of Division I of Part I to First \r\nSchedule as the case may be.] \r\n \r\n(3) Where an employer agrees to pay the tax chargeable on an \r\nemployee’s salary, the amount of the employee’s income chargeable under the \r\nhead “Salary” shall be grossed up by the amount of tax payable by the employer. \r\n \r\n (4) No deduction shall be allowed for any expenditure incurred by an \r\nemployee in deriving amounts chargeable to tax under the head “Salary”.  \r\n                                            \r\n1 Sub-section (2A) inserted by the Finance Act, 2025. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n50 \r\n \r\n \r\n (5) For the purposes of this Ordinance, an amount or perquisite shall be \r\ntreated as received by an employee from any employment regardless of whether \r\nthe amount or perquisite is paid or provided — \r\n \r\n(a) by the employee’s employer, an associate of the employer, or \r\nby a third party under an arrangement with the employer or an \r\nassociate of the employer; \r\n \r\n(b) by a past employer or a prospective employer; or \r\n \r\n(c) to the employee or to an associate of the employee 1[or to a third \r\nparty under an agreement with the employee or an associate of \r\nthe employee.] \r\n (6) An employee who has received an a mount referred to in sub -clause \r\n(iii) of clause (e) of sub -section (2) in a tax year may, by notice in writing to the \r\nCommissioner, elect for the amount to be taxed at the rate computed in \r\naccordance with the following formula, namely: — \r\n \r\nA/B% \r\nwhere — \r\n \r\nA is the total tax paid or payable by the employee on the employee’s total \r\ntaxable income for the three preceding tax years; and  \r\n \r\nB is the employee’s total taxable income for the three preceding tax years.  \r\n \r\n(7) Where — \r\n \r\n(a) any amount chargeable under the h ead “Salary” is paid to an \r\nemployee in arrears; and \r\n \r\n(b) as a result the employee is chargeable at higher rates of tax than \r\nwould have been applicable if the amount had been paid to the \r\nemployee in the tax year in which the services were rendered, \r\n \r\nthe employee may, by notice in writing to the Commissioner, elect for the \r\namount to be taxed at the rates of tax that would have been applicable if the salary \r\nhad been paid to the employee in the tax year in which the services were rendered. \r\n \r\n(8) An election unde r sub-section (6) or (7) shall be made by the due \r\ndate for furnishing the employee’s return of income or employer certificate, as the \r\ncase may be, for the tax year in which the amount was received or by such later \r\ndate as the Commissioner may allow.  \r\n \r\n13. Value of perquisites.— (1)  For the purposes of computing the income of \r\nan employee for a tax year chargeable to tax under the head “Salary”, the value of \r\n                                            \r\n1 Inserted by the Finance Act, 2002 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n51 \r\n \r\nany perquisite provided by an employer to the employee in that year that is \r\nincluded in the employee’ s salary under section 12 shall be determined in \r\naccordance with this section. \r\n \r\n(2) This section shall not apply to any amount referred to in clause (c) or \r\n(d) of sub-section (2) of section 12.  \r\n \r\n1(3)  Where, in a tax year, a motor vehicle is provided by a n employer to \r\nan employee wholly or partly for the private use of the employee, the amount \r\nchargeable to tax to the employee under the head “Salary” for that year shall \r\ninclude an amount computed as may be prescribed.] \r\n \r\n2[   ] \r\n (5) Where, in a tax year, the services of a housekeeper, driver, gardener or \r\nother domestic assistant is provided by an employer to an employee, the amount \r\nchargeable to tax to the employee under the head “Salary” for that year shall include \r\nthe total salary paid to the domestic assistant 3[such house keeper, driver, gardener \r\nor other domestic assistant] in that year for services rendered to the employee, as \r\nreduced by any payment made 4[to the employer]for such services. \r\n \r\n(6) Where, in a tax year, utilities are provided by an employe r to an \r\nemployee, the amount chargeable to tax to the employee under the head “Salary” \r\nfor that year shall include the fair market value of the utilities provided, as reduced \r\nby any payment made by the employee for the utilities. \r\n \r\n                                            \r\n1Substituted by the Finance Ordinance, 2002. The substituted sub-section (3) read as follows:- \r\n “ (3) Subject to sub-section (4), where, in a tax year, a motor vehicle is provided by an employer to \r\nan employee wholly or partly for the private use of the employee, the amount chargeable to tax to \r\nthe employee under the head “Salary” for that year shall include the amount computed in accordance \r\nwith the following formula, namely:-  \r\n(A*B)-C \r\nWhere,  \r\nA is the cost to the employer of acquiring the motor vehicle or, if the vehicle is leased by the \r\nemployer, the fair market value of the vehicle at the commencement of the lease; \r\nB is- \r\n (a) where the vehicle is wholly for private use, fifteen per cent; \r\n (b) where the vehicle is only partly for private use, seven and a half per cent; and \r\nC is any payment made by the employee for the use of the motor vehicle or for its running costs.” \r\n2 Sub-section (4) omitted by the Finance Act, 2002. The omitted sub-section (4) read as follows: \r\n“(4)  Where a motor vehicle referred  to in sub -section (3) is available to more than one \r\nemployee for a tax year, the amount chargeable to tax under the head “Salary” for each such \r\nemployee for that year shall be the amount determined under sub-section (3) divided by the number \r\nof employees permitted to use the vehicle.” \r\n3 The words “domestic assistant” substituted by the Finance Act, 2002 \r\n4 The words  “by the employee” substituted by the Finance Act, 2002 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n52 \r\n \r\n1[(7) Where a loan is mad e, on or after the 1 st day of July, 2002, by an \r\nemployer to an employee and either no profit on loan is payable by the employee \r\nor the rate of profit on loan is less than the benchmark rate, the amount chargeable \r\nto tax to the employee under the head “Sala ry” for a tax year shall include an \r\namount equal to— \r\n \r\n(a)  the profit on loan computed at the benchmark rate, where no profit \r\non loan is payable by the employee, or \r\n \r\n(d) the difference between the amount of profit on loan paid by the \r\nemployee in that tax year and the amount of profit on loan  \r\ncomputed at the benchmark rate, as the case may be2[:] ] \r\n3[Provided that this sub -section shall not apply to such benefit \r\narising to an employee due to waiver of interest by such employee on \r\nhis account with the employer4[:] ] \r\n \r\n5[Provided further that this sub-section shall not apply to loans \r\nnot exceeding 6[one million]rupees.] \r\n \r\n (8) For the purposes of this Ordinance not including sub -section (7), \r\nwhere the employee uses a loan referred to in sub -section (7) wholly or part ly for \r\nthe acquisition of 7[any asset or property]producing income chargeable to tax \r\nunder any head of income, the employee shall be treated as having paid an amount \r\nas profit equal to the benchmark rate on the loan or that part of the loan used to \r\nacquire 8[ ][asset or property.] \r\n \r\n (9) Where, in a tax year, an obligation of an employee to pay or repay an \r\namount owing by the employee to the employer is waived by the employer, the \r\namount chargeable to tax to the employee under the head “Salary” for that year  \r\nshall include the amount so waived. \r\n \r\n                                            \r\n1 Sub-section (7) substituted by the Finance Act, 2002. The substituted sub-section (7) read as \r\nfollows: \r\n“(7) Where, in a tax year, a loan is made by an employer to an employee, the amount \r\nchargeable to tax to the employee under the head “Salary” for that year shall include the difference \r\nbetween the profit paid by the employee on the loan in the tax year, if any, and the profit which would \r\nhave been paid by the employee on the loan for the year if the loan had been made at the benchmark \r\nrate for that year.” \r\n2Full stop substituted by the Finance Act, 2010. \r\n3Added by the Finance Act, 2010. \r\n4Full stop substituted by the Finance Act, 2012. \r\n5Added by the Finance Act, 2012. \r\n6The word “five hundred thousand” substituted by Finance Act, 2017 \r\n7 The word “property” substituted by the Finance Act, 2002 \r\n8The word “the” omitted by the Finance Act, 2014 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n53 \r\n \r\n(10) Where, in a tax year, an obligation of an employee to pay or repay an \r\namount 1[owing]by the employee to another person is paid by the employer, the \r\namount chargeable to tax to the employee under the head “Salary” for that year \r\nshall include the amount so paid. \r\n \r\n(11) Where, in a tax year, property is transferred or services are provided \r\nby an employer to an employee, the amount chargeable to tax to the employee \r\nunder the head “Salary” for that year shall include the  fair market value of the \r\nproperty or services determined at the time the property is transferred or the \r\nservices are provided, as reduced by any payment made by the employee for the \r\nproperty or services. \r\n \r\n2[(12) Where, in the tax year, accommodation or ho using is provided by an \r\nemployer to an employee, the amount chargeable to tax to the employee under \r\nthe head “Salary\" for that year shall include an amount computed as may be \r\nprescribed.] \r\n \r\n (13) Where, in a tax year, an employer has provided an employee wi th a \r\nperquisite which is not covered by sub -sections (3) through (12), the amount \r\nchargeable to tax to the employee under the head “Salary” for that year shall \r\ninclude the fair market value of the perquisite, 3[except where the rules, if any, \r\nprovide other wise,] determined at the time it is provided, as reduced by any \r\npayment made by the employee for the perquisite. \r\n \r\n4[(14) In this section,— \r\n \r\n(a)  “benchmark rate” means —- \r\n \r\n                                            \r\n1 The word “owed” substituted by the Finance Act, 2002 \r\n2 Sub-section (12) substituted by the Finance Act, 2002. The substituted sub -section (12) read as \r\nfollows: \r\n“(12) Where, in a tax year, accommodation or housing is provided by an employer to an \r\nemployee, the amount chargeable to tax to the employee under the head “Salary” for that year shall \r\ninclude – \r\n(a) where the employer or an associate owns the accommodation or housing, the \r\nfair market rent of the accommodation or housing; or  \r\n(b) in any other case, th e rent paid by the employer for the accommodation or \r\nhousing, as reduced by any payment made by the employee for the \r\naccommodation or housing.” \r\n3Inserted by the Finance Act, 2002 \r\n4 Sub-section (14) substituted  by the Finance Act, 2002. The substituted sub -section (14) read as \r\nfollows: \r\n“(14) In this section, - \r\n“benchmark rate” means the State Bank of Pakistan discount rate at the \r\ncommencement of the tax year;  \r\n“services” includes the making available of any facility; and   \r\n“utilities” includes electricity, gas, water and telephone.” \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n54 \r\n \r\n(i)  for the tax year commencing on the first day of July, 2002, \r\na rate of five per cent per annum; and  \r\n \r\n(ii)  for the tax years next following the tax year referred to in \r\nsub-clause (i), the rate for each successive year taken at \r\none per cent above the rate applicable for the immediately \r\npreceding tax year, but not exceeding 1[ten per cent per \r\nannum]  in respect of any tax year;  \r\n \r\n(b)  “services” includes the provision of any facility; and  \r\n \r\n(c)  “utilities” includes electricity, gas, water and telephone.] \r\n \r\n14. Employee share schemes. — (1) The value of a right or option to acquire \r\nshares under an employee share scheme granted to an employee shall not be \r\nchargeable to tax. \r\n \r\n (2) Subject to sub-section (3), where, in a tax year, an employee is issued \r\nwith shares under an employee share scheme including as a result of the exercise \r\nof an opti on or right to acquire the shares, the amount chargeable to tax to the \r\nemployee under the head “Salary” for that year shall include the fair market value \r\nof the shares determined at the date of issue, as reduced by any consideration \r\ngiven by the employee for the shares including any amount given as consideration \r\nfor the grant of a right or option to acquire the shares. \r\n \r\n (3) Where shares issued to an employee under an employee share \r\nscheme are subject to a restriction on the transfer of the shares — \r\n \r\n(a) no amount shall be chargeable to tax to the employee under the \r\nhead “Salary” until the earlier of — \r\n \r\n (i) the time the employee has a free right to transfer the \r\nshares; or \r\n \r\n(ii)  the time the employee disposes of the shares; and  \r\n \r\n(b) the amount chargeable t o tax to the employee shall be the fair \r\nmarket value of the shares at the time the employee has a free \r\nright to transfer the shares or disposes of the shares, as the \r\ncase may be, as reduced by any consideration given by the \r\nemployee for the shares includin g any amount given as \r\nconsideration for the grant of a right or option to acquire the \r\nshares. \r\n \r\n                                            \r\n1The words “such rate, if any, as the Federal. Government may, by notification, specify” substituted \r\nby the Finance Act, 2012 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n55 \r\n \r\n (4) For purposes of this Ordinance, where sub -section (2) or (3) applies, \r\nthe cost of the shares to the employee shall be the sum of — \r\n \r\n(a) the consideration, if any, given by the employee for the shares; \r\n \r\n(b) the consideration, if any, given by the employee for the grant of \r\nany right or option to acquire the shares; and \r\n \r\n(c) the amount chargeable to tax under the head “Salary” under \r\nthose sub-sections. \r\n \r\n (5) Where, in a tax year, an employee disposes of a right or option to \r\nacquire shares under an employee share scheme, the amount chargeable to tax \r\nto the employee under the head “Salary” for that year shall include the amount of \r\nany gain made on the disposal computed in accordance with the following formula, \r\nnamely:— \r\n \r\nA—B \r\nwhere — \r\n \r\nA is the consideration received for the disposal of the right or option; and \r\n \r\nB is the employee’s cost in respect of the right or option. \r\n \r\n (6) In this sub-section, “employee share scheme” means any agreement \r\nor arrangement under which a company may issue shares in the company to — \r\n \r\n(a) an employee of the company or an employee of an associated \r\ncompany; or \r\n \r\n(b) the trustee of a trust and under the trust deed the trustee may \r\ntransfer the s hares to an employee of the company or an \r\nemployee of an associated company. \r\n \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n56 \r\n \r\nPART III \r\nHEAD OF INCOME: INCOME FROM PROPERTY \r\n \r\n15. Income from property.— (1)  The rent received or receivable by a person \r\n1[for] a tax year, other than rent exempt from tax und er this Ordinance, shall be \r\nchargeable to tax in that year under the head “Income from Property”. \r\n \r\n (2) Subject to sub -section (3), “rent” means any amount received or \r\nreceivable by the owner of land or a building as consideration for the use or \r\noccupation of, or the right to use or occupy, the land or building, and includes any \r\nforfeited deposit paid under a contract for the sale of land or a building. \r\n \r\n (3) This section shall not apply to any rent received or receivable by any \r\nperson in respect of the lease of a building together with plant and machinery and \r\nsuch rent shall be chargeable to tax under the head “Income from Other Sources”. \r\n \r\n2[(3A)  Where any amount is included in rent received or receivable by any \r\nperson for the provision of amenities, utili ties or any other service connected with \r\nthe renting of the building, such amount shall be chargeable to tax under the head \r\n“Income from Other Sources”.] \r\n \r\n(4) Subject to sub-section (5), where the rent received or receivable by a \r\nperson is less than the fair market rent for the property, the person shall be treated \r\nas having derived the fair market rent for the period the property is let on rent in \r\nthe tax year. \r\n \r\n(5) Sub-section (4) shall not apply where the fair market rent is included \r\nin the income of the lessee chargeable to tax under the head “Salary”. \r\n \r\n 3[  ]  \r\n \r\n 4[  ]   \r\n \r\n5[  ] \r\n                                            \r\n1 Substituted for the word “in” by the Finance Act, 2003. \r\n2 Inserted by the Finance Act, 2003. \r\n3 Sub-section (6) omitted by the Finance Act, 2013. The omitted sub-section (6) read as follows: \r\n“(6)  Income under this section shall be liable to tax at the rate specified in Division VI of Part \r\nI of the First Schedule.” \r\n4Sub-section (7) omitted by the Finance Act, 2013. The omitted sub-section (6) read as follows: \r\n“(7)  the provisions of sub-section (1), shall not apply in respect of a taxpayer who—  \r\n    (i)  is an individual or association of persons;   \r\n  (ii)  derives income chargeable to tax under this sectio n not exceeding  Rs. 150,000 in a \r\ntax year; and \r\n (iii)  does not derive taxable income under any other head.” \r\n5 Clause (6) inserted by the Finance Act, 2016. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n57 \r\n \r\n1[   ]  \r\n \r\n2[    ] \r\n \r\n 3[   ]   \r\n \r\n4[15A. Deductions in computing income chargeable under the head \r\n“Income from Pr operty”.— (1) In computing the income of a 5[ ] 6[person] \r\nchargeable to  tax under the head “Income from Property” for a tax year, a \r\ndeduction shall be allowed for the following expenditures or allowances, namely: - \r\n \r\n(a)   In respect of repairs to a building, an allowance equal to one -fifth of \r\nthe rent chargeable to tax in resp ect of the building for the year, \r\ncomputed before any deduction allowed under this section; \r\n \r\n(b) any premium paid or payable by the 7[  ] 8[person]  in the year to insure \r\nthe building against the risk of damage or destruction; \r\n \r\n(c) any local rate, tax, charge or cess in respect of the property or the rent \r\nfrom the property paid or payable by the 9[  ] 10[person]  to any local \r\nauthority or government in the year, not being any tax payable under \r\nthis Ordinance; \r\n \r\n(d) any ground rent paid or payable by the 11[  ] 12[person]  in the year in \r\nrespect  of the property; \r\n \r\n(e) any profit paid or payable by the 13[ ] 14[person]  in the year on any \r\nmoney borrowed including by way of mortgage, to acquire, construct, \r\nrenovate, extend or reconstruct the property; \r\n                                            \r\n1 Clause (6) omitted by the Finance Act, 2021. The omitted clause read as follows: \r\n    “(6) Income under this section derived by an individual or an association of persons shall be liable \r\nto tax at the rate specified in Division VIA of Part I of the First Schedule.”   \r\n2 Clause (7) inserted by the Finance Act, 2016. \r\n3 Clause (7) omitted by the Finance Act, 2021. The omitted clause read as follows: \r\n“(7) The provisions of sub-section (1), shall not apply in respect of an individual  or association of \r\npersons who derive income chargeable to tax under this section not exceeding two hundred \r\nthousand rupees in a tax year and does not derive taxable income under any other head.” \r\n4Inserted by the Finance Act, 2013. \r\n5 The word “person” substituted by the Finance Act, 2016. \r\n6 The word “company” substituted by the Finance Act, 2021.  \r\n7The word “person” substituted by the Finance Act, 2016. \r\n8 The word “company” substituted by the Finance Act, 2021.  \r\n9The word “person” substituted by the Finance Act, 2016. \r\n10 The word “company” substituted by the Finance Act, 2021.  \r\n11The word “person” substituted by the Finance Act, 2016. \r\n12 The word “company” substituted by the Finance Act, 2021.  \r\n13 The word “person” substituted by the Finance Act, 2016. \r\n14 The word “company” substituted by the Finance Act, 2021.  \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n58 \r\n \r\n(f)  where the property has been acquired, constructed, renovated, \r\nextended, or reconstructed by the 1[ ] 2[person] with capital contributed \r\nby the House Building Finance Corporation or a scheduled bank under \r\na scheme of investment in property on the basis of sharing the  rent \r\nmade by the Corporation or bank, the share in rent and share towards \r\nappreciation in the value of property (excluding the return of capital, if \r\nany) from the property paid or payable by the 3[  ] 4[person] to the said \r\nCorporation or the bank in the year under that scheme; \r\n \r\n(g)  where the property is subject to mortgage or other capital charge, the \r\namount of profit or interest paid on such mortgage or charge; \r\n \r\n5[(h)  any expenditure, not exceeding 6[four] per cent of the rent chargeable \r\nto tax in respe ct of the property for the year computed before any \r\ndeduction allowed under this section, paid or payable by the 7[ ] \r\n8[person] in the year wholly and exclusively for the purpose of deriving \r\nrent chargeable to tax under the head, “Income from Property” \r\nincluding administration and collection charges;”] \r\n \r\n(i) any expenditure paid or payable by the 9[  ] 10[person] in the tax year \r\nfor legal services acquired to defend the 11[  ] 12[persons]’s title to the \r\nproperty or any suit connected with the property in a court; and \r\n \r\n(j) where there are reasonable grounds for believing that any unpaid rent \r\nin respect of the property is irrecoverable, an allowance equal to the \r\nunpaid rent where— \r\n \r\n(i) the tenancy was bona fide, the defaulting tenant has vacated \r\nthe property or steps have  been taken to compel the tenant to \r\nvacate the property and the defaulting tenant is not in \r\noccupation of any other property of the 13[  ] 14[person]; \r\n                                            \r\n1The word “person” substituted by the Finance Act, 2016. \r\n2 The word “company” substituted by the Finance Act, 2021.  \r\n3The word “person” substituted by the Finance Act, 2016. \r\n4 The word “company” substituted by the Finance Act, 2021.  \r\n5Clause (h) substituted by the Finance Act, 2015. The substituted (h) read as follows:- \r\n“(h)  any expenditure (not exceeding six per cent of the rent chargeable to tax in respect of the \r\nproperty for the year computed before any deduction allowed under this section) paid or \r\npayable by the person in the year for the purpose of collecting the rent due in  respect of \r\nthe property;” \r\n6The word “six” substituted by “four” through Finance Act, 2020 dated 30th June, 2020 \r\n7The word “person” substituted by the Finance Act, 2016. \r\n8 The word “company” substituted by the Finance Act, 2021.  \r\n9The word “person” substituted by the Finance Act, 2016. \r\n10 The word “company” substituted by the Finance Act, 2021.  \r\n11The word “person” substituted by the Finance Act, 2016. \r\n12 The word “company” substituted by the Finance Act, 2021.  \r\n13The word “person” substituted by the Finance Act, 2016. \r\n14 The word “company” substituted by the Finance Act, 2021.  \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n59 \r\n \r\n(ii) the 1[ ] 2[persons] has taken all reasonable steps to institute \r\nlegal proceedings for the recovery of the u npaid rent or has \r\nreasonable grounds to believe that legal proceedings would be \r\nuseless; and  \r\n \r\n(iii) the unpaid rent has been included in the income of the 3[ ] \r\n4[persons] chargeable to tax under the head “Income from \r\nProperty” for the tax year in which the rent was due and tax has \r\nbeen duly paid on such income. \r\n \r\n (2)  Where any unpaid rent allowed as a deduction under clause (j) of \r\nsub-section (1) is wholly or partly recovered, the amount recovered shall be \r\nchargeable to tax in the tax year in which it is recovered. \r\n \r\n (3)  Where a person has been allowed a deduction for any expenditure \r\nincurred in deriving rent chargeable to tax under the head “Income from Property” \r\nand the person has not paid the liability or a part of the liability to which the \r\ndeduction relate s within three years of the end of the tax year in which the \r\ndeduction was allowed, the unpaid amount of the liability shall be chargeable to \r\ntax under the head “Income from Property” in the first tax year following the end of \r\nthe three years. \r\n \r\n (4)  Where an unpaid liability is chargeable to tax as a result of the \r\napplication of sub -section (3) and the person subsequently pays the liability or a \r\npart of the liability, the person shall be allowed a deduction for the amount paid in \r\nthe tax year in which the payment is made. \r\n \r\n (5)  Any expenditure allowed to a person under this section as a \r\ndeduction shall not be allowed as a deduction in computing the income of the \r\nperson chargeable to tax under any other head of income.  \r\n \r\n (6)  The provisions of section 21 s hall apply in determining the \r\ndeductions allowed to a person under this section in the same manner as they \r\napply in determining the deductions allowed in computing the income of a person \r\nchargeable to tax under the head “Income from Business”.] \r\n \r\n 5[  ] \r\n  \r\n  6[   ] \r\n                                            \r\n1The word “person” substituted by the Finance Act, 2016. \r\n2 The word “company” substituted by the Finance Act, 2021.  \r\n3The word “person” substituted by the Finance Act, 2016. \r\n4 The word “company” substituted by the Finance Act, 2021.  \r\n5 New sub-section (7) added by Finance Act, 2019 \r\n6 Sub-section (7) omitted by the Finance Act, 2021. The omitted sub-section read as follows: \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n60 \r\n \r\n16. Non-adjustable amounts received in relation to buildings.— (1)  Where \r\nthe owner of a building receives from a tenant an amount which is not adjustable \r\nagainst the rent payable by the tenant, the amount shall be treated as rent \r\nchargeable to tax under the head “Income from Property” in the tax year in which \r\nit was received and the following nine tax years in equal proportion. \r\n \r\n (2) Where an amount (hereinafter referred to as the “earlier amount”) \r\nreferred to in sub-section (1) is refunded by the owner to the tenant on termination \r\nof the tenancy before the expiry of ten years, no portion of the amount shall be \r\nallocated to the tax year in which it is refunded or to any subsequent tax year \r\nexcept as provided for in sub-section (3). \r\n \r\n (3) Where the circumstances specified in sub-section (2) occur and the \r\nowner lets out the building or part thereof to another person (hereinafter referred \r\nto as the “succeeding tenant”) and receives from the succeeding tenant any \r\namount (hereinafter referred to as the “s ucceeding amount”) which is not \r\nadjustable against the rent payable by the succeeding tenant, the succeeding \r\namount as reduced by such portion of the earlier amount as was charged to tax \r\nshall be treated as rent chargeable to tax under the head “Income fro m Property” \r\nas specified in sub-section (1). \r\n1[  ] \r\n                                            \r\n“(7) Notwithstanding sub-section (6) of section 15, the provisions of this section shall apply to \r\nan individual or an association of persons,6[ ] who opts to pay tax at the rate specified in \r\nDivision I of Part I of the First Schedule.” 1 Section 17 omitted  by the Finance Act, 2006. The omitted section 17 read as follows:  \r\n “17. Deductions in computing income chargeable under the head “Income from \r\nProperty”.- (1)  In computing the income of a person chargeable to tax under the head “Income from \r\nProperty” for a tax year, a deduction shall be allowed for the following expend itures or allowances, \r\nnamely:– \r\n(a) In respect of repairs to a building, an allowance equal to one-fifth of the rent chargeable to tax in respect \r\nof the building for the year, computed before any deduction allowed under this section; \r\n(b) any premium paid or payable by the person in the year to insure the building against the risk \r\nof damage or destruction; \r\n(c) any local rate, tax, charge, or cess in respect of the property or the rent from the property paid \r\nor payable by the person to any local authority or g overnment in the year, not being any tax \r\npayable under this Ordinance; \r\n(d) any ground rent paid or payable by the person in the year in respect of the property; \r\n(e) any profit paid or payable by the person in the year on any money borrowed including by way \r\nof mortgage, to acquire, construct, renovate, extend, or reconstruct the property; \r\n(f) where the property has been acquired, constructed, renovated, extended, or reconstructed by \r\nthe person with capital contributed by the House Building Finance Corporation or a scheduled \r\nbank under a scheme of investment in property on the basis of sharing the rent made by the \r\nCorporation or bank, the share in rent and share towards appreciation in the value of property \r\n(excluding the return of capital, if any) from the property paid or payable by the person to the \r\nsaid Corporation or the bank in the year under that scheme; \r\n (fa)  where the property is subject to mortgage or other capital charge, the amount of profit or interest \r\npaid on such mortgage or charge; \r\n(g) any expenditure (not exceeding six per cent of the rent chargeable to tax in respect of the \r\nproperty for the year computed before any deduction allowed under this section) paid or \r\npayable by the person in the year for the purpose of collecting the rent due in resp ect of the \r\nproperty; \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n61 \r\n \r\nPART IV \r\nHEAD OF INCOME: INCOME FROM BUSINESS \r\n \r\nDivision I \r\nIncome from Business \r\n \r\n18. Income from business.— (1)  The following incomes of a person for a tax \r\nyear, other than income exempt from tax under this Ordinance, shall be chargeable \r\nto tax under the head “Income from Business” — \r\n \r\n(a) the profits and gains of any business carried on by a person at any time \r\nin the year; \r\n \r\n(b) any income derived by any trade, professional or similar association from \r\nthe sale of goods or provision of services to its members 1[. \r\n  \r\nExplanation.– For the removal of doubt, it is clarified that income \r\nderived by co-operative societies 2[including recreational club] from the \r\nsale of goods, immoveable property or provision of servic es to its \r\n                                            \r\n(h) any expenditure paid or payable by the person in the tax year for legal services acquired to defend the \r\nperson’s title to the property or any suit connected with the property in a Court; and \r\n(i) where there are reasonable grounds f or believing that any unpaid rent in respect of the \r\nproperty is irrecoverable, an allowance equal to the unpaid rent where – \r\n  (i) the tenancy was bona fide, the defaulting tenant has vacated the property or steps have \r\nbeen taken to compel the tenant to vacate the property, and the defaulting tenant is not \r\nin occupation of any other property of the person; \r\n (ii) the person has taken all reasonable steps to institute legal proceedings for the recovery \r\nof the unpaid rent or has reasonable grounds to believe t hat legal proceedings would \r\nbe useless; and \r\n(iii) the unpaid rent has been included in the income of the person chargeable to tax under \r\nthe head “Income from Property” for the tax year in which the rent was due and tax has \r\nbeen duly paid on such income. \r\n (2) Where any unpaid rent allowed as a deduction under clause (i) of sub -section (1) is \r\nwholly or partly recovered, the amount recovered shall be chargeable to tax in the tax year in which it \r\nis recovered. \r\n (3) Where a person has been allowed a deduction for any expenditure incurred in deriving \r\nrent chargeable to tax under the head “Income from Property” and the person has not paid the liability \r\nor a part of the liability to which the deduction relates within three years of the end of the tax year in \r\nwhich the deduction was allowed, the unpaid amount of the liability shall be chargeable to tax under \r\nthe head “Income from Property” in the first tax year following the end of the three years. \r\n (4) Where an unpaid liability is chargeable to tax as a result of the application of sub-section \r\n(3) and the person subsequently pays the liability or a part of the liability, the person shall be allowed a \r\ndeduction for the amount paid in the tax year in which the payment is made.  \r\n (5) Any expenditure allowed to a person u nder this section as a deduction shall not be \r\nallowed as a deduction in computing the income of the person chargeable to tax under any other head \r\nof income. \r\n (6) The provisions of section 21 shall apply in determining the deductions allowed to a \r\nperson under this section in the same manner as they apply in determining the deductions allowed in \r\ncomputing the income of a person chargeable to tax under the head “Income from Business”.” \r\n1 Semi colon substituted and Explanation added by the Finance Act, 2021. \r\n2 Words inserted by the Finance Act, 2025. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n62 \r\n \r\nmembers is and has always been chargeable to tax under the \r\nprovisions of this Ordinance;] \r\n \r\n(c) any income from the hire or lease of tangible movable property;  \r\n \r\n(d) the fair market value of any benefit or perquisite, whether \r\nconvertible into money or not, derived by a person in the course \r\nof, or by virtue of, a past, present, or prospective business \r\nrelationship1[.]  \r\n \r\n2[Explanation. — For the purposes of this clause, it is declared that \r\nthe word ‘benefit’ includes any benefit derived by way of waiver of \r\nprofit on debt or the debt itself under the State Bank of Pakistan \r\nBanking Policy Department’s Circular No.29 of 2002 or in any other \r\nscheme issued by the State Bank of Pakistan;] \r\n \r\n(e) any management fee derived by a management company \r\n(including a modaraba 3[management company] ).]   \r\n \r\n4[Explanation.—For the removal of doubt it is clarified that \r\nincome subject to taxation under sections 5A, 5AA, 6, 7 and 7A \r\nshall not be chargeable to tax under this section.”] \r\n \r\n (2) Any profit on debt derived by a person where the person’s business is \r\nto derive such income shall be chargeable to tax under the head “Income from \r\nBusiness” and not under the head “Income from Other Sources”. \r\n \r\n5[(3) Where a 6[lessor], being a scheduled bank or an investment bank or \r\na development finance institution or a modaraba or a leasing company has leased \r\nout any asset, whether owned by it or not, to another person, any amount paid or \r\npayable by the said person in connection with the lease of said asset shall be \r\ntreated as the income of the said 7[lessor] and shall be chargeable to tax under the \r\nhead “Income from Business”.] \r\n \r\n8[(4) Any amount received by a banking company or a non-banking finance \r\ncompany, where such amount represents distribution by a mutual fund 9[or a \r\n                                            \r\n1The semi-colon and the word “and” substituted by the Finance Act, 2011. \r\n2Inserted by the Finance Act, 2011. \r\n3 Inserted by the Finance Act, 2002 \r\n4 Added by the Finance Act, 2018 \r\n \r\n5 Added by the Finance Act, 2003. \r\n6The word “lesser”  substituted by the word “lessor”  by the Finance Act, 2014. \r\n7The word “lesser”  substituted by the word “lessor”  by the Finance Act, 2014. \r\n8Added by the Finance Act, 2003. \r\n9Inserted by the Finance Act, 2007. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n63 \r\n \r\nPrivate Equity and Venture Capital Fund] out of its income from profit on debt, shall \r\nbe chargeable to tax under the head “Income from Business” and not under the \r\nhead “Income from Other Sources”.] \r\n \r\n19. Speculation business.— (1)  Where a person carries on a speculation \r\nbusiness – \r\n \r\n(a) that business shall be treated as distinct and separate from any \r\nother business carried on 1[by]the person; \r\n \r\n(b) this Part shall apply separately to the speculation business and \r\nthe other business of the person; b head “Income from \r\nBusiness” for that year; and \r\n \r\n(e) any loss of the person arising from the speculation business \r\nsustained for a tax year computed in accordance with this Part \r\nshall be dealt with under section 58. \r\n \r\n (2) In this section, “speculation business” means any business in which a \r\ncontract for the purchase and sale of any commodity (including 2[stocks] and \r\nshares) is periodically or ultimately settled otherwise than by the actual delivery or \r\ntransfer of the commodity, but does not include a business in which — \r\n \r\n(a) a contract in respect of raw materials or merchandise is entered \r\ninto by a person in the course of a manufacturing or mercantile \r\nbusiness to guard against loss through future price fluctuations \r\nfor the purpose of fulfilling the person’s other contracts for the \r\nactual delivery of the goods to be manufactured or merchandise \r\nto be sold; \r\n(b) a contract in respect of stocks and shares is entered into by a \r\ndealer or investor therein to guard against loss in the person’s \r\nholding of stocks and shares through price fluctuations; or \r\n \r\n(c) a contract is entered into by a member of a forward market or \r\nstock exchange in the course of any transaction in the nature of \r\njobbing 3[arbitrage] to guard against any loss which may arise in \r\nthe ordinary course of the person’s business as such member. \r\n \r\n  \r\n                                            \r\n1Inserted by the Finance Act, 2002 \r\n2 The word “stock” substituted by the Finance Act, 2005. \r\n3 The word “arbitrate” substituted by the Finance Act, 2005. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n64 \r\n \r\nDivision II \r\nDeductions: General Principles \r\n \r\n20. Deductions in computing income chargeable under the head “Income \r\nfrom Business”.— (1)  Subject to this Ordinance, in computing the income of a \r\nperson chargeable to tax under the head “Income from Business” for a tax year, a \r\ndeduction shall be allowed for any expenditure incurred by the person in the year \r\n1[wholly and exclusively for the purposes of business]. \r\n \r\n 2[(1A) Subject to this Ordinance, where animals which have been used for \r\nthe purposes of  the business or profession otherwise than as stock -in-trade and \r\nhave died or become permanently useless for such purposes, 3[a deduction shall \r\nbe allowed equal to] the difference between the actual cost to the taxpayer of the \r\nanimals and the amount, if any, realized in respect of the carcasses or animals.] \r\n \r\n (2) Subject to this Ordinance, where the expenditure referred to in sub -\r\nsection (1) is incurred in acquiring a depreciable asset or an intangible with a useful \r\nlife of more than one year or is pre-commencement expenditure, the person must \r\ndepreciate or amortise the expenditure in accordance with sections 22, 23, 24 and \r\n25. \r\n \r\n4[(3) Subject to this Ordinance, where any expenditure is incurred by an \r\namalgamated company on legal and financial advisory servic es and other \r\nadministrative cost relating to planning and implementation of amalgamation, a \r\ndeduction shall be allowed for such expenditure.] \r\n \r\n21. Deductions not allowed. — Except as otherwise provided in this \r\nOrdinance, no deduction shall be allowed in com puting the income of a person \r\nunder the head “Income from Business” for — \r\n \r\n(a) any cess, rate or tax paid or payable by the person in Pakistan or a \r\nforeign country that is levied on the profits or gains of the business or \r\nassessed as a percentage or otherwise on the basis of such profits or \r\ngains; \r\n(b) any amount of tax deducted under Division III of Part V of Chapter X \r\nfrom an amount derived by the person;  \r\n                                            \r\n1 The words “to the extent the expenditure is incurred in deriving income from business chargeable to \r\ntax” substituted by the Finance Act, 2004. \r\n2Inserted by the Finance Act, 2009. \r\n3 Inserted by the Finance Act, 2021. \r\n4 Added  by the Finance Act, 2002 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n65 \r\n \r\n1[(c) any expenditure from which the person is required to deduct or collect \r\ntax under Part V of Chap ter X or Chapter XII, unless the person has \r\npaid or deducted and paid the tax as required by Division IV of Part V \r\nof Chapter X: \r\nProvided that disallowance in respect of purchases of raw \r\nmaterials and finished goods under this clause shall not exceed twenty \r\nper cent of purchases of raw materials and finished goods: \r\nProvided further that recovery of any amount of tax under \r\nsections 161 or 162 shall be considered as tax paid.] \r\n2[(ca) any amount of commission paid or payable in respect of supply of \r\nproducts li sted in the Third Schedule of the Sales Tax Act, 1990, \r\nwhere the amount of commission paid or payable exceeds 0.2 percent \r\nof gross amount of supplies thereof unless the person to whom \r\ncommission is paid or payable, as the case may be, is appearing in \r\nthe active taxpayer list under this Ordinance;]  \r\n(d) any entertainment expenditure in excess of such limits 3[or in violation \r\nof such conditions] as may be prescribed; \r\n(e) any contribution made by the person to a fund that is not a recognized \r\nprovident fund4[,]5[approved pension fund], approved superannuation \r\nfund or approved gratuity fund; \r\n6[(ea) an amount in excess of fifty percent of contribution made by a person \r\nto an approved gratuity fund, an approved pension fund or an \r\napproved superannuation fund.]  \r\n \r\n(f) any contribution made by the person to any provident or other fund \r\nestablished for the benefit of employees of the person, unless the \r\nperson has made effective arrangements to secure that tax is \r\ndeducted under section 149 from any payments made by the fun d in \r\nrespect of which the recipient is chargeable to tax under the head \r\n\"Salary\";  \r\n                                            \r\n1Clause (c) substituted by the Finance Act, 2016. The substituted clause (c) read as follows: \r\n“(c) any salary, rent, brokerage or commission, profit on debt, payment to non-resident, payment \r\nfor services or fee paid by the person from which the person is required to deduct tax under \r\nDivision III of Part V of Chapter X or section 233 of chapter XII, 1[unless] the person has 1[paid \r\nor] deducted and paid the tax as required by Division IV of Part V of Chapter X” \r\n2New clause (ca) inserted by Finance Act, 2019. \r\n3 Inserted by the Finance Act, 2003. \r\n4Inserted by Finance Act, 2014. \r\n5 Inserted by the Finance Act, 2005. \r\n6 Clause (ea) inserted by the Finance Act, 2022. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n66 \r\n \r\n(g) any fine or penalty paid or payable by the person for the violation of \r\nany law, rule or regulation; \r\n(h) any personal expenditures incurred by the person;  \r\n(i) any amount carried to a reserve fund or capitalised in any way;  \r\n(j) any profit on debt, brokerage, commission, salary or other \r\nremuneration paid by an association of persons to a member of the \r\nassociation;  \r\n 1[  ] \r\n  2[(l)  any expenditure for a transaction, paid or payable under a  single account \r\nhead which, in aggregate, exceeds 3[two hundred and fifty]  thousand \r\nrupees, made other than by a crossed cheque drawn on a bank or by \r\ncrossed bank draft or crossed pay order or any other crossed banking \r\ninstrument showing transfer of amount from the business bank account \r\nof the taxpayer: \r\nProvided that online transfer of payme nt from the business \r\naccount of the payer to the business account of payee as well as \r\npayments through credit card shall be treated as transactions through \r\nthe banking channel, subject to the condition that such transactions \r\nare verifiable from the bank statements of the respective payer and \r\nthe payee: \r\nProvided further that this clause shall not apply in the case of — \r\n(a)  expenditures not exceeding 4[twenty-five] thousand \r\nrupees;  \r\n   (b)  expenditures on account of — \r\n    (i)  utility bills; \r\n    (ii)  freight charges; \r\n                                            \r\n1 Clause (k) omitted by the Finance Act, 2006. The omitted clause (k) read as follows: \r\n “(k) any expenditure paid or payable by an employer on the provision of perquisites and allowances \r\nto an employee where the sum of the value of the p erquisites computed under section 13 and \r\nthe amount of the allowances exceeds fifty per cent of the employee’s salary for a tax year \r\n(excluding the value of the perquisites or amount of the allowances);” \r\n2 Clause (l) substituted by the Finance Act, 2006. The substituted clause (l) read as follows: \r\n“(l) any expenditure paid or payable under a single account head which, in aggregate, exceeds fifty \r\nthousand rupees made other than by a crossed bank cheque or crossed bank draft, except \r\nexpenditures not exceeding ten thousand rupees or on account of freight charges, travel fare, \r\npostage, utilities or payment of taxes, duties, fee, fines or any other statutory obligation;” \r\n3 Expression substituted through Finance Act, 2020 dated 30th June, 2020 \r\n4 Expression substituted through Finance Act, 2020 dated 30th June, 2020 \r\n \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n67 \r\n \r\n    (iii)  travel fare;  \r\n    (iv)  postage; and \r\n(v)  payment of taxes, duties, fee, fines or any other  \r\nstatutory obligation 1[:]] \r\n2[Provided further also that this clause shall not \r\napply to a company from the date clause (la) has been \r\nmade effective through the not ification issued by the \r\nBoard. \r\n   \r\n(la) any expenditure by a taxpayer being a company for a transaction, paid \r\nor payable under a single account head which, in aggregate, exceeds \r\nrupees two hundred and fifty thousand, made other than by digital \r\nmeans from business bank account of the taxpayer notified to the \r\nCommissioner under section 114A: \r\n \r\nProvided that this clause shall not apply in the case of- \r\n \r\n(a) expenditures not exceeding Rupees twenty-five thousand; and \r\n(b) expenditures on account of — \r\n(i) utility bills;  \r\n(ii) freight charges; \r\n(iii) travel fare; \r\n(iv) postage; and \r\n(v) payment of taxes, duties, fee, fines or any other statutory \r\nobligation: \r\n \r\nProvided further that this clause shall be effective from such date \r\nas the Board may notify.]   \r\n \r\n(m) any salary paid or payable exceeding 3[  ] 4[thirty-two thousand rupees \r\nper month to an individual] other than by a crossed cheque or direct \r\ntransfer of funds to the employee’s bank account  5[or through digital \r\nmeans]; 6[   ] \r\n                                            \r\n1 Semi colon substituted by the Finance Act, 2022. \r\n2 Inserted by the Finance Act, 2022. \r\n3 The word “fifteen” substituted by the Finance Act, 2020 dated 30th June, 2020. \r\n4 The expression “twenty-five thousand rupees per month” substituted by the Finance Act, \r\n2023. \r\n5 Inserted by the Finance Act, 2022. \r\n6 The word “and” omitted by the Finance Act, 2016. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n68 \r\n \r\n(n) except as provided in Division III of this Part, any expenditure paid or \r\npayable of a capital nature; 1[   ]  \r\n2[(o) any expenditure in respect of sales promotion, advertisement and \r\npublicity i n excess of 3[ten] per cent of turnover incurred by \r\npharmaceutical manufacturers 4[;] ] \r\n5[(p) any expenditure on account of utility bill in excess of such limits and in \r\nviolation of such conditions as may be prescribed; 6[  ]  \r\n7[(q)  ten percent of the claimed expenditure made attributable to purchases \r\nmade from persons who are not National Tax Number holders:  \r\nProvided that in case of purchase of agricultural produce this \r\nclause shall only apply to the purchase made from middle man:  \r\nProvided further that the Board may, by notification in the official \r\nGazette, exempt persons or classes of persons from this clause \r\nsubject to such conditions and limitations as may be specified therein;] \r\n8[(r)  any expenditure attributable to sales claimed by any person who is  \r\nrequired to integrate but fails to integrate his business with the Board \r\nthrough approved fiscal electronic device and software: \r\n \r\n                                            \r\n1 The word “and” omitted by the Finance Act, 2020 dated 30th June, 2020. \r\n2 Inserted by the Finance Act, 2016 \r\n3 The word “five” substituted by the Finance Act, 2017 \r\n4 Full stop substituted by semi colon through Finance Act, 2020 dated 30th June, 2020 \r\n5 New clauses (p) and (q)  added through Finance Act, 2020 dated 30th June, 2020 \r\n6 The word “and” omitted by the Finance Act, 2025. \r\n7 Clause (q) substituted by the Finance Act, 2025. The substituted clause read as follows: \r\n   “(q) any expenditure attributable to sales made to persons required to be registered but not \r\nregistered under the Sales Tax Act, 1990 by an in dustrial undertaking computed according to \r\nthe following formula, namely:- \r\n (A/B) x C \r\n Where— \r\n A is the total amount of deductions claimed under this Part; \r\n B is the turnover for the tax year; and  \r\nC is the total amount of sales exclusive of sales tax and federal excise duty to persons \r\nrequired to be registered but not registered under the Sales Tax, 1990 where sales \r\nequal or exceed rupees one hundred million per person: \r\n   Provided that disallowance of expenditure under this clause shall not exceed \r\nten percent of total deductions claimed under this Part: \r\n   Provided further that the Board may, by notification in the official Gazette, \r\nexempt persons or classes of persons from this clause subject to such conditions and \r\nlimitations as may be specified therein: \r\n   Provided also that this clause shall come into force with effect from the first day \r\nof October, 2020.]” \r\n8 Inserted by the Finance Act, 2022. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n69 \r\n \r\nProvided that disallowance of expenditure under this clause \r\nshall not exceed eight percent of the allowable deduction 1[; and] ]  \r\n \r\n2[(s) fifty percent of the expenditure claimed in respect of sale where the \r\ntaxpayer received payment exceeding two hundred thousand rupees \r\notherwise than through a banking channel or digital means against a \r\nsingle invoice containing one or more than one transactions of supply \r\nof goods or provisions of services.] \r\n \r\nDivision III \r\nDeductions: Special Provisions \r\n \r\n22. Depreciation.— (1)  Subject to this section, a person shall be allowed a \r\ndeduction for the depreciation of the person’s depreciable assets us ed in the \r\nperson’s business in the tax year 3[: \r\n \r\nProvided that the depreciation expense shall not be allowed for the \r\namount paid for addition of capital assets to a seller in all relevant tax years \r\nif the tax deductible under sections 152 or 153 of the Ord inance in respect \r\nof those payments has not been deducted and deposited in the treasury, by \r\nnot adding such amount paid for addition in capital assets in the assets for \r\ncomputation of tax depreciation.] \r\n \r\n (2) Subject to 4[sub-section] (3) 5[  ], the depreciation deduction for a tax year \r\nshall be computed by applying the rate specified in Part I of the Third Schedule against \r\nthe written down value of the asset at the beginning of the year 6[ ] 7[.] \r\n \r\n 8[  ]  \r\n \r\n (3) Where a depreciable asset is used in a tax ye ar partly in deriving \r\nincome from business chargeable to tax and partly for another use, the deduction \r\nallowed under this section for that year shall be restricted to the fair proportional \r\n                                            \r\n1 Full stop substituted by the Finance Act, 2025. \r\n2 Clause (s) inserted by the Finance Act, 2025.  \r\n3 Full stop substituted by colon and thereafter the new proviso added by the Finance Act, 2025. \r\n4 The word “sub-sections” substituted by the Finance Act, 2005. \r\n5 The word, brackets and figure “and (4)” omitted by Finance Act, 2004. \r\n6 Full stop substituted by colon and thereafter the new proviso added through Finance Act, 2020 \r\ndated 30th June, 2020 \r\n7 Colon substituted by the Finance Act, 2025. \r\n8 Proviso omitted by the Finance Act, 2022. The omitted proviso read as follows: \r\n“Provided that where a depreciable asset is use d in the person’s business for the first \r\ntime in a tax year commencing on or after the 1st day of July, 2020, the depreciation deduction \r\nshall be reduced by fifty percent.” \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n70 \r\n \r\npart of the amount that would be allowed if the asset 1[was] wholly used to 2[derive] \r\nincome from business chargeable to tax. \r\n \r\n 3[  ] \r\n \r\n (5) The written down value of a depreciable asset of a person at the \r\nbeginning of the tax year shall be — \r\n \r\n(a) where the asset was acquired in the tax year, the cost of the \r\nasset to the p erson as reduced by any initial allowance in \r\nrespect of the asset under section 23; or \r\n(b) in any other case, the cost of the asset to the person as reduced \r\nby the total depreciation deductions (including any initial \r\nallowance under section 23) allowed to the person in respect of \r\nthe asset in previous tax years. \r\n \r\n4[“Explanation,- For the removal of doubt, it is clarified that where any \r\nbuilding, furniture, plant or machinery is used for the purposes of \r\nbusiness during any tax year for which the income from such business \r\nis exempt, depreciation admissible under sub -section (1) shall be \r\ntreated to have been allowed in respect of the said tax year and after \r\nexpiration of the exemption period, written down value of such assets \r\nshall be determined after reducing total depreciation deductions \r\n(including any initial allowance under section 23) in accordance with \r\nclauses (a) and (b) of this sub-section.”] \r\n (6) Where sub-section (3) applies to a depreciable asset for a tax year, \r\nthe written down value of the asset sha ll be computed on the basis that the asset \r\nhas been solely used to derive income from business chargeable to tax.  \r\n (7) The total deductions allowed to a person during the period of \r\nownership of a depreciable asset under this section and section 23 shall n ot \r\nexceed the cost of the asset. \r\n                                            \r\n1The word “were” substituted by the Finance Act, 2010. \r\n2 The word “derived” substituted by the Finance Act, 2003. \r\n3 Sub-section (4) omitted by the Finance Act, 2004. The omitted sub-section (4) reads as follows: \r\n“(4) Where a depreciable asset is not used for the whole of the tax year in deriving income \r\nfrom business chargeable to tax, th e deduction allowed under this section shall be computed \r\naccording to the following formula, namely:– \r\nA x B/C \r\nwhere – \r\nA is the amount of depreciation computed under sub-section (2) or (3), as the case may be;  \r\nB is the number of months in the tax year the asset is used in deriving income from business \r\nchargeable to tax; and \r\nC is the number of months in the tax year.” \r\n4 Inserted by the Finance Act, 2016. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n71 \r\n \r\n (8) Where, in any tax year, a person disposes of a depreciable asset, no \r\ndepreciation deduction shall be allowed under this section for that year and — \r\n(a) if the consideration received exceeds the written down value of \r\nthe asset at the time of disposal, the excess shall be chargeable \r\nto tax in that year under the head “Income from Business”; or  \r\n(b) if the consideration received is less than the written down value of \r\nthe asset at the time of disposal, the difference shall be allowed as \r\na deduction in computing the person’s income chargeable under \r\nthe head “Income from Business” for that year 1[:] \r\n2[  ]  \r\n (9) Where sub-section (3) applies, the written down value of the asset for \r\nthe purposes of sub -section (8) shall be incre ased by the amount that is not \r\nallowed as a deduction as a result of the application of sub-section (3). \r\n (10) Where clause (a) of sub -section (13) applies, the 3[consideration \r\nreceived on disposal] of the passenger transport vehicle for the purposes of su b-\r\nsection (8) shall be computed according to the following formula — \r\nA x B/C \r\nwhere – \r\nA is the 4[amount] received on disposal of the vehicle; \r\nB is the amount referred to in clause (a) of sub-section (13); and \r\nC is the actual cost of acquiring the vehicle. \r\n (11) Subject to sub-sections (13) and (14), the rules in Part III of Chapter IV \r\nshall apply in determining the cost and consideration received in respect of a \r\ndepreciable asset for the purposes of this section. \r\n \r\n5[(12) The depreciation deductions allowed t o a leasing company or an \r\ninvestment bank or a modaraba or a scheduled bank or a development finance \r\n                                            \r\n1 Full stop substituted by colon and thereafter the new proviso added through Finance Act, 2020 \r\ndated 30th June, 2020 \r\n \r\n2 Proviso omitted by the Finance Act, 2022. The omitted proviso read as follows: \r\n“Provided that where a depreciable asset is used in the person’s business for the first time in \r\na tax year commencing on or after the 1st day of July, 2020, depreciation deduction equal to fifty \r\npercent of the rate specified in Part I of the Third Schedule shall be allowed in the year of disposal.”. \r\n3 The words “written down value” substituted by the Finance Act, 2004. \r\n4 The word “consideration” substituted by the Finance Act, 2004. \r\n5 Sub-section (12) substituted by the Finance Act, 2002. The substituted sub -section (12)  read as \r\nfollows: \r\n“(12) The depreciation deductions allowed to a leasing company in respect of assets owned \r\nby the company and leased to another p erson shall be deductible only against the lease rental \r\nincome derived in respect of such assets.”  \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n72 \r\n \r\ninstitution in respect of assets owned by the leasing company or an investment \r\nbank or a modaraba or a scheduled bank or a development finance institution and \r\nleased to another person shall be deductible only against the lease rental income \r\nderived in respect of such assets.] \r\n \r\n (13) For the purposes of this section, — \r\n \r\n(a) the cost of a depreciable asset being a passenger transport \r\nvehicle not pl ying for hire shall not exceed  1[seven and a half]  \r\nmillion rupees; \r\n \r\n  2[  ] \r\n \r\n(b) the cost of immovable property or a structural improvement to \r\nimmovable property shall not include the cost of the land; \r\n \r\n3[(c)  any asset owned by a leasing company or an investment ban k \r\nor a modaraba or a scheduled bank or a development finance \r\ninstitution and leased to another person is treated as used in the \r\nleasing company or the investment bank or the modaraba or the \r\nscheduled bank or the development finance institution’s \r\nbusiness; and] \r\n \r\n(d) where the consideration received on the disposal of immovable \r\nproperty exceeds the cost of the property, the consideration \r\nreceived shall be treated as the cost of the property. \r\n \r\n (14) Where a depreciable asset that has been used by a person in Pakistan \r\nis exported or transferred out of Pakistan, the person shall be treated as having \r\ndisposed of the asset at the time of the export or transfer for a consideration \r\nreceived equal to the cost of the asset. \r\n \r\n (15) In this section, — \r\n \r\n“depreciable asset” means any tangible movable property, immovable \r\nproperty (other than unimproved land), or structural improvement to \r\nimmovable property, owned by a person that — \r\n \r\n(a) has a normal useful life exceeding one year; \r\n \r\n                                            \r\n1 The expression “1[two]1[and half]” substituted by the Finance Act, 2022. \r\n2Proviso omitted by the Finance Act, 2009. The omitted proviso read as follows: \r\n   “Provided that the prescribed limit of one million rupees shall not apply to passenger transport \r\nvehicles, not plying for hire, acquired on or after the first day of July, 2005.” \r\n3Clause (c) substituted by the Finance Act, 2002. The substituted clause read as follows: \r\n“(c)  an asset owned by a financial institution or leasing company and leased to another person \r\nis treated as used in the financial institution or leasing company’s business; and”. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n73 \r\n \r\n(b) is likely to lose value as a result of normal wear and tear, or \r\nobsolescence; and \r\n \r\n(c) is used wholly or partly by the person in deriving income from \r\nbusiness chargeable to tax, \r\n \r\nbut shall not include any tangible movable property, immovable \r\nproperty, or structural improvement to immovable prop erty in relation \r\nto which a deduction has been allowed under another section of this \r\nOrdinance for the entire cost of the property or improvement in the tax \r\nyear in which the property is acquired or improvement made by the \r\nperson; and \r\n \r\n“structural improvem ent” in relation to immovable property, includes \r\nany building, road, driveway, car park, railway line, pipeline, bridge, \r\ntunnel, airport runway, canal, dock, wharf, retaining wall, fence, power \r\nlines, water or sewerage pipes, drainage, landscaping or dam 1[:] \r\n \r\n2[Provided that where a depreciable asset is jointly owned by a \r\ntaxpayer and an Islamic financial institution licensed by the State Bank \r\nof Pakistan or Securities and Exchange Commission of Pakistan, as \r\nthe case may be, pursuant to an arrangement of Musharika financing \r\nor diminishing Musharika financing, the depreciable asset shall be \r\ntreated to be wholly owned by the taxpayer.] \r\n \r\n23. Initial allowance.—(1)  A person who places an eligible depreciable asset \r\ninto service in Pakistan for the first time in a tax year shall be allowed a deduction \r\n(hereinafter referred to as an “initial allowance”) computed in accordance with sub-\r\nsection (2), provided the asset is 3[used by the person for the purposes of his \r\nbusiness for the first time or the tax year in which  commercial production is \r\ncommenced, whichever is later]. \r\n(2) The amount of the initial allowance of a person shall be computed by \r\napplying the rate specified in Part II of the Third Schedule against the cost of the \r\nasset. \r\n (3) The rules in section 76 shall apply in determining the cost of an eligible \r\ndepreciable asset for the purposes of this section. \r\n                                            \r\n1Full stop substituted by Finance Act, 2017. \r\n2Added by the Finance Act, 2017. \r\n3Substituted for “wholly and exclusively used by the person in deriving income from business \r\nchargeable to tax” by Finance Act,2004 dated June 24,2004 w.e.f July 1,2004 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n74 \r\n \r\n1[(4) A deduction allowed under this section to a leasing company or an \r\ninvestment bank or a modaraba or a scheduled bank or a development finance \r\ninstitution in respect of assets owned by the leasing company or the investment \r\nbank or the modaraba or the scheduled bank or the development finance institution \r\nand leased to another person shall be deducted only against the leased rental \r\nincome derived in respect of such assets.] \r\n (5) In this section, “eligible depreciable asset” means a depreciable asset \r\n2[  ] other than — \r\n(a) any road transport vehicle unless the vehicle is plying for hire; \r\n(b) any furniture, including fittings; \r\n(c) any plant or machinery 3[that h as been used previously in \r\nPakistan]; 4[ ]  \r\n(d) any plant or machinery in relation to which a deduction has been \r\nallowed under another section of this Ordinance for the entire \r\ncost of the asset in the tax year in which the asset is acquired    \r\n5[; or \r\n (e) immovable property or structural improvement to the immovable \r\nproperty.] \r\n \r\n6[  ] \r\n 7[  ] \r\n                                            \r\n1 Sub-section (4) substituted by the Finance Act, 2002. The substituted sub-section (4) read as follows: \r\n  “(4) A deduction allowed under this section to a leasing company in respect of assets owned \r\nby the company and leased to another person shall be deductible only against the lease rental \r\nincome derived in respect of such assets.”  \r\n2 The words and comma “that is plant and machinery,” omitted by the Finance Act, 2003. \r\n3The words “that is acquired second hand” substituted by the Finance Act.2003 \r\n4 The word “or” omitted by the Finance Act, 2022. \r\n5 The full stop substituted with semi colon and the word “or” and thereafter clause (e) added by the \r\nFinance Act, 2022. \r\n6Inserted by the Finance Act, 2008. \r\n7 Section 23A omitted by the Finance Act, 2021. Earlier this omission was made through Tax Laws \r\n(Second Amendment) Ordinance, 2021. The omitted section read as follows: \r\n“23A. First Year Allowance .— (1)  Plant, machinery and equipment installed by any industrial \r\nundertaking set up in specified rural and under developed areas 7[or engaged in the manufacturing of \r\ncellular mobile phones  and qualifying for exemption under clause (126N) of Part I of the Second \r\nSchedule] and owned and managed by a company shall be allowed first year allowance in lieu of initial \r\nallowance under section 23 at the rate specified in Part II of the Third Schedule against the cost of the \r\n“eligible depreciable assets” put to use after July 1, 2008. \r\n(2) The provisions of section 23 except sub-sections (1) and (2) thereof, shall mutatis mutandis \r\napply. \r\n(3) The Federal Government may notify “specified areas” for the purposes of sub-section (1).] \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n75 \r\n \r\n1[23B. Accelerated depreciation to alternate energy projects. — (1) Any plant, \r\nmachinery and equipments installed for generation of alternate energy by an \r\nindustrial undertaking set up anywhere in Pakistan and owned and managed by a \r\ncompany shall be allowed first year allowance in lieu of initial allowance under \r\nsection 23, at the rate specified in Part II of the Third Schedule against the cost of \r\nthe eligible depreciation assets put to use after first day of July, 2009. \r\n (2)  The provisions of section 23 except sub -sections (1) and (2) thereof, \r\nshall mutatis mutandis apply.] \r\n24. Intangibles.—(1) A person shall be allowed an amortisation deduction in \r\naccordance with this section in a tax year for the cost of the person’s intangibles– \r\n(a) that are wholly or partly used by the person in the tax year in \r\nderiving income from business chargeable to tax; and \r\n(b) that have a normal useful life exceeding one year. \r\n (2) No deduction s hall be allowed under this section where a deduction \r\nhas been allowed under another section of this Ordinance for the entire cost of the \r\nintangible in the tax year in which the intangible is acquired. \r\n (3) Subject to sub-section (7), the amortization deduction of a person for \r\na tax year shall be computed according to the following formula, namely:— \r\n \r\nA \r\nB \r\nwhere — \r\n \r\nA is the cost of the intangible; and  \r\n \r\nB is the normal useful life of the intangible in whole years. \r\n \r\n 2[(4) An intangible that does not have an as certainable useful life shall be \r\ntreated as if it had a normal useful life of 3[fifteen years].]  \r\n \r\n (5) Where an intangible is used in a tax year partly in deriving income \r\nfrom business chargeable to tax and partly for another use, the deduction allowed \r\nunder this section for that year shall be restricted to the fair proportional part of the \r\namount that would be allowed if the intangible were wholly used to derive income \r\nfrom business chargeable to tax. \r\n                                            \r\n1Inserted by the Finance Act, 2009. \r\n2 In sub-section 4 of section 24 is substituted by the Finance Act, 2019, the substituted sub -section \r\nread as follow:  \r\n(4) An intangible — \r\n(a) with a normal useful life of more than ten years; or \r\n(b) that does not have an ascertainable useful life, \r\nshall be treated as if it had a normal useful life of ten years. \r\n \r\n3 The expression “twenty-five years” substituted by the Finance Act, 2025. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n76 \r\n \r\n \r\n (6) Where an intangible is not used for the whole of the tax year in deriving \r\nincome from business chargeable to tax, the deduction allowed under this section \r\nshall be computed according to the following formula, namely: — \r\n \r\nA x B/C \r\nwhere — \r\n \r\nA is the amount of 1[amortization] computed under sub -section (3) o r (5), as \r\nthe case may be; \r\n \r\nB is the number of days in the tax year the intangible is used in deriving income \r\nfrom business chargeable to tax; and \r\n \r\nC is the number of days in the tax year. \r\n \r\n (7) The total deductions allowed to a person under this section i n the \r\ncurrent tax year and all previous tax years in respect of an intangible shall not \r\nexceed the cost of the intangible. \r\n \r\n (8) Where, in any tax year, a person disposes of an intangible, no \r\namortisation deduction shall be allowed under this section for that year and — \r\n \r\n(a) if the consideration received by the person exceeds the written \r\ndown value of the intangible at the time of disposal, the excess \r\nshall be income of the person chargeable to tax in that year \r\nunder the head “Income from Business”; or  \r\n \r\n(b) if the consideration received is less than the written down value \r\nof the intangible at the time of disposal, the difference shall be \r\nallowed as a deduction in computing the person’s income \r\nchargeable under the head “Income from Business” in that year. \r\n \r\n (9) For the purposes of sub-section (8) — \r\n \r\n(a) the written down value of an intangible at the time of disposal \r\nshall be the cost of the intangible reduced by the total \r\ndeductions allowed to the person under this section in respect \r\nof the intangible or, whe re the intangible is not wholly used to \r\nderive income chargeable to tax, the amount that would be \r\nallowed under this section if the intangible were wholly so used; \r\nand \r\n \r\n                                            \r\n1 The word “depreciation” substituted by the Finance Act, 2002 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n77 \r\n \r\n(b) the consideration received on disposal of an intangible shall be \r\ndetermined in accordance with section 77. \r\n \r\n (10) For the purposes of this section, an intangible that is available for use \r\non a day (including a non-working day) is treated as used on that day. \r\n \r\n(11) In this section, — \r\n \r\n“cost” in relation to an intangible, means any expendi ture incurred in \r\nacquiring or creating the intangible, including any expenditure incurred \r\nin improving or renewing the intangible; and  \r\n \r\n“intangible” means any patent, invention, design or model, secret \r\nformula or process, copyright 1[, trade mark, scienti fic or technical \r\nknowledge, computer software, motion picture film, export quotas, \r\nfranchise, licence, intellectual property], or other like property or right, \r\ncontractual rights and any expenditure that provides an advantage or \r\nbenefit for a period of mor e than one year (other than expenditure \r\nincurred to acquire a depreciable asset or unimproved land, 2[but shall \r\nnot include self -generated goodwill or any adjustment arising on \r\naccount of accounting treatment in the manner as may be prescribed]  \r\n \r\n25. Pre-commencement expenditure.—(1)  A person shall be allowed a \r\ndeduction for any pre-commencement expenditure in accordance with this section.  \r\n \r\n (2) Pre-commencement expenditure shall be amortized on a straight-line \r\nbasis at the rate specified in Part III of the Third Schedule. \r\n \r\n (3) The total deductions allowed under this section in the current tax year \r\nand all previous tax years in respect of an amount of pre -commencement \r\nexpenditure shall not exceed the amount of the expenditure. \r\n \r\n (4) No deduction shall be allowed under this section where a deduction \r\nhas been allowed under another section of this Ordinance for the entire amount of \r\nthe pre-commencement expenditure in the tax year in which it is incurred.  \r\n \r\n (5) In this section, “pre -commencement expenditure” m eans any \r\nexpenditure incurred before the commencement of a business wholly and \r\nexclusively to derive income chargeable to tax, including the cost of feasibility \r\nstudies, construction of prototypes, and trial production activities, but shall not \r\ninclude any expenditure which is incurred in acquiring land, or which is depreciated \r\nor amortised under section 22 or 24.  \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2The words Inserted by the Finance Act, 2019. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n78 \r\n \r\n26. Scientific research expenditure. — (1)  A person shall be allowed a \r\ndeduction for scientific research expenditure incurred in Pakistan in a tax year \r\nwholly and exclusively for the purpose of deriving income from business \r\nchargeable to tax.  \r\n \r\n (2) In this section — \r\n“scientific research” means any 1[activity] 2[undertaken in Pakistan] in \r\nthe fields of natural or applied science for the developme nt of human \r\nknowledge; \r\n \r\n“scientific research expenditure” means any expenditure incurred by \r\na person on scientific research 3[undertaken in Pakistan] for the \r\npurposes of developing the person’s business, including any \r\ncontribution to a scientific research institution to undertake scientific \r\nresearch for the purposes of the person’s business, other than \r\nexpenditure incurred – \r\n \r\n (a) in the acquisition of any depreciable asset or intangible; \r\n (b) in the acquisition of immovable property; or \r\n \r\n(c) for the purpose of ascertaining the existence, location, extent or \r\nquality of a natural deposit; and \r\n \r\n“scientific research institution” means any institution certified by the \r\n4[Board] as conducting scientific research in Pakistan.  \r\n \r\n27. Employee training and facilities.— A person shall be allowed a deduction \r\nfor any expenditure (other than capital expenditure) incurred in a tax year in \r\nrespect of— \r\n \r\n(a) any educational institution or hospital in Pakistan established for \r\nthe benefit of the person’s employees and their dependents; \r\n \r\n(b) any institute in Pakistan established for the training of industrial \r\nworkers recognized, aided, or run by the Federal Government \r\n5[or a Provincial Government] or a 6[Local Government]; or \r\n                                            \r\n1 The word  “activities” substituted by the Finance Act, 2002 \r\n2 Inserted by the Finance Act, 2003. \r\n3 Inserted by the Finance Act, 2003. \r\n4The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n5Inserted by the Finance Act, 2003. \r\n6The words “local authority” substituted by the Finance Act, 2008. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n79 \r\n \r\n(c) the training of any person, being a citizen of Paki stan, in \r\nconnection with a scheme approved by the 1[Board] for the \r\npurposes of this section.  \r\n \r\n28. Profit on debt, financial costs and lease payments. — (1) Subject to this \r\nOrdinance, a deduction shall be allowed for a tax year for — \r\n(a) any profit on debt incurred by a person in the tax year to the \r\nextent that the proceeds or benefit of the debt have been used \r\nby the person 2[for the purposes of business]; \r\n \r\n(b) any lease rental incurred by a person in the tax year to a \r\nscheduled bank, financial institution, an approved modaraba, an \r\napproved leasing company or a Special Purpose Vehicle on \r\nbehalf of the Originator for an asset used by the person 3[for the \r\npurposes of business] 4[:] \r\n \r\n   5[Provided that for the purpose of determining the \r\ndeduction on account of lease rentals the cost of a passenger \r\ntransport vehicle not paying for hire to the extent of principal \r\namount shall not exceed two and a half million rupees;] \r\n  \r\n(c) any amount incurred by a person in the tax year to a modaraba \r\nor a participation term certificate holder for any funds borrowed \r\nand used by the person 6[for the purposes of business]; \r\n \r\n(d) any amount incurred by a scheduled bank in the tax year to a \r\nperson maintaining a profit or loss sharing account or a deposit \r\nwith the bank as a distribution of profits by the bank in respect \r\nof the account or deposit; \r\n \r\n(e) any amount incurred by the House Building Finance \r\nCorporation (hereinafter referred to as “the Corporation”) \r\nconstituted under the House Building Finance Corporation Act, \r\n1952 (XVIII of 1952 ), in the tax year to the State Bank of \r\n                                            \r\n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n2 The words “in deriving income chargeable to tax under the head “Income from Business” \r\nsubstituted by the Finance Act, 2004. \r\n3 The words “in deriving income chargeable to tax under the head “Income from Business” \r\nsubstituted by the Finance Act, 2004. \r\n4 Sami colon substituted by colon and thereafter the new proviso added through Finance Act, 2020 \r\ndated 30th June, 2020 \r\n \r\n5 Proviso added through Finance Act, 2020 dated 30th June, 2020  \r\n6 The words “in deriving income chargeable to tax under the head “Income from Business” \r\nsubstituted by the Finance Act, 2004. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n80 \r\n \r\nPakistan (hereinafter referred to as “the Bank”) as the share of \r\nthe Bank in the profits derived by the Corporation on its \r\ninvestment in property made under a scheme of partnership in \r\nprofit and loss, where the inves tment is provided by the Bank \r\nunder the House Building Finance Corporation (Issue and \r\nRedemption of Certificates) Regulations, 1982; \r\n \r\n(f) any amount incurred by the National Development Leasing \r\nCorporation Limited (hereinafter referred to as “the \r\nCorporation”) in the tax year to the State Bank of Pakistan \r\n(hereinafter referred to as “the Bank”) as the share of the Bank \r\nin the profits derived by the Corporation on its leasing operations \r\nfinanced out of a credit line provided by the Bank on a profit and \r\nloss sharing basis; \r\n \r\n(g) any amount incurred by the 1[Small and Medium Enterprises \r\nBank (hereinafter referred to as “the SME Bank”)]in the tax year to \r\nthe State Bank of Pakistan (hereinafter referred to as the “Bank”) \r\nas the share of the Bank in the profits derived by the 2[SME Bank] \r\non investments made in small business out of a credit line provided \r\nby the Bank on a profit and loss sharing basis; \r\n \r\n(h) any amount incurred by a person in the tax year to a banking \r\ncompany under a scheme of musharika representing the bank’s \r\nshare in the profits of the musharika; \r\n \r\n(i) any amount incurred by a person in the tax year to a certificate \r\nholder under a musharika scheme approved by the Securities \r\nand Exchange Commission and Religious Board formed under \r\nthe Modaraba Companie s and Modaraba (Floatation and \r\nControl) Ordinance, 1980 (XXXI of 1980) representing the \r\ncertificate holder’s share in the profits of the musharika; or \r\n \r\n(j) the financial cost of the securitization of receivables incurred by \r\nan Originator in the tax year fr om a Special Purpose Vehicle \r\nbeing the difference between the amount received by the \r\nOriginator and the amount of receivables securitized from a \r\nSpecial Purpose Vehicle. \r\n \r\n (2) Notwithstanding any other provision in this Ordinance, where any assets \r\nare transferred by an Originator, as a consequence of securitisation3[“or issuance of \r\n                                            \r\n1The words “ Small Business Finance Corporation (hereinafter referred to as “the Corporation”)” \r\nsubstituted by the Finance Act, 2009. \r\n2The word “Corporation” substituted by the Finance Act, 2011. \r\n3 Inserted by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016.  \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n81 \r\n \r\nsukuks”], to a Special Purpose Vehicle, it shall be treated as a financing transaction \r\nirrespective of the method of accounting adopted by the Originator. \r\n \r\n (3) In this section, — \r\n \r\n“approved leasing company” means a leasing company approved by \r\nthe 1[Board] for the purposes of clause (b) of sub-section (1); and  \r\n“approved modaraba” means a modaraba approved by the 2[Board] \r\nfor the purposes of clause (b) of sub-section (1). \r\n \r\n29. Bad debts.— (1)  A person shall be allowed a deduction for a bad debt in \r\na tax year if the following conditions are satisfied, namely:— \r\n \r\n(a)  the amount of the debt was – \r\n \r\n(i) previously included in the person’s income from business \r\nchargeable to tax; or \r\n \r\n(ii) in respect of money lent by a financial institution in \r\nderiving income from business chargeable to tax;  \r\n \r\n(b) the debt or part of the debt is written off in the accounts of the \r\nperson in the tax year; and \r\n \r\n(c) there are reasonable grounds for believing t hat the debt is \r\nirrecoverable. \r\n \r\n (2) The amount of the deduction allowed to a person under this section \r\nfor a tax year shall not exceed the amount of the debt written off in the accounts \r\nof the person in the tax year. \r\n \r\n (3) Where a person has been allowed a deduction in a tax year for a bad \r\ndebt and in a subsequent tax year the person receives in cash or kind any amount \r\nin respect of that debt, the following rules shall apply, namely:– \r\n \r\n(a) where the amount received exceeds the difference between the \r\nwhole of such bad debt and the amount previously allowed as a \r\ndeduction under this section, the excess shall be included in the \r\nperson’s income under the head “Income from Business” for the \r\ntax year in which it was received; or \r\n \r\n(b) where the amount received is less than the difference between \r\nthe whole of such bad debt and the amount allowed as a \r\n                                            \r\n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n82 \r\n \r\ndeduction under this section, the shortfall shall be allowed as a \r\nbad debt deduction in computing the person’s income under the \r\nhead “Income from Business” for the tax year in which it was \r\nreceived. \r\n \r\n1[29A. Provision regarding consumer loans. — (1) A 2[ ] 3[non-banking \r\nfinance company or the House Building Finance Corporation] shall be allowed a \r\ndeduction, not exceeding three per cent of the income for the tax year, arising out \r\nof consumer loans for creation of a reserve to off-set bad debts arising out of such \r\nloans. \r\n \r\n (2) Where bad debt cannot be wholly set off against reserve, any amount \r\nof bad debt, exceeding the reserves shall be carried forward for adjustment against \r\nthe reserve for the following years.] \r\n \r\n4[Explanation.— In this section, “consumer loan” means a loan of \r\nmoney or its equivalent made by 5[ ] a non-banking finance company \r\nor the House Building Finance Corporation to a debtor (consumer) \r\nand the loan is ent ered primarily for personal, family or household \r\npurposes and includes debts created by the use of a lender credit card \r\nor similar arrangement as well as insurance premium financing.] \r\n \r\n30. Profit on non-performing debts of a banking company or development \r\nfinance institution.—(1) A banking company or development finance institution 6[or \r\nNon-Banking Finance Company (NBFC) or modaraba] shall be allowed a deduction for \r\nany profit accruing on a non-performing debt of the banking company or institution 7[or \r\nNon-Banking Finance Company (NBFC) or modaraba] where the profit is credited to a \r\nsuspense account in accordance with the Prudential Regulations for Banks or 8[Non-\r\nBanking Finance Company or modaraba] Non-bank Financial Institutions, as the case \r\nmay be, issued by the State Bank of Pakistan 9[or the Securities and Exchange \r\nCommission of Pakistan]. \r\n \r\n (2) Any profit deducted under sub -section (1) that is subsequently \r\nrecovered by the banking company or development finance institution 10[or Non-\r\nBanking Finance Company (NBFC) or modaraba] shall be included in the income \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2The words “banking company or” omitted by the Finance Act, 2009. \r\n3 Inserted by the Finance Act, 2004. \r\n4 Added by the Finance Act, 2004. \r\n5The words “a banking company or” omitted by the Finance Act, 2009. \r\n6 Inserted by the Finance Act, 2003. \r\n7 Inserted by the Finance Act, 2003. \r\n8 The words “Non-bank Financial Institutions” substituted by the Finance Act, 2003. \r\n9 Inserted by the Finance Act, 2003. \r\n10 Inserted by the Finance Act, 2003. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n83 \r\n \r\nof the company or institution 1[or Non -Banking Finance Company (NBFC) or \r\nmodaraba] chargeable under the head “Income from Business” for the tax year in \r\nwhich it is recovered. \r\n \r\n31. Transfer to participatory reserve.—(1) Subject to this section, a \r\ncompany shall be allowed a deduction for a tax year for any amount transferred by \r\nthe company in the year to a participatory reserve created under 2[section 66 of \r\nthe Companies Act, 2017 (XIX of 2017)] in accordance with an agreement relating \r\nto participatory redeemable capital entered into between the company and a \r\nbanking company as defined in the 3[Financial Institutions(Recovery of Finances) \r\nOrdinance,2001 (XLVI of 2001).] \r\n \r\n (2) The deduction allowed under subsection (1) for a tax year shall be limited \r\nto five per cent of the value of the company’s participatory redeemable capital. \r\n \r\n (3) No deduction shall be allowed under subsection (1) if the amount of \r\nthe tax exempted accumulation in the participatory reserv e exceeds ten per cent \r\nof the amount of the participatory redeemable capital. \r\n \r\n (4) Where any amount accumulated in the participatory reserve of a company \r\nhas been allowed as a deduction under this section is applied by the company towards \r\nany purpose other than payment of share of profit on the participatory redeemable capital \r\nor towards any purpose not allowable for deduction or exemption under this Ordinance \r\nthe amount so applied shall be included in the income from business of the company in \r\nthe tax year in which it is so applied.  \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2 The expression “section 120 of the Companies Ordinance, 1984 (XLVII of 1984)” substituted by the \r\nFinance Act, 2021. \r\n3The words “Banking Tribunals Ordinance, 1984” substituted by the words “Financial Institutions \r\n(Recovery Of Finances)    Ordinance, 2001 (XLVI of 2001) by the Finance Act 2014”. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n84 \r\n \r\nDivision IV \r\nTax Accounting \r\n \r\n32. Method of accounting.—1[(1) Subject to this Ordinance, a person’s income \r\nchargeable to tax shall be computed in accordance with the method of accounting \r\nregularly employed by such person.]  \r\n \r\n (2) Subject to sub -section (3), a company shall account for income \r\nchargeable to tax under the head “Income from Business” on an accrual basis, \r\nwhile other persons may account for such income on a cash or accrual basis.  \r\n \r\n (3) The 2[Board] may prescribe that any class of persons shall account \r\nfor income chargeable to tax under the head “Income from Business” on a cash or \r\naccrual basis. \r\n \r\n (4) A person may apply, in writing, for a change in the person’s  method \r\nof accounting and the Commissioner may, by 3[order] in writing, approve such an \r\napplication but only if satisfied that the change is necessary to clearly reflect the \r\nperson’s income chargeable to tax under the head “Income from Business”.  \r\n \r\n (5) If a person’s method of accounting has changed, the person sha ll \r\nmake adjustments to items of income, deduction, or credit, or to any other items \r\naffected by the change so that no item is omitted and no item is taken into account \r\nmore than once. \r\n \r\n33. Cash-basis accounting.—A person accounting for income chargeable to  \r\ntax under the head “Income from Business” on a cash basis shall derive income \r\nwhen it is received and shall incur expenditure when it is paid.  \r\n \r\n34. Accrual-basis accounting.—(1)  A person accounting for income \r\nchargeable to tax under the head “Income from Business” on an accrual basis shall \r\nderive income when it is due to the person and shall incur expenditure when it is \r\npayable by the person.  \r\n \r\n (2) Subject to this Ordinance, an amount shall be due to a person when \r\nthe person becomes entitled to receive it even if the time for discharge of the \r\nentitlement is postponed or the amount is payable by instalments. \r\n \r\n                                            \r\n1 Sub-section (1) substituted by the Finance Act, 2003. The substituted sub-section (1) read as follows: \r\n“(1) A person’s income chargeable to tax under the head “Income from Business” shall be \r\ncomputed in accordance with the method of accounting regularly employed by the person.” \r\n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n3 Substituted for the word “notice” by the Finance Act, 2003. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n85 \r\n \r\n (3) Subject to this Ordinance, an amount shall be payable by a person \r\nwhen all the events that determine liability have occurred and the amount of the \r\nliability can be determined with reasonable accuracy 1[  ]. \r\n \r\n2[   ] \r\n \r\n (5) Where a person has been allowed a deduction for any expenditure \r\nincurred in deriving income chargeable to tax under the head “Income from \r\nBusiness” and the person has not paid the liability or a part of the liability to which \r\nthe deduction relates within three years of the end of the tax year in which the \r\ndeduction was allowed, the unpaid amount of the liability shall be chargeable to \r\ntax under the head “Income from Business” in t he first tax year following the end \r\nof the three years. \r\n \r\n3[(5A)  Where a person has been allowed a deduction in respect of a trading \r\nliability and such person has derived any benefit in respect of such trading liability, \r\nthe value of such benefit shall be chargeable to tax under 4[the] head “Income from \r\nBusiness” for the tax year in which such benefit is received.] \r\n \r\n (6) Where an unpaid liability is chargeable to tax as a result of the \r\napplication of sub -section (5) and the person subsequently pays the liab ility or a \r\npart of the liability, the person shall be allowed a deduction for the amount paid in \r\nthe tax year in which the payment is made.  \r\n \r\n35. Stock-in-trade.— (1)  For the purposes of determining a person’s income \r\nchargeable to tax under the head “Inco me from Business” for a tax year, the cost \r\nof stock -in-trade disposed of by the person in the year shall be computed in \r\naccordance with the following formula, namely:— \r\n \r\n(A + B) – C \r\nwhere — \r\n \r\nA is the opening value of the person’s stock-in-trade for the year; \r\n \r\nB is cost of stock-in-trade acquired by the person in the year; and \r\n \r\n                                            \r\n1The comma and words “, but not before economic performance occurs” omitted by the Finance Act, 2004. \r\n2 Sub-section (4) omitted by the Finance Act, 2004. The omitted sub-section (4) read as follows:  \r\n“(4) For the purposes of sub-section (3), economic performance shall occur - \r\n(a) in the case of the acquisition of services or assets, at the time the services or \r\nassets are provided; \r\n(b) in the case of the use of assets, at the time the assets are used; and \r\n(c) in any other case, at the time payment is made in full satisfaction of the \r\nliability.” \r\n3 Inserted by the Finance Act, 2003. \r\n4 Inserted by the Finance Act, 2005. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n86 \r\n \r\nC is the closing value of stock-in-trade for the year. \r\n  \r\n (2) The opening value of stock-in-trade of a person for a tax year shall be — \r\n \r\n(a) the closing value of the person’s stock-in-trade at the end of the \r\nprevious year; or \r\n \r\n(b) where the person commenced to carry on business in the year, \r\nthe fair market value of any stock -in-trade acquired by the \r\nperson prior to the commencement of the business. \r\n \r\n (3) The fair market value of stock-in-trade referred to in clause (b) of sub-\r\nsection (2) shall be determined at the time the stock -in-trade is ventured in the \r\nbusiness. \r\n \r\n (4) The closing value of a person’s stock -in-trade for a tax year shall be \r\nthe lower of cost or 1[net realisable]value of the person’s stock-in-trade on hand at \r\nthe end of the year.  \r\n \r\n (5) A person accounting for income chargeable to tax under the head \r\n“Income from Business” on a cash basis may compute the person’s cost of stock -\r\nin-trade on the prime -cost method or absorptio n-cost method, and a person \r\naccounting for such income on an accrual basis shall compute the person’s cost \r\nof stock-in-trade on the absorption-cost method. \r\n \r\n (6) Where particular items of stock -in-trade are not readily identifiable, a \r\nperson may account fo r that stock on the first -in-first-out method or the average -\r\ncost method but, once chosen, a stock valuation method may be changed only \r\nwith the written permission of the Commissioner and in accordance with any \r\nconditions that the Commissioner may impose. \r\n \r\n (7) In this section, — \r\n \r\n“absorption-cost method” means the generally accepted accounting \r\nprinciple under which the cost of an item of stock -in-trade is the sum \r\nof direct material costs, direct labour costs, and factory overhead \r\ncosts; \r\n \r\n“average-cost meth od” means the generally accepted accounting \r\nprinciple under which the valuation of stock -in-trade is based on a \r\nweighted average cost of units on hand; \r\n \r\n“direct labour costs” means labour costs directly related to the \r\nmanufacture or production of stock-in-trade; \r\n \r\n                                            \r\n1 Substituted for the words “fair market” by the Finance Act, 2002 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n87 \r\n \r\n“direct material costs” means the cost of materials that become an \r\nintegral part of the stock-in-trade manufactured or produced, or which \r\nare consumed in the manufacturing or production process; \r\n“factory overhead costs” means the total costs of man ufacturing or \r\nproducing stock-in-trade, other than direct labour and direct material \r\ncosts;  \r\n \r\n“first-in-first-out method” means the generally accepted accounting \r\nprinciple under which the valuation of stock -in-trade is based on the \r\nassumption that stock is sold in the order of its acquisition; \r\n \r\n“prime-cost method” means the generally accepted accounting \r\nprinciple under which the cost of stock -in-trade is the sum of direct \r\nmaterial costs, direct labour costs, and variable factory overhead \r\ncosts; \r\n \r\n“stock-in-trade” means anything produced, manufactured, purchased, \r\nor otherwise acquired for manufacture, sale or exchange, and any \r\nmaterials or supplies to be consumed in the production or \r\nmanufacturing process, but does not include stocks or shares; and \r\n \r\n“variable factory overhead costs” means those factory overhead costs \r\nwhich vary directly with changes in volume of stock -in-trade \r\nmanufactured or produced. \r\n \r\n36. Long-term contracts.— (1)  A person accounting for income chargeable to \r\ntax under the head “Income from B usiness” on an accrual basis shall compute \r\nsuch income arising for a tax year under a long -term contract on the basis of the \r\npercentage of completion method.  \r\n \r\n (2) The percentage of completion of a long -term contract in a tax year \r\nshall be determined by c omparing the total costs allocated to the contract and \r\nincurred before the end of the year with the estimated total contract costs as \r\ndetermined at the commencement of the contract. \r\n \r\n (3) In this section, — \r\n \r\n“long-term contract” means a contract for manufacture, installation, or \r\nconstruction, or, in relation to each, the performance of related \r\nservices, which is not completed within the tax year in which work \r\nunder the contract commenced, other than a contract estimated to be \r\ncompleted within six months of the date on which work under the \r\ncontract commenced; and  \r\n \r\n“percentage of completion method” means the generally accepted \r\naccounting principle under which revenue and expenses arising under \r\na long -term contract are recognised by reference to the stage of \r\ncompletion of the contract, as modified by sub-section (2). \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n88 \r\n \r\nPART V \r\nHEAD OF INCOME: CAPITAL GAINS \r\n \r\n37. Capital gains. — (1)  Subject to this Ordinance, a gain arising on the \r\ndisposal of a capital asset by a person in a tax year, other than a gain that is \r\nexempt from tax under this Ordinance, shall be chargeable to tax in that year under \r\nthe head “Capital Gains”. \r\n \r\n 1[     ] \r\n \r\n 2[(1A) Notwithstanding anything contained in sub-section (1), gain arising on \r\ndisposal of immovable property situated in Pakistan, to a person in a tax year shall \r\nbe chargeable to tax under the head capital gains at the rates specified in Division \r\nVIII of Part I of the First Schedule.] \r\n \r\n (2) Subject to 3[sub-section (4)] , the gain arising on the disposal of a \r\ncapital asset by a person shal l be computed in accordance with the following \r\nformula, namely:– \r\n \r\nA – B \r\nwhere — \r\n \r\nA is the consideration received by the person on disposal of the asset; and  \r\n \r\nB is the cost of the asset. \r\n \r\n 4[   ]  \r\n \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2012. \r\n2 Sub-section (1A) substituted by the Finance Act, 2022. Substituted sub-section (1A) reads as \r\nfollows: \r\n“(1A) Notwithstanding anything contained in sub-sections (1) and (3) gain 2[under sub-section \r\n(3A) 2[  ] ] 2[ ]  by a person in a tax year, shall be chargeable to tax in that year under the head Capital \r\nGains at the rates specified in Division VIII of Part I of the First Schedule.” \r\n3 The expression “sub-sections (3) and” omitted by the Finance Act, 2022. \r\n4 Sub-section (3) omitted by the Finance Act, 2022. Omitted sub-section (3) reads as follows: \r\n    “(3) Where a capital asset has been held by a person for more than one year,4[other than shares of \r\npublic companies in cluding the vouchers of Pakistan Telecommunication Corporation, \r\nmodaraba certificates or any instrument of redeemable capital as defined in the 4[Companies \r\nAct, 2017 (XIX of 2017)] , ] the amount of any gain arising on disposal of the asset shall be \r\ncomputed in accordance with the following formula, namely: — \r\nA x ¾ \r\nwhere A is the amount of the gain determined under sub-section (2).” \r\n \r\n \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n89 \r\n \r\n   1[    ]  \r\n     \r\n    2[     ] \r\n \r\n3[  ]  \r\n                                            \r\n1 The sub-section (3A) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted  \r\nsub-section read as follows: \r\n(3A) Notwithstanding anything contained in sub -section (3), the amount of any gain arising on \r\ndisposal of immovable property being an open plot shall be computed in accordance with the formula \r\nspecified in the Table below, namely:- \r\nTABLE \r\nS.No. Holding Period  Gain \r\n(1) (2) (3) \r\n1. Where the holding period of open plot does not exceed one year A \r\n2. Where the holding period of open plot exceeds one year but does not \r\nexceed eight years  \r\nA x 3/4 \r\n3. Where the holding period of open plot exceeds eight years 0 \r\n  where A is the amount of the gain determined under sub-section (2). \r\n \r\n2 Sub-sections (3A) omitted by the Finance Act, 2022. Omitted sub-section reads as follows: \r\n(3A) Notwithstanding anything contained in sub-section (3), the amount of any gain arisin g \r\non disposal of an immovable property shall be computed in accordance with the formula specified \r\nin the Table below, namely:- \r\nTABLE \r\nS.No. Holding period Gain \r\n(1) (2) (3) \r\n1. Where the holding period of an immovable property \r\ndoes not exceed one year  \r\nA \r\n2. Where the holding period of an immovable property \r\nexceeds one year but does not exceed two years  \r\nA x 3/4 \r\n3. Where the holding period of an immovable property \r\nexceeds two years but does not exceed three \r\nyears  \r\nA x 1/2 \r\n4. Where the holding period of an immovable property \r\nexceeds three years but does not exceed four \r\nyears  \r\nA x 1/4 \r\n5. Where the holding period of an immovable property \r\nexceeds four years  \r\n0 \r\nwhere A is the amount of gain determined under sub-section (2).] \r\n3 Sub-section (3B) omitted through Finance Act, 2020 dated 30th June, 2020. The omitted clause read \r\nas follows: (3B) Notwithstanding anything contained in sub-section (3), the amount of any gain arising \r\non disposal of immovable property being a constructed property shall be computed in accordance with \r\nthe formula specified in the Table below, namely:- \r\nTABLE \r\nS.No. Holding Period  Gain \r\n(1) (2) (3) \r\n1. Where the holding period of constructed property does not exceed one year A \r\n2. Where the holding period of constructed property exceeds one year but \r\ndoes not exceed four years  \r\nA x 3/4 \r\n3. Where the holding period of constructed property exceeds four years 0 \r\nwhere A is the amount of the gain determined under sub-section (2).]  \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n90 \r\n \r\n(4) For the purposes of determining component B of the formula in sub -\r\nsection (2), no amount shall be included in the cost of a capital asset for any \r\nexpenditure incurred by a person – \r\n \r\n(a) that is or may be deducted under another provision of this \r\nChapter; or \r\n(b) that is referred to in section 21. \r\n \r\n1[     ] \r\n \r\n 2[     ]  \r\n \r\n (5) In this section, “capital asset” means property of any kind held by a \r\nperson, whether or not connected with a business, but does not include — \r\n \r\n3[(a)  any stock-in-trade 4[ ], consumable stores or raw materials held \r\nfor the purpose of business;] \r\n \r\n(b) any property with respect to which the person is entitled to a \r\ndepreciation deduction under section 22 or amortisation \r\ndeduction under section 24; 5[or] \r\n \r\n 6[  ] \r\n \r\n(d) any movable property 7[excluding capital a ssets specified i n \r\nsub-section (5) of section 38 ] held for personal use by the \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2 Sub-section (4A) omitted through Finance Act, 2022. Omitted sub-section read as follows: \r\n“(4A) Where the capital asset becomes the property of the person — \r\n(a)  under a gift 2[from a relative as defined in sub section (5) of section 85], bequest or will;  \r\n(b)  by succession, inheritance or devolution; \r\n(c)  a distribution of assets on dissolution of an association of persons; or  \r\n(d)  on distribution of assets on liquidation of a company,  \r\n \r\nthe fair market value of the asset, on the date of its transfer or acquisition by the person shal l be \r\ntreated to be the cost of the asset 2[: \r\nProvided that, if the capital asset acquired through gift is disposed of within two years of \r\nacquisition and the Commissioner is satisfied that such gift arrangement is a part of tax avoidance \r\nscheme, then the p rovisions of sub -section (3) of section 79 shall apply for the purpose of \r\ndetermining the cost of asset in the hands of recipient of the gift.] \r\n3 The brackets and words “(a) any stock-in-trade;” substituted by the Finance Act, 2002 \r\n4The brackets and words “(not being stocks and shares)” omitted by the Finance Act, 2010. \r\n5Inserted by the Finance Act, 2012. \r\n6Clause (c) omitted by the Finance Act, 2012. Omitted clause (c) read as follows:- \r\n   “(c)  any immovable property; or” \r\n7 The brackets, commas and words “(including wearing apparel, jewellery, or furniture)” substituted \r\nby the Finance Act, 2003. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n91 \r\n \r\nperson or any member of the person’s family dependent on the \r\nperson1[.] \r\n \r\n2[  ] \r\n \r\n3[(6) The person acquiring a capital asset, being shares of a company, shall \r\ndeduct advance adjus table tax from the gross amount paid  4[or payable]  as \r\nconsideration for the shares  5[at the time of payment or at the time of registration \r\nof shares by the Securities and Exchange Commission of Pakistan or by the State \r\nBank of Pakistan, whichever is earlier] at the rate of ten percent of the fair market \r\nvalue of the shares which shall be paid to the Commissioner by way of credit to \r\nthe Federal Government, within fifteen days of the payment. \r\n \r\n (7) Notwithstanding the provisions of section 68, the value of shares, for the \r\npurpose of sub -section (6), shall be the fair market value, as prescribed for sub -\r\nsection (4) of section 101A, without reduction of liabilities. \r\n \r\n (8) The Commissioner may, on application made by the person acquiring of \r\nthe shares, and after making such inquiry as the Commissioner thinks fit, allow to \r\nmake the payment, without deduction of tax or deduction of tax at a reduced rate.  \r\n \r\n(9) The provisions of sections 161, 162, entry No. 15 of the Table in section \r\n182, clause (c) of sub -section (1)  of section 191 and section 205 shall mutatis \r\nmutandis apply to the tax deductible and payable under this section. \r\n \r\n(10) The person disposing of the capital asset, being shares of a company, \r\nshall furnish to the Commissioner within thirty days of the trans action of disposal, \r\nthe prescribed information or documents, in a statement as may be prescribed:  \r\n \r\n Provided that the Commissioner may, by notice in writing, require the \r\nsaid person, to furnish information, documents and statement within a period of \r\nless than thirty days as specified in the notice.] \r\n \r\n                                            \r\n1 The comma and word “; or” substituted by the Finance Act, 2002 \r\n2 Clause (e) omitted by the Finance Act, 2001. The omitted clause (e)  read as follows: \r\n“(e) any modaraba certificate or any instrument of redeemable capital listed on any stock exchange \r\nor shares of a public company.” \r\n3 Sub-sections (6) to (10) added by the Finance (Supplementary) Act, 2023 (X of 2023) dated \r\n23.02.2023. \r\n4 Words inserted by the Finance Act, 2024. \r\n5 Expression inserted by the Finance Act, 2024. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n92 \r\n \r\n1[37A.  Capital gain on disposal of securities. — (1) The capital gain arising \r\non or after the first day of July 2010, from disposal of securities 2[  ]3[, other than a \r\ngain that is exempt from tax under this Or dinance], shall be chargeable to tax at \r\nthe rates specified in Division VII of Part I of the First Schedule: \r\n4[ ] \r\n \r\n   Provided 5[ ] that this section shall not apply to a banking  \r\n  company and an insurance company 6[: \r\n \r\n7[Provided further that this section shall not apply to the disposal \r\nof shares –  \r\n \r\n(i)    of a listed company made otherwise than through registered \r\nstock exchange and which are not settled through NCCPL;  \r\n \r\n(ii)  through initial public offer during listing process except \r\nwhere the detail of such disposal is furnished to NCCPL for \r\ncomputation of capital gains and tax thereon under this \r\nsection, \r\n \r\nand the provisions of section 37 shall apply on such disposal of \r\nshares of a listed company or disposal of shares through initial public \r\noffer, accordingly.]] \r\n \r\n \r\n 8[(1A) The gain arising on the disposal of a security by a person shall be \r\ncomputed in accordance with the following formula, namely: — \r\n \r\nA – B \r\n  Where — \r\n \r\n(i)  ‘A’ is the consideration received by the person on disposal of \r\nthe security; and \r\n                                            \r\n1Added by the Finance Act, 2010. \r\n2 Omitted by Finance Act, 2015. The omitted words read as follows:- \r\n“ held for a period of less than a year,” \r\n3Inserted by the Finance Act, 2012. \r\n5 The First proviso omitted by Finance Act, 2014. The omitted proviso read as follows: \r\n“Provided that this section shall not apply if the securities are held for a period of more than a \r\nyear.” \r\n5The word “further” omitted by Finance Act, 2014 \r\n6 Full stop substituted with colon and new proviso added by the by the Finance (Supplementary) Act, \r\n2023 (X of 2023) dated 23.02.2023. \r\n7 Second proviso substituted by the by the Finance Act, 2023. The substituted second proviso read as \r\nfollows: \r\n“Provided further that this section shall not apply to the disposal of shares of a listed company made \r\notherwise than through registered stock exchange and which are not settled through NCCPL and \r\nthe provisions of section 37 shall apply on such disposal of shares of a listed company, accordingly.” \r\n8Inserted by the Finance Act,2012. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n93 \r\n \r\n  (ii)  ‘B’ is the cost of acquisition of the security.] \r\n \r\n (2) The holding period of a security, for the purposes of this section, shall \r\nbe reckoned from the date of acquisition (whether before, on or after the thirtieth \r\nday of June, 2010) to the date of disposal of such security falling after the thirtieth \r\nday of June, 2010. \r\n (3) For the purposes of this section “security” means share of a public \r\ncompany, voucher of Pakistan Telecommunication Corporation, Modaraba \r\nCertificate, an instrument of redeemable capit al1[,debt Securities] 2[, unit of \r\nexchange traded fund] and derivative products. \r\n \r\n3[(3A)  For the purpose of this section, “debt securities” means - \r\n \r\n(a) Corporate Debt Securities such as Term Finance Certificates \r\n(TFCs), Sukuk Certificates (Sharia Complia nt Bonds), \r\nRegistered Bonds, Commercial Papers, Participation Term \r\nCertificates (PTCs) and all kinds of debt instruments issued by \r\nany Pakistani or foreign company or corporation registered in \r\nPakistan; and  \r\n \r\n(b) Government Debt Securities such as Treasury  Bills (T -bills), \r\nFederal Investment Bonds (FIBs), Pakistan Investment Bonds \r\n(PIBs), Foreign Currency Bonds, Government Papers, \r\nMunicipal Bonds, Infrastructure Bonds and all kinds of debt \r\ninstruments issued by Federal Government, Provincial \r\nGovernments, Local Authorities and other statutory bodies.] \r\n \r\n4[“Explanation: For removal of doubt it is clarified that derivative \r\nproducts include future commodity contracts entered into by the \r\nmembers of Pakistan Mercantile Exchange whether or not \r\nsettled by physical delivery.”] \r\n \r\n5[(3B)  For the purpose of this section, “shares of a public company” \r\nshall be considered as security if such company is a public company at the time of \r\ndisposal of such shares.] \r\n \r\n (4) Gain under this section shall be treated as a separate block of income. \r\n  \r\n (5) Notwithstanding anything contained in this Ordinance, where a person \r\nsustains a loss on disposal of securities in a tax year, the loss shall be set off only \r\n                                            \r\n1Inserted by the Finance Act, 2014. \r\n2 Inserted by the Finance Act, 2021. \r\n3The sub-section (3A) inserted by the Finance Act, 2014. \r\n4Inserted by the Finance Act, 2016. \r\n5 New sub-section (3B) inserted through Finance Act, 2020 dated 30th June, 2020  \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n94 \r\n \r\nagainst the gain of the person from any other securities chargeable to tax under  \r\nthis section and no loss shall be carried forward to the subsequent tax year 1[:] \r\n \r\n2[Provided that so much of the loss sustained on disposal of securities in tax \r\nyear 20l9 and onwards that has not been set off against the gain of the person \r\nfrom disposal of securities chargeable to tax under this section shall be carried \r\nforward to the following tax year and set off only against the gain of the person \r\nfrom disposal of securities chargeable to tax under this section , but no such loss \r\nshall be carried forward to more than three tax years immediately succeeding the \r\ntax year for which the loss was first computed.] \r\n \r\n3[(6) To carry out purpose of this section, the Board may prescribe rules.]  \r\n \r\n38. Deduction of losses in computing the amount chargeable under the \r\nhead “Capital Gains”.— (1)  Subject to this Ordinance, in computing the amount \r\nof a person chargeable to tax under the head “Capital Gains” for a tax year, a \r\ndeduction shall be allowed for any loss on the disposal of a capital asset by the \r\nperson in the year.  \r\n \r\n (2) No loss shall be deducted under this section on the disposal of a \r\ncapital asset where a gain on the disposal of such asset would not be chargeable \r\nto tax.  \r\n \r\n (3) The loss arising on the disposal of a capital asset by a person shall \r\nbe computed in accordance with the following formula, namely: — \r\n \r\nA – B \r\nwhere — \r\n \r\nA is the cost of the asset; and  \r\n \r\nB is the consideration received by the person on disposal of the asset. \r\n \r\n (4) The provisions of sub -section (4) of section 37 shall apply in \r\ndetermining component A of the formula in sub-section (3). \r\n \r\n (5) No loss shall be recognized under this Ordinance on the disposal of \r\nthe following capital assets, namely:— \r\n \r\n(a) A painting, sculpture, drawing or other work of art; \r\n \r\n(b) jewellery; \r\n \r\n(c) a rare manuscript, folio or book; \r\n \r\n(d) a postage stamp or first day cover; \r\n \r\n(e) a coin or medallion; or \r\n \r\n(f) an antique. \r\n                                            \r\n1 Full stop substituted by colon through Finance Supplementary (Second Amendment) Act, 2019 \r\n2 New Proviso added through Finance Supplementary (Second Amendment) Act, 2019 \r\n3 Added by the Finance Act, 2021. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n95 \r\n \r\nPART VI \r\nHEAD OF INCOME: INCOME FROM OTHER SOURCES \r\n \r\n39. Income from other sources.  — (1) Income  of every kind received by a \r\nperson in a tax year, 1[if it is not included in any other head,]  other than income \r\nexempt from tax under this Ordinance, shall be chargeable to tax in that year under \r\nthe head “Income from Other Sources”, including the following namely: — \r\n \r\n(a) 2[Dividend;] \r\n \r\n(b) 3[royalty;] \r\n \r\n(c) profit on debt; \r\n \r\n4[(cc)  additional payment on delayed refund under any tax law;] \r\n \r\n(d) ground rent; \r\n \r\n(e) rent from the sub-lease of land or a building; \r\n \r\n(f) income from the lease of any building together with plant or machinery; \r\n \r\n5[(fa) income from provision of ame nities, utilities or any other service \r\nconnected with renting of building;] \r\n \r\n(g) any annuity or pension; \r\n \r\n(h) any prize bond, or winnings from a raffle, lottery 6[, prize on winning a \r\nquiz, prize offered by companies for promotion of sale] or cross -word \r\npuzzle; \r\n \r\n(i) any other amount received as consideration for the provision, use or \r\nexploitation of property, including from the grant of a right to explore \r\nfor, or exploit, natural resources;  \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2002 \r\n2 The word “Dividends” substituted by the Finance Act, 2002 \r\n3 The word “royalties” substituted by the Finance Act, 2002 \r\n4Inserted by the Finance Act, 2012. \r\n5 Inserted by the Finance Act, 2003. \r\n6 Inserted by the Finance Act, 2003. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n96 \r\n \r\n(j) the fair market value of any benefit, whether convertible to m oney or \r\nnot, received in connection with the provision, use or exploitation of \r\nproperty; 1[ ] \r\n \r\n(k) any amount received by a person as consideration for vacating the \r\npossession of a building or part thereof, reduced  by any amount paid \r\nby the person to acqu ire possession of such building or part thereof ; \r\n2[ ] \r\n \r\n3[(l)  any amount received by a person from Approved Income Payment \r\nPlan or Approved Annuity Plan under Voluntary Pension System \r\nRules, 20054[; 5[ ] ]  \r\n \r\n6[(Ia) subject to sub -section (3), any amount or  fair market value of any \r\nproperty received without consideration or received as gift, other than \r\ngift received from 7[relative as defined in sub-section (5) of section 85] \r\n] 8[; and] \r\n \r\n9[(lb)    income arising to the shareholder of a company, from the issuance of \r\nbonus shares;]   \r\n \r\n10[ 11[ ] ] \r\n \r\n (2) Where a person receives an amount referred to in clause (k) of sub -\r\nsection (1), the amount shall be chargeable to tax under the head “Income from \r\nOther Sources” in the tax year in which it was received and the foll owing nine tax \r\nyears in equal proportion.  \r\n \r\n (3) Subject to sub-section (4), any amount received as a loan, advance, \r\ndeposit 12[for issuance of shares] or gift by a person in 13[a tax year] from another \r\nperson (not being a banking company or financial instit ution) otherwise than by a \r\n                                            \r\n1 The word “and” omitted by the Finance Act, 2014. \r\n2 The word “and” omitted by the Finance Act, 2019.  \r\n3 Added by the Finance Act,  2005. \r\n4 The “full stop” substituted by word “;and” by the Finance Act, 2019. \r\n5 The word “and” omitted by the Finance Act, 2023. \r\n6 New clause (Ia) inserted by the Finance Act, 2019. \r\n7 The expression “grandparents, parents, spouse, brother, sister, son or a daughter” substituted by \r\nthe Finance Act, 2021. \r\n8 Full stop substituted with a semi-colon and the word “and” added by the Finance Act, 2023. \r\n9 Clause added by the Finance Act, 2023. \r\n10 Clause (m) added by the Finance Act, 2014. \r\n11 Clause (m) omitted by the Finance Act, 2018,the omitted clause(m) reads as follows:- \r\n   “(m) income arising to the shareholder of a company, from the issuance of bonus shares” \r\n12 Inserted by the Finance Act, 2003. \r\n13 The words “an income year” substituted by the Finance Act, 2002 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n97 \r\n \r\ncrossed cheque drawn on a bank or through a banking channel 1[or through digital \r\nmeans as defined in section 2]  from a person holding a National Tax Number 2[ ] \r\nshall be treated as income chargeable to tax under the head “Income from Other \r\nSources” for the tax year in which it was received. \r\n \r\n (4) Sub-section (3) shall not apply to an advance payment for the sale of \r\ngoods or supply of services. \r\n \r\n3[(4A) Where — \r\n \r\n(a)  any profit on debt derived from investment in National Savings \r\nDeposit Certificates including Defence Savings Certificate paid \r\nto a person in arrears or the amount received includes profit \r\nchargeable to tax in the tax year or years preceding the tax year \r\nin which it is received; and \r\n \r\n(b)  as a result the person is charge able at higher rate of tax than \r\nwould have been applicable if the profit had been paid to the \r\nperson in the tax year to which it relates,  \r\n \r\nthe person may, by notice in writing to the Commissioner, elect for the profit to be \r\ntaxed at the rate of tax that would have been applicable if the profit had been paid \r\nto the person in the tax year to which it relates.]  \r\n \r\n4[(4B)  An election under sub-section (4A) shall be made by the due date for \r\nfurnishing the person’s return of income for the tax year in which the amount was \r\nreceived or by such later date as the Commissioner may allow by an order in \r\nwriting.]  \r\n \r\n (5) This section shall not apply to any income received by a person in a \r\ntax year that is chargeable to tax under any other head of income or subject to tax \r\nunder section 5[5, 5AA, 6, 7 or 7B].  \r\n \r\n6[  ] \r\n \r\n40. Deductions in computing income chargeable under the head “Income \r\nfrom Other Sources”.— (1)  Subject to this Ordinance, in computing the income \r\nof a person chargeable to tax under the head “Income from Othe r Sources” for a \r\ntax year, a deduction shall be allowed for any expenditure paid by the person in \r\n                                            \r\n1 The expression inserted by the Finance Act, 2025. \r\n2 The word “Card” omitted by the Finance Act, 2006. \r\n3 Inserted by the Finance Act, 2003. \r\n4 Inserted by the Finance Act, 2003. \r\n5 The expression “5, 6 or 7” substituted by the Finance Act, 2021. \r\n6 Sub-section (6) omitted by the Finance Act, 2002. The omitted sub-section (6) read as follows: \r\n“(6)  Expenditure is of a capital nature if it has a normal useful life of more than one year.” \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n98 \r\n \r\nthe year to the extent to which the expenditure is paid in deriving income \r\nchargeable to tax under that head, other than expenditure of a capital nature.  \r\n (2) A person receiving any profit on debt chargeable to tax under the head \r\n“Income from Other Sources” shall be allowed a deduction for any Zakat paid by \r\nthe person 1[  ] under the Zakat and Ushr Ordinance, 1980 (XVIII of 1980), at the \r\ntime the profit is paid to the person. \r\n \r\n (3) A person receiving income referred to in clause 2[  ] (f) of sub-section \r\n(1) of section 39 chargeable to tax under the head “Income from Other Sources” \r\nshall be allowed — \r\n \r\n(a) a deduction for the depreciation of any plant, machinery o r \r\nbuilding used to derive that income in accordance with section \r\n22; and \r\n \r\n(b) an initial allowance for any plant or machinery used to derive \r\nthat income in accordance with section 23. \r\n \r\n (4) No deduction shall be allowed to a person under this section to th e \r\nextent that the expenditure is deductible in computing the income of the person \r\nunder another head of income.  \r\n \r\n (5) The provisions of section 21 shall apply in determining the deductions \r\nallowed to a person under this section in the same manner as they apply in \r\ndetermining the deductions allowed in computing the income of the person \r\nchargeable to tax under the head \"Income from Business\". \r\n \r\n3[(6)  Expenditure is of a capital nature if it has a normal useful life of more \r\nthan one year.] \r\n                                            \r\n1 The words “on the profit” omitted by the Finance Act, 2003. \r\n2 The brackets, letter and word “(e) or” omitted by the Finance Act, 2003. \r\n3 Added by the Finance Act,  2002. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n99 \r\n \r\nPART VII \r\nEXEMPTIONS AND TAX CONCESSIONS \r\n \r\n41. Agricultural income. — (1) Agricultural income derived by a person shall \r\nbe exempt from tax under this Ordinance. \r\n \r\n(2) In this section, “agricultural income” means, — \r\n \r\n(a) any rent or revenue derived by a person from land which i s \r\nsituated in Pakistan and is used for agricultural purposes; \r\n \r\n(b) any income derived by a person from land situated in Pakistan \r\nfrom — \r\n \r\n(i) agriculture; \r\n \r\n(ii) the performance by a cultivator or receiver of rent -in-kind \r\nof any process ordinarily employed b y such person to \r\nrender the produce raised or received by the person fit to \r\nbe taken to market; or \r\n \r\n(iii) the sale by a cultivator or receiver of rent -in-kind of the \r\nproduce raised or received by such person, in respect of \r\nwhich no process has been perform ed other than a \r\nprocess of the nature described in sub-clause (ii); or \r\n \r\n(c) any income derived by a person from — \r\n \r\n(i) any building owned and occupied by the receiver of the \r\nrent or revenue of any land described in clause (a) or (b); \r\n \r\n(ii) any building occupied by the cultivator, or the receiver of \r\nrent-in-kind, of any land in respect of which, or the \r\nproduce of which, any operation specified in sub -clauses \r\n(ii) or (iii) of clause (b) is carried on,  \r\n \r\nbut only where the building is on, or in the immediate v icinity of \r\nthe land and is a building which the receiver of the rent or \r\nrevenue, or the cultivator, or the receiver of the rent -in-kind by \r\nreason of the person’s connection with the land, requires as a \r\ndwelling-house, a store-house, or other out-building. \r\n \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n100 \r\n \r\n42. Diplomatic and United Nations exemptions.  — (1) The income of an \r\nindividual entitled to privileges under the Diplomatic and Consular Privileges Act, \r\n1972 (IX of 1972) shall be exempt from tax under this Ordinance to the extent \r\nprovided for in that Act. \r\n \r\n (2) The income of an individual entitled to privileges under the United \r\nNations (Privileges and Immunities) Act, 1948 (XX of 1948), shall be exempt from \r\ntax under this Ordinance to the extent provided for in that Act. \r\n \r\n (3) Any pension received by a pe rson, being a citizen of Pakistan, by \r\nvirtue of the person’s former employment in the United Nations or its specialised \r\nagencies (including the International Court of Justice) provided the person’s salary \r\nfrom such employment was exempt under this Ordinance. \r\n \r\n43. Foreign government officials.— Any salary received by an employee of a \r\nforeign government as remuneration for services rendered to such government \r\nshall be exempt from tax under this Ordinance provided — \r\n \r\n(a) the employee is a citizen of the foreign country and not a citizen \r\nof Pakistan; \r\n \r\n(b) the services performed by the employee are of a character \r\nsimilar to those performed by employees of the Federal \r\nGovernment in foreign countries; 1[and]  \r\n \r\n(c) the foreign government grants a similar exemption t o \r\nemployees of the Federal Government performing similar \r\nservices in such foreign country2[.] \r\n \r\n3[  ] \r\n \r\n44. Exemptions under international agreements.— (1)  Any Pakistan-source \r\nincome which Pakistan is not permitted to tax under a tax treaty shall be exempt \r\nfrom tax under this Ordinance. \r\n \r\n (2) Any salary received by an individual (not being a citizen of Pakistan) \r\nshall be exempt from tax under this Ordinance to the extent provided for in an Aid \r\nAgreement between the Federal Government and a foreign government  or public \r\ninternational organization, where – \r\n  \r\n                                            \r\n1 Added by the Finance Act, 2002 \r\n2 The comma and word  “,and” substituted by the Finance Act, 2002 \r\n3 Clause (d) omitted by the Finance Act, 2002. The omitted clause (d) read as under: \r\n“(d) the income is subject to tax in that foreign country.” \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n101 \r\n \r\n(a) the individual is either 1[not a resident] individual or a resident \r\nindividual solely by reason of the performance of services under \r\nthe Aid Agreement; \r\n \r\n(b) if the Aid Agreement is with a foreign country, the individual is a \r\ncitizen of that country; and \r\n \r\n(c) the salary is paid by the foreign government or public \r\ninternational organisation out of funds or grants released as aid \r\nto Pakistan in pursuance of such Agreement. \r\n \r\n (3) Any income received by 2[any person] engaged as a contractor, \r\nconsultant, or expert on a project in Pakistan shall be exempt from tax under this \r\nOrdinance to the extent provided for in a bilateral or multilateral 3[   ] agreement \r\nbetween the Federal Government and a foreign government or public international \r\norganisation, where — \r\n \r\n(a) the project is financed out of grant funds in accordance with the \r\nagreement; \r\n \r\n(b) the person is either a non -resident person or a resident person \r\nsolely by reason of the performance of services under the \r\nagreement; and \r\n \r\n(c) the income is paid out of the funds of the grant in pursuance of \r\nthe agreement. \r\n \r\n4[(4) Federal Government may, in respect of an official development \r\nassistance financed loans and grants -in-aid, subject to such conditions and \r\nlimitations as it may specify, exempt income of any person on a case to case basis \r\nthrough a notification in the official Gazette.] \r\n \r\n5[44A. Exemption under Foreign Investment (Promotion and Protection) Act, \r\n2022 (XXXV of 2022).  – (1) Taxes on income (including capita l gains), advance \r\ntax, withholding taxes, minimum and final taxes under this Ordinance shall, for the \r\nperiod and to the extent provided in the Second and Third Schedules to the Foreign \r\nInvestment (Promotion and Protection) Act, 2022 (XXXV of 2022) in respe ct of \r\nqualified investment as specified at Sr. No.1 of the First Schedule to the said Act \r\n                                            \r\n1 The words “a non-resident” substituted by the Finance Act, 2003. \r\n2 The expression “a person (not being a citizen of Pakistan)” substituted by the Finance Act, 2022. \r\n3 The expression “technical assistance” omitted by the Finance Act, 2022. \r\n4 Sub-section (4) inserted by the Finance Act, 2022. \r\n5 Section 44A inserted by the Finance Act, 2023. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n102 \r\n \r\nor investors, be exempt or subject to tax at the rate and in the manner specified \r\nunder the said Act.  \r\n \r\n(2) All investors and shareholders of the qualified investment , their \r\nassociates and companies specified in the Second and Third Schedules to the said \r\nAct including third party lenders on account of any loan shall also be exempt from \r\ntaxes and other provisions of this Ordinance or subject to tax at the rate and in the \r\nmanner specified under the said Act for the period and to the extent provided in \r\nthe Second and Third Schedules to the said Act.  \r\n \r\n(3) Provisions of this Ordinance relating to Anti -Avoidance, for the period \r\nand to the extent specified in the said Act inc luding sections 106, 106A, 108, 109 \r\nand 109A, shall not apply to the persons and amounts mentioned in sub -sections \r\n(1) and (2).  \r\n \r\n(4) Rates of depreciation, initial allowance and pre -commencement \r\nexpenditure under sections 22, 23 and 25 as on the 20th day of March, 2022 shall \r\ncontinue to be applicable for thirty years as provided in the Third Schedule to the \r\nsaid Act in respect of persons mentioned in sub-sections (1) and (2).  \r\n \r\n(5) For the purpose of this section, the terms defined under the Second and \r\nThird Schedules to the said Act shall apply mutatis mutandis to this Ordinance.]  \r\n \r\n45. President’s honours.— (1)  Any allowance attached to any Honour, Award, \r\nor Medal awarded to a person by the President of Pakistan shall be exempt from \r\ntax under this Ordinance. \r\n \r\n (2) Any monetary award granted to a person by the President of Pakistan \r\nshall be exempt from tax under this Ordinance. \r\n \r\n46. Profit on debt.— Any profit received by a non-resident person on a security \r\nissued by a resident person shall be exempt from tax under this Ordinance \r\nwhere— \r\n \r\n(a) the persons are not associates; \r\n \r\n(b) the security was widely issued by the resident person outside \r\nPakistan for the purposes of raising a loan outside Pakistan for \r\nuse in a business carried on by the person in Pakistan; \r\n \r\n(c) the profit was paid outside Pakistan; and \r\n \r\n(d) the security is approved by the 1[Board] for the purposes of this \r\nsection.  \r\n                                            \r\n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n103 \r\n \r\n \r\n47. Scholarships.— Any scholarship granted to a person to meet the cost of \r\nthe person’s education shall be exempt from tax und er this Ordinance, other than \r\nwhere the scholarship is paid directly or indirectly by an associate. \r\n \r\n48. Support payments under an agreement to live apart. —1[Any income \r\nreceived by a spouse as support payment under an agreement to live apart] shall \r\nbe exempt from tax under this Ordinance. \r\n \r\n49. Federal 2[Government,] Provincial Government, and 3[Local \r\nGovernment] income.— (1) The income of the Federal Government shall be \r\nexempt from tax under this Ordinance. \r\n \r\n (2) The income of a Provincial Government or a 4[Local Government] in \r\nPakistan shall be exempt from tax under this Ordinance, other than income \r\nchargeable under the head “Income from Business” derived by a Provincial \r\nGovernment or 5[Local Government] from a business carried on outside its \r\njurisdictional area. \r\n \r\n 6[(3)  Subject to sub -section (2), any payment received by the Federal \r\nGovernment, a Provincial Government or a 7[Local Government] shall not be liable \r\nto any collection or deduction of advance tax.] \r\n \r\n 8[(4)  Exemption under this section shall not  be available in the case of \r\ncorporation, company, a regulatory authority, a development authority, other body \r\nor institution established by or under a Federal law or a Provincial law or an existing \r\nlaw or a corporation, company, a regulatory authority, a development authority or \r\nother body or institution set up, owned and controlled, either directly or indirectly, \r\nby the Federal Government or a Provincial Government, regardless of the ultimate \r\ndestination of such income as laid down in Article 165A of the Constitution of the \r\nIslamic Republic of Pakistan9[:] \r\n                                            \r\n1 The words “Any support payment received by a spouse under an agreement to live apart” substituted \r\nby the Finance Act, 2002. \r\n2 The word “and” substituted by the Finance Act, 2009. \r\n3The words “local authority” substituted by the Finance Act, 2008. \r\n4The words “local authority” substituted by the Finance Act, 2008. \r\n5The words “local authority” substituted by the Finance Act, 2008. \r\n6Added by the Finance Act, 2006. \r\n7The words “local authority” substituted by the Finance Act, 2008. \r\n8Added by the Finance Act, 2007. \r\n9Full stop substituted by a colon by the Finance Act, 2014. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n104 \r\n \r\n1[Provided that the income from sale of spectrum licenses 2[and \r\nrenewal thereof] by Pakistan Telecommunication Authority on behalf \r\nof the Federal Government after the first day of March 2014 shall be \r\ntreated as income of the Federal Government and not of the Pakistan \r\nTelecommunication Authority.] \r\n \r\n50. Foreign-source income of short -term resident individuals. — (1)  \r\nSubject to sub-section (2), the foreign-source income of an individual 3[  ] — \r\n \r\n(a) who is a resident individual solely by reason of the individual’s \r\nemployment; and  \r\n \r\n(b) who is present in Pakistan for a period or periods not exceeding \r\nthree years, \r\n \r\nshall be exempt from tax under this Ordinance. \r\n \r\n (2) This section shall not apply to — \r\n \r\n(a) any income derived from a business of the person established \r\nin Pakistan; or \r\n \r\n(b) any foreign-source income brought into or received in Pakistan \r\nby the person. \r\n \r\n51. Foreign-source income of returning expatriates. —4[(1)] Any foreign -\r\nsource income derived by a citizen of Pakistan in a tax year who was not a resident \r\nindividual in any of the four tax years preceding the tax year in which the individual \r\nbecame a resident shall be exempt from tax under this Ordinance in the tax year \r\nin which the individual became a resident individual and in the following tax year. \r\n \r\n 5[(2)  Where a citizen of Pakistan leaves Pakistan during a tax year and \r\nremains abroad during that tax year, any income chargeable under the head \r\n“Salary” earned by him outside Pakistan during that year shall be exempt from tax \r\nunder this Ordinance.] \r\n6[  ] \r\n                                            \r\n1Added by the Finance Act, 2014. \r\n2 The words “and renewal thereof” inserted through Finance Supplementary (Second Amendment) \r\nAct, 2019 \r\n3 The brackets and words “(other than a citizen of Pakistan)” omitted by the Finance Act, 2003. \r\n4 Section 51 numbered as sub-section (1) of section 51 by the Finance Act, 2003. \r\n5 Added by the Finance Act, 2003. \r\n6 Section 52 omitted by the Finance Act, 2002. The omitted section 52 read as follows: \r\n“52. Non-resident shipping and airline enterprises.- (1)  Subject to sub-section (2), any income of a non-\r\nresident person, for the time being approved by the Federal Government for the purpose of this section, \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n105 \r\n \r\n53. Exemptions and tax concessions in the Second Schedule. —(1) The \r\nincome or classes of income, or persons or classes of persons specified in the \r\nSecond Schedule shall be — \r\n \r\n(a) exempt from tax under this Ordinance, subject to any conditions \r\nand to the extent specified therein; \r\n \r\n(b) subject to tax under this Ordinance at such rates, which are less \r\nthan the rates specified in the First Schedule, as are specified \r\ntherein; \r\n \r\n(c) allowed a reduction in tax liability under this Ordinance, subject \r\nto any conditions and to the extent specified therein; or \r\n \r\n(d) exempted from the operation of any provision of this Ordinance, \r\nsubject to any conditions and to the extent specified therein. \r\n \r\n 1[  ] \r\n \r\n (2) The 2[Federal Government or the] 3[ ] 4[ ] 5[ ] 6[Board with the approval \r\nof the Federal Minister-in-charge may, from time to time, pursuant to the approval \r\nof the Economic Coordination Committee of the Cabinet] whenever circumstances \r\nexist to take immediate action for the purposes of national security, natural \r\ndisaster, national food security in emergency situations, protection of national \r\neconomic interests in situations arising out of abnormal fluctuation in international \r\ncommodity prices, 7[ ] 8[,] implementation of bilateral and multilateral agreements  \r\n                                            \r\nfrom the operation of ships and aircraft in international traffic shall be exempt from tax under this Ordinance, \r\nother than income from ships and aircraft operated principally to transport passengers, livestock, mail, or \r\ngoods exclusively between places in Pakistan.  \r\n(2) Sub-section (1) shall not apply to a non -resident person where the person’s country of \r\nresidence does not allow a similar exemption to a resident of Pakistan.” \r\n1Sub-section (1A) omitted by the Finance Act, 2012. The omitted sub-section (1A) read as follows:- \r\n           “(1A)  Where any income which is exempt from tax under any provision of the Second \r\nSchedule, such income, as may be specified in the said Schedule and subject to such conditions \r\nas may be specified therein, shall be included in the total income, however the tax shall not be \r\npayable in respect of such income.” \r\n2Inserted by the Finance Act, 2022. \r\n3 the expression “Federal Government” substituted by Finance Act, 2017. \r\n4Inserted by the Finance Act, 2015. \r\n5The expression “Board with the approval of Federal Minister-in-charge may, from time to time  \r\npursuant to the approval of the Economic Coordination Committee of Cabinet, ” substituted by the  \r\n    Finance Act, 2018. \r\n6 The words “Federal Government may” substituted by the Finance Act, 2021.  \r\n7 The words “removal of anomalies in taxes, development of backward areas” omitted by Finance \r\nAct, 2019. \r\n8 Inserted by the Finance Act, 2016. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n106 \r\n \r\n1[or granting  an exemption from any tax imposed under this Ordinance including \r\na reduction in the rate of tax imposed under this Ordinance or a reduction in tax \r\nliability under this Ordinance or an exemption from the operation of any provision \r\nof this Ordinance to any international financial institution or foreign Government \r\nowned financial institution operating under an agreement, memorandum of \r\nunderstanding or any other arrangement with the Government of Pakistan] ], by \r\nnotification in the official Gazette, make such amendment in the Second Schedule \r\nby — \r\n \r\n(a) adding any clause or condition therein; \r\n(b) omitting any clause or condition therein; or \r\n(c) making any change in any clause or condition therein, \r\nas the Governm ent may think fit, and all such amendments shall have effect in \r\nrespect of any tax year beginning on any date before or after the commencement \r\nof the financial year in which the notification is issued. \r\n \r\n (3) The Federal Government shall place before the National Assembly all \r\namendments made by it to the Second Schedule in a financial year.  \r\n \r\n2[“(4) Any notification issued under sub-section (2) after the commencement \r\nof the Finance Act, 2015, shall, if not earlier rescinded, stand rescinded on the \r\nexpiry of the financial year in which it was issued3[:] \r\n \r\n4[Provided that all such notifications, except those earlier rescinded, \r\nshall be deemed to have been in force with effect from the first day of July, \r\n2016 and shall continue to be in force till the thirtieth da y of June, 2018, if not \r\nearlier rescinded: \r\n \r\nProvided  further that all notifications issued on or after the first day \r\nof July, 2016 and placed before the National Assembly as required under sub-\r\nsection (3) shall continue to remain in force till the thirtie th day of June, 2018, \r\nif not earlier rescinded by the Federal Government or the National Assembly.] \r\n \r\n54. Exemptions and tax provisions in other laws.—No provision in any other \r\nlaw providing for — \r\n \r\n(a) an exemption from any tax imposed under this Ordinance; \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2016. \r\n2Inserted by the Finance Act, 2015. \r\n3Full stop substituted by the Finance Act, 2017. \r\n4Added by the Finance Act, 2017 \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n107 \r\n \r\n(b) a reduction in the rate of tax imposed under this Ordinance; \r\n \r\n(c) a reduction in tax liability of any person under this Ordinance; or \r\n \r\n(d) an exemption from the operation of any provision of this \r\nOrdinance, \r\n \r\nshall have legal effect unless also provided for in this Ordinance 1[.]  \r\n \r\n2[  ] \r\n  \r\n55. Limitation of exemption. — (1)  Where any income is exempt from tax \r\nunder this Ordinance, the exemption shall be, in the absence of a specific provision \r\nto the contrary contained in this Ordinance, limited to the original recipient of that \r\nincome and shall not extend to any person receiving any payment wholly or in part \r\nout of that income. \r\n \r\n3[  ]  \r\n \r\n                                            \r\n1The colon substituted by the Finance Act, 2008. \r\n2Proviso omitted by the Finance Act, 2008. The omitted proviso read as follows: \r\n“Provided that any exemption from income tax or a reduction in the rate of tax or a reduction in \r\ntax liability of any person or an exemption from the operation of any provision of this Ordinance \r\nprovided in any other law and in force on the commencement of this Ordinance shall continue to be \r\navailable unless withdrawn.” \r\n3 Sub-section (2) omitted by the Finance Act, 2003. Omitted sub-section (2) read as follows: - \r\n“(2) Where a person’s income from business is exempt from tax under this Ordinance as a \r\nresult of a tax concession, any loss susta ined in the period of the exemption shall not be set off \r\nagainst the person’s income chargeable to tax after the exemption expires.” \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n108 \r\n \r\nPART VIII \r\nLOSSES \r\n \r\n56. Set off of losses. — (1)  Subject to sections 58 and 59, where a person \r\nsustains a loss for any tax year under any head of income specified in section 11, \r\nthe person shall be entitled to have the amount of the loss set off against the \r\nperson’s income, if any, chargeable to tax under any other head of income 1[except \r\nincome under the head salary 2[ ] ] for the year 3[: \r\n \r\n Provided that the adjustment of business loss shall not be allowed against \r\nincome from property for the tax year.] \r\n \r\n (2) Except as provided in this Part, where a person sustains a loss under a \r\nhead of income for a tax year that cannot be set off under sub-section (1), the person \r\nshall not be permitted to carry the loss forward to the next tax year. \r\n \r\n (3) Where,4[in a tax year,]a person sustains a loss under the head \r\n“Income from Business” and a loss under another head of income, the los s under \r\nthe head “Income from Business shall be set off last. \r\n \r\n5[56A.  Set off of losses of companies operating hotels.— Subject to sections \r\n56 and 57, where a 6[public company as defined in the Companies Act, 2017 and] \r\nregistered in Pakistan  7[,Gilgit-Baltistan] or Azad Jammu and Kashmir (AJ&K), \r\noperating hotels in Pakistan 8[,Gilgit-Baltistan] or AJ&K, sustains a loss in Pakistan \r\n9[,Gilgit-Baltistan] or AJ&K for any tax year under the head “income from business” \r\nshall be entitled to have the amount of the  loss set off against the company’s \r\nincome in Pakistan 10[,Gilgit-Baltistan] or AJ&K, as the case may be, from the tax \r\nyear 2007 11[onward]. \r\n \r\n57.  Carry forward of business losses. —(1) Where a person sustains a loss \r\nfor a tax year under the head “Income from  Business” (other than a loss to which \r\n                                            \r\n1Inserted by the Finance Act, 2013. \r\n2 The words “or income from property” omitted by the Finance Act, 2021.  \r\n3 Full stop substituted with a colon and thereafter a new proviso added by the Finance Act, 2025. \r\n4 Inserted by the Finance Act, 2002 \r\n5 Inserted by the Finance Act, 2007. \r\n6 The word “company” substituted by the Finance Act, 2019. \r\n7After word “Pakistan” the expression “, Gilgit-Baltistan”  inserted by the Finance Act, 2019.  \r\n8After word “Pakistan” the expression “, Gilgit-Baltistan”  inserted by the Finance Act, 2019. \r\n9After word “Pakistan” the expression “, Gilgit-Baltistan”  inserted by the Finance Act, 2019. \r\n10After word “Pakistan” the expression “, Gilgit-Baltistan”  inserted by the Finance Act, 2019. \r\n11The word “onward” substituted by the word “onward” by the Finance Act, 2014. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n109 \r\n \r\n1[sub-section (4) or] section 58 applies) and the loss cannot be wholly set off under \r\nsection 56, so much of the loss that has not been set off shall be carried forward \r\nto the following tax year and set off against the person’s income chargeable under \r\nthe head “Income from Business” for that year. \r\n \r\n (2) If a loss sustained by a person for a tax year under the head “Income \r\nfrom Business” is not wholly set off under sub -section (1), then the amount of the \r\nloss not set of f shall be carried forward to the following tax year and applied as \r\nspecified in sub -section (1) in that year, and so on, but no loss can be carried \r\nforward to more than six tax years immediately succeeding the tax year for which \r\nthe loss was first computed. \r\n \r\n2[(2A) Where a loss, referred to in sub -section (2), relating to any \r\nassessment year commencing on or after 1st day of July, 1995, and ending on the \r\n30th day of June 2001, is sustained by a banking company wholly owned by the \r\nFederal Government as on first day of June, 2002, which is approved by the State \r\nBank of Pakistan for the purpose of this sub-section, the said loss shall be carried \r\nforward for a period of ten years.] \r\n \r\n3[(2B) Where a loss, referred to in sub -section (2), relating to a tax year \r\ncommencing on or after the first day of July, 2020 is sustained by a resident \r\ncompany engaged in the hotel business in Pakistan, the said loss shall be carried \r\nforward for a period of eight years.]  \r\n \r\n 4[(2C) Where a loss, referred to in sub -section (2), relat ing to a tax year \r\ncommencing on or after the first day of January, 2017 is sustained by Pakistan \r\nInternational Airlines Corporation Limited, the said loss shall be carried forward for \r\na period of ten years.] \r\n  \r\n(3)   Where a person has a loss carried forwar d under this section for more \r\nthan one tax year, the loss of the earliest tax year shall be set off first. \r\n \r\n          5[(4) The loss attributable to deductions allowed under sections  22, 23, 6[ ] \r\n23B and 24 that has not been set off against income, the loss not set off shall be \r\n                                            \r\n1Inserted by the Finance Act, 2018. \r\n \r\n2 Inserted by the Finance Act, 2002. \r\n3 New sub-section (2B) inserted through Finance Act, 2020 dated 30th June, 2020 \r\n4 Sub-section (2C) inserted by the Finance Act, 2024. \r\n5Sub Section (4) substituted by the finance Act 2018,the substituted subsection (4) is read as follows \r\n“(4) Where the loss referred to in sub -section (1) includes deductions allowed under sections 22, 23 \r\n5[23A, 23B] and 24 that have not been set off against income, the amount not set off shall be added to the deductions \r\nallowed under those sections in the following tax year, and so on until com pletely set off”. \r\n6 The expression “23A” omitted by the Finance Act, 2021. Earlier this omission was made through \r\nTax Laws (Second Amendment) Ordinance, 2021. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n110 \r\n \r\nset off against fifty percent of the person's balance income chargeable under the \r\nhead \"income from business\" after setting off loss under sub -section (1), in the \r\nfollowing tax year and so on until completely set off: \r\n \r\nProvided that such loss shall be set off against hundred percent of the \r\nsaid balance income if the taxable income for the year is less than ten million \r\nRupees.\"] \r\n  \r\n (5) In determining whether a person’s deductions under sections 22, 23 , \r\n1[ 2[ ] 23B] and 24 have been set off against income, the deductions allowed under \r\nthose sections shall be taken into account last.  \r\n \r\n3[57A. Set off of business loss consequent to amalgama tion.—4[(1) The \r\nassessed loss (excluding capital loss) for the tax year, other than brought forward \r\nand capital loss, of the amalgamating company or companies shall be set off \r\nagainst business profits and gains of the amalgamated company, and vice versa, \r\nin the year of amalgamation and where the loss is not adjusted against the profits \r\nand gains for the t ax year the unadjusted loss shall be carried forward for \r\nadjustment upto a period of six tax years succeeding the year of amalgamation.]  \r\n \r\n (2)  The provisions of sub -section (4) and (5) of section 57 shall, mutatis \r\nmutandis, apply for the purposes of allow ing unabsorbed depreciation of \r\namalgamating company or companies in the assessment of amalgamated \r\ncompany 5[and vice versa]6[:]  \r\n \r\n7[Provided that the losses referred to in sub -section (1) and \r\nunabsorbed depreciation referred to in sub-section (2) shall be allowed set \r\noff subject to the condition that the amalgamated company continues the \r\nbusiness of the amalgamating company for a minimum period of five years \r\nfrom the date of amalgamation.] \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2009. \r\n2 The expression “23A” omitted by the Finance Act, 2021. Earlier this omission was made through Tax \r\nLaws (Second Amendment) Ordinance, 2021. \r\n3 Added by the Finance Act, 2002. \r\n4Sub-section (1) substituted by the Finance Act, 2007. The substituted sub-section (1) read as follows: \r\n“(1) The accumulated loss under the head “Income from Business” (not being a loss to which section \r\n58 applies) of an amalgamating company or companies shall be set off or carried forward against \r\nthe business profits and gains of the amalgamated company and vice versa, up to a period of six \r\ntax years immediately succeeding the tax year in which the loss was first computed in the case of \r\namalgamated company or amalgamating company or companies.” \r\n5 Inserted by the Finance Act, 2005. \r\n6 Full stop substituted by the Finance Act, 2005. \r\n7 Inserted by the Finance Act, 2005. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n111 \r\n \r\n 1[(2A).In case of amalgamation of Banking Company or Non-banking \r\nFinance Company, modarabas or insurance company, the accumulated loss under \r\nthe head “Income from Business” (not being speculation business losses) of an \r\namalgamating company or companies shall be set off or carried forward against \r\nthe business profits and gains of the amalgamated company and vice versa, up to \r\na period of six tax years immediately succeeding the tax year in which the loss was \r\nfirst computed in the case of amalgamated company or amalgamating company or \r\ncompanies: \r\n \r\nProvided that the provisions  of this sub -section shall in the case of \r\nBanking companies be applicable from July 1, 2007.] \r\n \r\n (3)  Where any of the conditions as laid down by the State Bank of \r\nPakistan or the Securities and Exchange Commission of Pakistan 2[or any court], \r\nas the case may be, in the scheme of amalgamation, are not fulfilled, the set off of \r\nloss or allowance for depreciation made in any tax year of the amalgamated \r\ncompany 3[or the amalgamating company or companies] shall be deemed to be \r\nthe income of that amalgamated comp any 4[or the amalgamating company or \r\ncompanies, as the case may be,] for the year in which such default is discovered \r\nby the Commissioner or taxation officer, and all the provisions of this Ordinance \r\nshall apply accordingly.] \r\n \r\n58. Carry forward of speculat ion business losses. —(1) Where a person \r\nsustains a loss for a tax year in respect of a speculation business carried on by the \r\nperson (hereinafter referred to as a “speculation loss”), the loss shall be set off \r\nonly against the income of the person from any  other speculation business of the \r\nperson chargeable to tax for that year. \r\n \r\n (2) If a speculation loss sustained by a person for a tax year is not wholly \r\nset off under sub-section (1), then the amount of the loss not set off shall be carried \r\nforward to the following tax year and applied against the income of any speculation \r\nbusiness of the person in that year and applied as specified in     sub-section (1) \r\nin that year, and so on, but no speculation loss shall be carried forward to more \r\nthan six tax years immediately succeeding the tax year for which the loss was first \r\ncomputed. \r\n \r\n (3) Where a person has a loss carried forward under this section for more \r\nthan one tax year, the loss of the earliest tax year shall be set off first. \r\n \r\n59. Carry forward of capital losses.— (1)  Where a person sustains a loss for \r\na tax year under the head “Capital Gains” (hereinafter referred to as a “capital \r\nloss”), the loss shall not be set off against the person’s income, if any, chargeable \r\n                                            \r\n1Inserted by the Finance Act, 2008. \r\n2 Inserted by the Finance Act, 2005. \r\n3 Inserted by the Finance Act, 2005. \r\n4 Inserted by the Finance Act, 2005. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n112 \r\n \r\nunder any other head of income for the year, but shall be carried forward to the \r\nnext tax year and set off against the capital gain, if any, chargeable under the head \r\n“Capital Gains” for that year. \r\n \r\n (2) If a capital loss sustained by a person for a tax year under the head \r\n“Capital Gains” is not wholly set off under sub -section (1), then the amount of the \r\nloss not set off shall be carried forward to the following tax year, and so on, but no \r\nloss shall be carried forward to more than six tax years immediately succeeding \r\nthe tax year for which the loss was first computed. \r\n (3) Where a person has a loss carried forward under this section for more \r\nthan one tax year, the loss of the earliest tax year shall be set off first. \r\n \r\n1[59A. Limitations on set off and carry forward of losses.— \r\n \r\n2[  ] \r\n \r\n3[  ] \r\n  \r\n (3)  In case of association of persons 4[any loss] shall be set off or carried \r\nforward and set off only against the income of the association. \r\n \r\n (4)  Nothing contained in section 56, 57, 58 or 59 shall entitle — \r\n \r\n(a)  any member of an association of persons 5[  ] to set off any loss \r\nsustained by such association of persons, as the case may be, \r\nor have it carried forward and set off, against his income; or  \r\n(b)  any person who has succeeded, in such capacity, any other \r\nperson carrying on any business or prof ession, otherwise than \r\nby inheritance, to carry forward and set off against his income, \r\nany loss sustained by such other person. \r\n \r\n6[(5)  Subject to sub-section (4) of section 57, sub-section (12) of section 22 and \r\nsub-section (6), where in computing the taxable  income for any tax year, \r\n                                            \r\n1 Added by the Finance Act,  2003. \r\n2Sub-section (1) omitted by the Finance Act, 2012. The omitted sub-section (1) read as follows: \r\n   “(1) In case of an association of persons to which sub-section (3) of section 92 applies, any loss which \r\ncannot be set off against any other income of the association of persons in accordance with section \r\n56, shall be dealt with as provided under sub-section (2) of section 93. \r\n3Sub-section (2) omitted by the Finance Act, 2012. The omitted sub-section (2) read as follows: \r\n   “(2)  Nothing contained in section 57, section 58 or section 59 shall entitle an association of persons, \r\nto which sub-section (3) of section 92 applies to have its loss carried forward and set off thereunder. \r\n4The words, figures, commas and brackets “, to which sub-section (3) of section 92 does not apply, \r\nany loss for such association” substituted by the Finance Act, 2012. \r\n5 The words, figures, commas and brackets “to which sub-section (3) of section 92 does not apply,” \r\nomitted by the Finance Act, 2012. \r\n6  Sub section (5) substituted by the finance Act 2018,the substituted sub section (5) is read as follows \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n113 \r\n \r\nfull effect cannot be given to the loss relating to deductions under section \r\n22, 23, 24 or 25 owing to there being no profits or gains chargeable for \r\nthat year or such profits  or gains as mentioned in \r\nsub-section (4) of section 57, being less than the said loss, the loss or \r\npart of the loss, as the case may be, shall be set off against fifty percent \r\nof the person’s income chargeable under  the head  “income from \r\nbusiness” for the following year or if there is no “income from business” \r\nfor that year, be set off against fifty percent of the person’s income \r\nchargeable under the head ”income from business” for the next following \r\nyear and soon for succeeding years.] \r\n \r\n (6)  Where, under sub-section (5), deduction is also to be carried forward, \r\neffect shall first be given to the provisions of section 56 and sub-section (2) of section \r\n58. \r\n \r\n (7)  Notwithstanding anything contained in this Ordinance, no loss which \r\nhas not been assessed or determined in pursuance of an order made under \r\nsection 59, 59A, 62, 63 or 65 of the repealed Ordinance or an order made or \r\ntreated as made under section 120, 121 or 122 shall be carried forward and set off \r\nunder section 57, sub-section (2)of section 58 or section 59.] \r\n \r\n1[59AA. Group taxation.— (1) Holding companies and subsidiary companies of \r\n100% owned group may opt to be taxed as one fiscal unit. In such cases, besides \r\nconsolidated group accounts as required under the 2[Companies Act, 2017 (XIX of \r\n2017)], computation of income and tax payable shall be made for tax purposes. \r\n \r\n (2)  The companies in the group shall give irrevocable option for taxation \r\nunder this section as one fiscal unit. \r\n \r\n (3)  The group taxation shall be restricted to companies locally \r\nincorporated under the 3[Companies Act, 2017 (XIX of 2017)]. \r\n \r\n (4) The relief under group taxation would not be available to losses prior \r\nto the formation of the group. \r\n \r\n                                            \r\n“(5)  Where in computing the taxable income for any tax year, full effect cannot be given to \r\na deduction mentioned in section 22, 23, 24 or 25 owing to there being no profits or gains \r\nchargeable for that year or such profits or gains being less than the deduction, then, subject to \r\nsub-section (12) of section 22, and sub-section (6), the deduction or part of the deduction to which \r\neffect has not been given, as the case may be, shall be added to the amount of such deduction \r\nfor the following year and be treated to be part of that deduction, or if there is no such deduction \r\nfor that year, be treated to be the deduction for that year and so on for succeeding years.” \r\n1 Inserted by the Finance Act, 2007. \r\n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \r\n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n114 \r\n \r\n (5) The option of group taxation shall be available to those group \r\ncompanies which comply with such corporate governance requirements 1[and \r\ngroup designation rules or regulations] as may be specified by the Securities and \r\nExchange Commission of Pakistan from time to time and are designated as \r\ncompanies entitled to avail group taxation. \r\n \r\n (6) Group taxation may be regulated through rules as m ay be made by \r\nthe2[Board]. \r\n \r\n3[59B. Group relief. — (1) Subject to sub -section (2), any company, being a \r\nsubsidiary 4[or] a holding company, may surrender its assessed loss 5[as computed \r\nin sub-section (1A)] (excluding capital loss) for the tax year (other t han brought \r\nforward losses and capital losses), in favour of its holding company or its subsidiary \r\nor between another subsidiary of the holding company: \r\n \r\nProvided that where one of the company in the group is a public \r\ncompany listed on a registered stock e xchange in Pakistan, the holding \r\ncompany shall directly hold fifty -five per cent or more of the share capital of \r\nthe subsidiary company. Where none of the companies in the group is a listed \r\ncompany, the holding company shall hold directly seventy -five per cent or \r\nmore of the share capital of the subsidiary company. \r\n                                            \r\n1Inserted by the Finance Act, 2013. \r\n2The words “Central Board of Revenue” substituted by the word “Board” by the Finance Act.  2014. \r\n3Section 59B substituted by the Finance Act, 2007. The substituted section 59B read as follows: \r\n“59B. Group Relief. - (1) Subject to sub -section (2), any company, being a subsidiary of a public \r\ncompany listed on a registered s tock exchange in Pakistan, owning and managing an industrial \r\nundertaking or an undertaking engaged in providing services, may surrender its assessed loss for \r\nthe tax year other than brought forward losses, in favour of its holding company provided such \r\nholding company owns or acquires seventy-five per cent or more of the share capital of the subsidiary \r\ncompany. \r\n (2)  The loss surrendered by the subsidiary company may be claimed by the holding \r\ncompany for set off against its income under the head “income from Business” in the tax year and the \r\nfollowing two tax years subject to the following conditions, namely:- \r\n(a) there is continued ownership of share capital of the subsidiary company to the \r\nextent of seventy-five per cent or more for five years; and  \r\n(b) the subsidiary company continues the same business during the said period of \r\nfive years. \r\n(3)  The subsidiary company shall not be allowed to surrender its assessed losses for set \r\noff against income of the holding company for more than three tax years.  \r\n (4)  Where t he losses surrendered by a subsidiary company are not adjusted against \r\nincome of the holding company in the said three tax years, the subsidiary company shall carry forward \r\nthe unadjusted losses in accordance with the provision of section 57. \r\n(5)  If there has been any disposal of shares by the holding company during the aforesaid \r\nperiod of five years to bring the ownership of the holding company to less than seventy-five per cent, \r\nthe holding company shall, in the year of disposal, offer the amount of profit on which taxes have not \r\nbeen paid due to set off of losses surrendered by the subsidiary company.” \r\n4 The word “of” substituted by the Finance Act, 2021.  \r\n5Inserted by the Finance Act, 2016. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n115 \r\n \r\n1[(1A)   The loss to be surrendered under sub -section (1) shall be \r\nallowed as per following formula, namely:- \r\n \r\n(A/100) x B \r\nwhere— \r\n \r\nA is the percentage share capital held by the holding \r\ncompany of its subsidiary company; and \r\n \r\nB is the assessed loss of the subsidiary company.] \r\n  \r\n(2) The loss surrendered by the subsidiary company may be claimed by \r\nthe holding company or a subsidiary company for set off against its income under \r\nthe head “Income from B usiness” in the tax year and the following two tax years \r\nsubject to the following conditions, namely:— \r\n \r\n(a) there is continued ownership for five years, of share capital of \r\nthe subsidiary company to the extent of fifty-five per cent in the \r\ncase of a listed  company, or seventy -five per cent or more, in \r\nthe case of other companies; \r\n \r\n(b) a company within the group engaged in the business of trading \r\nshall not be entitled to avail group relief; \r\n \r\n2[(ba) a company or companies within the group whose income from \r\nbusiness is chargeable to tax under any provisions of this \r\nOrdinance other than Division II of Part I of the First Schedule \r\nto the Ordinance shall not be entitled to avail group relief;] \r\n \r\n(c) holding company, being a private limited company with seventy-\r\nfive per cent of ownership of share capital gets itself listed within \r\nthree years from the year in which loss is claimed; \r\n \r\n(d) the group companies are locally incorporated companies under \r\nthe 3[Companies Act, 2017 (XIX of 2017)]; \r\n \r\n(e) the loss surrendered and loss claimed under this section shall have \r\napproval of the Board of Directors of the respective companies; \r\n \r\n(f) the subsidiary company continues the same business during \r\nthe said period of three years; \r\n \r\n                                            \r\n1  Inserted by the Finance Act, 2016. \r\n2 Clause (ba) inserted by the Finance Act, 2025. \r\n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n116 \r\n \r\n(g) all the companies in the group shall comply with such corporate \r\ngovernance requirements 1[and group designation rules or \r\nregulations] as may be specified by the Securities and \r\nExchange Commission of Pakistan from time to time, and are \r\ndesignated as companies entitled to avail group relief; and \r\n \r\n(h) any other condition as may be prescribed. \r\n \r\n (3) The subsidiary company shall not be allowed to surrender its \r\nassessed losses for set off against income of the holding company for more than \r\nthree tax years. \r\n \r\n (4) Where the losses surrendered by a subsidiary comp any are not \r\nadjusted against income of the holding company in the said three tax years, the \r\nsubsidiary company shall carry forward the unadjusted losses in accordance with \r\nsection 57. \r\n \r\n (5) If there has been any disposal of shares by the holding company \r\nduring the aforesaid period of five years to bring the ownership of the holding \r\ncompany to less than fifty -five per cent or seventy-five per cent, as the case may \r\nbe, the holding company shall, in the year of disposal, offer the amount of profit on \r\nwhich tax es have not been paid due to set off of losses surrendered by the \r\nsubsidiary company. \r\n \r\n (6) Loss claiming company shall, with the approval of the Board of \r\nDirectors, transfer cash to the loss surrendering company equal to the amount of \r\ntax payable on the p rofits to be set off against the acquired loss at the applicable \r\ntax rate. The transfer of cash would not be taken as a taxable event in the case of \r\neither of the two companies. \r\n \r\n (7) The transfer of shares between companies and the share holders, in \r\none direction, would not be taken as a taxable event provided the transfer is to \r\nacquire share capital for formation of the group and approval of the Security and \r\nExchange Commission of Pakistan or State Bank of Pakistan, as the case may be, \r\nhas been obtained in this effect. Sale and purchase from third party would be taken \r\nas taxable event.] \r\n \r\n2[     ]   \r\n                                            \r\n1Inserted by the Finance Act, 2013. \r\n2 Section 59C shall be omitted and shall be deemed to have been omitted with effect from 2nd March, \r\n2022 through Finance Act, 2022. The omitted section read as follows: \r\n59C. Carry forward of business losses of sick industrial units. - (I) Subject to sub -section (2), \r\nwhere a company hereinafter referred to as acquiring company, acquires under a scheme o f \r\nacquisition majority share capital of another company being a sick industrial unit, hereinafter referred \r\nto as acquired company, the acquiring company shall be entitled to adjust loss for the latest tax year \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n117 \r\n \r\nPART IX \r\nDEDUCTIBLE ALLOWANCES \r\n \r\n60. Zakat.— (1)  A person shall be entitled to a deductible allowance for the \r\namount of any Zakat paid by the person in a tax yea r under the Zakat and Ushr \r\nOrdinance, 1980 (XVIII of 1980). \r\n \r\n (2) Sub-section (1) does not apply to any Zakat taken into account under \r\nsub-section (2) of section 40. \r\n \r\n (3) Any allowance or part of an allowance under this section for a tax year \r\nthat is not able to be deducted under section 9 for the year shall not be refunded, \r\ncarried forward to a subsequent tax year, or carried back to a preceding tax year.  \r\n \r\n1[60A. Workers’ Welfare Fund. — A person shall be entitled to a deductible \r\nallowance for the amount of any Workers’ Welfare Fund paid by the person in tax \r\n                                            \r\nand brought forward assessed business losses excluding capital loss of the acquired company subject \r\nto provisions of section 57 for a period of three years.  \r\n(2) Sub-section (I) shall apply subject to the following conditions, namely:– (a) there is continued \r\nownership for five years starting from the 30th June, 2023 and there is no change in share capital of \r\nthe acquiring company; \r\n(b) the assets of the acquired company shall not be sold upto the 30\" June, 2026; and \r\n(c) the acquired company continues the same business till the 30th June, 2026. \r\n(3) Where the losses surrendered by the acquired company are not adjusted against income of \r\nthe acquiring company in the said three tax years, the acquired company shall carry forward the \r\nunadjusted losses in accordance with section 57. \r\n(4) The loss of the acquired  company referred to in sub -section (1) shall be adjusted against \r\nincome under the head \"income from business\" of the acquiring company as per following formula, \r\nnamely:-  \r\n(A/I00) x B  \r\nwhere—  \r\nA is the percentage share capital held by the acquiring company of the acquired company; and  \r\nB is the loss of the acquired company referred to in sub-section (I). \r\n(5) If the acquiring company fails to revive the acquired company by tax year 2026, the \r\nacquiring company shall, in tax year 2027 offer the amount of profit on which taxes have not been paid \r\ndue to set off of losses surrendered by the acquired company. \r\n(6) For the removal of doubt, this section shall not apply to any scheme of amalgamation \r\nor merger.  \r\n(7) For the purposes of this section, -  \r\n(a) a sick industrial unit referred to as acquired company in sub-section (I), shall be deemed to \r\nbe revived if the said company attains maximum production capacity that was obtained before the \r\nindustrial unit vent sick:  \r\nProvided that the acquired company produces a cert ificate to the effect that it stands revived, \r\nduly issued by Engineering Development Board, along with the return of income filed for tax year 2026.  \r\n(b) \"sick industrial unit\" means a company being an industrial undertaking, which – \r\n(i) has accumulated lo sses, for a continuous period of three years prior to the I\" July, 2022, \r\nequal to or exceeding its entire capital and reserves at the time of acquisition, as the ease may be; or  \r\n(ii) has defaulted towards repayment of outstanding debts owing to banking companies or non-\r\nbanking financial institutions for a consecutive period of three years immediately before acquisition, as \r\nthe case may be, or  \r\n(iii) has been declared as such by the Federal Government in a notification published in the \r\nofficial Gazette.\"; \r\n1Added by the Finance Act, 2003. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n118 \r\n \r\nyear under Workers’ Welfare Fund Ordinance, 1971 (XXXVI of 1971)  1[or under \r\nany law relating to the Workers’ Welfare Fund enacted by Provinces after the \r\neighteenth Constitutional amendment Act, 2010: \r\n \r\nProvided that this section shall not apply in respect of any amount of \r\nWorkers’ Welfare Fund paid to the Provinces by a trans-provincial establishment.] \r\n \r\n2[60B. Workers’ Participation Fund.— A person shall be entitled to a deductible \r\nallowance for the amount of any Workers’ Participation Fund paid by the person in \r\na tax year in accordance with the provisions of the Companies Profit (Workers’ \r\nParticipation) Act, 1968 (XII of 1968)  3[or under any law relating to the Workers’ \r\nProfit Participation Fund enacted b y Provinces after the eighteenth Constitutional \r\namendment Act, 2010: \r\nProvided that this section shall not apply in respect of any amount of \r\nWorkers’ Profit Participation Fund paid to the province by a trans -provincial \r\nestablishment.] \r\n \r\n4[    ] \r\n5[     ] \r\n \r\n6[60D. Deductible allowance for education expenses. — (1) Every individual \r\nshall be entitled to a deductible allowance in respect of tuition fee paid by the \r\nindividual in a tax year provided that the taxable income of the individual is less \r\nthan one 7[and a half]million rupees. \r\n \r\n(2) The amount of an individual‘s deductible allowance allowed under \r\nsub-section (1) for a tax year shall not exceed  the lesser of — \r\n \r\n(a) five per cent of the total tuition fee paid by the individual referred to in \r\nsub-section (1) in the year; \r\n \r\n                                            \r\n1 Added by the Finance Act, 2021.  \r\n2 Added by the Finance Act, 2004. \r\n3 Added by the Finance Act, 2021. \r\n4 Section 64A is re-numbered by the Finance Act 2017. \r\n5 Section 60C omitted by Finance Act, 2022 . Omitted section read as follows: \r\n   \"60C. Deductible allowance for profit on debt. — (1) Every individual shall be entitled to a \r\ndeductible allowance for the amount of any profit or share in rent and share in appreciation for value \r\nof house paid by the individual in a tax year on a loan by a scheduled bank or non-banking finance \r\ninstitution regulated by the Securities and Exchange Commission of Pakistan or advanced by \r\nGovernment or the Local Government, Provincial Government or a statutory body or a public \r\ncompany listed on a registered stock exchange in Pakistan where the individual utilizes the loan for \r\nthe construction of a new house or the acquisition of a house. \r\n(2) The amount of an individual‘s deductible allowance allowed under sub-section (1) for a tax \r\nyear shall not exceed fifty percent of taxable income or 5[“two”] million rupees, whichever is lower. \r\n(3) Any allowance or part of an allowance under this section for a tax year that is not able to be \r\ndeducted for the year shall not be carried forward to a subsequent tax year.” \r\n6 Section 64AB is re-numbered by the Finance Act, 2017. \r\n7 Inserted by the Finance Act, 2017. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n119 \r\n \r\n(b) twenty-five per cent of the person’s taxable income for the year; and \r\n \r\n(c) an amount computed by multiplying sixty thousand with number of \r\nchildren of the individual.  \r\n \r\n(3) Any allowance or part of an allowance under this section for a tax year \r\nthat is not able to be deducted for the year shall not be carried forward to a \r\nsubsequent tax year. \r\n \r\n(4) Allowance under this section shall be allowed against the tax liability \r\nof either of the parents making payment of the feeon furnishing national tax number \r\n(NTN) or name of the educational institution. \r\n \r\n(5) Allowance under this section shall not be taken into account for \r\ncomputation of tax deduction under section 149.] \r\nPART X \r\nTAX CREDITS \r\n \r\n61. Charitable donations. —1[(1) A person shall be entitled to a  tax credit in \r\nrespect of any sum paid, or any property given by the person in the tax year as a \r\ndonation 2[, voluntary contribution or subscription] to — \r\n \r\n(a)  any board of education or any university in Pakistan established \r\nby, or under, a Federal or a Provincial law; \r\n \r\n(b)  any educational institution, hospital or relief fund established or \r\nrun in Pakistan by Federal Government or a Provincial \r\nGovernment or a3[Local Government]; or \r\n \r\n(c)  any non-profit organization 4[or any person eligible for tax credit \r\nunder section 100C of this Ordinance; or \r\n(d)   entities, organizations and funds mentioned in the Thirteenth \r\nSchedule to this Ordinance.] \r\n                                            \r\n1 Sub-section (1) substituted by the Finance Act, 2003. The substituted sub-section (1) read as \r\nfollows:  \r\n“(1)  A person shall be entitled to a tax credit for a tax year in respect of any amount paid, or \r\nproperty given by the person in the tax year as a donation to a non-profit organization.” \r\n2 Inserted by the Finance Act, 2021. Earlier this insertion was made through Tax Laws (Second  \r\nAmendment) Ordinance, 2021. \r\n3The words “local authority” substituted by the Finance Act, 2008. \r\n4 Inserted by the Finance Act, 2021. Earlier this insertion was made through Tax Laws (Second  \r\nAmendment) Ordinance, 2021. \r\n \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n120 \r\n \r\n \r\n (2) The amount of a person’s tax credit allowed under sub-section (1) for \r\na tax year shall be computed according to the following formula, namely:— \r\n \r\n(A/B) x C \r\nwhere — \r\n \r\nA is the amount of tax assessed to the person for the tax year before allowance \r\nof any tax credit under this Part; \r\n \r\nB is the person’s taxable income for the tax year; and  \r\n \r\nC is the lesser of — \r\n \r\n(a) the total amount of the person’s donations referred to in sub -\r\nsection (1) in the year, including the fair market value of any \r\nproperty given; or \r\n(b) where the person is — \r\n \r\n \r\n(i) an individual or association of persons, thirty per cent of \r\nthe taxable income of the person for the year; or  \r\n \r\n(ii) a company, 1[twenty] per cent of the taxable income of \r\nthe person for the year 2[:  \r\n   \r\nProvided that where any sum is paid or any property is given to \r\nan associate by a donor, clause (b) of component C shall be, in the \r\ncase of –  \r\n \r\n(i) an individual or association of persons, fifteen percent of \r\nthe taxable income of the person for the year; or \r\n \r\n(ii) a company, ten percent of the taxable income of the \r\nperson for the year.] \r\n \r\n (3) For the purposes of clause (a) of component C of the formula in sub-\r\nsection (2), the fair market value of any property given shall be determined at the \r\ntime it is given. \r\n \r\n (4) A cash amount paid by a person as a donation shall be taken into \r\naccount under clause (a) of component C3[of]sub-section (2) only if it was paid by \r\na crossed cheque drawn on a bank. \r\n \r\n                                            \r\n1The word “fifteen” substituted by the Finance Act, 2009. \r\n2 Full stop substituted by colon and thereafter new proviso added through Finance Act, 2020 dated \r\n30th June, 2020 \r\n3 Inserted by the Finance Act, 2002. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n121 \r\n \r\n1[(5) The 2[Board] may make rules regulating the procedure of the grant of \r\napproval under sub -clause (c) of clause (36) of section 2 and any other matter \r\nconnected with, or incidental to, the operation of this section.]  \r\n \r\n3[     ] \r\n4[    ] \r\n                                            \r\n1 Added by the Finance Act, 2003. \r\n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n3Section 62 substituted by the Finance Act, 2011. The substituted section 62 read as follows: \r\n“62. Investment in shares.— (1)  A person 3[other than a company] shall be entitled to a tax credit for a tax year in respect \r\nof the cost of acquiring in the year new shares offered to the public by a public company listed on a stock exchange in Pakistan \r\nwhere the person 3[other than a company] is the original allottee of the shares or the shares are acquired from the Privatization \r\nCommission of Pakistan.  \r\n (2) The amount of a person’s tax credit allowed under sub -section (1) for a tax year shall \r\nbe computed according to the following formula, namely: — \r\n \r\n(A/B) x C \r\n \r\nwhere – \r\nA is the amount of tax assessed to the person for the tax year before allowance of any tax credit \r\nunder this Part; \r\nB is the person’s taxable income for the tax year; and  \r\nC is the lesser of — \r\n(a) the total cost of acquiring the shares referred to in sub-section (1) in the year; \r\n(b) ten per cent of the person’s 3[taxable] income for the year; or \r\n(c) 3[ 3[three] hundred] thousand rupees. \r\n (3) Where – \r\n(a) a person has 3[been allowed] a tax credit under sub-section (1) in a tax year in \r\nrespect of the purchase of a share; and \r\n(b) the person has made a disposal of the share within twelve months of the dat e \r\nof acquisition, \r\nthe amount of tax payable by the person for the tax year in which the shares were disposed of shall \r\nbe increased by the amount of the credit allowed.” \r\n4 Section 62 omitted by the Finance Act, 2022. Omitted section read as follows: \r\n“62. Tax credit for investment in shares and insurance. — (1) A resident person other than a company \r\nshall be entitled to a tax credit for a tax year either— \r\n(i) in respect of the cost of acquiring in the year new shares offered to the public by a \r\npublic company listed on a stock exchange in Pakistan, provided the resident person \r\nis the original allottee of the shares or the shares are acquired from the Privatization \r\nCommission of Pakistan;4[ ] \r\n4[(ia) in respect of cost of acquiring in the tax year, sukuks offered to the public by a public \r\ncompany listed and traded on  stock exchange in Pakistan, provided the resident \r\nperson is the original allottee of the sukuks; 4[ ] ] \r\n4[(ib)  in respect of cost of acquiring in the tax year, unit of exchange traded fund offered \r\nto public and traded on stock exchange in Pakistan; or] \r\n(ii) in respect of any life insurance premium paid on a policy to a life insurance company \r\nregistered by the Securities and Exchange Commission of Pakistan under the \r\nInsurance Ordinance, 2000 (XXXIX of 2000), p rovided the resident person is \r\nderiving income chargeable to tax under the head “salary” or “income from \r\nbusiness4[:] \r\n4[Provided that where tax credit has been allowed under this clause and \r\nsubsequently the insurance policy is surrendered within two years of its acquisition, \r\nthe tax credit allowed shall be deemed to have been wrongly allowed and the \r\nCommissioner, notwithstanding anything contained in this Ordinance, shall re -\r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n122 \r\n \r\n1[      ]  \r\n \r\n 2[      ] \r\n \r\n3[63.  Contribution to an Approved Pension Fund. — (1) An eligible person as \r\ndefined in sub-section (19A) of section 2 deriving income chargeable to tax under the \r\n                                            \r\ncompute the tax payable by the taxpayer for the relevant tax years and the  \r\nprovisions of this Ordinance, shall, so far as may, apply accordingly. ] \r\n(2)  The amount of a person’s tax credit allowed under sub -section (1) for a tax year shall be \r\ncomputed according to the following formula, namely: — \r\n(A/B) x C \r\n where— \r\nA is the amount of tax assessed to the person for the tax year before allowance \r\nof any tax credit under this Part; \r\n  B  is the person’s taxable income for the tax year; and \r\nC is the lesser of — \r\n(a)  the total cost of acquiring the shares, 4[or sukuks], or the total \r\ncontribution or premium paid by the person referred to in sub-section (1) \r\nin the year; \r\n(b)  4[twenty] per cent of the person’s taxable income for the year; or \r\n   (c)  4[ ] 4[ ] 4[two] million rupees]. \r\n (3)  Where — \r\n(a)  a person has been allowed a tax credit under sub -section (1) in a tax year in \r\nrespect of the purchase of a share; and \r\n(b)  the person has made a disposal of the share within 4[twenty-four] months of the \r\ndate of acquisition, the amount of tax payable by the person for the tax year in \r\nwhich the shares were disposed of shall be increased by the amount of the \r\ncredit allowed.”  \r\n1Inserted by the Finance Act, 2016. \r\n2 Section 62A omitted by the Finance Act, 2022. The omitted section read as follows: \r\n“62A. Tax credit for investment in health insurance. — (1) A resid ent person  2[ ] other than a \r\ncompany shall be entitled to a tax credit for a tax year in respect of any health insurance premium or \r\ncontribution paid to any insurance company registered by the Securities and Exchange Commission of \r\nPakistan under the Insur ance Ordinance, 2000 (XXXIX of 2000), provided the resident person 2[ ] is \r\nderiving income chargeable to tax under the head “salary” or “income from business”. \r\n(2) The amount of a person’s tax credit allowed under sub -section (1) for a tax year shall \r\nbe computed according to the following formula, namely: — \r\n                     (A/B) x C \r\nwhere— \r\nA is the amount of tax assessed to the person for the tax year before allowance of tax \r\ncredit under this section; \r\nB  is the person’s taxable income for the tax year; and \r\nC is the lesser of — \r\n(a) the total contribution or premium paid by the person referred to in sub-section \r\n(1) in the year; \r\n(a) five per cent of the person’s taxable income for the year; and \r\n(b) one hundred2[and fifty] thousand rupees.” \r\n3 Section 63 substituted by the Finance Act, 2005. The original section 63 read as follows: \r\n“63. Retirement annuity scheme. – (1)  Subject to sub -section (3), a resident individual deriving \r\nincome chargeable to tax under the head “Salary” or the head “Income from Business” shall be \r\nentitled to a tax credit for a tax year in respect of any contribution or premium paid in the year by the \r\nperson under a contract of annuity scheme approved by, Securities  and Exchange Commission of \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n123 \r\n \r\nhead “Salary” or the head “Income from Business” shall be entitled to a tax credit for a \r\ntax year in respect of any contribution or premium paid in the year by the person in \r\napproved pension fund under the Voluntary Pension System Rules, 2005.  \r\n \r\n(2)  The amount of a person’s tax credit allowed under sub-section (1) for \r\na tax year shall be computed according to the following formula, namely: — \r\n \r\n(A/B) x C \r\n \r\nWhere.- \r\n \r\nA is the amount of tax assessed to the person for the tax year, before \r\nallowance of any tax credit under this Part; \r\nB is the person’s taxable income for the tax year; and \r\nC is the lesser of — \r\n \r\n (i)  the total contribution or premium referred to in sub -section (1) \r\npaid by the person in the year; or \r\n \r\n(ii)  twenty per cent of the 1[eligible] person’s taxable income for the \r\nrelevant tax year; Provided that 2[an eligible person] joining the \r\npension fund at the age of forty-one years or above, during the \r\nfirst ten years 3[starting from July  1, 2006] shall be allowed \r\n                                            \r\nPakistan] of an insurance company duly registered under the Insurance Ordinance, 2000 (XXXIX of \r\n2000), having its main object the provision to the person of an annuity in old age. \r\n (2) The amount of a resident individual’s tax credit allowed under sub-section (1) for a tax \r\nyear shall be computed according to the following formula, namely: – \r\n(A/B) x C \r\nwhere – \r\nA   is the amount of tax assessed to the person for the tax year before allowance of any tax credit  \r\nunder this Part; \r\nB   is the person’s taxable income for the tax year; and  \r\nC   is the lesser of – \r\n(a) the total contribution or premium referred to in sub -section (1) paid by the \r\nindividual in the year; \r\n(b) ten per cent of the person’s taxable income for the tax year; or \r\n(c) two hundred thousand rupees. \r\n(3) A person shall not be entitled to a tax credit under sub-section (1) in respect of a contract \r\nof annuity which provides – \r\n(a) for the payment during the life of the person of any amount besides an annuity; \r\n(b) for the annuity payable to the person to commence before the person attains \r\nthe age of sixty years;  \r\n(c) that the annuity is capable, in whole or part, of surrender, commutation, \r\nor assignment; or for payment of the annuity outside Pakistan.” \r\n1 Inserted by the Finance Act, 2006. \r\n2 The words “a person” substituted by the Finance Act, 2006. \r\n3 The words, figure and commas “of the notification of the Voluntary Pension System Rules, 2005,” \r\nsubstituted by the Finance Act, 2006. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n124 \r\n \r\nadditional contribution of 2% per annum for each year of age \r\nexceeding forty year s. Provided further that the total \r\ncontribution allowed to such person shall not exceed 50% of the \r\ntotal taxable income of the preceding year 1[2[:] ] ] \r\n \r\n 3[Provided also that the additional contribution of two percent \r\nper annum for each year of age excee ding forty years shall be \r\nallowed up to the 30 th June, 2019 subject to the condition that \r\nthe total contribution allowed to such person shall not exceed \r\nthirty percent of the total taxable income of the preceding year.”] \r\n \r\n 4[  ] \r\n  \r\n5[(3)  The transfer by th e members of approved employment pension or \r\nannuity scheme or approved occupational saving scheme of their existing balance \r\nto their individual pension accounts maintained with one or more pension fund \r\nmanagers shall not qualify for tax credit under this section.] \r\n \r\n6[63A. Tax credit for interest paid on low-cost housing loan. — (1) An individual \r\nshall be entitled to a tax credit for a tax year in respect of any profit on debt or \r\nshare in rent or share in appreciation for value of house paid by the person in  the \r\nyear on a loan by a scheduled bank or any other financial institution regulated by \r\nthe Securities and Exchange Commission of Pakistan or advanced by Government \r\nor the Local Government or a statutory body or a public company listed on a \r\nregistered stock exchange in Pakistan where the person utilizes the loan for the \r\nconstruction (including land) or acquisition of one personal house having land area \r\nup to two thousand five hundred square feet or flat having total area up to two \r\nthousand square feet.  \r\n \r\n(2) The amount of a person‘s tax credit allowed under sub -section (1) for a \r\ntax year shall be computed according to the following formula, namely: —  \r\n \r\n(A/B) x C \r\n \r\nwhere —  \r\nA is the amount of tax assessed to the person for the tax year before \r\nallowance of any tax credit under this Part;  \r\n \r\nB  is the person‘s taxable income for the tax year; and  \r\n                                            \r\n1 The semi-colon and the word “or” substituted by the Finance Act, 2011. \r\n2 Full stop substituted by the Finance Act, 2016. \r\n3 Inserted by the Finance Act, 2016. \r\n4 Clause (iii) omitted by the Finance Act, 2011. The omitted clause (iii) read as follows: \r\n “(iii) five hundred thousand rupees.” \r\n5 Added by the Finance Act, 2006. \r\n6 Section 63A inserted by the Finance Act, 2025. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n125 \r\n \r\n \r\nC  is the lesser of —  \r\n \r\n(a) the total profit on debt referred to in sub -section (1) paid by the \r\nperson in the year; or  \r\n \r\n(b) thirty per cent of the person‘s taxable income for the year.  \r\n \r\n(3) The person shall not be entitled to tax credit under this section for any \r\nprofit deductible under section 15A.  \r\n \r\n(4) Where an individual has claimed tax credit under this section, he shall \r\nnot be entitled to claim tax credit for another house or flat under this section during \r\nthe subsequent fifteen tax years.] \r\n \r\n1[  ] \r\n2[  ]  \r\n3[  ] \r\n4[  ] \r\n \r\n5[64B. Tax credit for employment generation by manufacturers.—(1) Where a \r\ntaxpayer being a company formed for establishing and operating a new \r\nmanufacturing unit sets up a new manufacturing unit between the 1st day of July, \r\n                                            \r\n1 Section 64 omitted by the Finance Act, 2015. Omitted section read as follows:-  \r\n“64. Profit on debt.—1[(1) A person shall be entitled to a tax credit for a tax year in respect of any \r\nprofit or share in rent and share in appreciation for value of house paid by the person in the year on a \r\nloan by a scheduled bank or non-banking finance institution regulated by the Securities and Exchange \r\nCommission of Pakistan or advanced by Government or the1[Local Government] 1[or a statutory body \r\nor a public company listed on a regist ered stock exchange in Pakistan] where the person utilizes the \r\nloan for the construction of a new house or the acquisition of a house.] \r\n (2) The amount of a person’s tax credit allowed under sub -section (1) for a tax year shall \r\nbe computed according to the following formula, namely:— \r\n(A/B) x C \r\nwhere — \r\nA is the amount of tax assessed to the person for the tax year before allowance of any tax credit \r\nunder this Part; \r\nB is the person’s taxable income for the tax year; and  \r\nC is the lesser of — \r\n(a) the total profit referred to in sub-section (1) paid by the person in the year; \r\n(b) 1[fifty] per cent of the person’s 1[taxable] income for the year; or \r\n(c) 1[seven hundred and fifty] thousand rupees. \r\n (3) A person is not entitled to 1[tax credit]under this section for any profit deductible under \r\nsection 17.” \r\n2 Inserted by the Finance Act, 2016. \r\n3 Section 64A is re-numbered as section 60C by Finance Act, 2017 \r\n4 Section 64AB is re-numbered as section 60D by Finance Act, 2017 \r\n5 Inserted by the Finance Act, 2015. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n126 \r\n \r\n2015 and the 30th day of June, 1[2019], (both days inclusive) it shall be given a tax \r\ncredit for a period of ten years. \r\n \r\n(2)  The tax credit under sub -section (1) for a tax year sha ll be equal to \r\n2[two] percent of the tax payable for every fifty employees registered with The \r\nEmployees Old Age Benefits Institution or the Employees Social Security \r\nInstitutions of Provincial Governments during the tax year, subject to a maximum \r\nof ten percent of the tax payable. \r\n \r\n(3)  Tax credit under this section shall be admissible where— \r\n \r\n(a) the company is incorporated and manufacturing unit is setup \r\nbetween the first day of July, 2015 and the 30th day of June, \r\n2018, both days inclusive; \r\n \r\n(b) employs more than fifty employees in a tax year registered with \r\nThe Employees Old Age Benefits Institution and the Employees \r\nSocial Security Institutions of Provincial Governments; \r\n \r\n(c) manufacturing unit is managed by a company formed for  \r\noperating the said manufacturing unit and registered under the \r\n3[Companies Act, 2017 (XIX of 2017)] and having its registered \r\noffice in Pakistan; and \r\n \r\n(d) the manufacturing unit is not established by the splitting up  or \r\nreconstruction or reconstitution of an undertaking already  in \r\nexistence or by transfer of machinery or plant from an  \r\nundertaking established in Pakistan at any time before the1st \r\nJuly 2015. \r\n \r\n(4)  Where any credit is allowed under this section and subsequently  it is \r\ndiscovered, on the basis of documents or otherwise, by the Commissioner that any \r\nof the conditions specified in this section were not  fulfilled, the credit originally \r\nallowed shall be deemed to have been  wrongly allowed and the Commissioner \r\nmay, notwithstanding anything  contained in this Ordinance, re -compute the tax \r\npayable by the taxpayer for the relevant year and the provisions of this Ordinance \r\nshall, so far as may be, apply accordingly. \r\n \r\n(5)  For the purposes of this section, a manufacturing unit shall be treated \r\nto have been setup on the date on which the manufacturing unit is ready to go into \r\nproduction, whether trial production or commercial production.”] \r\n                                            \r\n1 The figure “2018” substituted by the Finance Act, 2016. \r\n2 The word “one” substituted by the Finance Act, 2016. \r\n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \r\n2021. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n127 \r\n \r\n \r\n1[  ]  \r\n2[   ] \r\n \r\n3[64D. Tax credit for point of sale machine.—(1) Any person who is required to \r\nintegrate with Board’s computerized system for real time reporting  of sale or \r\nreceipt, shall be entitled to tax credit in respect of the amount invested in purchase \r\nof point of sale machine. \r\n \r\n(2) The amount of tax credit allowed under sub -section (1) for a tax year in \r\nwhich point of sale machine is installed, integrated and configured with the Board’s \r\ncomputerized system shall be lesser of— \r\n \r\n(a) amount actually invested in purchase of point of sale machine; or \r\n \r\n(b) rupees one hundred and fifty thousand per machine. \r\n \r\n(3) For the purpose of this section, the term point of s ale machine means a \r\nmachine meant for processing and recording the sale  transactions for goods or \r\nservices, either in cash or through credit and debit cards or online payments in an \r\ninternet enabled environment.] \r\n \r\n                                            \r\n1 New sub-section 64C inserted by the Finance Act, 2019. \r\n2 Section 64C omitted by the Finance Act, 2021. Earlier this omission was made through Tax Laws \r\n(Second  Amendment) Ordinance, 2021. The omitted section read as follows: \r\n“64C. Tax credit for persons employing fresh graduates.– (1) A person employing freshly qualified \r\ngraduates from a university or institution recognized by Higher Education Commission shall be entitled \r\nto a tax credit in respect of the amount of annual salary paid to the freshly qualified graduates for a \r\ntax year in which such graduates are employed. \r\n(2) The amount of tax credit allowed under sub-section (1) for a tax year shall be computed \r\naccording to the following formula, namely:- \r\n(A/B) x C  \r\nwhere- \r\nA is the amount of tax assessed to the person for the tax year before allowance \r\nof tax credit under this section; \r\nB is the person’s taxable income for the tax year; and \r\n  C is the lessor of – \r\n(a) the annual salary paid to the freshly qualified graduates referred to in sub-\r\nsection (1) in the year; and  \r\n(b) five percent of the person’s taxable income for the year;  \r\n(3) The tax credit shall be allowed for salary paid to the number of freshly qualified \r\ngraduates not exceeding fifteen percent of the total employees of the company in the tax year. \r\n(4) In this section, “freshly qualified graduate” means a person who has graduated after the \r\nfirst day of July, 2017 from any institute or university recognized by the Higher Education Commission.” \r\n3 Inserted by the Finance Act, 2021. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n128 \r\n \r\n65.  Miscellaneous provisions relating to tax credits. — (1)  Where the \r\nperson entitled to a tax credit under 1[this]Part is a member of an association of \r\npersons to which sub-section (1) of section 92 applies, the following shall apply— \r\n \r\n(a) component A of the formula in sub -section (2) of section  61, sub -\r\nsection (2) of section 62, sub -section (2) of section 63 and sub -\r\nsection (2) of section 64 shall be the amount of tax that would be \r\nassessed to the individual if any amount derived in the year that is \r\nexempt from tax under sub-section (1) of section 92 were chargeable \r\nto tax; and \r\n \r\n(b) component B of the formula in sub -section (2) of section 61, sub -\r\nsection (2) of section 62, sub -section (2) of section 63 and sub -\r\nsection (2) of section 64 shall be the taxable income of the individual \r\nfor the year if any amount derived in the year that is exempt from tax \r\nunder sub-section (1) of section 92 were chargeable to tax. \r\n \r\n (2) Any tax credit allowed under this Part shall be applied in accordance \r\nwith sub-section (3) of section 4. \r\n \r\n (3) Subject to sub-section (4), any tax credit or part of a tax credit allowed \r\nto a person under this Part for a tax year that is not able to be credited under sub-\r\nsection (3) of section 4 for the year shall not be refunded, carried forward to a \r\nsubsequent tax year, or carried back to a preceding tax year. \r\n \r\n (4) Where the person to whom sub-section (3) applies is a member of an \r\nassociation of persons to which sub -section (1) of section 92 applies, the amount \r\nof any excess credit under sub -section (3) for a tax year may be claimed as a tax \r\ncredit by the association for that year.  \r\n \r\n (5) Sub-section (4) applies only where the member and the association \r\nagree in writing for the sub -section to apply and such agreement in writing must \r\nbe furnished with the association’s return of income for that year. \r\n \r\n2[(6) Where the person is entitled to a tax credit under section 65B, 65D or \r\n65E, provisions of clause (d) of sub -section (2) of section 169 and clause (d) of \r\nsub-section (1) of section 113 shall not apply.] \r\n \r\n3[  ] \r\n                                            \r\n1 Inserted by the Finance Act, 2002 \r\n2Inserted by the Finance Act, 2015 \r\n3Section 65A omitted by the Finance Act, 2017, Omitted section reads as follows: \r\n3[65A. Tax credit to a person registered under the Sales Tax Act, 1990. — (1) Every manufacturer, \r\nregistered under the Sales Tax Act, 1990, shall be entitled to a tax credit of 3[“three”] per cent of tax \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n129 \r\n \r\n \r\n1[65B. Tax credit for inve stment.— (1) Where a taxpayer being a company \r\ninvests any amount in the purchase of plant and machinery, for the purposes of \r\n2[extension, expansion,] balancing, modernization and replacement of the plant \r\nand machinery, already installed therein, in an indu strial undertaking set up in \r\nPakistan and owned by it, credit equal to ten per cent of the amount so invested \r\nshall be allowed against the tax payable 3[, including on account of minimum tax \r\nand final taxes payable under any of the provisions of this Ordin ance,] by it in the \r\nmanner hereinafter provided 4[:] \r\n   \r\n5[Provided that for the tax year 2019 the rate of credit shall be equal to five \r\npercent of the amount so invested: \r\n \r\n Provided further that the provisions of sub -section (5) relating to carry \r\nforward of the credit to be deducted from tax payable, to the following tax years, \r\nas specified in the said sub -section, shall continue to apply after tax year 2019 ; \r\nand] \r\n \r\n \r\n (2) The provisions of sub-section (1) shall apply if the plant and machinery \r\nis purchased and installed at any time between the first day of July, 2010, and the \r\n30th day of June, 6[ ] 7[ ] 8[2019]. \r\n \r\n (3) The amount of credit admissible under this section shall be deducted \r\nfrom the tax payable by the taxpayer in respect of the tax year in which t he plant \r\nor machinery in the purchase of which the amount referred to in sub-section (1) is \r\ninvested and installed. \r\n \r\n                                            \r\npayable for a tax year, if ninety per cent of his sales are to the person who is registered under the \r\naforesaid Act during the said tax year. \r\n(2) For claiming of the credit, the person shall provide complete details of the persons to whom \r\nthe sales were made. \r\n (3) No credit will be allowed to a person whose income is covered under final tax or minimum \r\ntax. \r\n (4) Carry forward of any amount where full credit may not be allowed against the tax liability for \r\nthe tax year, shall not be allowed. \r\n1Added by the Finance Act, 2010. \r\n2Inserted by the Finance Act, 2012. \r\n3 The coma and words inserted by Finance Act, 2012  \r\n4Full stop” substituted by “colon” by the Finance Act, 2019  \r\n5New provisos added by the Finance Act, 2019 \r\n6The figure “2015” substituted by Finance Act, 2015. \r\n7 The figure “2016” substituted by the Finance Act, 2016. \r\n8The figure “2021” substituted by Finance Act, 2019. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n130 \r\n \r\n 1[(4) The provisions of this section shall mutatis mutandis apply to a company \r\nsetup in Pakistan before the first day of July, 2011, which makes investment, through \r\nhundred per cent new equity, during first day of July, 2011 and 30th day of June, 2016, \r\nfor the purposes of balancing, modernization and replacement of the plant and \r\nmachinery already installed in an industrial undertaking owned by the company. \r\nHowever, credit equal to twenty per cent of the amount so invested shall be allowed \r\nagainst the tax payable, including on account of minimum tax and final taxes payable \r\nunder any of the provisions of this Ordinance. The credit shall be allowed in the year in \r\nwhich the plant and machinery in the purchase of which the investment as aforesaid is \r\nmade, is installed therein.  \r\n \r\n“Explanation.— For the purpose of this section the term “new equity” shall, \r\nhave the same meaning as defined in sub-section (7) of section 65E.] \r\n \r\n 2[(5) Where no tax is payable by the taxpayer in respect of the tax year in \r\nwhich such plant or machinery is installed, or where the tax payable is less than \r\nthe amount of credit as aforesaid, the amount of the credit or so much of it as is in \r\nexcess thereof, as the case may be, shall be carried forward and deducted from \r\nthe tax payable by the taxpayer in respect of the following tax year and so on, but \r\nno such amount shall be carried forward for more than two tax years in the case  \r\nof investment referred to in sub -section (1) and for more than five tax years in \r\nrespect of investment referred to in sub-section (4), however, the deduction made \r\nunder this section shall not exceed in aggregate the limit specified in sub -section \r\n(1) or sub-section (4), as the case may be.] \r\n \r\n 3[(6) Where any credit is allowed under this section and subsequently it is \r\ndiscovered by the Commissioner Inland Revenue that any one or more of the \r\nconditions specified in this section was, or were, not fulfilled, a s the case may be, \r\nthe credit originally allowed shall be deemed to have been wrongly allowed and \r\nthe Commissioner, notwithstanding anything contained in this Ordinance, shall re-\r\ncompute the tax payable by the taxpayer for the relevant year and the provisi ons \r\nof this Ordinance shall, so far as may be, apply accordingly.] \r\n                                            \r\n1Sub-section (4) substituted by the Finance Act, 2012. The substituted sub-section (4) read as follows: \r\n  “(4) Where no tax is payable by the taxpayer in respect of the tax year in which such plant \r\nor machinery is installed, or where the tax payable is less than the amount of credit, the amount of \r\nthe credit or so much of it as is in excess thereof, as the case may be, sh all be carried forward and \r\ndeducted from the tax payable by the taxpayer in respect of the following tax year, and so on, but no \r\nsuch amount shall be carried forward for more than two tax years, however, the deduction made \r\nunder sub-section (2) and this su b-section shall not exceed in aggregate the limit specified in sub -\r\nsection (1).” \r\n2Sub-section (5) substituted by the Finance Act, 2012. The substituted sub-section (5) read as follows: \r\n  “(5) Where any credit is allowed under this section and subsequently it is discovered by the \r\nCommissioner Inland Revenue that any one or more of the conditions specified in this section was, \r\nor were, not fulfilled, as the case may be, the credit originally allowed shall be deemed to have been \r\nwrongly allowed and the Commissioner Inland Revenue may, notwithstanding anything contained in \r\nthis Ordinance, re-compute the tax payable by the taxpayer for the relevant year and the provisions \r\nof this Ordinance shall, so far as may be, apply accordingly.” \r\n3Added by the Finance Act, 2012.  \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n131 \r\n \r\n1[    ]  \r\n2[    ] \r\n3[    ]  \r\n4[    ] \r\n                                            \r\n1Added by the Finance Act, 2010. \r\n2 Section 65C omitted by the Finance Act, 2021. Earlier this omission was made through Tax Laws \r\n(Second  Amendment) Ordinance, 2021. The omitted section read as follows: \r\n65C. Tax credit for enlistment. —(1) Where a taxpayer being a company opts for enlistment in any \r\nregistered stock exchange in Pakistan2[on or before the 30th day of June, 2022] a tax credit equal to \r\n2[twenty] percent of the tax payable shall be allowed for the tax year in which the said company is \r\nenlisted 2[“and for the following 2[three tax years:] \r\n[Provided that the tax credit for the last two years shall be ten per cent of the tax payable.] \r\n3Added by the Finance Act, 2011. \r\n4 Section 65D omitted by the Finance Act, 2021. The omitted section read as follows: \r\n   “65D. Tax credit for newly established industrial undertakings. — (1) Where a taxpayer being a \r\ncompany formed for establishing and operating a new industrial undertaking 4[including corporate \r\ndairy farming] sets up a new industrial undertaking4[including a corporate dairy farm], it shall be given \r\na tax credit equal to 4[“an amount as computed in sub-section (1A)”] of the tax payable               4[, \r\nincluding on account of minimum tax and final taxes payable under any of the provisions of this \r\nOrdinance,] on the taxable income arising from such industrial undertaking for a period of five years \r\nbeginning from the date of setting up or commencement of commercial production, whichever is \r\nlater. \r\n 4[“(1A)   The amount of a person’s tax credit allowed under sub-section (1) for a tax year shall \r\nbe computed according to the following formula, namely: — \r\nA x (B/C) \r\nwhere— \r\nA is the amount of tax assessed to the person for the tax year before \r\nallowance of any tax credit for the tax year; \r\nB is the equity raised through issuance of new shares for cash consideration; \r\nand \r\nC is the total amount invested in setting up the new industrial undertaking.”] \r\n (2)  Tax credit under this section shall be admissible where— \r\n(a)  the company is incorporated and industrial underta king is setup between the \r\nfirst day of July, 2011 and 30th day of June, 4[4[“2021”]]; \r\n(b)  industrial undertaking is managed by a company formed for operating the \r\nsaid industrial undertaking and registered under the Companies \r\nOrdinance, 1984 (XLVII of 1984 ) and having its registered office in \r\nPakistan; \r\n(c)  the industrial undertaking is not established by the splitting up or reconstruction \r\nor reconstitution of an undertaking already in existence or by transfer of \r\nmachinery or plant from an industrial undertaking established in Pakistan at any \r\ntime before 1st July 2011; and \r\n(d)  the industrial undertaking is set up with 4[“at least seventy per cent”] \r\nequity4[raised through issuance of new shares for cash consideration:] \r\nProvided that short term loans and finances obtained from banking companies or non-banking \r\nfinancial institutions for the purposes of meeting working capital requirements shall not disqualify the \r\ntaxpayer from claiming tax credit under this section.] \r\n             [  ] \r\n (4)  Where any credit is allowed under this section and subsequently it is discovered, on the \r\nbasis of documents or otherwise, by the Commissioner Inland Revenue that 4[“the business has been \r\ndiscontinued in the subsequent five  years after the credit has been allowed or”] any of the 4[conditions] \r\nspecified in this section [were] not fulfilled, the credit originally allowed shall be deemed to have been \r\nwrongly allowed and the Commissioner Inland Revenue may, notwithstanding anything contained in \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n132 \r\n \r\n1[65E. Tax credit for industrial undertakings established before the first day \r\nof July, 2011.—2[(1) Where a taxpayer being a company, setup in Pakistan before \r\nthe first day of July, 2011, invests any amount, with 3[at least seventy  per cent] \r\nnew equity raised through issuance of new shares, in the purchase and installation \r\nof plant and machinery for an industrial undertaking, including corporate dairy \r\nfarming, for the purposes of- \r\n \r\n(i)  expansion of the plant and machinery already installed therein; or  \r\n \r\n(ii)   undertaking a new project, \r\n \r\na tax credit shall be allowed against the tax payable in the manner provided in sub-\r\nsection (2) and sub -section (3), as th e case may be, for a period of five years \r\nbeginning from the date of setting up or commencement of commercial production \r\nfrom the new plant or expansion project, whichever is later.] \r\n \r\n 4[(2) Where a taxpayer maintains separate accounts of an expansion \r\nproject or a new project, as the case may be, the taxpayer shall be allowed a tax \r\ncredit equal to one 5[an amount as computed in sub -section (3A)]  of the tax \r\npayable, including minimum tax and final taxes payable under any of the provisions \r\nof this Ordinance, attributable to such expansion project or new project.] \r\n \r\n 6[(3) In all other cases, the credit under 7[sub-section (3A)] shall be such \r\nproportion of the tax payable, including minimum tax and final taxes payable under \r\n                                            \r\nthis Ordinance, re-compute the tax payable by the taxpayer for the relevant year and the provisions of \r\nthis Ordinance shall, so far as may be, apply accordingly.] \r\n[(5) For the purposes of this section and sections 65B and 65E, an industrial undertaking \r\nshall be treated to have been setup on the date on which the industrial undertaking is ready to go into \r\nproduction, whether trial production or commercial production.] \r\n \r\n1Added by the Finance Act, 2011. \r\n2Sub-section (1) substituted by the Finance Act, 2012. The substituted sub-section (1) read as \r\nfollows:  \r\n“(1) Where a taxpayer being a company invests any amount, with hundred per cent equity \r\ninvestment, in the purchase and installation of plant and machinery for the purposes of balancing, \r\nmodernization, replacement, or for expansion of the plant a nd machinery already installed in an \r\nindustrial undertaking setup in Pakistan before the first day of July 2011, a tax credit shall be allowed \r\nagainst the tax payable in the manner provided hereinafter, in the same proportion, which exists \r\nbetween the total investment and such equity investment made by the industrial undertaking.” \r\n3 The words “hundred per cent” substituted by the Finance Act, 2016. \r\n4Sub-section (2) substituted by the Finance Act, 2012. The substituted sub-section (1) read as \r\nfollows:  \r\n“(2) The provisions of sub-section (1) shall apply if the plant and machinery is purchased and \r\ninstalled at any time between the first day of July, 2011, and the 30th day of June, 2016.” \r\n5 The words “hundred per cent” substituted by the Finance Act, 2016. \r\n6Sub-section (3) substituted by the Finance Act, 2012. The substituted sub-section (1) read as \r\nfollows:  \r\n“(3) The amount of credit admissible under this section shall be deducted from the tax payable \r\nby the taxpayer in respect of the tax year in which the plant or machinery referred in sub-section (1) \r\nis purchased and installed and for the subsequent four years.” \r\n7 The words “this section” substituted by the Finance Act, 2016. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n133 \r\n \r\nany of the provisions of this Ordinance, as is the proportion between the new equity \r\nand the total equity including new equity.] \r\n \r\n1[(3A) The amount of a person’s tax credit allowed under sub-section (1) for \r\na tax year shall be computed according to the following formula, namely: — \r\n \r\nA x (B/C) \r\nwhere—  \r\n \r\nA is the amount of tax assessed to the person for the tax year before \r\nallowance of any tax credit for the tax year;   \r\n \r\nB is the equity raised through issuance of new shares for cash \r\nconsideration; and \r\n \r\nC is the total amount invested in the purchase  and installation of plant \r\nand machinery for the industrial undertaking.] \r\n \r\n 2[(4) The provisions of sub-section (1) shall apply if the plant and machinery \r\nis installed at any time between the first day of July, 2011 and the 30th day of June, \r\n3[ 4[2021] .] \r\n \r\n 5[(5) The amount of credit admissible under this section shall be deducted \r\nfrom the tax payable, including minimum tax and final taxes payable under any of \r\nthe provisions of this Ordinance, by the taxpayer  6[, for a period of five years \r\nbeginning from the date of setting up or commencement of commercial production \r\nfrom the new plant or expansion project, whichever is later.] \r\n \r\n 7[(6)] Where any credit is allowed under this section and subsequently it is \r\ndiscovered, on the basis of documents or otherwise, b y the Commissioner Inland \r\nRevenue that 8[“the business has been discontinued in the subsequent five  years \r\nafter the credit has been allowed or ”]any of the condition specified in this section \r\n                                            \r\n1Inserted by the Finance Act, 2016. \r\n2Sub-section (4) substituted by the Finance Act, 2012. The substituted sub-section (1) read as follows:  \r\n“(4) Where no tax is payable by the taxpayer in respect of the tax year in which such plant or \r\nmachinery is installed, or where the tax payable is less than the amount of tax credit, the amount of \r\nsuch credit or so much of it as is in excess thereof, shall be carried forward and deducted from the \r\ntax payable by the taxpayer in respect of the following tax year: \r\n Provided that no such amount shall be carried forward for  more than four tax years: \r\n  Provided further that deduction made under sub-section (1) and under this sub-section \r\nshall not exceed in aggregate the limit of the tax credit specified in sub-section (1).” \r\n3 The figure “2016” substituted by the Finance Act, 2016. \r\n4The figure “2019” substituted by Finance Act, 2018. \r\n5Inserted by the Finance Act, 2012. \r\n6 The words “in respect of the tax year in which the plant or machinery referred to in sub-section (1) is \r\ninstalled and for the subsequent four years” substituted by Finance Act, 2015. \r\n7Sub-section (5) renumbered by the Finance Act, 2012. \r\n8 Inserted by the Finance Act, 2016. \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n134 \r\n \r\nwas not fulfilled, the credit originally allowed shall be deemed to have been wrongly \r\nallowed and the Commissioner Inland Revenue may, notwithstanding anything \r\ncontained in this Ordinance, re -compute the tax payable by the taxpayer for the \r\nrelevant year and the provisions of this Ordinance shall apply accordingly. \r\n   \r\n1[(7) For the purposes of this section, ‘new equity’ means equity raised \r\nthrough fresh issue of shares against cash by the company and shall not include \r\nloans obtained from shareholders or directors: \r\n \r\nProvided that short term loans and finances obtained fro m banking \r\ncompanies or non-banking financial institutions for the purposes of meeting \r\nworking capital requirements shall not disqualify the taxpayer from claiming \r\ntax credit under this section.] \r\n \r\n2[65F. Tax credit for certain persons. – (1) Following person s or incomes shall \r\nbe allowed a tax credit equal to one hundred per cent of the tax payable under any \r\nprovisions of this Ordinance including minimum, alternate corporate tax and final \r\ntaxes for the period, to the extent, upon fulfillment of conditions and subject to \r\nlimitations detailed as under:-  \r\n \r\n3[(a)  persons engaged in coal mining projects in Sindh , to the extent,  the \r\nincome is derived from supplying coal to power generation projects.]  \r\n \r\n(b)  a startup as defined in clause (62A) of section 2 for the tax year in which \r\nthe startup is certified by the Pakistan Software Export Board and the \r\nnext following two tax years 4[.] \r\n \r\n5[Explanation. – For the removal of doubt it is clarified that tax credit under \r\nclause (a) shall only be available to the income derived from the operations \r\nof coal mining projects in Sindh supplying coal to power generation \r\nprojects.] \r\n \r\n6[     ] \r\n \r\n(2) The tax credit under sub -section (1) shall be available subject to \r\nfulfillment of the following conditions, where applicable, namely:- \r\n                                            \r\n1Added by the Finance Act, 2012. \r\n2 Sections 65F and 65G inserted by the Finance Act, 2021. Earlier this insertion was made through \r\nTax Laws (Second  Amendment) Ordinance, 2021.   \r\n3 Clause (a) substituted by the Finance Act, 2025. The substituted clause (a) read as follows: \r\n   “(a)  persons engaged in coal mining projects in Sindh supplying coal exclusively to power generation \r\nprojects;” \r\n4 Expression “; and” substituted by the Finance Act, 2024. \r\n5 Explanation inserted by the Finance Act, 2024. \r\n6 Clause (c) omitted by the Finance Act, 2022. The omitted clause read as follows: \r\n  “(c)  Income from exports of computer software or IT services or IT enabled services as defined in \r\nclause (30AD) and (30AE) of section 2 upto the period ending on the 30th day of June, 2025:  \r\nProvided that eighty percent of the export proceeds is brought into Pakistan in foreign \r\nexchange remitted from outside Pakistan through normal banking channels.”  \r\n   \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n135 \r\n \r\n \r\n(a) return has been filed; \r\n \r\n(b) withholding tax statements for the relevant tax year have been filed in  \r\nrespect of those provisions of the Ordinance, where the person is a \r\nwithholding agent; and  \r\n \r\n(c) sales tax returns for the tax periods corresponding to r elevant tax year \r\nhave been filed if the person is required to file Sales Tax Return under \r\nany of the Federal or Provincial sales tax laws.  \r\n \r\n65G. Tax credit for specified industrial undertakings.- (1) When making certain \r\neligible capital investments as spe cified in sub -section (2), the eligible taxpayers \r\ndefined in sub -section (3) shall be allowed to take an investment tax credit of \r\ntwenty five percent of the eligible investment amount, against tax payable under \r\nthe provisions of this Ordinance including minimum and final taxes. The tax credit \r\nnot fully adjusted during the year of investment shall be carried forward to the \r\nsubsequent tax year subject to the condition that it may be carried forward for a \r\nperiod not exceeding two years.  \r\n \r\n(2) For the purposes of this section, the eligible investment means \r\ninvestment made in purchase and installation of new machinery, buildings, \r\nequipment, hardware and software, except self-created software and used capital \r\ngoods.       \r\n(3) For the purpose of this section, eligible person means —  \r\n \r\n(a) green field industrial undertaking as defined in clause (27A) of  \r\nsection 2 engaged in — \r\n \r\n(i)    the manufacture of goods or materials or the subjection of goods  \r\nor materials to any process which substantially changes their \r\noriginal condition; or \r\n \r\n(ii)  ship building:  \r\n \r\nProvided that the person incorporated between the 30th \r\nday of June, 2019 and the 30th day of June, 2024 and the \r\nperson is not formed by the splitting up or reconstitution of an \r\nundertaking already in existence or by  transfer of machinery, \r\nplant or building from an undertaking established in Pakistan \r\nprior to commencement of the new business and is not part of \r\nan expansion project; and  \r\n \r\n(b)  industrial undertaking set up by the 30th day of June 2023 and  \r\nengaged in t he manufacture of plant, machinery, equipment and \r\nitems with dedicated use (no multiple uses) for generation of \r\nrenewable energy from sources like solar and wind, for a period of \r\nfive years beginning from the date such industrial undertaking is set \r\nup.] \r\nChapter III – Tax on Taxable Income ______________________ \r\n \r\n136 \r\n \r\n 1[     ] \r\n                                            \r\n1 Section 65H shall be omitted and shall be deemed to have been omitted with effect from 2nd March, \r\n2022 through Finance Act, 2022. The omitted section read as follows: \r\n\"65H. Tax credit for foreign investment for industrial promotion.- (I) Where a taxpayer being —  \r\n(a) a non-resident Pakistani citizen having continued non-residential status for more than five \r\nyears; or \r\n(b)  a resident individual having foreign assets declared in terms of section 116 or 116A by the \r\n31\" December, 2021, \r\ninvests in a company incorporated on or after the 1 st March, 2022, to set up an industrial undertaking \r\nin Pakistan with equity, not less than fifty million rupees, with funds remitted into Pakistan through \r\nproper banking channel as per the procedure to be prescribed by the State Bank of Pakistan, at any \r\ntime up to the 31st December, 2022, that company shall be entitled to a one-time tax credit equal to one \r\nhundred percent of the amount remitted and credited in rupees in the bank account of such company \r\nagainst tax liability for the tax year in which commercial production commences.  \r\n(2) Where no tax is payable by the taxpayer in respect of the tax year in which the commercial \r\nproduction has commenced or where the tax payable is less than the amount of credit as aforesaid, \r\nthe amount of the credit or so much of it as is in excess thereof, as the case may be, shall be carried \r\nforward and deducted from the tax payable by the taxpayer in respect of the following tax year and so \r\non, but no such amount shall be carried forward for more than five tax years in the case of investment \r\nreferred to in sub -section (1), however, the deduction made under this section shall not exceed in \r\naggregate the limit specified in sub-section (1).  \r\n(3) This section shall not apply to a company or an industrial undertaking established by splitting \r\nup or reconstitution of a company or an industrial undertaking already in existence or by transfer of \r\nmachinery or plant from an industrial undertaking established at any time before the 1st March, 2022.  \r\n(4) The provisions of sub-section ( I) shall apply if commercial production commences by the \r\n30th June, 2024.  \r\n(5) Where any credit is allowed under this section and subsequently it is discovered by the \r\nCommissioner Inland Revenue that any one or more of the conditions spec ified in this section was or \r\nwere not fulfilled, as the case may be, the credit originally allowed shall be deemed to have been \r\nwrongly allowed and the Commissioner, notwithstanding anything contained in this Ordinance, shall re-\r\ncompute the tax payable by the taxpayer for the relevant year and the provisions of this Ordinance \r\nshall, so far as may be, apply accordingly.” \r\nChapter IV – Common Rules_____________________________ \r\n \r\n137 \r\n \r\nCHAPTER IV \r\nCOMMON RULES \r\n \r\nPART I \r\nGENERAL \r\n \r\n66. Income of joint owners.—(1)  For the purposes of this Ordinance and subject \r\nto sub-section (2), where any property is owned by two or more persons and their \r\nrespective shares are definite and ascertainable – \r\n \r\n(a) the persons shall not be assessed as an association of persons \r\nin respect of the property; and \r\n(b) the share of each person in the income from the property for a \r\ntax year shall be taken into account in the computation of the \r\nperson’s taxable income for that year. \r\n \r\n (2) This section shall not apply in computing income chargeable under \r\nthe head “Income from Business”. \r\n \r\n67. Apportionment of deductions. — (1)  Subject to this Ordinance, where an \r\nexpenditure1[“expenditures, deductions and allowances”] relates to – \r\n(a) the derivation of more than one head of income; or \r\n \r\n2[(ab) derivation of income comprising of taxable income and any \r\nclass of income to which sub -sections (4) and (5) of section 4 \r\napply, or;] \r\n \r\n(b) the derivation of income chargeable to ta x under a head of \r\nincome and to some other purpose, \r\nthe expenditure 3[“expenditures, deductions and allowances”] shall be apportioned \r\non any reasonable basis taking account of the relative nature and size of the \r\nactivities to which the amount relates. \r\n \r\n (2) The 4[Board] may make rules under section 5[237] for the purposes of \r\napportioning deductions 6[expenditures and allowances].  \r\n \r\n                                            \r\n1 Substituted by the Finance Act, 2016. \r\n2Inserted by the Finance Act, 2002. \r\n3Substituted by the Finance Act, 2016. \r\n4The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n5The figure “232” substituted by the Finance Act, 2002. \r\n6 Inserted by the Finance Act, 2016. \r\nChapter IV – Common Rules _____________________________ \r\n \r\n138 \r\n \r\n68. Fair market value.— (1)  For the purposes of this Ordinance, the fair market \r\nvalue of any property 1[or rent], asset, service, benefit or perquisite at a particular \r\ntime shall be the price which the property 2[or rent], asset, service, benefit or \r\nperquisite would ordinarily fetch on sale or supply in the open market at that time.  \r\n \r\n (2) The fair market value of any property 3[or rent], asset, service, benefit \r\nor perquisite shall be determined without regard to any restriction on transfer or to \r\nthe fact that it is not otherwise convertible to cash. \r\n \r\n4[(3)  Where the price  5[other than the price of immoveable property]  \r\nreferred t o in sub -section (1) is not ordinarily ascertainable, such price may be \r\ndetermined by the Commissioner.] \r\n \r\n6[(4)  Notwithstanding anything contained in sub -sections (1) and (3), 7[the \r\nBoard may, from time to time, by notification in the official Gazette, de termine the \r\nfair market value of immovable property of the area or areas as may b e specified \r\nin the notification] .] \r\n \r\n8[(5)  Where the fair market value of any immovable property of an area or \r\nareas has not been determined by the Board in the notification referred to in    sub-\r\nsection (4), the fair market value of such immovable property shall be deemed to \r\nbe the value fixed by the District Officer (Revenue) or provincial or any other \r\nauthority authorized in this behalf for the purposes of stamp duty.] \r\n \r\n9[(6)  In respect of immovable property— \r\n \r\n(i) component A of the formula in sub-section (2) of section 37; \r\n \r\n(ii) “consideration received\" as mentioned in Division X of Part IV of First \r\nSchedule;  \r\n \r\n(iii) “value of immovable property\" as mentioned in Division s XVIII of Part \r\nIV of the First Schedule; and \r\n(iv) valuation for the purposes of section 111,shall not be less than the fair \r\nmarket value as determined under sub-section (4) or (5). \r\n \r\n  \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2Inserted by the Finance Act, 2003. \r\n3 Inserted by the Finance Act, 2003. \r\n4 Added by the Finance Act, 2003. \r\n5 Inserted by the Finance Act, 2016.  \r\n6Inserted by the Finance Act, 2016. \r\n7Substituted by the Income Tax (Fourth Amendment) Act, 2016 dated 02.12.2016. The substituted \r\nexpression read as follows: \r\n “the fair market value of immovable property shall be determined on the basis of valuation made by a \r\npanel of approved values of the State Bank of Pakistan”. \r\n8Added by the Income Tax (Fourth Amendment) Act, 2016 dated 02.12.2016.  \r\n9Added by the Income Tax (Fourth Amendment) Act, 2016 dated 02.12.2016. \r\nChapter IV – Common Rules _____________________________ \r\n \r\n139 \r\n \r\nExplanation.—(1) For the removal of doubt, it is clarified that the fair \r\nmarket value as determined under sub-section (4) or(5) shall be for carrying \r\nout the purposes of this Ordinance only. \r\n \r\n(2)  It is further clarified that for the purposes of clauses (i) to (iv) of \r\nthis sub-section if the fair market value determined under sub-section (4) or \r\n(5) is different than the auction price the applicable price shall be the higher \r\nof the two.] \r\n \r\n69. Receipt of income.— For the purposes of this Ordinance, a person shall be \r\ntreated as having received an amount, benefit, or perquisite if it is — \r\n \r\n(a) actually received by the person; \r\n \r\n(b) applied on behalf of the person, at the instruction of the person \r\nor under any law; or \r\n \r\n(c) made available to the person.  \r\n \r\n70. Recouped expenditure.— Where a person has been allowed a deduction \r\nfor any expenditure or loss incurred in a tax year in the computation of the person’s \r\nincome chargeable to tax under a head of income and, subsequently, the person \r\nhas received, in cash or in kind, any amount in respect of such expenditure or loss, \r\nthe amount so received shall be included in the income chargeable under that head \r\nfor the tax year in which it is received. \r\n \r\n71. Currency conversion. — (1)  Every amount taken into account under this \r\nOrdinance shall be in Rupees. \r\n \r\n (2) Where an amount is in a currency other than rupees, the amount shall \r\nbe converted to the Rupee at the State Bank of Pakistan 1[  ] rate applying between \r\nthe foreign currency and the Rupee on the date the amount is taken into account \r\nfor the purposes of this Ordinance. \r\n \r\n72. Cessation of source of income.— Where — \r\n \r\n(a) any income is derived by a person in a tax year from any business, \r\nactivity, investment or other source that has ceased either before the \r\ncommencement of the year or during the year; and \r\n \r\n(b) if the income had been derived before the business, activity , \r\ninvestment or other source ceased it would have been chargeable to \r\ntax under this Ordinance, \r\n \r\nthis Ordinance shall apply to the income on the basis that the business, activity, \r\ninvestment or other source had not ceased at the time the income was derived.  \r\n \r\n                                            \r\n1 The word “mid-exchange” omitted by the Finance Act, 2003. \r\nChapter IV – Common Rules _____________________________ \r\n \r\n140 \r\n \r\n73. Rules to prevent double derivation and double deductions.— (1)  For the \r\npurposes of this Ordinance, where – \r\n \r\n(a) any amount is chargeable to tax under this Ordinance on the basis that \r\nit is receivable, the amount shall not be chargeable again on the basis \r\nthat it is received; or \r\n(b) any amount is chargeable to tax under this Ordinance on the basis that \r\nit is received, the amount shall not be chargeable again on the basis \r\nthat it is receivable. \r\n \r\n (2) For the purposes of this Ordinance, where — \r\n \r\n(a) any expenditure is deductible under this Ordinance on the basis \r\nthat it is payable, the expenditure shall not be deductible again \r\non the basis that it is paid; or \r\n \r\n(b) any expenditure is deductible under this Ordinance on the basis \r\nthat it is paid, the expend iture shall not be deductible again on \r\nthe basis that it is payable. \r\n \r\nChapter IV – Common Rules _____________________________ \r\n \r\n141 \r\n \r\nPART II \r\nTAX YEAR \r\n \r\n1[74.  Tax year.— (1) For the purpose of this Ordinance and subject to this section, \r\nthe tax year shall be a period of twelve months ending on the 30 th day of June \r\n(hereinafter referred to as ‘normal tax year’) and shall, subject to sub -section (3), \r\nbe denoted by the calendar year in which the said date falls.  \r\n \r\n (2)  Where a person’s income year, under the repealed Ordinance, is \r\ndifferent from the normal tax year, or where a person is allowed, by an order under \r\nsub-section (3), to use a twelve months’ period different from normal tax year, such \r\nincome year or such period shall be that person’s tax year (hereinafter referred to \r\nas ‘special tax year’) and shall, subject to  sub-section (3), be denoted by the \r\ncalendar year relevant to normal tax year in which the closing date of the special \r\ntax year falls. \r\n \r\n2[(2A) The 3[Board],— \r\n \r\n(i)  in the case of a class of persons having a special tax year \r\ndifferent from a normal tax year may permit, by a notification in \r\nthe official Gazette, to use a normal tax year; and \r\n \r\n                                            \r\n1Section 74 substituted by the Finance Act, 2002. The substituted section 74  read as follows: \r\n “74. Tax year.- (1)  For the purposes of this Ordinance and subject to this section, the tax year shall \r\nbe the period of twelve months ending on the 30 th day of June (referred to in this section as the \r\nfinancial year).  \r\n(2) A person may apply, in writing, to use as the person’s tax year a twelve -month period \r\n(hereinafter referred to as a “special year”) other than the financial year and the Commissioner may, \r\nsubject to sub-section (4), by notice in writing, approve the application. \r\n(3) A person granted permission under sub-section (2) to use a special year may apply, in \r\nwriting, to ch ange the person’s tax year to the financial year or to another special year and the \r\nCommissioner may, subject to sub-section (4), by notice in writing, approve such application. \r\n(4) The Commissioner may approve an application under sub-section (2) or (3) only if the \r\nperson has shown a compelling need to use a special year or to change the person’s tax year and \r\nany approval shall be subject to such conditions as the Commissioner may prescribe. \r\n(5) The Commissioner may, by notice in writing to a person, withd raw the permission to \r\nuse a special year granted under sub-section (2) or (3). \r\n(6) A notice served by the Commissioner under sub-section (2) shall take effect on the date \r\nspecified in the notice and a notice under sub -section (3) or (5) shall take effect a t the end of the \r\nspecial year of the person in which the notice was served. \r\n(7) Where the tax year of a person changes as a result of sub -section (2), (3) or (5), the \r\nperiod between the last full tax year prior to the change and the date on which the changed tax year \r\ncommences shall be treated as a separate tax year, to be known as the “transitional year”. \r\n(8) In this Ordinance, a reference to a particular financial year shall include a special year \r\nor a transitional year of a person commencing during the financial year.  \r\n(9) A person dissatisfied with a decision of the Commissioner under sub-section (2), (3) or \r\n(5) may challenge the decision only under the appeal procedure in Part III of Chapter X.” \r\n2 Added by the Finance Act, 2004. \r\n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\nChapter IV – Common Rules _____________________________ \r\n \r\n142 \r\n \r\n(ii)  in the case of a class of persons having a normal tax year may \r\npermit, by a notification in the official Gazette, to use a special \r\ntax year.]  \r\n \r\n (3)  A person may apply, in writing, to the Commissioner to allow him to \r\nuse a twelve months’ period, other than normal tax year, as special tax year and \r\nthe Commissioner may, subject to sub -section (5), by an order, allow him to use \r\nsuch special tax year. \r\n \r\n (4)  A person using a special tax year, under sub -section (2), may apply \r\nin writing, to the Commissioner to allow him to use normal tax year and the \r\nCommissioner may, subject to sub -section (5), by an order, allow him to use \r\nnormal tax year. \r\n \r\n (5)  The Commissioner shall grant permission under sub-section (3) or (4) \r\nonly if the person has shown a compelling need to use special tax year or normal \r\ntax year, as the case may be, and the permission shall be subject to such \r\nconditions, if any, as the Commissioner may impose. \r\n \r\n (6)  An order under sub-section (3) or (4) shall be made after providing to \r\nthe applicant an opportunity of being heard and where his application is rejected \r\nthe Commissioner shall record in the order the reasons for rejection. \r\n \r\n (7)  The Commissioner may,  after providing to the person concerned an \r\nopportunity of being heard, by an order, withdraw the permission granted under \r\nsub-section (3) or (4). \r\n \r\n (8)  An order under sub-section (3) or (4) shall take effect from such date, \r\nbeing the first day of the special tax year or the normal tax year, as the case may \r\nbe, as may be specified in the order. \r\n \r\n (9)  Where the tax year of a person changes as a result of an order under \r\nsub-section (3) or sub-section (4), the period between the end of the last tax year \r\nprior to change and the date on which the changed tax year commences shall be \r\ntreated as a separate tax year, to be known as the “transitional tax year”.  \r\n \r\n (10)  In this Ordinance, a reference to a particular financial year shall, \r\nunless the context otherwise requires, include a special tax year or a transitional \r\ntax year commencing during the financial year. \r\n \r\n (11)  A person dissatisfied with an order under sub -section (3), (4) or (7) \r\nmay file a review application to the 1[Board], and the decision by the 2[Board] on \r\nsuch application shall be final.] \r\n                                            \r\n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\nChapter IV – Common Rules _____________________________ \r\n \r\n143 \r\n \r\nPART III \r\nASSETS \r\n \r\n75.  Disposal and acquisition of assets.—(1) A person who holds an asset shall \r\nbe treated as having made a disposal of the asset at the time the person parts with \r\nthe ownership of the asset, including when the asset is — \r\n \r\n(a) sold, exchanged, transferred or distributed; or \r\n \r\n(b) cancelled, redeemed, relinquished, destroyed, lost, expired or \r\nsurrendered. \r\n \r\n (2) The transmission of an asset by succession or under a will shall be \r\ntreated as a disposal of the asset by the deceased at the time asset is transmitted. \r\n \r\n (3) The application of a business asset to personal use shall be treated as a \r\ndisposal of the asset by the owner of the asset at the time the asset is so applied. \r\n \r\n1[(3A) Where a business asset is discarded or ceases to be used in \r\nbusiness, it shall be treated to have been disposed of.] \r\n \r\n (4) A disposal shall include the disposal of a part of an asset.  \r\n \r\n (5) A person shall be treated as having acquired an asset at the time the \r\nperson begins to own the asset, including at the time the person is granted any right.  \r\n \r\n (6) The application of a personal asset to business use shall be treated \r\nas an acquisition of the asset by the owner at the time the asset is so applied.  \r\n \r\n (7) In this section, -  \r\n \r\n“business asset” means an asset held wholly or partly for use in a \r\nbusiness, including stock-in-trade and a depreciable asset; and \r\n \r\n“personal asset” means an asset held wholly for personal use. \r\n \r\n2[75A. Purchase of assets through banking channel 3[or digital means].- (1) \r\nNotwithstanding anything contained in any other law, for the time being in force, \r\nno person shall purchase-  \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2003.  \r\n2 New section 75A inserted by the Finance Act, 2019. \r\n3 Words inserted by the Finance Act, 2025.  \r\nChapter IV – Common Rules _____________________________ \r\n \r\n144 \r\n \r\n(a) immovable property having fair market value greater than five million \r\nRupees; or \r\n \r\n(b) any other asset having fair market value more than one million Rupees,  \r\notherwise than by a crossed cheque drawn on a bank or through crossed \r\ndemand draft or crossed pay order or any other crossed banking \r\ninstrument 1[or through digital means]  showing transfer of amount from \r\none bank account to another bank account.  \r\n \r\n(2) For the purposes of this section in case of immovable property, fair \r\nmarket value means value notified by the Board under sub -section (4) of section \r\n68 or value fixed by the provincial authority for the purposes of stamp duty, \r\nwhichever is higher. \r\n \r\n(3) In case the transaction is not undertaken in the manner specified in \r\nsub-section (1), -    \r\n(a) such asset shall not be eligible for any allowance under sections 22, 23, \r\n24 and 25 of this Ordinance; and  \r\n \r\n(b) such amount shall not be treated as cost in  terms of section 76 of this \r\nOrdinance for computation of any gain on sale of such asset.]  \r\n \r\n76. Cost.—(1) Except as otherwise provided in this Ordinance, this section shall \r\nestablish the cost of an asset for the purposes of this Ordinance. \r\n \r\n (2) Subject to sub-section (3), the cost of an asset purchased by a person \r\nshall be the sum of the following amounts, namely:— \r\n \r\n(a) The total consideration given by the person for the asset, \r\nincluding the fair market value of any consideration in kind \r\ndetermined at the time the asset is acquired; \r\n \r\n(b) any incidental expenditure incurred by the person in acquiring \r\nand disposing of the asset; and  \r\n(c) any expenditure incurred by the person to alter or improve the \r\nasset, \r\n \r\nbut shall not include any expenditure under clauses (b) and (c) that has been fully \r\nallowed as a deduction under this Ordinance. \r\n \r\n (3) The cost of an asset treated as acquired under sub -section (6) of \r\nsection 75 shall be the fair market value of the asset determined at the date it is \r\napplied to business use. \r\n \r\n                                            \r\n1 Words inserted by the Finance Act, 2025.  \r\nChapter IV – Common Rules _____________________________ \r\n \r\n145 \r\n \r\n (4) The cost of an asset produced or constructed by a person shall be the \r\ntotal costs incurred by the person in producing or constructing the asset plus any \r\nexpenditure referred to 1[in] clauses (b) and (c) of sub -section (2) incurred by the \r\nperson. \r\n (5) Where an asset has been acquired by a person with a loan denominated \r\nin a foreign currency and, before full and final repayment of the loan, there is an \r\nincrease or decrease in the liability of the person under the loan as expressed in \r\nRupees, the amount by which the liability is increased or reduced shall be added to or \r\ndeducted from the cost of the asset, as the case may be. \r\n \r\n 2[Explanation.-Difference, if any, on account of foreign currency fluctuation, \r\nshall be taken into account in the year of occu rrence for the purposes of \r\ndepreciation.] \r\n \r\n(6) In determining whether the liability of a person has increased or \r\ndecreased for the purposes of sub -section (5), account shall be taken of the \r\nperson’s position under any hedging agreement relating to the loan. \r\n \r\n (7) Where a part of an asset is disposed of by a person, the cost of the \r\nasset shall be apportioned between the part of the asset retained and the part \r\ndisposed of in accordance with their respective fair market values determined at \r\nthe time the person acquired the asset. \r\n \r\n (8) Where the acquisition of an asset by a person is the derivation of an \r\namount chargeable to tax, the cost of the asset shall be the amount so charged \r\nplus any amount paid by the person for the asset. \r\n \r\n (9) Where the acquisition of  an asset by a person is the derivation of an \r\namount exempt from tax, the cost of the asset shall be the exempt amount plus \r\nany amount paid by the person for the asset. \r\n \r\n (10) The cost of an asset does not include the amount of any grant, \r\nsubsidy, rebate, commission or any other assistance (other than a loan repayable \r\nwith or without profit) received or receivable by a person in respect of the \r\nacquisition of the asset, except to the extent to which the amount is chargeable to \r\ntax under this Ordinance. \r\n \r\n 3[(11) Notwithstanding anything contained in this section, the Board may \r\nprescribe rules for determination of cost for any asset.] \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2003. \r\n2Added by the Finance Act, 2009. \r\n3Added by the Finance Act, 2012. \r\nChapter IV – Common Rules _____________________________ \r\n \r\n146 \r\n \r\n77. Consideration received.—(1)  The consideration received by a person on \r\ndisposal of an asset shall be the total amount received by the person for the asset \r\n1[or the fair market value thereof, whichever is the higher], including the fair market \r\nvalue of any consideration received in kind determined at the time of disposal.  \r\n \r\n (2) Where an asset has been lost or destroyed by a per son, the \r\nconsideration received for the asset shall include any compensation, indemnity or \r\ndamages received by the person under — \r\n \r\n(a) an insurance policy, indemnity or other agreement; \r\n(b) a settlement; or \r\n(c) a judicial decision. \r\n (3) The consideration received for an asset treated as disposed of under \r\nsub-section (3) 2[or (3A)] of section 75 shall be the fair market value of the asset \r\ndetermined at the time it is applied to personal use 3[or discarded or ceased to be \r\nused in business, as the case may be]. \r\n \r\n (4) The consideration received by a scheduled bank, financial institution, \r\nmodaraba, or leasing company approved by the Commissioner (hereinafter \r\nreferred to as a “leasing company”) in respect of an asset leased by the company \r\nto another person shall be the residual value received by the leasing company on \r\nmaturity of the lease agreement subject to the condition that the residual value \r\nplus the amount realized during the term of the lease towards the cost of the asset \r\nis not less than the original cost of the asset. \r\n \r\n (5) Where two or more assets are disposed of by a person in a single \r\ntransaction and the consideration received for each asset is not specified, the total \r\nconsideration received by the person shall be apportioned among the assets \r\ndisposed of in proportion to their respective fair market values determined at the \r\ntime of the transaction. \r\n \r\n 4[(6) Notwithstanding anything contained in this section, the Board may \r\nprescribe rules for determination of consideration received for any asset.] \r\n \r\n78. Non-arm’s length transactions.— Where an asset is disposed of in a non-\r\narm’s length transaction — \r\n \r\n(a) the person disposing of the asset shall be treated as having received \r\nconsideration equal to the fair market value of the asset determined at \r\nthe time the asset is disposed; and \r\n(b) the person acquiring the asset shall be treated as having a cost equal \r\nto the amount determined under clause (a).  \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2 Inserted by the Finance Act, 2003. \r\n3Inserted by the Finance Act, 2003. \r\n4Added by the Finance Act, 2012. \r\nChapter IV – Common Rules _____________________________ \r\n \r\n147 \r\n \r\n79. Non-recognition rules. — (1)  For the purposes of this Ordinance and \r\nsubject to sub-section (2), no gain or loss shall be taken to arise on the disposal of \r\nan asset – \r\n \r\n(a) between spouses under an agreement to live apart; \r\n(b) by reason of the transmission of the asset to an executor or beneficiary \r\non the death of a person;  \r\n(c) by reason of a gift of the asset 1[to a relative, as defined in sub-section \r\n(5) of section 85]; \r\n(d) by reason of the compulsory acquisition of the asset under any law \r\nwhere the consideration received for the disposal is reinvested by the \r\nrecipient in an asset of a like kind within one year of the disposal;  \r\n(e) by a company to its shareholders on liquidation of the company; or \r\n(f) by an association of persons to its members on dissolution of the \r\nassociation where the assets are distributed to members in accordance \r\nwith their interests in the capital of the association. \r\n (2) Sub-section (1) shall not apply where the person acquiring the asset \r\nis a non-resident person at the time of the acquisition 2[in respect of disposal of an \r\nasset as mentioned in clauses (d), (e) and (f) of sub-section (1)]. \r\n \r\n (3) Where clause (a), (b), (c), (e) or (f) of sub -section (1) applies, the \r\nperson acquiring the asset shall be treated as — \r\n \r\n(a) acquiring an asset of the same character as the person \r\ndisposing of the asset; and \r\n \r\n(b) acquiring the asset for a cost equal t o the cost of the asset for \r\nthe person disposing of the asset at the time of the disposal.  \r\n \r\n (4) The person’s cost of a replacement asset referred to in clause (d) of \r\nsub-section (1) shall be the cost of the asset disposed of plus the amount by which \r\nany consideration given by the person for the replacement asset exceeds the \r\nconsideration received by the person for the asset disposed of.\r\n                                            \r\n1Inserted by the Finance Act, 2018. \r\n2 Inserted by the Finance Act, 2021. \r\nChapter V – Provisions Governing Persons_________________ \r\n \r\n148 \r\nCHAPTER V \r\nPROVISIONS GOVERNING PERSONS \r\n \r\nPART I \r\nCENTRAL CONCEPTS \r\n \r\nDivision I \r\nPersons \r\n \r\n80. Person. — (1)  The following shall be treated as persons for the purposes of \r\nthis Ordinance, namely: — \r\n \r\n(a) An individual; \r\n \r\n(b) a company or association of persons incorporated, formed, organised \r\nor established in Pakistan or elsewhere;  \r\n \r\n(c) the Federal Government, a foreign government, a political sub-Division \r\nof a foreign government, or public international organisation.  \r\n \r\n(2) For the purposes of this Ordinance — \r\n \r\n(a) “association of persons” includes a firm, a Hindu undivided \r\nfamily, any artificial juridical person and anybody of per sons \r\nformed under a foreign law, but does not include a company;  \r\n \r\n(b) “company” means — \r\n \r\n  (i) a company as defined in the 1[Companies Act, 2017 (XIX \r\nof 2017)];  \r\n \r\n (ii) a body corporate formed by or under any law in force in \r\nPakistan;  \r\n \r\n(iii) a modaraba;  \r\n \r\n(iv) a body incorporated by or under the law of a country \r\noutside Pakistan relating to incorporation of companies;  \r\n \r\n2[(v)  a co -operative society, a finance society or any other \r\nsociety;] \r\n                                            \r\n1 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \r\n2Clause (v) substituted by the Finance Act, 2013. The substituted Clause (v) read as follows:- \r\n“(v) a trust,  a co -operative  society or a finance society or any other society \r\nestablished or constituted by or under any law for the time being in force;” \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n149 \r\n \r\n1[(va)  a non-profit organization;] \r\n \r\n2[(vb)  a trust, an entity o r a body of persons established or \r\nconstituted by or under any law for the time being in force;] \r\n \r\n(vi) a foreign association, whether incorporated or not, which \r\nthe 3[Board] has, by general or special order, declared to \r\nbe a company for the purposes of this Ordinance; \r\n \r\n(vii) a Provincial Government; 4[  ]  \r\n \r\n(viii) a 5[Local Government] in Pakistan; 6[or] \r\n \r\n7[(ix)  a Small Company as defined in section 2;] \r\n \r\n(c) “firm” means the relation between persons who have agreed to \r\nshare the profits of a business carrie d on by all or any of them \r\nacting for all; \r\n \r\n(d) “trust” means an obligation annexed to the ownership of \r\nproperty and arising out of the confidence reposed in and \r\naccepted by the owner, or declared and accepted by the owner \r\nfor the benefit of another, or of  another and the owner, and \r\nincludes a unit trust; and \r\n \r\n(e) “unit trust” means any trust under which beneficial interests are \r\ndivided into units such that the entitlements of the beneficiaries \r\nto income or capital are determined by the number of units held. \r\n \r\n \r\n \r\n \r\n                                            \r\n \r\n1Inserted by the Finance Act, 2013. \r\n2Inserted by the Finance Act, 2013. \r\n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n4The word “or” omitted by the Finance Act, 2005. \r\n5The words “local authority” substituted by the Finance Act, 2008. \r\n6Inserted by the Finance Act, 2005. \r\n7 Added by the Finance Act, 2005. \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n150 \r\n \r\nDivision II \r\nResident and Non-Resident Persons \r\n \r\n81.  Resident and non -resident persons.— (1)  A person shall be a resident \r\nperson for a tax year if the person is — \r\n \r\n(a) a resident individual, resident company or resident association of \r\npersons for the year; or \r\n \r\n(b) the Federal Government. \r\n \r\n(2) A person shall be a non-resident person for a tax year if the person is \r\nnot a resident person for that year. \r\n \r\n82. Resident individual. — An individual shall be a resident individual for a tax \r\nyear if the individual — \r\n \r\n(a) is present in Pakistan for a period of, or periods amounting in aggregate \r\nto, one hundred and 1[eighty-three] days or more in the tax year; 2[ ] 3[or] \r\n \r\n4[   ]  \r\n5[   ] \r\n6[   ] \r\n \r\n(c) is an employee or official of the Federal Government or a Provincia l \r\nGovernment posted abroad in the tax year 7[; \r\n  \r\n(d)  being a citizen of Pakistan is not present in any other country for more \r\nthan one hundred and eighty-two days during the tax year or who is not \r\na resident taxpayer of any other country.] \r\n \r\n                                            \r\n1The words “eighty-two” substituted by the Finance Act, 2006. \r\n2The word “or” omitted by the Finance Act, 2019. \r\n3The word “or” added by the Finance Act, 2022. \r\n4New clause (ab) inserted by Finance Act, 2019 \r\n5 Clause (ab) omitted by the Finance Act, 2021. The omitted clause read as follows: \r\n“(ab) is present in Pakistan for a period of, or periods amounting in aggregate to, one hundred and \r\ntwenty days or more in the tax year and, in the four years preceding the tax year, has been in \r\nPakistan for a period of, or periods amounting in aggregate to, three hundred and sixty-five \r\ndays or more; or” \r\n6 Clause (b) omitted by the Finance Act, 2003. The omitted clause (b) read as follows:  \r\n“(b) is present in Pakistan for a period of, or periods amounting in aggregate to, \r\nninety days or more in the tax year and who, in the four years preceding the tax \r\nyear, has been in Pakistan for a period of, or periods amounting in a ggregate \r\nto, three hundred and sixty-five days or more; or” \r\n7The full stop substituted with a semicolon and clause (d) inserted by the Finance Act, 2022. \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n151 \r\n \r\n83. Resident company.— A company shall be a resident company for a tax year \r\nif — \r\n \r\n(a) it is incorporated or formed by or under any law in force in \r\nPakistan;  \r\n \r\n(b) the control and management of the affairs of the company is \r\nsituated wholly 1[  ] in Pakistan at any time in the year; or  \r\n \r\n(c) it is a Provincial Government or 2[Local Government] in Pakistan. \r\n \r\n84. Resident association of persons.  — An association of persons shall be a \r\nresident association of persons for a tax year if the control and management of the \r\naffairs of the association is situated wholly or partly in Pakistan at any time in the \r\nyear. \r\n \r\nDivision III \r\nAssociates \r\n \r\n85. Associates. — 3[(1) Subject to sub -section (2), two persons shall be \r\nassociates where – \r\n  \r\n(i) the relationship between the two is such that o ne may reasonably be \r\nexpected to act in accordance with the intentions of the other, or both \r\npersons may reasonably be expected to act in accordance with the \r\nintentions of a third person;  \r\n \r\n(ii) one person sufficiently influences, either alone or together with an \r\nassociate or associates, the other person;  \r\n \r\nExplanation. – For the purpose of this section, two persons shall be \r\ntreated as sufficiently influencing each other, where one or both persons, \r\ndirectly or indirectly, are economically and financially dependent on each \r\nother and, decisions are made in accordance with the directions, \r\ninstructions or wishes of each other for common economic goal; or  \r\n(iii) one person enters into a transaction, directly or indirectly, with the other \r\nwho is a resident of jurisdiction with zero taxation regime.]  \r\n \r\n                                            \r\n1The words “or almost wholly” omitted by the Finance Act, 2003. \r\n2The words “local authority” substituted by the Finance Act, 2008. \r\n3 Sub-section (1) substituted by the Finance Act, 2023. The substituted sub-section read as follows: \r\n“(1)  Subject to sub -section (2), two persons shall be associates where the relationship between the \r\ntwo is such that one may reasonably be expected to act in accordance with the intentions of the other, \r\nor both persons may reasonably be expected to act in accordance with the intentions of a third \r\nperson.” \r\n \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n152 \r\n \r\n (2) Two persons shall not be associates solely by reason of the fact that \r\none person is an employee of the other or both persons are employees of a third \r\nperson.  \r\n \r\n (3) Without limiting the generality of sub -section (1) and subject to sub -\r\nsection (4), the following shall be treated as associates — \r\n \r\n(a) an individual and a relative of the individual; \r\n \r\n(b) members of an association of persons; \r\n \r\n(c) a member of an association of persons and the association, \r\nwhere the mem ber, either alone or together with an associate \r\nor associates under another application of this section, controls \r\nfifty per cent or more of the rights to income or capital of the \r\nassociation; \r\n \r\n(d) a trust and any person who benefits or may benefit under th e \r\ntrust; \r\n \r\n(e) a shareholder in a company and the company, where the \r\nshareholder, either alone or together with an associate or \r\nassociates under another application of this section, controls \r\neither directly or through one or more interposed persons — \r\n \r\n  (i) fifty per cent or more of the voting power in the company; \r\n \r\n (ii) fifty per cent or more of the rights to dividends; or \r\n \r\n(iii) fifty per cent or more of the rights to capital; and \r\n \r\n(f) two companies, where a person, either alone or together with \r\nan assoc iate or associates under another application of this \r\nsection, controls either directly or through one or more \r\ninterposed persons — \r\n \r\n  (i) fifty per cent  or more of the voting power in both \r\ncompanies; \r\n \r\n (ii) fifty per cent  or more of the rights to dividends  in both \r\ncompanies; or \r\n \r\n(iii) fifty per cent  or more of the rights to capital in both \r\ncompanies. \r\n \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n153 \r\n \r\n (4) Two persons shall not be associates under clause (a) or (b) of sub -\r\nsection (3) where the Commissioner is satisfied that neither person may \r\nreasonably be expected to act in accordance with the intentions of the other. \r\n \r\n 1[(5) In this section, –  \r\n \r\n(i) “relative” in relation to an individual, means —  \r\n \r\n(a) an ancestor, a descendant of any of the grandparents, or \r\nan adopted child, of the individual, or of a sp ouse of the \r\nindividual; or  \r\n \r\n(b)  a spouse of the individual or of any person specified in \r\nclause (a); \r\n \r\n(ii) jurisdiction with zero taxation regime means jurisdiction as may \r\nbe prescribed.] \r\n \r\n \r\n \r\n \r\n \r\n \r\n                                            \r\n1 Sub-section (5) substituted by the Finance Act. 2023. The substituted sub-section (5) read as \r\nfollows:  \r\n“(5) In this section, “relative” in relation to an individual, means — \r\n(a) an ancestor, a descendant of any of the grandparents, or an adopted child, of the \r\nindividual, or of a spouse of the individual; or \r\n(b) a spouse of the individual or of any person specified in clause (a).” \r\n \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n154 \r\n \r\nPART II \r\nINDIVIDUALS \r\n \r\nDivision I \r\nTaxation of Individuals \r\n \r\n86. Principle of taxation of individuals. — Subject to this Ordinance, the \r\ntaxable income of each individual shall be determined separately. \r\n \r\n87. Deceased individuals. — (1)  The legal representative of a deceased \r\nindividual shall be liable for — \r\n \r\n(a) any tax that the individual would have become liable for if the \r\nindividual had not died; and \r\n \r\n(b) any tax payable in respect of the income of the deceased’s \r\nestate. \r\n \r\n (2) The liability of a legal representative under this section shall be limited \r\nto the extent to which the deceased’s estate is capable of meeting the liability. \r\n \r\n 1[(2A) The liability under this Ordinance shall be the first charge on the \r\ndeceased’s estate.] \r\n \r\n (3) For the purpose of this Ordinance, — \r\n \r\n(a) any proceeding taken under this Ordinance agai nst the \r\ndeceased before his or her death shall be treated as taken \r\nagainst the legal representative and may be continued against \r\nthe legal representative from the stage at which the proceeding \r\nstood on the date of the deceased’s death; and \r\n \r\n(b) any proceed ing which could have been taken under this \r\nOrdinance against the deceased if the deceased had survived \r\nmay be taken against the legal representative of the deceased. \r\n \r\n (4) In this section, “legal representative” means a person who in law \r\nrepresents the est ate of a deceased person, and includes any person who \r\nintermeddles with the estate of the deceased and where a party sues or is sued in \r\nrepresentative character the person on whom the estate devolves on the death of \r\nthe party so suing or sued. \r\n \r\n                                            \r\n1Added by the Finance Act, 2010. \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n155 \r\n \r\nDivision II \r\nProvisions Relating to Averaging \r\n \r\n88. An individual as a member of an association of persons. — If, for a tax \r\nyear, an individual has taxable income and derives an amount or amounts exempt \r\nfrom tax under sub -section (1) of section 92, the amount of tax pay able on the \r\ntaxable income of the individual shall be computed in accordance with the following \r\nformula, namely: — \r\n \r\n(A/B) x C \r\nwhere — \r\n \r\nA is the amount of tax that would be assessed to the individual for the year if \r\nthe amount or amounts exempt from tax under sub-section (1) of section 92 \r\nwere chargeable to tax; \r\n \r\nB is the taxable income of the individual for the year if the amount or amounts \r\nexempt from tax under sub-section (1) of section 92 were chargeable to tax; \r\nand  \r\n \r\nC is the individual’s actual taxable income for the year. \r\n \r\n1[  ] \r\n \r\n89. Authors. — Where the time taken by an author of a literary or artistic work \r\nto complete the work exceeds twenty -four months, the author may elect to treat \r\nany lump sum amount received by the author in a tax year on account of royalties \r\nin respect of the work as having been received in that tax year and the preceding \r\ntwo tax years in equal proportions. \r\n \r\n                                            \r\n1Section 88A omitted by Finance Act, 2014. The omitted section read as follows: \r\n“88A. Share profits of company to be added to taxable income. —(1) Notwithstanding the \r\nprovisions of sub -section (1) of section 92, the share of profits derived by a company from an \r\nassociation of persons shall be added to the taxable income of the company. \r\n(2) The company shall be allowed a tax credit in accordance with the following formu la, \r\nnamely: — \r\n(A/B) x C \r\nWhere — \r\n \r\nA is the amount of share of profits received by the company from the association; \r\nB is the taxable income of the association; and \r\nC is the amount of tax assessed on the association. \r\n(3) The tax credit allowed under this section shall be applied in accordance with sub-section \r\n(3) of section 4.”  \r\n \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n156 \r\n \r\nDivision III \r\nIncome Splitting \r\n \r\n90. Transfers of assets. — (1) For the purposes of this Ordinance and subject \r\nto sub-section (2), where there has been a revocable transfer of an asset, any \r\nincome arising from the asset shall be treated as the income of the transferor and \r\nnot of the transferee.  \r\n \r\n (2) Sub-section (1) shall not apply to any income derived by a person by \r\nvirtue of a transfer that is not revocable during the lifetime of the person and the \r\ntransferor derives no direct or indirect benefit from such income. \r\n \r\n(3) For the purposes of this Ordinance, where there has been a transfer \r\nof an asset but the asset remains the property of the transferor, any income arising \r\nfrom the asset shall be treated as the income of the transferor.  \r\n \r\n (4) For the purposes of this Ordinance and subject to sub-section (5), any \r\nincome arising from any asset transferred by a person directly or indirectly to— \r\n \r\n(a) the person’s spouse or minor child; or  \r\n \r\n(b) any other person for the benefit of a person or persons referred \r\nto in clause (a), \r\n \r\nshall be treated as the income of the transferor. \r\n \r\n (5) Sub-section (4) shall not apply to any transfer made — \r\n \r\n(a) for adequate consideration; or  \r\n \r\n(b) in connection with an agreement to live apart. \r\n \r\n (6) For the purposes of clause (a) of sub -section (5), a transfer shall not \r\nbe treated as made for adequate consideration if the transferor has provided, by \r\nway of loan or otherwise, to the transferee, directly or indirectly, with the funds for \r\nthe acquisition of the asset. \r\n \r\n (7) Sub-section (5) does not apply where the transferor fails to produce \r\nevidence of the transfer of the asset by way of its registration or m utation in the \r\nrelevant record and the income arising from the asset shall be treated as the \r\nincome of the transferor for the purposes of this Ordinance. \r\n \r\n (8) For the purposes of this section, — \r\n \r\n(a) a transfer of an asset shall be treated as revocable if — \r\n(i) there is any provision for the re -transfer, directly or \r\nindirectly, of the whole or any part of the asset to the \r\ntransferor; or \r\n \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n157 \r\n \r\n(ii) the transferor has, in any way, the right to resume power, \r\ndirectly or indirectly, over the whole or any part of th e \r\nasset;  \r\n \r\n(b) “minor child” shall not include a married daughter; and \r\n \r\n(c) “transfer” includes any disposition, settlement, trust, covenant, \r\nagreement or arrangement. \r\n \r\n91. Income of a minor child.— (1)  Any income of a minor child for a tax year \r\nchargeable under the head \"Income from Business\" shall be chargeable to tax as the \r\nincome of the parent of the child with the highest taxable income for that year.  \r\n \r\n (2)  Sub-section (1) shall not apply to the income of a minor child from a \r\nbusiness acquired by the child through an inheritance. \r\n \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n158 \r\n \r\nPART III \r\nASSOCIATIONS OF PERSONS \r\n \r\n92. Principles of taxation of associations of persons.—(1) 1[ ] An association \r\nof persons shall be liable to tax separately from the members of the association and \r\n2[where the association of persons has paid tax the] amount received by a member \r\nof the association in the capacity as member out of the income of the association \r\nshall be exempt from tax3[:] \r\n \r\n 4[Provided that if at least one member of the association of persons is \r\na company, the share of such company or companies shall be excluded  for \r\nthe purpose of computing the total income of the association of persons and \r\nthe company or the companies shall be taxed separately, at the rate \r\napplicable to the companies, according to their share 5[: ] \r\n \r\nProvided further that the share of a member of an association of \r\npersons having turnover of three hundred million rupees or above during the \r\ntax year or any of the preceding tax years shall not be exempt if financial \r\nstatements duly audited by a firm of Chartered Accountants as defined under \r\nthe Chartered Accountants Ordinance, 1961 (X of 1961), or a firm of Cost \r\nand Management Accountants as defined under the Cost and Management \r\nAccountants Act, 1966 (XIV of 1966) have not been filed along with retu rn \r\nof income by the association of persons to whom he is a member:] \r\n \r\n6[Explanation.– For removal of doubt it is clarified that if the income of \r\nassociation of persons is exempt and no tax is payable under the Ordinance \r\ndue to this exemption, the share received in the capacity as member out of \r\nthe income of the association shall remain exempt.] \r\n 7[  ] \r\n 8[  ] \r\n 9[  ] \r\n                                            \r\n1The words, brackets, figure and comma “Subject to sub-section (2)” omitted by the Finance Act, 2007. \r\n2 Inserted by the Finance Act, 2003. \r\n3Full stop substituted by a colon by the Finance Act, 2014. \r\n4Added by the Finance Act, 2014. \r\n5 Full stop substituted and new proviso inserted by the Finance Act, 2024. \r\n6 Explanation added by the Finance Act, 2022. \r\n7 Sub-section (2) omitted by the Finance Act, 2007. The omitted sub-section (2) read as follows:  \r\n“ (2) Sub-section (1) shall not apply to an association of persons that is a professional firm prohibited \r\nfrom incorporating by any law or the rules of the body regulating the profession.” \r\n8Sub-section (3) omitted by the Finance Act, 2007. The omitted sub-section (3) read as follows: \r\n“(3)  An association of persons to which subsection (2) applies shall not be liable to tax and the income \r\nof the association shall be taxed to the members in accordance with section 93”. \r\n9 Sub-section (4) omitted by the Finance Act, 2007. The omitted sub-section (4) read as follows:  \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n159 \r\n \r\n 1[  ] \r\n 2[  ] \r\nPART IV \r\nCOMPANIES \r\n \r\n94. Principles of taxation of companies.- (1)  A company shall be liable to tax \r\nseparately from its shareholders. \r\n \r\n (2) A dividend paid by a 3[  ] company shall be taxable in accordance with \r\nSection 5. \r\n \r\n 4[ ] \r\n \r\n                                            \r\n“(4)An association of persons referred to in sub -section (3) shall furnish a return of total income for \r\neach tax year. \r\n1Sub-section (5) omitted by the Finance Act, 2007. The omitted sub-section (5) read as follows: \r\n“(5) Sections 114, 118 and 119 shall apply to a return of total income required to be furnished under \r\nsub-section (4).” \r\n2 Section 93 omitted by the Finance Act, 2007. The omitted section read as follows:  \r\n“93. Taxation of members of an association of persons. - (1)  Where sub-section (3) of section \r\n92 applies, the income of a member of an association of persons chargeable under the head “Income \r\nfrom Business” for a tax year shall include – \r\n(a) in the case of a resident member, t he member’s share in the total income of the \r\nassociation; or \r\n(b) in the case of a non-resident member, the member’s share in so much of the total income \r\nof the association as is attributable to Pakistani-source income. \r\n (2) Where an association of persons to which sub-section (3) of section 92 applies sustains \r\na loss that cannot be set off against any other income of the association in accordance with section 56, \r\nthe amount of the loss shall be apportioned among the members of the association according to t heir \r\ninterest in the association and the members shall be entitled to have their share of the loss set off and \r\ncarried forward for set off under Part VIII of Chapter III in computing their taxable income under this \r\nOrdinance. \r\n (3) The share of a loss refer red to in sub -section (2) of a non -resident member shall be \r\nlimited to the extent that the loss relates to the derivation of Pakistan-source income. \r\n (4) The total income of an association of persons for the purposes of sub -section (1) and \r\nthe loss of an a ssociation for the purposes of sub -section (2) shall be computed as if the association \r\nwere a resident person. \r\n (5) Income, expenditures and losses of an association of persons to which this section \r\napplies shall retain their character as to geographic source and type of income, expenditure or loss in \r\nthe hands of the members of the association, and shall be treated as having passed through the \r\nassociation on a pro rata basis, unless the Commissioner permits otherwise by order in writing to the \r\nassociation. \r\n (6) The share of a member in the total income of an association of persons shall be \r\ndetermined according to the  member’s interest in the association and shall include any profit on debt, \r\nbrokerage, commission, salary or other remuneration received or due from the association.” \r\n3The word “resident” omitted by the Finance Act, 2015 \r\n4Sub-section (3) omitted by the Finance Act 2017. Omitted sub-section reads as follows: \r\n    “A dividend paid by a non-resident company to a resident person shall be chargeable to tax under \r\nthe head “Income from Business” or “Income from Other Sources”, as the case may be, unless the \r\ndividend is exempt from tax.” \r\n \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n160 \r\n \r\n95. Disposal of business by individual to wholly -owned company. - (1)  \r\nWhere a resident individual (hereinafter referred to as the “transferor”) disposes of \r\nall the assets of a business of the transferor to a resident company, no gain or loss \r\nshall be taken to arise on the disposal if the following conditions are satisfied, \r\nnamely:— \r\n(a) The consideration received by the transferor for the disposal is \r\na share or shares in the company (other than redeemable \r\nshares); \r\n \r\n(b) the transferor must beneficially own all the issued shares in the \r\ncompany immediately after the disposal; \r\n(c) the company must undertake to discharge any liability in respect \r\nof the assets disposed of to the company; \r\n \r\n(d) any liability in respect of the assets disposed of to the company \r\nmust not exceed the transferor’s cost of the assets at the time \r\nof the disposal; \r\n \r\n(e) the fair market value of the share or shares received by the \r\ntransferor for the disposal must be substantially the same as the \r\nfair market value of the assets disposed of to the company, less \r\nany liability that the company has undertaken to discharge in \r\nrespect of the assets; and \r\n \r\n(f) the company must not be exempt from tax for the t ax year in \r\nwhich the disposal takes place. \r\n \r\n (2) Where sub-section (1) applies — \r\n \r\n(a) each of the assets acquired by the company shall be treated as \r\nhaving the same character as it had in the hands of the \r\ntransferor; \r\n \r\n(b) the company’s cost in respect of t he acquisition of the assets \r\nshall be — \r\n \r\n  (i) in the case of a depreciable asset or amortised intangible, \r\nthe written down value of the asset or intangible \r\nimmediately before the disposal;  \r\n \r\n (ii) in the case of stock-in-trade valued for tax purposes under \r\nsub-section (4) of section 35 1[  ], that value; or  \r\n \r\n                                            \r\n1The words “at fair market value” omitted by the Finance Act, 2007. \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n161 \r\n \r\n(iii) in any other case, the transferor’s cost at the time of the \r\ndisposal; \r\n \r\n(c) if, immediately before the disposal, the transferor has \r\ndeductions allowed under sections 22, 23 and 24 in respect of \r\nthe assets transferred which have not been set off against the \r\ntransferor’s income, the amount not set off shall be added to the \r\ndeductions allowed under those sections to the company in the \r\ntax year in which the transfer is made; and \r\n(d) the transferor’s cost in respect of the share or shares received \r\nas consideration for the disposal shall be — \r\n \r\n(i) in the case of a consideration of one share, the \r\ntransferor’s cost of the assets transferred as determined \r\nunder clause (b), less the amount of any liability t hat the \r\ncompany has undertaken to discharge in respect of the \r\nassets; or  \r\n \r\n(ii) in the case of a consideration of more than one share, the \r\namount determined under sub -clause (i) divided by the \r\nnumber of shares received. \r\n \r\n (3) In determining whether the transferor’s deductions under sections 22, \r\n23 or 24 have been set off against income for the purposes of clause (c) of sub -\r\nsection (2), those deductions shall be taken into account last. \r\n  \r\n96. Disposal of business by association of persons to wholly -owned \r\ncompany.— (1)  Where a resident association of persons disposes of all the assets \r\nof a business of the association to a resident company, no gain or loss shall be taken \r\nto arise on the disposal if the following conditions are satisfied, namely: — \r\n \r\n(a) The consideration received by the association for the disposal is a \r\nshare or shares in the company (other than redeemable shares); \r\n(b) the association must own all the issued shares in the company \r\nimmediately after the disposal; \r\n(c) each member of the association  must have an interest in the \r\nshares in the same proportion to the member’s interest in the \r\nbusiness assets immediately before the disposal; \r\n(d) the company must undertake to discharge any liability in respect \r\nof the assets disposed of to the company; \r\n(e) any liability in respect of the assets disposed of to the company \r\nmust not exceed the association’s cost of the asset at the time \r\nof the disposal; \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n162 \r\n \r\n(f) the fair market value of the share or shares received by the \r\nassociation for the disposal must be substan tially the same as \r\nthe fair market value of the assets disposed of to the company, \r\nas reduced by any liability that the company has undertaken to \r\ndischarge in respect of the assets; and \r\n(g) the company must not be exempt from tax for the tax year in \r\nwhich the disposal takes place. \r\n \r\n (2) Where sub-section (1) applies — \r\n(a) each of the assets acquired by the company shall be treated as \r\nhaving the same character as it had in the hands of the \r\nassociation; \r\n(b) the company’s cost in respect of the acquisition of the assets \r\nshall be — \r\n  (i) in the case of a depreciable asset or amortised intangible, \r\nthe written down value of the asset or intangible \r\nimmediately before the disposal;  \r\n (ii) in the case of stock -in-trade valued for tax purposes \r\nunder sub-section (4) of section 351[  ], that value; or  \r\n(iii) in any other case, the association’s cost at the time of the \r\ndisposal; \r\n(c) if, immediately before the disposal, the association is subject to tax \r\nin accordance with sub -section (1) of section 92 and the \r\nassociation has deductions allowed under sections 22, 23 and 24 \r\nin respect of the assets transferred which have not been set off \r\nagainst the association’s income, the amount not set off shall be \r\nadded to the deductions allowed under those sections to the \r\ncompany in the tax year in which the transfer is made; and \r\n(d) the association’s cost in respect of the share or shares received \r\nas consideration for the disposal shall be — \r\n (i) in the case of a consideration of one share, the \r\nassociation’s cost of the assets transferred as determined \r\nunder clause (b), as reduced by the amount of any liability \r\nthat the company has undertaken to discharge in respect \r\nof the assets; or  \r\n                                            \r\n1 The words “at fair market value” omitted by the Finance Act, 2007. \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n163 \r\n \r\n(ii) in the case of a consideration of more than one share, the \r\namount determined under sub -clause (i) d ivided by the \r\nnumber of shares received. \r\n (3) In determining whether the association’s deductions under Sections \r\n22, 23 or 24 have been set off against income for the purposes of clause (c) of \r\nsub-section (2), those deductions are taken into account last.  \r\n97. Disposal of asset between wholly-owned companies.— (1)  Where a resident \r\ncompany (hereinafter referred to as the “transferor”) disposes of an asset to another \r\nresident company (hereinafter referred to as the “transferee”), no gain or loss shall \r\nbe taken to arise on the disposal if the following conditions are satisfied, namely:- \r\n(a) Both companies belong to a wholly-owned group of 1[resident] \r\ncompanies at the time of the disposal; \r\n(b) the transferee must undertake to discharge any liability in \r\nrespect of the asset acquired; \r\n(c) any liability in respect of the asset must not exceed the \r\ntransferor’s cost of the asset at the time of the disposal; and \r\n(d) the transferee must not be exempt from tax for the tax year in \r\nwhich the disposal takes place. \r\n (2) Where sub-section (1) applies — \r\n(a) the asset acquired by the transferee shall be treated as having \r\nthe same character as it had in the hands of the transferor; \r\n(b) the transferee’s cost in respect of the acquisition of the asset \r\nshall be — \r\n  (i) in the case of a depreciable asset or amortized intangible, \r\nthe written down value of the asset or intangible \r\nimmediately before the disposal;  \r\n (ii) in the case of stock-in-trade valued for tax purposes under \r\nsub-section (4) of section 35 2[  ], that value; or  \r\n(iii) in any other case, the transferor’s cost at the time of the \r\ndisposal;  \r\n(c) if, immediately before the disposal, the transferor has \r\ndeductions allowed under sections 22, 23 and 24 in respect of \r\nthe asset transferred which have not been set off against the \r\ntransferor’s income, the amount not set off shall be added to the \r\n                                            \r\n1Inserted by the Finance Act, 2003. \r\n2The words “at fair market value” omitted by the Finance Act, 2007. \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n164 \r\n \r\ndeductions allowed under those sections to the transferee in the \r\ntax year in which the transfer is made; and \r\n(d) the transferor’s cost in respect of any consideration in kind \r\nreceived for the asset shall be the transferor’s cost of the asset \r\ntransferred as determined under clause (b), as reduced by the \r\namount of any liability that the transferee has undertaken to \r\ndischarge in respect of the asset. \r\n (3) In determining whether the transferor’s deductions under sections 22, \r\n23 or 24 in respect of the asset transferred have been set off against income for \r\nthe purposes of clause (c) of sub-section (2), those deductions shall be taken into \r\naccount last.  \r\n (4) The transferor and transferee companies belong to a wholly -owned \r\ngroup if — \r\n(a) one company beneficially holds all the issued shares of the \r\nother company; or \r\n(b) a third company beneficially holds all the issued shares in both \r\ncompanies. \r\n1[97A. Disposal of asset under a scheme of arrangement and  \r\nreconstruction.—(1) No gain or loss shall be taken to arise on disposal of asset \r\nfrom one company (hereinafter referred to as the “transferor”) to another company \r\n(hereinafter referred to as the “transferee”) by virtue of operation of a Scheme of \r\nArrangement and Reconstruction under sections 282L and 284 to 287 of the \r\n2[Companies Act, 2017 (XIX of 2017)] or section 48 of the Banking Companies \r\nOrdinance, 1962 (LVII of 1962), if the following conditions are satisfied, namely:— \r\n(a) the transferee must underta ke to discharge any liability in \r\nrespect of the asset acquired; \r\n(b) any liability in respect of the asset must not exceed the \r\ntransferor’s cost of the asset at the time of the disposal; \r\n(c) the transferee must not be exempt from tax for the tax year in \r\nwhich the disposal takes place; and \r\n(d) scheme is approved by the High Court, State Bank of Pakistan \r\nor Securities and Exchange Commission of Pakistan, as the \r\ncase may be, on or after first day of July, 2007. \r\n (2) No gain or loss shall be taken to arise on is sue, cancellation, \r\nexchange or receipt of shares as a result of Scheme of Arrangement and \r\nReconstruction under sections 282L and 284 to 287 of the Companies Act, 2017 \r\n                                            \r\n1 Inserted by the Finance Act, 2007. \r\n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” wherever occurring substituted by \r\n“Companies Act, 2017 (XIX of 2017)” through Finance Act, 2020 dated 30th June, 2020 \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n165 \r\n \r\n(XIX of 2017)  or section 48 of the Banking Companies Ordinance, 1962 (LVII of \r\n1962) and approved by:— \r\n(a) the High Court; \r\n(b) State Bank of Pakistan; or \r\n(c) Securities and Exchange Commission of Pakistan, as the case \r\nmay be, on or after first day of July, 2007. \r\n (3) Where sub-section (1) applies— \r\n(a) the asset acquired by the transferee shall be treated as having \r\nthe same character as it had in the hands of the transferor; \r\n \r\n(b) the transferee’s cost in respect of acquisition of the asset shall be— \r\n(i) in the case of a depreciable asset or amortised intangible, \r\nthe written down value of the asse t or intangible \r\nimmediately before the disposal; \r\n(ii) in the case of stock -in-trade valued for tax purposes \r\nunder sub-section (4) of section 35, that value; or \r\n(iii) in any other case, the transferor’s cost at the time of the \r\ndisposal; \r\n(c) if, immediately before the disposal, the transferor has \r\ndeductions allowed under sections 22, 23 and 24 in respect of \r\nthe asset transferred which have not been set off against the \r\ntransferor’s income, the amount not set off shall be added to the \r\ndeduction allowed under those sections to the transferee in the \r\ntax year in which the transfer is made. \r\n (4) In determining whether the transferor’s deductions under sections 22, \r\n23 or 24 in respect of the asset transferred have been set off against income for \r\nthe purposes of clause (c) of sub-section (2), those deductions shall be taken into \r\naccount last. \r\n \r\n (5) Where sub-section (2) applies and the shares issued vested by virtue \r\nof the Scheme of Arrangement and Reconstruction under sections 282L and 284 \r\nto 287 of the Companies Act, 2017 (XIX of 2017) or section 48 of the Banking \r\nCompanies Ordinance, 1962 (LVII of 1962) and approved by the Court or State \r\nBank of Pakistan or Securities and Exchange Commission of Pakistan as the case \r\nmay be, are disposed of, the cost of shares shall be the cost prior to the operation \r\nof the said scheme.] \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n166 \r\n \r\nPART V \r\n \r\nCOMMON PROVISIONS APPLICABLE TO  \r\nASSOCIATIONS OF PERSONS AND COMPANIES \r\n \r\n98.  Change in control of an entity. - (1)  Where there is a change of fifty per \r\ncent or more in the underlying ownership of an entity, any loss incurred for a tax \r\nyear before the change shall not be allowed as a deduction in a tax year after the \r\nchange, unless the entity — \r\n \r\n(a) continues to conduct the same business after the change as it \r\nconducted before the change until th e loss has been fully set \r\noff; and \r\n \r\n(b) does not, until the loss has been fully set off, engage in any new \r\nbusiness or investment after the change where the principal \r\npurpose of the entity or the beneficial owners of the entity is to \r\nutilise the loss so as  to reduce the income tax payable on the \r\nincome arising from the new business or investment. \r\n \r\n (2) In this section, — \r\n \r\n“entity” means a company or association of persons to which sub -\r\nsection (1) of section 92 applies; \r\n \r\n“ownership interest” means a share in  a company or the interest of a \r\nmember in an association of persons; and \r\n \r\n“underlying ownership” in relation to an entity, means an ownership \r\ninterest in the entity held, directly or indirectly through an interposed \r\nentity or entities, by an individual or by a person not ultimately owned \r\nby individuals. \r\n \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n167 \r\n \r\n1[PART VA \r\nTAX LIABILITY IN CERTAIN CASES \r\n \r\n98A.  Change in the constitution of an association of persons. —Where, \r\nduring the course of a tax year, a change occurs in the constitution of an \r\nassociation of per sons, liability of filing the return on behalf of the association of \r\npersons for the tax year shall be on the association of persons as constituted at \r\nthe time of filing of such return but the income of the association of persons shall \r\nbe apportioned among the members who were entitled to receive it and, where the \r\ntax assessed on a member cannot be recovered from him it shall be recovered \r\nfrom the association of persons as constituted at the time of filing the return.  \r\n \r\n98B.  Discontinuance of business or d issolution of an association of \r\npersons.— (1) Subject to the provisions of section 117, where any business or \r\nprofession carried on by an association of persons has been discontinued, or \r\nwhere an association of persons is dissolved, all the provisions of t his Ordinance, \r\nshall, so far as may be, apply as if no such discontinuance or dissolution had taken \r\nplace. \r\n \r\n(2)  Every person, who was, at the time of such discontinuance or \r\ndissolution, a member of such association of persons and the legal representative \r\nof any such person who is deceased, shall be jointly and severally liable for the \r\namount of tax payable by the association of persons. \r\n \r\n98C. Succession to business, otherwise than on death.— (1) Where a person \r\ncarrying on any business or profession has been succeeded in any tax year by any \r\nother person (hereafter in this section referred to as the “predecessor” and \r\n“successor” respectively), otherwise than on the death of the predecessor, and the \r\nsuccessor continues to carry on that business or profession,-  \r\n \r\n(a)  the predecessor shall be liable to pay tax in respect of the income of \r\nthe tax year in which the succession took place upto the date of \r\nsuccession and of the tax year or years preceding that year; and  \r\n \r\n(b)  the successor shall be liable to pay tax  in respect of the income of \r\nsuch tax year after the date of succession.  \r\n \r\n (2)  Notwithstanding anything contained in sub -section (1), where the \r\npredecessor cannot be found, the tax liability in respect of the tax year in which the \r\nsuccession took place u pto the date of succession and of the tax year or years \r\npreceding that year shall be that of the successor in like manner and to the same \r\nextent as it would have been that of the predecessor, and all the provisions of this \r\nOrdinance shall, so far as may be, apply accordingly. \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2003. \r\nChapter V – Provisions Governing Persons ________________ \r\n \r\n168 \r\n \r\n (3)  Where any tax payable under this section in respect of such business \r\nor profession cannot be recovered from the predecessor, it shall be recoverable \r\nfrom the successor, who shall be entitled to recover it from the predecessor.]\r\nChapter VI – Special Industries___________________________ \r\n \r\n169 \r\nCHAPTER VI \r\nSPECIAL INDUSTRIES \r\n \r\nPART I \r\nINSURANCE BUSINESS \r\n \r\n99. Special provisions relating to insurance business.  — The profits and \r\ngains of any insurance business shall be computed in accordance with the rules in \r\nthe Fourth Schedule. \r\n \r\n1[   ] \r\n \r\n2[  ] \r\n \r\n3[99A. Special provisions relating to payment of tax through electricity \r\nconnections. (1) Notwithstanding anything contained in the Ordinance, a tax shall \r\n                                            \r\n1 Inserted by the National Assembly Secretariat’s O.M. No.F.22(2)/2016-Legis dated 29.01.2016.  \r\n2 Section 99A substituted by the Finance Act, 2022. The substituted section read as follows: \r\n“99A. Special provisions relating to traders.-(1) Subject to sub-section (3), tax payable on the profits \r\nand gains of a trader as defined in sub-section (4) who upto thirty first day of December, 2015 has not \r\nfiled a return for any of the preceding ten tax years shall be computed in accordance with the rules laid \r\ndown in Part I of the Ninth Schedule. \r\n(2)  Subject to sub-section (3), tax payable on the profits and gains of any trader as defined \r\nin sub-section (4), who-  \r\n(a)  is a filer; or \r\n(b) is NTN holder and a non-filer  but has filed return or returns in any of the last ten \r\npreceding tax years, shall be computed in accordance with the rules laid down in \r\nPart II of  the Ninth Schedule.  \r\n(3)  Sub-sections (1) and (2) shall apply, if- \r\n(a)  the return filed by the trader qualifies for acceptance in accordance with the rules \r\nlaid down in the Ninth Schedule; \r\n(b)   return relates to tax years 2015 to 2018; and  \r\n(c) income from business consists of profits and  gains from trading activity only. \r\n(4) For the purpose of this section and the Ninth Schedule, ‘trader’ means an individual or \r\nan association of persons (AOP) buying goods or merchandise and selling the same without further \r\nprocessing and providing, business-related after sales, services by doing repair jobs. \r\n Explanation 1.-  For the removal of doubt it is clarified that any person engaged in- \r\n(a) rendering of, or providing, services as defined in clause (ii) of sub-section (7) of section 153; or \r\n(b) business of retailer falling under rule (5) of Chapter II of the Sales Tax Special Procedures Rules, \r\n2007, shall not be treated as a trader for the purposes of this section. \r\nExplanation 2.- It is also clarified that this section shall not apply to a person who is a Member of \r\nthe Senate of Pakistan, the National Assembly of Pakistan or a Provincial Assembly.”] \r\n3 Section 99A substituted and shall be deemed to have been so substituted from 1st day of July, 2022 \r\nby the Tax Laws (Amendment) Act, 2023 (XVI of 2023) dated 20.04. 2023. Earlier this section was \r\nsubstituted through Tax Laws (Second Amendment) Ordinance, 2022 (VI of 2022) dated 22.08.2022. \r\nThe substituted section read as follows: \r\n“99A. Special provisions relating to payment of tax through electricity connections .– (1) \r\nNotwithstanding anything contained in the Ordinance, a tax shall be charged and collected from \r\nretailers other than Tier-I retailers as defined in Sales Tax Act, 1990 (VII of 1990) and specified service \r\nChapter VI – Special Industries ___________________________ \r\n \r\n170 \r\n \r\nbe charged and collected from retailers other than Tier-I retailers as defined in the \r\nSales Tax Act, 1990 ( VII of 1990) and specified service providers on commercial \r\nelectricity connections at the rates specified in the income tax general order issued \r\nin terms of sub-section (2). \r\n \r\n(2) For the purposes of this section, the Federal Government or the Board \r\nwith th e approval of the Minister in -charge pursuant to the approval of the \r\nEconomic Coordination Committee of the Cabinet may, issue an income tax \r\ngeneral order to — \r\n \r\n(a) provide the scope, time, payment, recovery, penalty, default \r\nsurcharge, adjustment or refun d of tax payable under this section in \r\nsuch manner and with such conditions as may be specified; \r\n \r\n(b) provide the collection of tax on the amount of bill or on any basis of \r\nconsumption, in addition to or in lieu of advance tax collectible under \r\nsub-section (1) of section 235, at such rates or amounts, from such \r\ndate and with such conditions as may be specified; \r\n \r\n(c) provide record keeping, filing of return, statement and assessment in \r\nsuch manner and with such conditions as may be specified; \r\n \r\n(d) provide me chanism of collection, deduction and payment of tax in \r\nrespect of any person; \r\n \r\n(e) include or exempt any person or classes of persons, any income or \r\nclasses of income from the application of this section, in such manner \r\nand with such conditions as may be specified; and \r\n \r\n(f) provide that tax collected under this section shall in respect of such \r\npersons or classes of persons be adjustable, final or minimum, in \r\n                                            \r\nproviders on commercial electricity connections at the rates provided in clause (2A) of Division IV, Part \r\nIV of the First Schedule.  \r\n(2) A retailer who has paid sales tax under sub -section (9) of section 3 of Sales Tax Act, \r\n1990 (VII of 1990), shall not be required to pay tax under this section and the sales ta x so paid shall \r\nconstitute discharge of tax liability under this section. \r\n(3) The tax collected or paid under this section shall be final tax on the income of persons \r\ncovered under this section in respect of business being carried out from the premises where t he \r\nelectricity connection is installed. \r\n(4) For the purposes of this section, Board with the approval of the Minister in-charge may \r\nissue an income tax general order to- \r\n(a) provide the scope, time, payment, recovery, penalty, default surcharge, adjustment or \r\nrefund of tax payable under this section in such manner and with such conditions as \r\nmay be specified. \r\n(b) provide record keeping, filing of return, statement and assessment in such manner and \r\nwith such conditions as may be specified; \r\n(c) provide mechanism of collection, deduction and payment of tax in respect of any person; \r\nor \r\n(d) include or exempt any person or classes of persons, any income or classes of income \r\nfrom the application of this section, in such manner and with such conditions as may be \r\nspecified.] \r\n  \r\nChapter VI – Special Industries ___________________________ \r\n \r\n171 \r\n \r\nrespect of any income to such extent and with such conditions as \r\nmay be specified. \r\n \r\n(3) The provisio ns of sub -section (1) of section 235 shall apply to the \r\npersons as specified therein unless specifically exempted under the income tax \r\ngeneral order issued under sub-section (2). \r\n \r\n(4) The provisions of section 100BA and rule 1 of the Tenth Schedule \r\nshall not apply to the tax collectible under this section unless specifically provided \r\nin respect of the person or class of persons mentioned in the income tax general \r\norder issued under sub-section (2).] \r\n \r\n1[99B. Special procedure for small traders and shopkeepers:-Notwithstanding \r\nanything contained in this Ordinance the 2[Board with the approval of the Minister-\r\nin-charge] may, by notification in the official Gazette, prescribe special procedure \r\nfor scope and payment of tax, filing of return and assessment in resp ect of such \r\nsmall traders and shopkeepers, in such cities or territories, as may be specified \r\ntherein.] \r\n \r\n3[99C. Special procedure for certain persons. - Notwithstanding anything \r\ncontained in this Ordi nance, the 4[Board with the approval of the Minister -in-\r\ncharge] may, by notification in the official Gazette, prescribe special procedure for \r\nscope and payment of tax, record keeping, filing of return and assessment in \r\nrespect of small businesses, construction businesses, medi cal practitioners, \r\nhospitals, educational institutions and any other sector specified by 5[Board with \r\nthe approval of the Minister -in-charge], in such cities or territories, as may be \r\nspecified therein.] \r\n \r\n6[99D. Additional tax on certai n income, profits and gains. – (1) \r\nNotwithstanding anything contained in this Ordinance or any other law for the time \r\nbeing in force, for any of the last three tax years preceding the tax year 2023 and \r\nonwards, in addition to any tax charged or chargeable, paid or payable under any \r\nof the provisions of this Ordi nance, an additional tax shall be imposed on every \r\nperson being a company who has any income, profit or gains that have arisen due \r\nto any economic factor or factors that resulted in windfall income, profits or gains.  \r\n \r\n(2) The Federal Government may, by notification in the official Gazette, –  \r\n \r\n(a) specify sector or sectors, for which this section applies;  \r\n                                            \r\n1 New Section 99B inserted through Finance Supplementary (Second Amendment) Act, 2019. \r\n2 The words “Federal Government” substituted by the Finance Act, 2021. \r\n3 New section 99C inserted through Finance Act, 2019  \r\n4 The words “Federal Government” substituted by the Finance Act, 2021. \r\n5 The words “Federal Government” substituted by the Finance Act, 2021. \r\n6 New section 99D inserted by the Finance Act, 2023.  \r\nChapter VI – Special Industries ___________________________ \r\n \r\n172 \r\n \r\n(b) determine windfall income, profits or gains and economic factor or \r\nfactors including but not limited to international price fluctuation having \r\nbearing on any commodity price in Pakistan or any sector of the \r\neconomy or difference in income, profit or gains on account of foreign \r\ncurrency fluctuation;  \r\n \r\n(c) provide the rate not exceeding fifty percent of such income, profits or \r\ngains;  \r\n \r\n(d) provide for t he scope, time and payment of tax payable under this \r\nsection in such manner and with such conditions as may be specified \r\nin the notification; and  \r\n \r\n(e) exempt any person or classes of persons, any income or classes of \r\nincome from the application of this se ction, subject to any conditions \r\nas may be specified in the notification.  \r\n \r\n(3) The Federal Government shall place before the National Assembly \r\nthe notification issued under this section within ninety days of the issuance of such \r\nnotification or by the 30th day of June of the financial year, whichever is earlier.] \r\nChapter VI – Special Industries ___________________________ \r\n \r\n173 \r\n \r\nPART II \r\n \r\nOIL, NATURAL GAS AND OTHER MINERAL DEPOSITS \r\n \r\n100. Special provisions relating to the production of oil and natural gas, and \r\nexploration and extraction of other mineral deposits. —(1) Subj ect to sub -\r\nsection (2), the profits and gains from — \r\n \r\n(a) the exploration and production of petroleum including natural \r\ngas and from refineries set up at the Dhodak and Bobi fields; \r\n \r\n(b) the pipeline operations of exploration and production \r\ncompanies; or \r\n \r\n(c) the manufacture and sale of liquefied petroleum gas or \r\ncompressed natural gas, \r\n \r\nand the tax payable thereon shall be computed in accordance with the rules in Part \r\nI of the Fifth Schedule. \r\n \r\n (2) Sub-section (1) shall not apply to the profits and gains a ttributable to \r\nthe production of petroleum including natural gas discovered before the 24 th day \r\nof September, 19541[:] \r\n \r\n2[Provided that the for tax year 2017 and onward the provisions of this \r\nsub-section shall not apply on profit and gains derived from sui gas field.] \r\n \r\n         (3) The profits and gains of any business which consists of, or includes, \r\nthe exploration and extraction of such mineral deposits of a wasting nature (not \r\nbeing petroleum or natural gas) as may be specified in this behalf by the 3[Board \r\nwith the approval of the Minister-in-charge] carried on by a person in Pakistan shall \r\nbe computed in accordance with the rules in Part II of the Fifth Schedule. \r\n  \r\n4[100A. Special provisions relating to banking business. —(1) Subject to sub-\r\nsection (2), the income, profits and gains of any banking company as defined in \r\nclause (7) of section 2 and tax payable thereon shall be computed in accordance \r\nwith the rules in the Seventh Schedule. \r\n \r\n (2) Sub-section (1) shall apply to the profits and gains of the ban king \r\ncompanies relevant to tax year 2009 and onwards. \r\n                                            \r\n1Full stop substituted by the Finance Act 2017. \r\n2Inserted by the Finance Act, 2017. \r\n3 The words “Federal Government” substituted by the Finance Act, 2021. \r\n4Inserted by the Finance Act, 2007. \r\nChapter VI – Special Industries ___________________________ \r\n \r\n174 \r\n \r\n1[(3) Notwithstanding anything contained in sub-section (1), income,  profits  \r\nand  gains  and  tax  payable  thereon  shall  be computed subject to  the limitations \r\nand  provisions contained in Chapters VII and VIII.] \r\n \r\n2[100B. Special provision relating to capital gain tax.— (1) Capital gains on \r\ndisposal of listed securities and tax thereon 3[including super tax under section 4C  \r\n], subject to section 37A, shall be computed, determined, collected and de posited \r\nin accordance with the rules laid down in the Eighth Schedule. \r\n \r\n (2) The provisions of sub –section (1) shall not apply to the following \r\npersons or class of persons, namely:- \r\n \r\n  (a)  a mutual fund; \r\n  \r\n(b)  banking company, a non-banking finance company and an  \r\ninsurance company subject to tax under the Fourth Schedule; \r\n \r\n  (c)  a modaraba;  \r\n \r\n4[(d)  a company, in respect of debt securities only; and] \r\n(e)  any other person or class of persons notified by the Board.] \r\n \r\n5[100BA. Special provisions relating to persons not appear ing in active \r\ntaxpayers’ list. -(1) The collection or deduction of advance income tax, \r\ncomputation of income and tax payable thereon  6[in respect of a person not \r\nappearing on the active taxpayers’ list ] 7[or persons appearing on the act ive \r\ntaxpayers’ list who have not filed return by the due date specified in section 118 \r\nor by the due date as extended under section 119 or 214A]  shall be determined \r\nin accordance with the rules in the Tenth Schedule. \r\n \r\n  (2) The provisions of the Tenth Sche dule shall have effect \r\nnotwithstanding anything to the contrary contained in this Ordinance.]   \r\n  \r\n                                            \r\n1 Added by the Finance Act, 2018. \r\n2 Added by the Finance Act, 2012. \r\n3 Words inserted by the Finance Act, 2023.  \r\n4 Clause (d) substituted by new clause (d) by the Finance Act, 2014. The substituted clause read as  \r\nfollows: \r\n“(d) “a foreign institutional investor” being a person registered with NCCPL as a foreign \r\ninstitutional investor; and”  \r\n5 New section 100BA inserted through Finance Act, 2019.  \r\n6 Words inserted through Finance Act, 2020 dated 30th June, 2020.  \r\n7 Expression inserted by the Finance Act, 2024. \r\nChapter VI – Special Industries ___________________________ \r\n \r\n175 \r\n \r\n1[  ] \r\n \r\n2[100C. Tax credit for charitable organizations.— (1) The persons mentioned in \r\nsub-section (2) shall be allowed a tax credit equal to one hundred perce nt of tax \r\npayable under any of the provisions of this Ordinance including minimum and final \r\n                                            \r\n1 Inserted by the Finance Act, 2014. \r\n2 Section 100C substituted by the Finance Act, 2021. Earlier this substitution was made through Tax \r\nLaws (Second  Amendment) Ordinance, 2021. The substituted section read as follows: \r\n“100C. Tax credit for certain persons.- (1) 2[The income of]Non-profit organizations, trusts or welfare \r\ninstitutions, as mentioned in sub-section (2) shall be allowed a tax credit equal to one hundred per cent \r\nof the tax payable, including minimum tax and final taxes payable under any of the provisions of this \r\nOrdinance, subject to the following conditions, namely:- \r\n(a) return has been filed; \r\n(b) tax required to be deducted or collected has been deducted or collected and paid;2[ ] \r\n(c) withholding tax statements for the immediately preceding tax year have been filed2[;] \r\n2[(d)  the administrative and management expenditure does not exceed 15% of the total receipts: \r\n“Provided that clause (d) shall not apply to a non-profit organization, if— \r\n2[(i) charitable and welfare activities of the non -profit organization have commenced for \r\nthe first time within last three years; and  \r\n(ii)] total receipts of the non -profit organization during the tax year are less than one \r\nhundred million Rupees” 2[;]  \r\n2[(e) approval of Commissioner has been obtained as per the requirement of clause (36) of \r\nsection 2: \r\n  Provided that this clause shall take effect from the first day of July, 2020; 2[  ] \r\n(f) none of the assets of trusts or welfare institutions confers, or may confer, a private benefit \r\nto the donors or family, children or author of the trust or his descendents or the maker of \r\nthe institution or to any other person: \r\nProvided that where such private benefit is conferred, the amount of such benefit s hall be \r\nadded to the income of the donor 2[; and] \r\n(g) a statement of voluntary contributions and donations received in the immediately preceding \r\ntax year has been filed in the prescribed from and manner.] \r\n2[(1A) Notwithstanding anything contained in sub -section (1), surplus funds of non -profit \r\n2[organizations, trusts or welfare institutions] shall be taxed at a rate of ten percent. \r\n(1B)  For the purpose of sub-section (1A), surplus funds mean funds or monies: \r\n(a) not spent on charitable and welfare activities during the tax year; \r\n(b) received during the tax year as donations, voluntary contributions, subscriptions and \r\nother incomes; \r\n(c) which are more than twenty -five percent of the total receipts of the non -profit \r\norganization received during the tax year; and \r\n(d) are not part of restricted funds. \r\n Explanation.- For the purpose of this sub -section, “restricted funds” mean any \r\nfund received by the organization but could not be spent and treated as revenue during \r\nthe year due to any obligation placed by the donor.] \r\n(2) Persons 2[and incomes] eligible for tax credit under this section include- \r\n(a) any income of a trust or welfare institution or non -profit organization from donations, \r\nvoluntary contributions, subscriptions, house property, investments in the securities of \r\nthe Federal Government and so much of the income chargeable under the head \r\n\"income from business\" as is expended in Pakistan for the purposes of carrying out \r\nwelfare activities: \r\nProvided that in the case of income under the head \"income from business\", the \r\nexemption in respect of income under the said head shall not exceed an amount which \r\nbears to the income, under the said head, the same proportion as the said amount \r\nbears to the aggregate of the incomes from the aforesaid sources of income. \r\n \r\nChapter VI – Special Industries ___________________________ \r\n \r\n176 \r\n \r\ntaxes in respect of incomes mentioned in sub-section (3) subject to the conditions \r\nand limitations laid down in subsection (4). \r\n \r\n(2) The provisions of this section shall apply to the following persons, \r\nnamely:— \r\n \r\n(a)  persons specified in 1[  ] clause (66) of Part I of the Second Schedule to \r\nthis Ordinance; \r\n \r\n(b) a trust administered under a scheme approved by the Federal \r\nGovernment and established in Pakistan exclusively for the purposes of \r\n                                            \r\n(b) a trust administered under a scheme approved by the Federal Government in this \r\nbehalf and established in Pakistan exclusively for the purposes of carrying out such \r\nactivities as are for the benefit and welfare of— \r\n \r\n(i) ex-servicemen and serving personnel, including c ivilian employees of the \r\nArmed Forces, and their dependents; or \r\n(ii) ex-employees and serving personnel of the Federal Government or a Provincial \r\nGovernment and their dependents, where the said trust is administered by a \r\ncommittee nominated by the Federal Gover nment or, as the case may be, a \r\nProvincial Government; \r\n(c) 2[  ]  \r\n(d) income of a university or other educational institution being run by a non -profit \r\norganization existing solely for educational purposes and not for purposes of profit;  \r\n(e) any income which is deriv ed from investments in securities of the Federal \r\nGovernment, profit on debt from scheduled banks 2[and microfinance banks], grant \r\nreceived from Federal Government or Provincial Government or District Governments, \r\nforeign grants and house property held unde r trust or other legal obligations wholly, \r\nor in part only, for religious or charitable purposes and is actually applied or finally set \r\napart for application thereto: \r\nProvided that nothing in this clause shall apply to so much of the income as is \r\nnot expended within Pakistan: \r\nProvided further that if any sum out of the amount so set apart is expended \r\noutside Pakistan, it shall be included in the total income of the tax year in which it is \r\nso expended or of the year in which it was set apart, whichever is the greater, and the \r\nprovisions of section 122 shall not apply to any assessment made or to be made in \r\npursuance of this proviso. \r\nExplanation.— Notwithstanding anything contained in the Mussalman Wakf \r\nValidating Act, 1913 (VI of 1913), or any other law for the time being in force or in the \r\ninstrument relating to the trust or the institution, if any amount is set apart, expended \r\nor disbursed for the maintenance and support wholly or partially of the family, children \r\nor descendants of the author of the trust or  the donor or, the maker of the institution \r\nor for his own maintenance and support during his life time or payment to himself or \r\nhis family, children, relations or descendants or for the payment of his or their debts \r\nout of the income from house property dedicated, or if any expenditure is made other \r\nthan for charitable purposes, in each case such expenditure, provision, setting apart, \r\npayment or disbursement shall not be deemed, for the purposes of this clause, to be \r\nfor religious or charitable purposes; or \r\n(f) any income of a religious or charitable institution derived from voluntary contributions \r\napplicable solely to religious or charitable purposes of the institution: \r\nProvided that nothing contained in this clause shall apply to the income of a private \r\nreligious trust which does not ensure for the benefit of the public.”;] \r\n \r\n1 The expression “Table - II of” omitted by the Finance Act, 2025.  \r\nChapter VI – Special Industries ___________________________ \r\n \r\n177 \r\n \r\ncarrying out such activities as are for the welfare of ex -employees and \r\nserving personnel of the Federal Government or a Provincial \r\nGovernment or armed forces including civilian employees of armed \r\nforces and their dependents where t he said trust is administered by a \r\ncommittee nominated by the Federal Government or a Provincial \r\nGovernment; \r\n \r\n(c)  a trust; \r\n \r\n(d) a welfare institution registered with Provincial or Islamabad Capital \r\nTerritory (ICT) social welfare department; \r\n \r\n(e)  a not fo r profit company registered with the Securities and Exchange \r\nCommission of Pakistan under section 42 of the Companies Act, 2017;  \r\n \r\n(f)   a welfare society registered under the provincial or Islamabad Capital \r\nTerritory (ICT) laws related to registration of co-operative societies; \r\n \r\n(g)  a waqf registered under Mussalman Waqf Validating Act, 1913 (VI of \r\n1913) or any other law for the time being in force or in the instrument \r\nrelating to the trust or the institution; \r\n \r\n(h)  a university or education institutions being run by nonprofit organization \r\nexisting solely for educational purposes and not for the purposes of \r\nprofit; \r\n \r\n(i)  a religious or charitable institution for the benefit of public registered \r\nunder any law for the time being in force; and \r\n \r\n(j) international non-governmental organizations (INGOs)  approved by the \r\nFederal Government. \r\n \r\n(3) The following income is eligible for tax credit, namely:— \r\n \r\n(a) income from donations, voluntary contributions and subscriptions; \r\n \r\n(b) income from house property; \r\n \r\n(c) income from investments in the securities of the Federal Government; \r\n \r\n(d) profit on debt from scheduled banks and microfinance banks; \r\n \r\n(e) grant received from Federal, Provincial, Local or foreign Government;  \r\n \r\nChapter VI – Special Industries ___________________________ \r\n \r\n178 \r\n \r\n(f) so much of the income chargeable under the head “income from \r\nbusiness” as is expended in Pakistan for the purposes of carrying out \r\nwelfare activities: \r\n \r\nProvided that in the case of income under the head “income from \r\nbusiness”, only so much of such income shall be eligible for tax credit \r\nunder this section that bears the same proportion as the said amount of \r\nbusiness income bears to the aggregate of income from all sources; and \r\n \r\n(g) any income of the persons mentioned in clauses (a), (b) and (h) of sub - \r\nsection (2) of this section. \r\n \r\n(4) Eligibility for ta x credit shall be subject to the following conditions, \r\nnamely:— \r\n \r\n(a) return has been filed; \r\n \r\n(b) tax required to be deducted or collected has been deducted or collected \r\nand paid; \r\n \r\n(c) withholding tax statements for the relevant tax year have been filed;  \r\n \r\n(d) the administrative and management expenditure does not exceed 15% \r\nof the total receipts: \r\n \r\nProvided that clause (d) shall not apply to a nonprofit organization, if— \r\n \r\n(i) charitable and welfare activities of the non -profit organization have \r\ncommenced for the first time within last three years; or \r\n \r\n(ii) total receipts of the non-profit organization during the tax year are less \r\nthan one hundred million Rupees; \r\n \r\n(e) approval of Commissioner has been obtained as per requirement of \r\nclause (36) of section 2: \r\n \r\nProvided that the condition of approval in respect of persons \r\nmentioned in 1[  ]  clause (66) of Part I of the Second Schedule to this \r\nOrdinance, shall take effect from the first day of July, 2[2023] and the \r\nrequirements of clause (36) of section 2, shall not  be applicable for \r\nearlier years; \r\n \r\n                                            \r\n1 The expression “Table - II of” omitted by the Finance Act, 2025.  \r\n2 The figure 2022 substituted by the Finance Act, 2022. \r\nChapter VI – Special Industries ___________________________ \r\n \r\n179 \r\n \r\n(f)    none of the assets of trusts or welfare institutions confers, or may confer, \r\na private benefit to the donors or family, children or author of the trust or \r\nhis descendants or the maker of the institution or to any other person: \r\n \r\nProvided that where such private benefit is conferred, the amount \r\nof such benefit shall be added to the income of the donor; and \r\n \r\n(g) a statement of voluntary contributions and donations received in the \r\nimmediately preceding tax year has been  filed in the prescribed form \r\nand manner. \r\n \r\n(5) Notwithstanding anything contained in sub -section (1), surplus funds of \r\norganizations to which this section applies shall be taxed at a rate of ten percent.  \r\n \r\n(6) For the purpose of sub -section (5), surplus fun ds mean funds or \r\nmonies— \r\n \r\n(a)  not spent on charitable and welfare activities during the tax year; \r\n \r\n(b) received during the tax year as donations, voluntary contributions, \r\nsubscriptions and other incomes; \r\n \r\n(c)  which are more than twenty-five percent of the total receipts of the non-\r\nprofit organization received during the tax year; and \r\n \r\n(d)  are not part of restricted funds. \r\n \r\nExplanation.—For the purpose of this clause, “restricted funds” mean \r\nany fund received by the organization but could not be spent and treated \r\nas revenue during the year due to any obligation placed by the donor or \r\nfunds received in kind.] \r\n \r\n1[100D. Special provisions relating to builders and developers. – (1) For tax \r\nyear 2020 and onwards, the tax payable by a builder or a developer, as defined in \r\nsub-section (9), who opt to pay tax under this section shall be computed and paid \r\nin accordance with the rules in the Eleventh Schedule on a project by project basis \r\n                                            \r\n1 New section (100D) inserted through Finance Act, 2020 dated 30th June, 2020 \r\nChapter VI – Special Industries ___________________________ \r\n \r\n180 \r\n \r\non the income, profits and gains derived from the sale of buildings or sale of plots, \r\nas the case may be, from – \r\n   \r\n(a) a new project to be completed by the 1[30th day of September, 2023]; or \r\n \r\n(b) an incomplete existing project to be completed by the 2[30th day of \r\nSeptember, 2023]: \r\n \r\n Provided that any income, profits and gains of a builder o r developer \r\nof an incomplete existing project earned up to tax year 2019 3[or tax year \r\n2020, as the case may be ] shall be subject to the provisions of this \r\nOrdinance as were in force prior to the commencement of the Tax Laws \r\n(Amendment) Ordinance, 2020 (Ordinance I of 2020): \r\n   \r\nProvided further that any income of a builders or developer other than \r\nincome, profits and gains subject to this section shall be subject to tax as \r\nper the provisions of this Ordinance.  \r\n \r\n(2) Where sub-section (1) applies,-  \r\n \r\n(a) the income shall not be chargeable to tax under any head of income in \r\ncomputing the taxable income of the person; \r\n \r\n(b) no deduction shall be allowed under this Ordinance for any expenditure \r\nincurred in deriving the income: \r\n \r\n(c) the amount of the income shall not be reduced by – \r\n \r\n(i) any deductible allowance under Part IX of Chapter III: or  \r\n \r\n(ii) the set off of any loss;   \r\n \r\n(d) no tax credit shall be allowed against the tax payable under sub -section \r\n(1) except credit for tax under section 236A or 236K collected from the \r\nbuilder or dev eloper after the commencement of the Tax Law \r\n(Amendment) Ordinance, 2020 (1 of 2020) on purchase of immoveable \r\nproperty utilized in a project; \r\n \r\n                                            \r\n1 The expression “ 30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n2 The expression “30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n3 This expression inserted by the Finance Act, 2021. Earlier this expression was made through Income \r\nTax (Amendment) Ordinance, 2021. \r\nChapter VI – Special Industries ___________________________ \r\n \r\n181 \r\n \r\n(e) there shall be no refund of any tax collected or deducted under this \r\nOrdinance; \r\n \r\n(f) if the tax payable has not been paid or short paid, the said amount of tax \r\nmay be recovered and all the provisions of this Ordinance shall apply \r\naccordingly; and  \r\n \r\n(g) section 113 and 113C shall not apply on the turnover, income, profits and \r\ngains of a builder or developer from a project. \r\n \r\n(3)  The provisions of section 111 shall not apply to capital investment made \r\nin a new project under clause (a) of sub -section (1) in the form of money or land, \r\nsubject to the following conditions, namely:- \r\n \r\n(a) if the investment is made by a builder or developer being an individual-  \r\n \r\n(i) in the form of money, such builder or developer shall open a new \r\nbank account and deposit such amount in it on or before the 1[30th \r\nday of June, 2021]; or \r\n \r\n(ii) in the form of land, such builder or developer shall have the \r\nownership title of the land at the time of commencement of the Tax \r\nLaws (Amendment) Ordinance, 2020 (I of 2020); \r\n \r\n(b) if the investment is made by a person in a project through a company \r\nor an association of persons,-  \r\n \r\n(i) such company or association of person shall be a single object \r\n(builder or developer) company or association of persons registered \r\nunder the Companies Act, 2017 (XIX of 2017), the Limited Liability \r\nPartnership Act, 2017 (XV of 2017) or the Partnership Act  1932 (IX \r\nof 1932), as the case may be,  after the date of commencement of \r\nthe Tax Laws (Amendment) Ordinance, 2020 (I of 2020) and on or \r\nbefore the 2[30th day of June, 2021]; and \r\n    \r\n(ii) the person shall be a member or shareholder of such association of \r\npersons or company, as the case may be; \r\n \r\n  and if the capital investment is made,- \r\n  \r\n                                            \r\n1 The expression “ 31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n2 The expression “ 31st day of December, 2020” substi tuted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\nChapter VI – Special Industries ___________________________ \r\n \r\n182 \r\n \r\n(i) in the form of money, such amount shall be invested through a \r\ncrossed banking instrument deposited in the bank account of \r\nsuch association of persons or company, as the case may be, \r\nno or before the 1[30th day of June, 2021]; or \r\n \r\n(ii) in the form of land, such land shall be transferred to such \r\nassociation of persons or company, as the case may be, on or \r\nbefore the 2[30th day of June, 2021]: \r\n  \r\n Provided that the person shall have the ownership title of the \r\nland at the time of commencement of the Tax Laws \r\n(Amendment) Ordinance, 2020 (I of 2020) \r\n \r\n(c) a person making an investment under clause (a) or (b) shall submit a \r\nprescribed form on Iris web portal 3[by 30th day of June, 2021]; \r\n \r\n(d) the money or land invested under clause (a) or (b) shall be wholly utilized \r\nin a project; and  \r\n \r\n(e) completion of the project shall be certified in the following manner, \r\nnamely:- \r\n \r\n(i) in case of a builder, the ma p approving authority or NESPAK \r\nshall certify that grey structure as per the appr oved map has \r\nbeen completed by the builder on or before the 4[30th day of \r\nSeptember, 2023]; and \r\n \r\n(ii) in case of a develop,- \r\n  \r\n(A) the map approving authority or NESPAK shall certify that \r\nlandscaping has been completed on or before the 5[30th day \r\nof September, 2023]; \r\n \r\n(B) a firm of chartered accountants having an ICAP QCR rating \r\nof ‘satisfactory’, notified by the Board for this purpose, shall \r\n                                            \r\n1 The expression “ 31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n2 The expression “ 31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n3 The expression inserted by the Finance Act, 2021. Earlier this insertion was made through Income \r\nTax (Amendment) Ordinance, 2021. \r\n4 The expression “ 30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n5 The expression “ 30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\nChapter VI – Special Industries ___________________________ \r\n \r\n183 \r\n \r\ncertify that at least 50% of the plots have been booked for \r\nsale and at least 40% of the sale proceeds have been \r\nreceived by the 1[30th day of September, 2023]; and \r\n \r\n(C) at least 50% of the roads have been laid up to sub -grade \r\nlevel as certified by the approving authority of NESPAK. \r\n \r\n(4) The provisions of section 111 shall also not apply to.- \r\n \r\n(a) the first purchaser of a building or a unit of the building purchased from \r\nthe builder in respect of purchase price of the building or unit of the \r\nbuilding subject to the following conditions, namely:- \r\n \r\n(i) full payment is made through a crossed banking instrument to \r\nthe builder during a period starting from the date of registration \r\nof the project with the Board under this section and ending on \r\nthe 2[31st day of March, 2023] , in case the purchase is from a  \r\nnew project; and \r\n \r\n(ii) full or balance amount of payment is made through a crossed \r\nbanking instrument to the builder during a period starting from \r\nthe date of registration of the project with the Board under this \r\nsection and ending on the 3[31st day of March, 2023] , in case \r\nthe purchase is from an existing incomplete project; and \r\n \r\n(b) the purchaser of a plot who intends to construct a building thereon, if-  \r\n \r\n(i) the purchase is made on a before the 4[30th day of June, 2021]; \r\n(ii) the full payment is made on or before the 5[30th day of June, \r\n2021] through a crossed banking instrument; \r\n(iii) construction on su ch plot is commenced on or before the 6[31st \r\nday of December, 2021]; \r\n                                            \r\n1 The expression “ 30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n2 The expression “ 30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n3 The expression “ 30th day of Sept ember, 2022” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n4 The expression “ 31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021.. \r\n5 The expression “ 31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n6 The expression “ 31st day of December, 2020” ” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\nChapter VI – Special Industries ___________________________ \r\n \r\n184 \r\n \r\n(iv) such construction is completed on or before the 1[30th day of \r\nSeptember, 2023]; and \r\n \r\n(v) the person registers himself with the Board on the online Iris \r\nwerb portal. \r\n \r\n(5) Where sub -section (3) or (4) apply, the value or price of land or \r\nbuilding, as the case may be, shall be the higher of clause (a) or (b) below:- \r\n \r\n(a) 130% of the fair market value as determined by the Board under sub -\r\nsection (4) of section 68; or \r\n \r\n(b) at the option of the person making investment, the lower of the values \r\nas determined by at least two independent value rs from the list of \r\nvaluers approved by the State Bank of Pakistan. \r\n \r\n(6) Sub-sections (3) and (4) shall not apply to -  \r\n \r\n(a) holder of any public office as defined in the Voluntar y Declaration of \r\nDomestic Assets Act, 2018 or his benamidar as defined in the Benami \r\nTransactions (Prohibition) Act, 2017 (V of 2017) or his spouse or \r\ndependents; \r\n \r\n(b) a public listed company, a real estate investment trust or a company \r\nwhose income is exempt under any provision of this Ordinance; or \r\n \r\n(c) any proceeds derived from the commission of a criminal offence \r\nincluding the crimes of money laundering extortion or terror financing \r\nbut excluding the offences under this Ordinance. \r\n \r\n(7) Divided income paid to a person by a builder or developer being a \r\ncompany out of the profits and gains derived from a project shall be exempt from \r\ntax. \r\n \r\n(8) Notwithstanding anything contained in this section or the Eleventh \r\nSchedule, where a return or declaration has been made through misrepresentation \r\nor suppression of facts, such return or declaration shall be void and all the \r\nprovisions of this Ordinance shall apply: \r\n  \r\n   Provided that no action under this sub -section shall be taken if such \r\nmisrepresentation has been made on account of a bona fide mistake: \r\n   \r\n                                            \r\n1 The expression “ 30th day of September, 2022” ” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\nChapter VI – Special Industries ___________________________ \r\n \r\n185 \r\n \r\n   Provided further that no action under this sub -section shall be taken \r\nwithout providing an opportunity of being heard and without prior approval of \r\nthe Board. \r\n \r\n(9) In this section.- \r\n \r\n(a) “builder” means a person who is regist ered as a builder with the Board \r\nand is engaged in the construction and disposal of residential or \r\ncommercial buildings; \r\n \r\n(b) “capital investment” means investment as equity resources and does not \r\ninclude borrowed funds; \r\n \r\n(c) “developer” means a person who is regi stered as a developer with the \r\nBoard and is engaged in the development of land in the form of plots of \r\nany kind either for itself or otherwise; \r\n \r\n(d) “existing project” means a construction or development project, which- \r\n \r\n(i) has commenced before the date of commen cement of the Tax Laws \r\n(Amendment) Ordinance, 2020; \r\n \r\n(ii) is incomplete; \r\n \r\n(iii) is completed on or before the 1[30th day of September, 2023];and \r\n \r\n(iv) a declaration is provided in the registration from under Eleventh \r\nSchedule to the effect of percentage of  the project completed up to \r\nthe last day of  the accounting period pertaining to tax year 2019  2[or \r\ntax year 2020 at the option of the taxpayer]; \r\n  \r\n(e) “first purchaser” means a person who purchases a building or a unit, as \r\nthe case may be, directly from the builder and does not include a \r\nsubsequent or a substituted purchaser; \r\n \r\n(f) “new project” means a construction or development project, which- \r\n \r\n(i)  is commenced during the period starting from the date of \r\ncommencement of the Tax Laws (Amendment) Ordinance, \r\n2020 and ending on the 3[31st day of December, 2021]; and  \r\n                                            \r\n1 The expression “ 30th day of September, 2022” ” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n2 This expression inserted ” by the Finance Act, 2021. Earlier this insertion was made through Income \r\nTax (Amendment) Ordinance, 2021. \r\n3 The expression “ 31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\nChapter VI – Special Industries ___________________________ \r\n \r\n186 \r\n \r\n(ii) is competed on or before the 1[30th day of September, 2023]; \r\n \r\n(g) “project” means a project for construction of a building with the object of \r\ndisposal, or a project for development of land into plots with the object \r\nof disposal or otherwise; \r\n \r\n(h) “registered with the Board” means registered after submission of form \r\non project-by-project basis on the online Iris web portal; \r\n \r\n(10) The provisions of the Ordinance not specifically dealt with in this \r\nsection or the rules made thereunder shall apply mutatis mutandis to builders and \r\ndevelopers in so far as they are not inconsistent with this section or the rules made \r\nthereunder.]  \r\n \r\n2[100E. Special provisions relating to small and medium enterprises. — (1) \r\nFor tax year 2021 and onwards, the tax payable by a small and medium enterprise \r\nas defined in clause (59A) of section 2 shall be computed and paid in accordance \r\nwith rules made under the Fourteenth Schedule.  \r\n \r\n(2) The Board may prescribe a simplified return for a s mall and medium \r\nenterprise.]   \r\n \r\n3[   ] \r\n                                            \r\n1 The expression “30th day of September, 2022” ” substituted by the Finance Act, 2021. Earlier the \r\nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \r\n2 Section 100E inserted by the Finance Act, 2021. \r\n3 Section 100F shall be omitted and shall be deemed to have been omitted with effect from 02nd March, \r\n2022 by the Finance Act, 2022. The omitted section read as follows: \r\n\"100F. Special provisions relating to investment for industrial promotion. — (1) Any eligible \r\nperson may file a statement by the 3 0th September, 2022, declaring therein the amount of funds \r\n(which have not been declared in any of the returns of income upto tax year 2021 filed by the 31 st \r\nDecember, 2021) for investment in a new company formed for establishing and operating an \r\nindustrial undertaking in accordance with this section:  \r\nProvided that the funds referred to in sub -section (I) shall be deposited in rupees in a \r\ndedicated bank account in Pakistan as equity of the newly formed company, incorporated under the \r\nCompanies Act, 2017 (XIX of 2017), before the filing of the statement and such funds shall only be \r\nused for purchase or import of plant and machinery through letter of credit or for construction of \r\nbuilding and structure for the industrial undertaking:  \r\nProvided further that th e minimum amount which would qualify for the purposes of this \r\nsection shall be fifty million rupees.  \r\n(2) The provisions of section 111 shall not apply to the funds declared under sub-section (I) \r\nsubject to fulfilment of conditions as laid down in this section and payment of an amount equal to five \r\npercent thereof along with the statement filed under sub-section (1).  \r\n(3) The new industrial undertaking in which such investment is made shall commence \r\ncommercial production by the 30 th June, 2024 and a certifi cate to that effect, duly issued by  \r\nEngineering Development Board, is submitted to the Commissioner along with the return filed for tax \r\nyear 2024.  \r\n(4) Any amount of tax paid under this section shall not be refundable or adjustable against \r\nany other tax liability of the declarant.  \r\nChapter VI – Special Industries ___________________________ \r\n \r\n187 \r\n \r\n                                            \r\n(5) Where a declarant has paid tax under this section in respect of funds declared under sub -\r\nsection (I), the declarant shall be entitled to incorporate the same in his wealth statement, financial \r\nstatements or books of accounts, as the case may be.  \r\n(6) For the purposes of this section, eligible person means all persons, except–  \r\n(a) holders of' public office, their spouses and dependent children;  \r\n(b) a public company as defined in clause (47) of section 2 of this Ordinance;  \r\n(c)  a person who has filed a declaration under the Voluntary Declaration of   Domestic \r\nAssets Act, 2018, the Foreign Assets (Declaration and Repatriation) Act, 2018, or the Assets \r\nDeclaration Act, 2019;  \r\n(d) a person that has been declared a bank loan defau lter by a bank or a financial institution \r\nwithin the last three years; or  \r\n(e) a director of a company who has been declared a bank loan defaulter by a bank or a financial \r\ninstitution within the last three years.  \r\n(7) The provisions of this section shall not apply to —  \r\n(a) any proceeds of crime, corruption, money laundering and terror financing;  \r\n(b)  any amount which is subject of any departmental or court proceedings; \r\n(c)  the investments made in following sectors, namely:—  \r\n(i)   arms and ammunitions; \r\n(ii)  explosives; \r\n(i) sugar;  \r\n(ii) cigarettes;  \r\n(iii) aerated beverages;  \r\n(iv) flour mills;  \r\n(v) vegetable ghee; and \r\n(vi) cooking oil manufacturing excluding extraction units.  \r\n(8) Notwithstanding the provisions of any other law for the time being in force including sub -\r\nsection (3) of section 216 of this Ordinance excluding clauses (a) and (g) of sub-section (3) thereof, \r\nthe National Accountability Ordinance, 1999 (XVIII of 1999), the Federal Investigation Agency Act, \r\n1974 (VIII of 1975) and the Right of Access to Information Act, 2017 (XXXI V of 2017), particulars of \r\nany person making a statement under this section or any information received in any statement made \r\nunder this section shall be confidential.  \r\n(9) The statement filed under sub-section (1) shall not be valid, if—  \r\n(a) the ne wly formed industrial undertaking company fails to prove commercial production in \r\nterms of sub-section (3);  \r\n(b) there is change in ownership of industrial undertaking company prior to the 30th June, 2026; \r\nor \r\n(c) the newly formed industrial undertaking company disposes of any of its assets prior to the \r\n30th June, 2026.  \r\n(10) Notwithstanding anything contained in this section, where the provisions of sub-section (7) \r\nor (9) apply, or where the statement under sub -section (I) has been made by misrepresentation  or \r\nsuppression of facts, such statement shall be void as if it had never been made and all the provisions \r\nof this Ordinance shall apply accordingly:  \r\nProvided that the Commissioner shall not take any action under this section without providing \r\nthe declarant an opportunity of being heard.  \r\n(11) The statement filed under this section shall be made in the form and manner as specified \r\nby the Board through a notification in the official Gazette.  \r\n(12) The provisions of this section shall apply, mutatis mutandis, to an existing company being \r\nan industrial undertaking, for investment in expansion and modernization from amount of funds \r\n(which have not been declared in any of the returns of income upto tax year 2021 filed by the 31 st \r\nDecember, 2021):  \r\nProvided that such company opens a dedicated bank account to deposit the said funds before \r\nthe filing of the statement and such funds shall only be used for expansion and modernization by \r\nway of purchase or import of plant and machinery including IT hardware through let ter of credit, \r\nor software and IT services or for construction of building and structure for the manufacturing \r\npremises of the existing industrial undertaking:  \r\nChapter VI – Special Industries ___________________________ \r\n \r\n188 \r\n \r\n \r\n                                            \r\nProvided further that the expansion and modernization shall be completed by the 30 th June, \r\n2024, and a certificate to that effect, duly issued by the Engineering Development Board, is \r\nsubmitted to the Commissioner along with the return filed for tax year 2024.  \r\n(13) In this section, unless there is anything repugnant in the subject or context,—  \r\n(a) \"declarant\" means a person filing a statement under sub-section (1);  \r\n(b)  \"holder of public office\" means a person as defined in the Voluntary Declaration of Domestic \r\nAssets Act, 2018;  \r\n(c)   \"industrial undertaking\" means a company being a new industrial undertaking setup for the \r\npurpose of this section and is not established by the splitting up or reconstruction or reconstitution \r\nof an undertaking already in existence or by transfer of machinery or plant from an existing \r\nindustrial undertaking established in Pakistan;  \r\n(d) \"investment\" means investment in equity and does not include borrowed funds and \r\ninvestment in land; and  \r\n(e) \"modernization\" includes acquisition or upgradation of IT hardware, software and IT \r\nservices.\";  \r\n \r\nChapter VII – International_______________________________ \r\n \r\n189 \r\nCHAPTER VII \r\nINTERNATIONAL \r\n \r\nPART I \r\nGEOGRAPHICAL SOURCE OF INCOME \r\n \r\n101. Geographical source of income.  — (1) Salary shall be Pakistan -source \r\nincome to the extent to which the salary — \r\n \r\n(a) is received from any employm ent exercised in Pakistan, \r\nwherever paid; or \r\n \r\n(b) is paid by, or on behalf of, the Federal Government, a Provincial \r\nGovernment, or a 1[Local Government] in Pakistan, wherever \r\nthe employment is exercised. \r\n \r\n(2) Business income of a resident person shall be P akistan-source \r\nincome to the extent to which the income is derived from any business carried on \r\nin Pakistan.  \r\n \r\n(3) Business income of a non -resident person shall be Pakistan -source \r\nincome to the extent to which it is directly or indirectly attributable to – \r\n \r\n(a) a permanent establishment of the non -resident person in \r\nPakistan;  \r\n \r\n(b) sales in Pakistan of goods  merchandise of the same or similar \r\nkind as those sold by the person through a permanent \r\nestablishment in Pakistan; 2[  ] \r\n \r\n(c) other business activiti es carried on in Pakistan of the same or \r\nsimilar kind as those effected by the non -resident through a \r\npermanent establishment in Pakistan 3[; or] \r\n \r\n4[(d)  any business connection in Pakistan 5[; or] \r\n                                            \r\n1The words “local authority” substituted by the Finance Act, 2008. \r\n2 The word “or” omitted by the Finance Act, 2003. \r\n3 Full stop substituted by the Finance Act, 2003. \r\n4 Inserted by the Finance Act, 2003. \r\n5Full stop substituted by the Finance Act, 2018. \r\n \r\nChapter VII – International_______________________________ \r\n \r\n190 \r\n \r\n1[(e) import of goods, whether or not the title to the goo ds passes outside  \r\n Pakistan, if the import is part of an overall arrangement for the supply of \r\ngoods, installation, construction, assembly,  commission, guarantees\r\n or supervisory   activities   and   all   or   principal   activities are undertaken  \r\nor  performed  either  by  the  associates  of  the person supplying the goods \r\nor its permanent establishment, whether  or  not  the  goods  are  imported  \r\nin  the  name  of  the person, associate of the person or any other person.  \r\n \r\nExplanation.—For  the  removal  of  doubt,  it  is  clarified  that where the \r\nincome is subject to taxation under sections 5A, 5AA, 6, 7 and 7A, the income \r\nshall not be chargeable to tax under the head income from business.”]  \r\n \r\n2[(3A) For the purposes of clause (d) of sub -section (3), business connection in \r\nPakistan shall include “significant economic presence in Pakistan” of a non -\r\nresident.  \r\n \r\n(3B) significant economic presence in Pakistan shall mean –  \r\n \r\n(a) transaction in respect of any goods, services or property carried out \r\nby a non -resident with any person in Pakistan including provision of \r\ndownload of data or software in Pakistan, if the aggregate of payments \r\narising from such transaction or transactions during the tax year \r\nexceeds such amount as may be prescribed; and  \r\n \r\n(b) systematic and continuous soliciting of business activities or engaging \r\nin interaction through digital means with such number of users in \r\nPakistan as may be prescribed, irrespective of whether or not —  \r\n \r\n(i) the agreement for such transactions or activities is si gned in \r\nPakistan;  \r\n(ii) the non -resident has a residence or place of business in \r\nPakistan; or  \r\n(iii) the non-resident renders services in Pakistan:  \r\n \r\nProvided that only so much of income as is attributable to the \r\ntransactions or activities referred to in clause (a) or clause (b) shall be \r\ndeemed to accrue or arise from a business connection in Pakistan.] \r\n \r\n                                            \r\n1Added by the Finance Act, 2018. \r\n2 Sub-sections (3A) and (3B) added by the Finance Act, 2024. \r\nChapter VII – International_______________________________ \r\n \r\n191 \r\n \r\n1[(4) Where the business of a non -resident person comprises the rendering of \r\nindependent services (including professional services and the services of \r\nentertainers and sports persons), the Pakistan -source business income of the \r\nperson shall include [in addition to any amounts treated as Pakistan-source income \r\nunder sub -section (3)] any remuneration derived by the person where the \r\nremuneration is paid by a resident person or borne by a permanent establishment \r\nin Pakistan of a non-resident person.] \r\n \r\n (5) Any gain from the disposal of any asset or property used in deriving \r\nany business income referred to in sub -section (2), (3) or (4) shall be Pakistan -\r\nsource income. \r\n \r\n (6) A dividend shall be Pakistan-source income if it is 2[—] \r\n \r\n  3[( a)  paid by a resident company; or] \r\n \r\n4[(b)  dividend as per provisions of sub -clause (f) of clause (19) of \r\nsection 2.] \r\n (7) Profit on debt shall be Pakistan-source income if it is — \r\n \r\n(a) paid by a resident person, except where the profit is payable in \r\nrespect of any debt used for the purposes of a business carried \r\non by the resident outside Pakistan through a permanent \r\nestablishment; or \r\n \r\n(b) borne by a permanent establishment in Pak istan of a non -\r\nresident person. \r\n \r\n (8) A royalty shall be Pakistan-source income if it is — \r\n \r\n(a) paid by a resident person, except where the royalty is payable \r\nin respect of any right, property, or information used, or services \r\nutilised for the purposes of a business carried on by the resident \r\noutside Pakistan through a permanent establishment; or \r\n \r\n                                            \r\n1 Sub-section (4) substituted by the Finance Act, 2003. The substituted sub-section (4) read as \r\nfollows: - \r\n“(4) Where the business of a non-resident person comprises the rendering of independent \r\nservices (including professional services and the services of entertainers and sports -persons), the \r\nPakistan-source business income of the person shall include (in addition to any amounts treated as \r\nPakistan-source income under sub-section (3)) any remuneration derived by the person where – \r\n(a) the remuneration is paid by a resident person or borne by a permanent \r\nestablishment in Pakistan of a non-resident; person; and \r\n(b) the aggregate gross amount (before deduction of expenses) of the \r\nremuneration is sixty thousand rupees or more.” \r\n2 The words and full stop “paid by a resident company.” substituted by the Finance Act, 2012. \r\n3Added by the Finance Act, 2012. \r\n4Added by the Finance Act, 2012. \r\n \r\nChapter VII – International_______________________________ \r\n \r\n192 \r\n \r\n(b) borne by a permanent establishment in Pakistan of a non -\r\nresident person. \r\n \r\n (9) Rental income shall be Pakistan -source income if it is derived from \r\nthe lease of immovable property in Pakistan whether improved or not, or from any \r\nother interest in or over immovable property, including a right to explore for, or \r\nexploit, natural resources in Pakistan.  \r\n \r\n (10)  Any gain from the alienation of any property or right referred to in sub-\r\nsection (9) or from the alienation of any share in a company the assets of which \r\nconsist wholly or principally, directly or indirectly, of property or rights referred to in \r\nsub-section (9) shall be Pakistan-source income. \r\n \r\n (11)  A pension or annuity shall be Pakistan -source income if it is paid by \r\na resident or borne by a permanent establishment in Pakistan of a non -resident \r\nperson. \r\n \r\n (12)  A technical fee shall be Pakistan-source income if it is – \r\n \r\n(a) paid by a resident person, except where the fee is payable in \r\nrespect of services utilised in a business carried on by the resident \r\noutside Pakistan through a permanent establishment; or \r\n \r\n(b) borne by a permanent establishment in Pakistan of a non -\r\nresident person. \r\n \r\n1[(12A)    A fee for offshore digital services shall be Pakistan- source income, if \r\nit is – \r\n \r\n(a) paid by a resident person, except where the fee is payable in respect  \r\nof  services  utilised  in  a  business  carried  on  by the resident\r\n outside Pakistan through a permanent establishment; or \r\n \r\n(b) borne  by  a  permanent  establishment  in  Pakistan  of  a   non-\r\nresident person.] \r\n \r\n (13)  Any gain arising on the disposal of shares in a resident company shall \r\nbe Pakistan-source income. \r\n \r\n2[(13A).Any amount paid on account of insurance  or re-insurance premium \r\nby an insurance company to an overseas insurance or re-insurance company shall \r\nbe deemed to be Pakistan source income.] \r\n \r\n (14)  Any amount not mentioned in the preceding sub -sections shall be \r\nPakistan-source income if it is paid by a resident person or borne by a permanent \r\nestablishment in Pakistan of a non-resident person.  \r\n \r\n                                            \r\n1Inserted  by the Finance Act, 2018. \r\n2Inserted by the Finance Act, 2008. \r\nChapter VII – International_______________________________ \r\n \r\n193 \r\n \r\n (15)  Where an amount may be dealt with under sub-section (3) and under \r\nanother sub-section (other than sub-section (14)), this section shall apply— \r\n \r\n(a) by f irst determining whether the amount is Pakistan -source \r\nincome under that other sub-section; and \r\n \r\n(b) if the amount is not Pakistan -source income under that sub -\r\nsection, then determining whether it is Pakistan -source income \r\nunder sub-section (3).  \r\n \r\n (16) An amount shall be foreign -source income to the extent to which it is \r\nnot Pakistan-source income. \r\n \r\n  \r\nChapter VII – International_______________________________ \r\n \r\n194 \r\n \r\n1[101A. Gain on disposal of assets outside Pakistan. — (1) Any gain from the \r\ndisposal or alienation outside Pakistan of an asset located in Pakistan of a non -\r\nresident company shall be Pakistan-source. \r\n(2) The gain under sub -section (1) shall be chargeable to tax at the rate \r\nand in the manner as specified in sub-section (10). \r\n(3) Where  the  asset  is  any  share  or  interest  in  a  non -resident \r\ncompany, the asset shall be treated to be located in Pakistan, if ─ \r\n \r\n(a) the  share  or  interest derives,  directly or  indirectly,  its  value \r\nwholly or principally from the assets located in Pakistan; and \r\n \r\n(b) shares or  interest  representing ten per  cent or  more of  the \r\nshare  capital  of  the  non -resident  company  are  disposed  or \r\nalienated. \r\n(4) The share or interest, as mentioned in sub -section (3), shall  be  \r\ntreated  to  derive  its  value  principally  from  the  assets  located  in  Pakistan, if \r\non the last  day of the tax year preceding the date of transfer ofa  share  or  an  \r\ninterest,  the  value  of  such  assets  exceeds  one  hundred million Rupees and \r\nrepresents at least fifty per cent of the value of all the assets owned by the     non-\r\nresident company. \r\n \r\n(5) Notwithstanding  the  provisions  of  section  68,  the  value  as \r\nmentioned  in  sub -section  (4)  shall  be  the  fair  market  value,  as  may  be \r\nprescribed, for the purpose of this section without reduction of liabilities.  \r\n \r\n(6) Where  the  ent ire  assets  by  the  non -resident  company  are not  \r\nlocated  in  Pakistan,  the  income  of  the  non -resident  company,  from disposal \r\nor alienation outside Pakistan of a share of, or interest in, such non -resident  \r\ncompany  shall  be  treated  to  be  located  in  Pakistan,  to  the extent  it  is  \r\nreasonably  attributable  to  assets  located  in  Pakistan  and determined as may \r\nbe prescribed. \r\n \r\n(7) Where the asset of a non -resident company derives, directly  or  \r\nindirectly,  its  value  wholly  or  prin cipally  from  the  assets  located  in Pakistan \r\nand the non-resident company holds, directly or indirectly, such assets through a \r\nresident company, such resident company shall, for the purposes of determination \r\n                                            \r\n1Inserted by the finance Act 2018. \r\nChapter VII – International_______________________________ \r\n \r\n195 \r\n \r\nof gain and tax thereon under sub -section (8)or, as the case may be, sub -section \r\n(9), shall furnish to the Commissioner within sixty days of the transaction of  \r\n disposal or alienation of the asset by the non -resident company, the \r\nprescribed information or documents, in a statement as may be prescribed: \r\n \r\nProvided that the Commissioner may, by notice in writing, require the  \r\nresident  company,  to  furnish  information,  documents  and  statement \r\nwithin a period of less than sixty days as specified in the notice. \r\n \r\n(8) The person acquiring the asset fro m the non -resident person shall \r\ndeduct tax from the gross amount paid as consideration for the asset at the rate of \r\nten percent of the fair market value of the asset and shall be paid to the  \r\nCommissioner by way of credit to the Federal Government through r emittance to \r\nthe Government Treasury or deposit in an authorized branch of the State Bank of \r\nPakistan or the National Bank of Pakistan, within fifteen days of the payment to the \r\nnon-resident. \r\n \r\n(9) The resident company as referred to in sub -section (7) shal l collect \r\nadvance tax as computed in sub -section (10) from the non -resident company \r\nwithin thirty days of the transaction of disposal or alienation of the asset by such \r\nnon-resident company: \r\n \r\nProvided  that  where  the  tax  has  been  deducted  and  paid  by  the \r\nperson  acquiring  the  asset  from  the  non -resident  person  under  sub - \r\nsection (8), the said tax shall be treated as tax collected and paid under this \r\nChapter VII – International_______________________________ \r\n \r\n196 \r\n \r\nsub-section and shall be allowed a tax credit for that tax in computing the \r\ntax under sub-section (10). \r\n \r\n(10) The tax to be collected under sub-section (9) shall be the higher of ─ \r\n \r\n(a) 20% of A, where A – fair market value less cost of acquisition of the \r\nasset; or \r\n \r\n(b) 10% of the fair market value of the asset. \r\n \r\n(11) Where tax has been paid under sub-section (8) or (9), no tax shall be \r\npayable by the non -resident company in respect of gain under sub -section (8) of \r\nsection 22 or capital gains under section 37 or 37A. \r\n(12) Where any gain is taxable under this section and also under any other \r\nprovision of this Ordinance, the said gain shall be taxable under other provision of \r\nthe Ordinance.] \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\nChapter VII – International_______________________________ \r\n \r\n197 \r\n \r\nPART II \r\nTAXATION OF FOREIGN-SOURCE INCOME OF RESIDENTS  \r\n \r\n102.  Foreign source salary of resident individuals.— (1)  Any foreign-source \r\nsalary received by a resident individual shall be exempt from tax if the individual \r\nhas paid foreign income tax in respect of the salary. \r\n \r\n (2) A resident individual shall be treated as having paid foreign income \r\ntax in respect of foreign-source salary if tax ha s been withheld from the salary by \r\nthe individual’s employer and paid to the revenue authority of the foreign country \r\nin which the employment was exercised. \r\n \r\n103.  Foreign tax credit.— (1)  Where a resident taxpayer derives foreign source \r\nincome chargeable to tax under this Ordinance in respect of which the taxpayer \r\nhas paid foreign income tax, the taxpayer shall be allowed a tax credit of an amount \r\nequal to the lesser of – \r\n \r\n(a) the foreign income tax paid; or \r\n \r\n(b) the Pakistan tax payable in respect of the income.  \r\n  \r\n(2) For the purposes of clause (b) of sub -section (1), the Pakistan tax \r\npayable in respect of foreign source income derived by a taxpayer in a tax year \r\nshall be computed by applying the average rate of Pakistan income tax applicable \r\nto the taxpayer for the year against the taxpayer’s net foreign -source income for \r\nthe year. \r\n \r\n (3) Where, in a tax year, a taxpayer has foreign income under more than \r\none head of income, this section shall apply separately to each head of income.  \r\n \r\n (4) For the purpos es of sub -section (3), income derived by a taxpayer \r\nfrom carrying on a speculation business shall be treated as a separate head of \r\nincome. \r\n \r\n (5) The tax credit allowed under this section shall be applied in \r\naccordance with sub-section (3) of section 4. \r\n \r\n (6) Any tax credit or part of a tax credit allowed under this section for a \r\ntax year that is not credited under sub-section (3) of section 4 shall not be refunded, \r\ncarried back to the preceding tax year, or carried forward to the following tax year. \r\n \r\n (7) A credit shall be allowed under this section only if the foreign income \r\ntax is paid within two years after the end of the tax year in which the foreign income \r\nto which the tax relates was derived by the resident taxpayer. \r\n \r\nChapter VII – International_______________________________ \r\n \r\n198 \r\n \r\n (8) In this section,— \r\n“average rate of Pakistan income tax” in relation to a taxpayer for a \r\ntax year, means the percentage that the Pakistani income tax (before \r\nallowance of the tax credit under this section) is of the taxable income \r\nof the taxpayer for the year; \r\n \r\n“foreign income tax” includes a foreign withholding tax; and   \r\n \r\n“net foreign-source income” in relation to a taxpayer for a tax year, \r\nmeans the total foreign-source income of the taxpayer charged to tax \r\nin the year, as reduced by any deductions allowed to the taxpayer \r\nunder this Ordinance for the year that – \r\n \r\n(a) relate exclusively to the derivation of the foreign-source income; \r\nand  \r\n \r\n(b) are reasonably related to the derivation of foreign -source \r\nincome in accordance with sub-section (1) of section 67 and any \r\nrules made for the purposes of that section. \r\n \r\n104.  Foreign losses. — (1)  Deductible expenditures incurred by a person in \r\nderiving foreign-source income chargeable to tax under a head of income shall be \r\ndeductible only against that income.  \r\n \r\n (2) If the total deductible expend itures referred to in sub -section (1) \r\nexceed the total foreign source income for a tax year chargeable to tax under a \r\nhead of income (hereinafter referred to as a “foreign loss”), the foreign loss shall \r\nbe carried forward to the following tax year and set off against the foreign source \r\nincome chargeable to tax under that head in that year, and so on, but no foreign \r\nloss shall be carried forward to more than six tax years immediately succeeding \r\nthe tax year for which the loss was computed.  \r\n \r\n (3) Where a taxpayer has a foreign loss carried forward for more than one \r\ntax year, the loss for the earliest year shall be set off first. \r\n \r\n (4) Section 67 shall apply for the purposes of this section on the basis \r\nthat — \r\n \r\n(a) income from carrying on a speculation busines s is a separate \r\nhead of income; and \r\n \r\n(b) foreign source income chargeable under a head of income \r\n(including the head specified in clause (a)) shall be a separate \r\nhead of income. \r\n \r\nChapter VII – International_______________________________ \r\n \r\n199 \r\n \r\nPART III \r\nTAXATION OF NON-RESIDENTS \r\n \r\n105.  Taxation of a permanent establishme nt in Pakistan of a non -resident \r\nperson.— (1)  The following principles shall apply in determining the income of a \r\npermanent establishment in Pakistan of a non -resident person chargeable to tax \r\nunder the head “Income from Business”, namely: — \r\n \r\n(a) The profit of the permanent establishment shall be computed on the \r\nbasis that it is a distinct and separate person engaged in the same or \r\nsimilar activities under the same or similar conditions and dealing \r\nwholly independently with the non -resident person of which  it is a \r\npermanent establishment; \r\n \r\n(b) subject to this Ordinance, there shall be allowed as deductions any \r\nexpenses incurred for the purposes of the business activities of the \r\npermanent establishment including executive and administrative \r\nexpenses so incurred, whether in Pakistan or elsewhere; \r\n \r\n(c) no deduction shall be allowed for amounts paid or payable by the \r\npermanent establishment to its head office or to another permanent \r\nestablishment of the non -resident person (other than towards \r\nreimbursement of actual expenses incurred by the non-resident person \r\nto third parties) by way of: \r\n \r\n  (i) royalties, fees or other similar payments for the use of any tangible \r\nor intangible asset by the permanent establishment; \r\n \r\n (ii) compensation for any services including m anagement services \r\nperformed for the permanent establishment; or \r\n \r\n(iii) profit on debt on moneys lent to the permanent establishment, \r\nexcept in connection with a banking business; and \r\n \r\n(d) no account shall be taken in the determination of the income of a \r\npermanent establishment of amounts charged by the permanent \r\nestablishment to the head office or to another permanent establishment \r\nof the non-resident person (other than towards reimbursement of actual \r\nexpenses incurred by the permanent establishment to thi rd parties) by \r\nway of: \r\n \r\n  (i) royalties, fees or other similar payments for the use of any tangible \r\nor intangible asset; \r\n   \r\nChapter VII – International_______________________________ \r\n \r\n200 \r\n \r\n (ii) compensation for any services including management services \r\nperformed by the permanent establishment; or \r\n \r\n(iii) profit on debt  on moneys lent by the permanent establishment, \r\nexcept in connection with a banking business. \r\n \r\n (2) No deduction shall be allowed in computing the income of a \r\npermanent establishment in Pakistan of a non -resident person chargeable to tax \r\nunder the head “Income from Business” for a tax year for head office expenditure \r\nin excess of the amount as bears to the turnover of the permanent establishment \r\nin Pakistan the same proportion as the non-resident’s total head office expenditure \r\nbears to its worldwide turnover. \r\n \r\n (3) In this section, “head office expenditure” means any executive or \r\ngeneral administration expenditure incurred by the non -resident person outside \r\nPakistan for the purposes of the business of the Pakistan permanent establishment \r\nof the person, including — \r\n \r\n(a) any rent, local rates and taxes excluding any foreign income tax, \r\ncurrent repairs, or insurance against risks of damage or \r\ndestruction outside Pakistan; \r\n \r\n(b) any salary paid to an employee employed by the head office \r\noutside Pakistan; \r\n \r\n(c) any travelling expenditures of such employee; and \r\n \r\n(d) any other expenditures which may be prescribed. \r\n \r\n (4) No deduction shall be allowed in computing the income of a \r\npermanent establishment in Pakistan of a non -resident person chargeable under \r\nthe head “Income from Business” for — \r\n \r\n(a) any profit paid or payable by the non-resident person on debt to \r\nfinance the operations of the permanent establishment; or \r\n \r\n(b) any insurance premium paid or payable by the non -resident \r\nperson in respect of such debt. \r\n \r\n106.  Thin capitalisation. — (1) Where a foreign -controlled resident company \r\n(other than a financial institution 1[or a banking company)] 2[or a branch of a foreign \r\n                                            \r\n1Inserted by the Finance Act, 2002 \r\n2Inserted by the Finance Act, 2008. \r\nChapter VII – International_______________________________ \r\n \r\n201 \r\n \r\ncompany operating in Pakistan,] has a foreign debt-to-foreign equity ratio in excess \r\nof three to one at any time during a tax year, a deduction shall be disallowed for \r\nthe profit on debt paid by the company in that year on that part of the debt which \r\nexceeds the three to one ratio.  \r\n \r\n (2) In this section, — \r\n \r\n“foreign-controlled resident company” means a resident company in \r\nwhich fifty per cent  or more of the underlying ownership of the \r\ncompany is held by a non -resident person (hereinafter referred to as \r\nthe “foreign controller”) either alone or together with an associate or \r\nassociates; \r\n \r\n“foreign debt” i n relation to a foreign -controlled resident company, \r\nmeans the greatest amount, at any time in a tax year, of the sum of \r\nthe following amounts, namely: — \r\n \r\n(a) The balance outstanding at that time on any debt obligation \r\nowed by the foreign -controlled reside nt company to a foreign \r\ncontroller or non-resident associate of the foreign controller on \r\nwhich profit on debt is payable which profit on debt is deductible \r\nto the foreign -controlled resident company and is not taxed \r\nunder this Ordinance or is taxable at a  rate lower than the \r\n1[corporate rate] of tax applicable on assessment to the foreign \r\ncontroller or associate; and \r\n \r\n(b) the balance outstanding at that time on any debt obligation owed \r\nby the foreign -controlled resident company to a person other \r\nthan the f oreign controller or an associate of the foreign \r\ncontroller where that  person has a balance outstanding of a \r\nsimilar amount on a debt obligation owed by the person to the \r\nforeign controller or a non -resident associate of the foreign \r\ncontroller; and \r\n \r\n“foreign equity” in relation to a foreign -controlled resident \r\ncompany and for a tax year, means the sum of the following \r\namounts, namely: — \r\n \r\n(a) The paid-up value of all shares in the company owned by \r\nthe foreign controller or a non -resident associate of the \r\nforeign controller at the beginning of the tax year;  \r\n \r\n(b) so much of the amount standing to the credit of the share \r\npremium account of the company at the beginning of the \r\n                                            \r\n1 The words “corporate tax” substituted by the Finance Act, 2002 \r\nChapter VII – International_______________________________ \r\n \r\n202 \r\n \r\ntax year as the foreign controller or a non -resident \r\nassociate would be entitled to if the company were wound \r\nup at that time; and \r\n \r\n(c) so much of the accumulated profits and asset revaluation \r\nreserves of the company at the beginning of the tax year \r\nas the foreign controller or a non-resident associate of the \r\nforeign controller would be entitled to if the company were \r\nwound up at that time; \r\n \r\nreduced by the sum of the following amounts, namely: — \r\n \r\n (i) the balance outstanding at the beginning of the tax \r\nyear on any debt obligation owed to the foreign -\r\ncontrolled resident company by the foreign \r\ncontroller or a non-resident associate of the foreign \r\ncontroller; and \r\n(ii) where the foreign-controlled resident company has \r\naccumulated losses at the beginning of the tax \r\nyear, the amount by which the return of capital to \r\nthe foreign controller or non -resident associate of \r\nthe foreign controller would be reduced by virtue of \r\nthe losses if the company were wound up at that \r\ntime. \r\n \r\n1[106A. Restriction on deduction of profit on debt payable to associated \r\nenterprise.-(1) Subject to sections 108 and 109, a part of deduction for foreign \r\nprofit on debt claimed by a foreign -controlled resident company(other than an \r\ninsurance company, or a banking company) during a tax year, shall be disallowed \r\naccording to the following formula, namely:-   \r\n \r\n[B] – [(A+B) x 0.15] \r\nwhere- \r\n \r\n A  is the taxable income before depreciation and amortization; and  \r\n \r\n B is the foreign profit on debt claimed as deduction  \r\n(2) This section shall not apply to a foreign -controlled resident company \r\nif the total foreign profit on debt claimed as deduction is less than ten \r\nmillion rupees for a tax year. \r\n \r\n(3) Where in computing the taxable income for a tax year, full effect \r\ncannot be given to a deduction for foreign profit on debt, the excessive \r\namount shall be added to the amount of foreign profit on deb t for the \r\n                                            \r\n1 New section 106A inserted through Finance Act, 2020 dated 30th June, 2020 \r\nChapter VII – International_______________________________ \r\n \r\n203 \r\n \r\nfollowing tax year and shall be treated to be part of that deduction, or \r\nif there is no such deduction for that tax year, be treated to be the \r\ndeduction for that tax year, be treated to be the deduction for that tax \r\nyear and so on for three tax years. \r\n \r\n(4) Notwithstanding the provisions of section 106, where deduction of \r\nforeign profit on debt is disallowed under this section and also under \r\nsection 106, the disallowed amount shall be the higher of the \r\ndisallowed amount under this section and section 106. \r\n \r\n(5) This section shall apply in respect of foreign profit on debt accrued \r\nwith effect from the first day of July, 2020, ever if debts were \r\ncontracted before the first day of July, 2020. \r\n \r\n(6) In this section- \r\n \r\n(a) “foreign-controlled resident company” means a resident company \r\nin which fifty per cent or more of the underlying ownership of the \r\ncompany is held by a non-resident person either alone or together \r\nwith an associate or association; and  \r\n \r\n(b) “foreign profit on debt” means interest paid or payable to  a non-\r\nresident person or an associate of the foreign-controlled resident \r\ncompany and includes- \r\n \r\n(i) interest on all forms of debt; \r\n \r\n(ii) payments made which are economically equivalent to \r\ninterest; \r\n \r\n(i) expenses incurred in connection with the raising of finance; \r\n \r\n(ii) payments under profit participating loans; \r\n \r\n(iii) imputed interest on instruments such as convertible bonds \r\nand zero coupon bonds; \r\n \r\n(iv) amounts under alternative financing arrangements such as \r\nIslamic finance; \r\n(v) the finance cost element of finance lease payments; \r\n \r\n(vi) capitalized interest included in the balance sheet value of \r\nrelated asset, or the amortisation of capitalised interest; \r\n \r\n(vii) amounts measured by reference to a funding return under \r\ntransfer pricing rules; \r\nChapter VII – International_______________________________ \r\n \r\n204 \r\n \r\n \r\n(viii) where applicable, national interest amounts under deriv ative \r\ninstruments or hedging arrangements related to an entity’s \r\nborrowings; \r\n \r\n(ix) certain foreign exchange gains and losses on borrowings and \r\ninstruments connected with the raising of finance; \r\n \r\n(x) guarantee fees with respect to financing arrangements; and  \r\n \r\n(xi) arrangements fee and similar cost related to the borrowing \r\nfunds.]  \r\n  \r\n   \r\n \r\n  \r\nChapter VII – International_______________________________ \r\n \r\n205 \r\n \r\nPART IV \r\nAGREEMENTS FOR THE AVOIDANCE OF DOUBLE TAXATION  \r\nAND PREVENTION OF FISCAL EVASION \r\n \r\n107.  Agreements for the avoidance of double taxation and prevention of \r\nfiscal evasion. —1[2[(1) The Federal Government may enter into a tax treaty, a \r\ntax information exchange agreement, a multilateral convention, an inter -\r\ngovernmental agreement or similar agreement or mechanism for the avoidance of \r\ndouble taxation 3[or assistance in the recovery o f taxes] or for the exchange of \r\ninformation for the prevention of fiscal evasion or avoidance of taxes including \r\nautomatic 4[and spontaneous] exchange of information with respect to taxes on \r\nincome imposed under this Ordinance or any other law for the time  being in force \r\nand under the corresponding laws in force in that country and may, by notification \r\nin the official Gazette, make such provisions as may be necessary for \r\nimplementing the said instruments.”;] and] \r\n \r\n5[“(1A) Notwithstanding anything contained in any other law to the contrary, \r\nthe Board shall have the powers to  obtain and collect information when solicited \r\nby another country under a tax treaty, a tax information exchange  agreement, a \r\nmultilateral convention, an inter -governmental agreement, a si milar arrangement \r\nor mechanism.] \r\n \r\n6[(1B) Notwithstanding the provisions of the Freedom of  Information \r\nOrdinance, 2002 (XCVI of 2002),  7[subject to clause (a) of sub -section (3) of \r\nsection 216 of this Ordinance] any information  received or supplied, and any  \r\n                                            \r\n1The sub-section (1) substituted by Finance Act, 2015. Substituted sub -section (1) read as follows: -  \r\n“(1) The Federal Government may enter into an agreement with the government of a foreign country \r\nfor the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income \r\nimposed under this Ordinance and under the corresponding laws in force in that country, and may, by \r\nnotification in the official Gazette make such provisions as may be necessary for implementing the \r\nagreement.” \r\n2Sub-section (1) substituted by the Finance Act, 2016. The substituted sub-section (1) reads as \r\nfollows:- \r\n“(1) The Federal Government may enter into an agreement, bilateral or multilateral with the \r\ngovernment or governments of foreign countries or tax jurisdictions for the avoidance of double \r\ntaxation and the prevention of fiscal evasion and exchange of information including automatic \r\nexchange of information with respect to taxes on income imposed under this Ordinance or any \r\nother law for the time being in force and under the corresponding laws in force in that country, \r\nand may, by notification in the official Gazette, make such provisions as may be necessary for \r\nimplementing the agreement.” \r\n3 Inserted by the Finance Act, 2021. \r\n4 The words “and spontaneous” inserted through Finance Act, 2020 dated 30th June, 2020 \r\n5Inserted by the Finance Act, 2015 \r\n6Inserted by the Finance Act, 2015 \r\n7The words inserted by the Finance Act, 2019. \r\nChapter VII – International_______________________________ \r\n \r\n206 \r\n \r\nconcomitant communication or  correspondence made, under a tax treaty, a tax \r\ninformation exchange agreement, a multilateral convention, a similar arrangement \r\nor mechanism, shall be confidential 1[  ]. \r\n \r\n (2) 2[Subject to section 109 , where] any agreement is  made in \r\naccordance with sub -section (1), the agreement and the provisions made by \r\nnotification for implementing the agreement shall, notwithstanding anything \r\ncontained in any law for the time being in force, have effect in so far as they provide \r\nfor 3[at least one of the following] – \r\n \r\n(a) relief from the tax payable under this Ordinance; \r\n \r\n(b) the determination of the Pakistan -source income of non -\r\nresident persons; \r\n \r\n(c) where all the operations of a business are not carried on within \r\nPakistan, the determina tion of the income attributable to \r\noperations carried on within and outside Pakistan, or the income \r\nchargeable to tax in Pakistan in the hands of non -resident \r\npersons, including their agents, branches, and permanent \r\nestablishments in Pakistan; \r\n \r\n(d) the determination of the income to be attributed to any resident \r\nperson having a special relationship with a non-resident person; \r\nand \r\n \r\n(e) the exchange of information for the prevention of fiscal evasion \r\nor avoidance of taxes on income chargeable under this \r\nOrdinance and under the corresponding laws in force in that \r\nother country. \r\n \r\n (3) Notwithstanding anything 4[contained] in sub-sections (1) or (2), any \r\nagreement referred to in sub-section (1) may include provisions for the relief from \r\ntax for any period before t he commencement of this Ordinance or before the \r\nmaking of the agreement.  \r\n \r\n \r\n \r\n                                            \r\n1The expression “subject to sub-section (3) of section 216” omitted by the Finance Act, 2016 \r\n2The word “where” substituted by the Finance Act, 2018. \r\n3Inserted by the Finance Act, 2016. \r\n4Inserted by the Finance Act, 2016. \r\nChapter VIII – Anti-Avoidance____________________________ \r\n \r\n207 \r\nCHAPTER VIII \r\nANTI-AVOIDANCE \r\n \r\n108.  Transactions between associates.  — (1)  The Commissioner may, in \r\nrespect of any transaction between persons who are associates, distribute, \r\napportion or allocate income, deductions or tax credits between the persons as is \r\nnecessary to reflect the income that the persons would have realised in an arm’s \r\nlength transaction. \r\n \r\n (2) In making any adjustment under sub -section (1), the Commissioner \r\nmay determine the source of income and the nature of any payment or loss as \r\nrevenue, capital or otherwise. \r\n \r\n1[(3) Every taxpayer who has entered into a transaction with its associate \r\nshall: \r\n \r\n(a) maintain a master file and a local file containing documents and \r\ninformation as may be prescribed; \r\n \r\n(b) keep 2[, maintain and furnish to the Board]  prescribed country -by-\r\ncountry report, where applicable; \r\n \r\n(c) keep and maintain any other information and document in respect of \r\ntransaction with its associate as may be prescribed; and \r\n \r\n(d) keep the files, documents, information and reports specified in clauses \r\n(a) to (c) for the period as may be prescribed. \r\n \r\n(4) A taxpayer who has entered into a transaction with its associate shall \r\nfurnish, within thirty days the documents and information to be kept and maintained \r\nunder 3[clause (a), (c) or (d) of] sub-section (3) if required by the Commissioner in \r\nthe course of any proceedings under this Ordinance.; \r\n \r\n(5) The Commissioner may, by an order in writing, grant the taxpayer an \r\nextension of time for furnishing the documents and information under sub -section \r\n(4), if the taxpayer applies in writing to the Commissioner for an extension of time \r\nto furnish the said documents or information: \r\n \r\nProvided that the Commissioner shall not grant an extension of more than \r\nforty-five days, when such information or documents were required to be furnished \r\nunder sub -section (4), unless there are exceptional circumstances justify ing a \r\nlonger extension of time.] \r\n                                            \r\n1 Added by the Finance Act, 2016. \r\n2The words “and maintain” substituted  by the Finance Act, 2018 \r\n3Insertedby the Finance Act, 2018 \r\n \r\nChapter VIII – Anti-Avoidance____________________________ \r\n \r\n208 \r\n \r\n1[(6) Notwithstanding the provisions of sub-section (1), for the tax year 2024 \r\nand onwards, where any amount is claimed as deduction for the tax year or for any \r\nof the two preceding tax years on account of royalty paid or payable to an associate \r\ndirectly or indirectly in respect of use of any brand name, logo, pa tent, invention, \r\ndesign or model, secret formula or process, copyright, trademark, scientific or \r\ntechnical knowledge, franchise, license, intellectual property or other like property \r\nor right or contractual right and on a notice issued by the Commissioner,  the \r\ntaxpayer fails to furnish any explanation or evidence that no benefit has been \r\nconferred on the associate, twenty five percent of the total expenditure for the tax \r\nyear in respect of sales promotion, advertisement and publicity shall be disallowed \r\nand allocated to the said associate.] \r\n \r\n2[108A. Report from independent chartered accountant or cost and \r\nmanagement accountant. – (1) Where the Commissioner is of the opinion that a \r\ntransaction has not been declared at arm’s length, the Commissioner may obtain  \r\nreport from an independent chartered accountant or cost and management \r\naccountant to determine the fair market value of asset, product, expenditure or \r\nservice at the time of transaction.  \r\n \r\n(2) The scope, terms and conditions of the report shall be as may be \r\nprescribed. \r\n \r\n(3) Where the Commissioner is satisfied with the report of the \r\nindependent chartered accountant or cost and management accountant, the fair \r\nmarket v alue of asset, product, expenditure or service determined in the report \r\nshall be treated as definite information for the purpose of sub-section (8) of section \r\n122. \r\n \r\n(4) Where the Commissioner is not stratified with the report of the \r\nindependent chartered accountant or cost and management accountant, the \r\nCommissioner may record reasons for being not satisfied with the report and seek \r\nreport from another independent chartered accountant or cost and management \r\naccountant, to determine the fair market value of asset, product, expenditure or \r\nservice at the time of transaction. \r\n \r\n(5) The Commissioner sha ll seek report under sub -section (1) or sub -\r\nsection (3), as the case may be, with prior approval of the Board.  \r\n \r\n108B.  Transactions under dealership arrangements. - (1) Where a person \r\nsupplies products listed in the Third Schedule to the Sales Tax Act, 1990  or any \r\nother products as prescribed by the Board, under a dealership arrangement with \r\nthe dealers who are not registered under Sales Tax Act, 1990 and ar e not \r\nappearing in the active taxpayers’ list under this Ordinance, an amount equal to \r\n                                            \r\n1 Sub-section (6) added by the Finance Act, 2024. \r\n2New sections (108A) & (108B) inserted through Finance Act, 2019 \r\nChapter VIII – Anti-Avoidance____________________________ \r\n \r\n209 \r\n \r\nseventy-five percent of the dealer’s margin shall be added to the income of the \r\nperson making such supplies. \r\n \r\n (2) For the purposes of operation of this section, ten percent of the sale \r\nprice of the manufacturer shall be treated as dealers margin.] \r\n \r\n109. Recharacterisation of income and deductions.  — (1) For the purposes \r\nof determining liability to tax under this Ordinance, the Commissioner may – \r\n \r\n(a) recharacterise a transaction or an element of a transaction that was \r\nentered into as part of a tax avoidance scheme;  \r\n \r\n(b) disregard a transaction that does not have substantial economic effect; \r\n1[   ] \r\n \r\n(c) recharacterise a transaction where the form of the transaction does not \r\nreflect the substance2[;] \r\n \r\n3[(d) from  tax  year  2018  and  onwards,  disregard  an  entity  or    a \r\ncorporate  structure  that  does  not  have  an  economic  or commercial  \r\nsubstance  or  was  created  as  part  of  the  tax avoidance scheme] 4[; \r\nor \r\n \r\n(e)    from tax year 2018 and onwards, treat a place of business in Pakistan \r\nas a permanent establishment, if the said place fulfills the conditions as \r\nspecified in sub-clause (g) of clause (41) of section 2.] \r\n \r\n(2) In this section, “tax avoidance scheme” means any transaction where \r\none of the main purposes of a person in entering into the transaction is t he \r\navoidance or reduction of any person’s liability to tax under this Ordinance. \r\n \r\n5[(3) Reduction in a person's liability to tax as referred to in sub-section (2) \r\nmeans a reduction, avoidance or deferral of tax  or increase in a refund of tax and \r\nincludes a reduction, avoidance or deferral of tax that would have been payable \r\nunder this Ordinance, but are not payable due to a tax treaty for the avoidance of \r\ndouble taxation as referred to in section 107.] \r\n \r\n                                            \r\n1The word “or” omitted by the finance Act 2022. \r\n2Full stop substituted with a semicolon by the finance Act 2022. \r\n3Inserted by the finance Act 2018 \r\n4Full stop substituted and a new clause (e) added by the Finance Act 2022. \r\n5 Added by the finance Act 2018 \r\nChapter VIII – Anti-Avoidance____________________________ \r\n \r\n210 \r\n \r\n1[109A. Controlled foreign company.— (1) There shall be included in the taxable \r\nincome of a resident person for a tax year an income attributable to controlled \r\nforeign company as defined in sub- section (2). \r\n \r\n(2)  For the purpose of this section, controlled foreign company means a \r\nnon-resident company, if ─ \r\n \r\n(a)  more than fifty percent of the capital or voting rights of the  non-\r\nresident company are held, directly or indirectly, by one or more \r\npersons resident in Pakistan o more than forty percent of the capital \r\nof the or voting rights of the non-resident company are held, directly  \r\nor indirectly, by a single resident person in Pakistan; \r\n \r\n(b) tax paid, after taking into account any foreign tax credits available to \r\nthe non-resident company, on the income derived or accrued, during \r\na foreign tax year, by the non-resident company to any  tax  authority \r\noutside Pakistan is less than sixty percent of the tax payable on the \r\nsaid income under this Ordinance; \r\n \r\n(c) the non-resident company does not derive active business  income  \r\nas defined under sub-section (3); and \r\n \r\n(d) the shares of the company are not traded on any stock exchange  \r\nrecognized by law of the country or jurisdiction of which the      non-\r\nresident company is resident for tax purposes. \r\n \r\n(3)   A  company  shall  be  treated  to  have  derived  active  income if─ \r\n \r\n(a)  more than eighty percent of income of the company does not  include \r\nincome from dividend, interest, property, capital gains,   royalty, \r\nannuity payment, supply of goods or services to an  associate, sale \r\nor licensing of intangibles and management,  holding or investment \r\nin securities and financial assets; and \r\n \r\n(b) principally derives income under the head  “income from business” \r\nin the country or jurisdiction of which it is a resident. \r\n \r\n(4) Income of a controlled foreign company is an amount equal to the taxable \r\nincome of that company determined in accordance with the provisions  of  this  \r\nOrdinance  as  if  that  controlled  foreign  company  is  a resident taxpayer and \r\nshall be taxed at the rate specified in Division III of Part I of the First Sch edule. \r\n \r\n(5)  The amount of attributable income under sub-section (1) for a tax   year \r\nshall be computed according to the following formula, namely:— \r\n                                            \r\n1Inserted by the finance Act 2018 \r\nChapter VIII – Anti-Avoidance____________________________ \r\n \r\n211 \r\n \r\n \r\nA x (B/100) \r\n \r\nWhere - \r\n \r\nA is the amount of income of a controlled foreign company under sub-\r\nsection (2); and \r\n \r\nB is the percentage of capital or voting rights, whichever  is higher, \r\nheld by the person, directly or indirectly, in the controlled foreign \r\ncompany. \r\n \r\n(6) The amount of attributable income shall be treated as zero, if the \r\ncapital or voting rights of the resident person is less than ten percent. \r\n \r\n(7) Income of a controlled foreign company shall be treated as zero, if it \r\nis less than ten million Rupees. \r\n \r\n(8) The income of a controlled foreign company in respect of a foreign tax \r\nyear, as defined in sub -section (9), shall be determined in the currency of that \r\ncontrolled foreign company and shall, for purposes of determining the amount to \r\nbe included in the income  of  any  resident  person  during  any  tax  year  under  \r\nthe provisions  of  this  section,  be  converted  into  Rupees  at  the  State Bank of \r\nPakistan rate applying between  that foreign currency and the Rupee on the last \r\nday of the tax year. \r\n \r\n(9) Foreign tax year, in relation to a non-resident company, means any  \r\nyear or period of reporting for income tax purposes by that non-resident company \r\nin the country or jurisdiction of residence or, if that company is not subject to \r\nincome tax, any annual period of financial reporting by that company. \r\n \r\n(10) The income attributable to controlled foreign company under        sub-\r\nsection (1) and taxed in Pakistan under this section shall not be taxed again when \r\nthe same income is received in Pakistan by the resident taxpayer. \r\n \r\n(11) Where tax has been paid by the resident person on the income  \r\nattributable to con trolled foreign company and in a subsequent  tax year the \r\nresident person receives dividend distributed by the controlled foreign company,  \r\nafter deduction of tax on dividend, the resident person shall be allowed a tax credit \r\nequal to the lesser of, — \r\n \r\n(i) foreign tax paid, as defined in sub-section (8) of section 103, on \r\ndividends; and \r\n \r\n(ii)  Pakistan tax payable, as defined in section 103, for the tax  year  \r\nin  which  the  dividend  is  received  by  the resident taxpayer.] \r\nChapter VIII – Anti-Avoidance____________________________ \r\n \r\n212 \r\n \r\n \r\n110. Salary paid by private co mpanies. — Where, in any tax year, salary is \r\npaid by a private company to an employee of the company for services rendered \r\nby the employee in an earlier tax year and the salary has not been included in the \r\nemployee’s salary chargeable to tax in that earlier year, the Commissioner may, if \r\nthere are reasonable grounds to believe that payment of the salary was deferred, \r\ninclude the amount in the employee’s income under the head “Salary” in that earlier \r\nyear. \r\n \r\n111. Unexplained income or assets. — (1) Where — \r\n \r\n(a) any amount is credited in a person’s books of account; \r\n \r\n(b) a person has made any investment or is the owner of any money \r\nor valuable article; 1[  ] \r\n \r\n(c) a person has incurred any expenditure2[; or] \r\n \r\n3[(d)  any person has concealed income or furnished i naccurate \r\nparticulars of income including — \r\n \r\n(i)  the suppression of any production, sales or any amount \r\nchargeable to tax; or  \r\n \r\n(ii)  the suppression of any item of receipt liable to tax in \r\nwhole or in part,] \r\n \r\nand the person offers no explanation about th e nature and source of the amount \r\ncredited or the investment, money, valuable article, or funds from which the \r\nexpenditure was made 4[suppression of any production, sales, any amount \r\nchargeable to tax and of any item of receipt liable to tax] or the explanation offered \r\nby the person is not, 5[in the Commissioner’s opinion, satisfactory-  \r\n \r\n(a)  the amount credited, value of the investment, money, value of the \r\narticle, or amount of expenditure  shall be included in the person’s \r\nincome chargeable to tax under t he head “Income from Other \r\nSources” to the extent it is not adequately explained; and \r\n                                            \r\n1The word “or” omitted by the Finance Act, 2011. \r\n2Comma substituted by the Finance Act, 2011. \r\n3Added by the Finance Act, 2011 \r\n4Inserted by the Finance Act, 2011. \r\n5The expressions “in the Commissioner’s opinion, satisfactory, the amount credited, value of the \r\ninvestment, money, value of the article, or amount of expenditure 5[suppressed amount of production, \r\nsales or any amount chargeable to tax or of any item of receipt liable to tax] shall be included in the \r\nperson’s income chargeable to tax under head “Income from 5[Other Sources”] to the extent it is not \r\nadequately explained” substituted through Finance Act, 2020 dated 30th June, 2020 \r\nChapter VIII – Anti-Avoidance____________________________ \r\n \r\n213 \r\n \r\n \r\n(b) the suppressed amount of production, sales or any amount \r\nchargeable to tax or of any item of receipt liable to tax shall be included \r\nin the person’s income chargeable to tax under the head “Income from \r\nBusiness” to the extent it is not adequately explained”]  1[:] \r\n \r\n2[Provided that where a taxpayer explains the nature and \r\nsource of the amount credited or the investment made, money or \r\nvaluable article owned or funds from which the expenditure was made, \r\nby way of agricultural income, such explanation shall be accepted to \r\nthe extent of agricultural income worked back on the basis of \r\nagricultural income tax paid under the relevant provincial law.] \r\n \r\n3[(2) The amount referred  to in sub -section (1) shall be included in the \r\nperson’s income chargeable to tax: \r\n(i) in the tax year to which such amount relates if the amount   \r\nrepresenting investment, money, valuable article or expenditure   \r\nis situated or incurred in Pakistan or con cealed income is  \r\nPakistan-source; and \r\n \r\n(ii) in the tax year immediately preceding the tax year in which the   \r\ninvestment, money, valuable article or expenditure is discovered \r\nby the Commissioner and is situated or incurred outside  Pakistan \r\n4[or] concealed income is foreign-source. \r\n \r\nExplanation.—For the removal of doubt, it is clarified that where  \r\nthe investment, money, valuable article or expenditure is  acquired \r\nor incurred outside Pakistan in a prior tax year and is liable to be \r\nincluded in the income of tax year 2018 and  onwards  on the basis \r\nof discovery made by the Commissioner during tax year 2019 and \r\nonwards and the person explains the  acquisition  of such asset \r\nor expenditure from sources relating to tax year in which such \r\nasset was acquired or expenditure was incurred, such explanation \r\nshall not be rejected on the basis that the source  does  not  relate  \r\nto  the  tax  year  in  which  the amount chargeable to tax is to be \r\nincluded.]  \r\n \r\n \r\n                                            \r\n1Full stop substituted by the Finance Act, 2013. \r\n2Added by the Finance Act, 2013. \r\n3Sub-section (2) substituted by the Finance Act, 2018. The substituted sub-section (2) read as follows:  \r\n“(2) The amount referred to in sub-section (1) shall be included in the person’s income chargeable to tax in the \r\ntax year 3[to which such amount relates.” \r\n4 The word “and” substituted by the Finance Act, 2021. \r\nChapter VIII – Anti-Avoidance____________________________ \r\n \r\n214 \r\n \r\n1[(2A) For the purposes of clause (ii) of sub -section (2) o f this section, the \r\n“year of discovery of foreign assets or expenditure or concealed income”, shall \r\nmean the year in which the Commissioner has issued a notice requiring the person \r\nto explain the nature and source of such foreign assets, expenditure or concealed \r\nincome.] \r\n \r\n2[(3) Where the declared cost of any investment or valuable article or the \r\ndeclared amount of expenditure of a person is less than reasonable cost of the \r\ninvestment or the valuable article, or the reasonable amount of the expenditure, \r\nthe Commissioner may, having regard to all the circumstances, include the \r\ndifference in the person’s income chargeable to tax under the head “Income from \r\nOther Sources” in the tax year 3[to which the investment, valuable article or the \r\nexpenditure relates].] \r\n \r\n4[   ] \r\n \r\n5[(4) Sub -section (1) does not apply to any amount of foreign exchange \r\nremitted from outside Pakistan through normal banking channels not exceeding \r\nfive million Rupees in a tax year that is en-cashed into rupees by a scheduled bank \r\nand a certificate from such bank is produced to that effect.] \r\n \r\n6[Explanation.— For removal of doubt, it is clarified that the remittance through \r\nmoney service bureaus, exchange companies or money transfer operators shall \r\nbe deemed to constitute foreign exchange remitted from outside Pakistan through \r\nnormal banking channels as provided under this sub-section. \r\n                                            \r\n1 Sub-section (2A) inserted by the Finance Act, 2024. \r\n2  Sub-section (3) substituted by the Finance Act, 2003. The substituted sub-section (3) read as \r\nfollows:  \r\n“(3) Where the declared value of any investment, valuable article or expenditure of a person \r\nis less than the cost of the investment or valuable article, or the amoun t of the expenditure, the \r\nCommissioner may, having regard to all the circumstances , include the difference in the person’s \r\nincome chargeable to tax under the head “Income from Other Sources” in the tax year in which the \r\ndifference is discovered.” \r\n3The words “immediately preceding the financial year in which the difference is discovered”  substituted \r\nby the Finance Act, 2010. \r\n4Sub-section (4) substituted by the Finance Act, 2004. The substituted sub-section (4) read as follows: \r\n“(4) Sub-section (1) does not apply to any amount of foreign exchange remitted from outside \r\nPakistan through normal banking channels that is encashed into rupees by a scheduled bank and a \r\ncertificate from such bank is produced to that effect.” \r\n5 Sub-section (4) substituted by the Finance Act, 2021. The substituted sub-section read as follows: \r\n(4) Sub-section (1) does not apply,— \r\n(a) to any amount of foreign exchange remitted from outside Pakistan through normal \r\nbanking channels 5[not exceeding 5[five] million Rupees in a tax year] that is \r\nencashed into rupees by a scheduled bank and a certificate from such bank is \r\nproduced to that effect5[.]  \r\n5[  ] \r\n5[  ] \r\n6 The explanation and sub-section (4A) inserted by the Finance Act, 2022. \r\nChapter VIII – Anti-Avoidance____________________________ \r\n \r\n215 \r\n \r\n(4A) Where a taxpayer, while explaining the nature and source of any \r\namount referred to in sub -section (1), takes into account any source of income \r\nwhich is subject to  final tax under any provision of the Ordinance, the taxpayer \r\nshall not be entitled to take credit of any sum as is in excess of imputable income, \r\nunless the excess amount is reasonably attributed to the business activities subject \r\nto final tax and the tax payer furnishes financial statements and accounts duly \r\naudited by a chartered accountant.] \r\n \r\n (5) The 1[Board] may make rules under section 2[237] for the purposes of \r\nthis section.  \r\n \r\n 3[   ] \r\n  \r\n4[Explanation.— For the removal of doubt, it is clarified that a separate notice \r\nunder this section is not required to be issued if the explanation regarding \r\nnature and sources of;  \r\n \r\n(i) any amount credited in a person’s books of account; or \r\n(ii) any investment made or ownership of money or valuable article; or \r\n(iii) funds from which expenditure was made; or \r\n(iv) suppression of any production, sales, or any amount chargeable to \r\ntax; or  \r\n(v) suppression of any item of receipt liable to tax in whole or in part has \r\nbeen confronted to the taxpayer through a notice under sub-section \r\n(9) of section 122 of the Ordinance.] \r\n \r\n112. Liability in respect of certain security transactions. — (1) Where the \r\nowner of any security disposes of the security and thereafter re -acquires the \r\nsecurity and the result of the transaction is that any income payable in respec t of \r\nthe security is receivable by any person other than the owner, the income shall be \r\ntreated, for all purposes of the Ordinance, as the income of the owner and not of \r\nthe other person.  \r\n \r\n (2) In this section, “security” includes 5[bonds, certificates, d ebentures,] \r\nstocks and shares.\r\n                                            \r\n1 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n2 The figure “232” substituted by the Finance Act, 2002. \r\n3 Added by the Finance Act, 2021.  \r\n4 The explanation substituted by the Finance Act, 2022. The substituted Explanation read as follows: \r\n“Explanation.—For the removal of doubt, a separate notice under this section is not required to be \r\nissued if the explanation regarding nature and sources of amount credited or the investment of money, \r\nvaluable article, or the funds from which expenditure was made has been confronted to the taxpayer \r\nthrough a notice under sub-section (9) of section 122 of this Ordinance.” \r\n5 Inserted by the Finance Act, 2003. \r\nChapter IX – Minimum Tax ______________________________ \r\n \r\n216 \r\nCHAPTER IX  \r\nMINIMUM TAX \r\n \r\n1[113.  Minimum tax on the income of certain persons. - (1) This section shall \r\napply to a resident company ,2[permanent establishment of a non -resident \r\ncompany,] 3[, an individual (having turnover of 4[  ] 5[hundred] million rupees or \r\nabove in the tax year 6[2017] or in any subsequent tax year) and an association of \r\npersons (having turnover of 7[  ] 8[hundred] million rupees or above in the tax year \r\n9[2017] or in any subsequent tax year)] where, for any reason whatsoever allowed \r\nunder this Ordinance, including any other law for the time being in force — \r\n \r\n  (a)  loss for the year;  \r\n \r\n(b)  the setting off of a loss of an earlier year; \r\n \r\n(c) exemption from tax; \r\n \r\n(d)  the application of credits or rebates; or \r\n \r\n(e)  the claiming of allowances or deductions (including depreciation \r\nand amortization deductions) no tax is payable or paid by the \r\nperson for a tax year or the tax payable or paid by the person \r\nfor a tax year is less than 10[ 11[the percentage as specified in \r\ncolumn (3) of the Table in Division IX of Part -I of the First \r\n                                            \r\n1Inserted by the Finance Act, 2009. \r\n2The expressions inserted through Finance Act, 2020 dated 30th June, 2020  \r\n3Inserted by the Finance Act, 2010. \r\n4The word “fifty” substituted by the Finance Act, 2016. \r\n5 The word “ten” substituted by the Finance Act, 2021. \r\n6The figure “2009” substituted by the Finance Act, 2016 \r\n7The word “fifty” substituted by the Finance Act, 2016. \r\n8 The word “ten” substituted by the Finance Act, 2021. \r\n9The figure “2007” substituted by the Finance Act, 2016 \r\n10The word “one-half” substituted by the Finance Act, 2013. \r\n11The word “one per cent” substituted by the Finance Act, 2017. \r\nChapter IX – Minimum Tax ______________________________ \r\n \r\n217 \r\n \r\nSchedule] ] of the amount representing the person’s turnover \r\nfrom all sources for that year: \r\n \r\n 1[    ] \r\n \r\n2[ 3[Explanation.-For the purpose of this sub -section, the expression \r\n“tax payable or paid” does not include-  \r\n \r\n(a) tax already paid or payable in respect of deemed income which \r\nis assessed as final discharge  of the tax liability under section \r\n169 or under any other provision of this Ordinance; and \r\n \r\n(b) tax payable or paid under section 4B 4[or 4C]. ] \r\n \r\n(2)       Where this section applies: \r\n \r\n(a) the aggregate of the person’s turnover as defined in sub-section \r\n(3) for the tax year shall be treated as the income of the person \r\nfor the year chargeable to tax 5[. \r\n \r\nExplanation.—For the removal of doubt, it is clarified that the \r\ndefinition of turnover covers receipts from all business activities \r\nin line with expression “ turnover from all sources” used in sub -\r\nsection (1) including but not limited to receipts from sale of \r\nimmoveable property where such receipt is  taxable under the \r\nhead Income from Business;] \r\n \r\n(b) the person shall pay as income tax for the tax year (instead of \r\nthe actual tax payable under this Ordinance), 6[minimum tax  \r\ncomputed on the basis of rates as specified in Division IX of Part \r\nI of First Schedule]; \r\n \r\n                                            \r\n1 Proviso omitted by the Finance Act, 2016. The omitted proviso reads as follows:- \r\n“Provided that this sub -section shall not apply in the case of a company, which has declared \r\ngross loss before set off of depreciation and other inadmissible expenses under the Ordinance. If the \r\nloss is arrived at by setting off the a foresaid or changing accounting pattern, the Commissioner may \r\nignore such claim and proceed to compute the tax as per historical accounting pattern and provision \r\nof this Ordinance and all other provisions of the Ordinance shall apply accordingly.” \r\n2Added by the Finance Act, 2012. \r\n3Explanation substituted by the Finance Act, 2016. The substituted Explanation reads as follows:- \r\n[“Explanation.- For the purpose of this sub-section, the expression “tax payable or paid” does \r\nnot include tax already paid or payabl e in respect of deemed income which is assessed as final \r\ndischarge  of the tax liability under section 169 or under any other provision of this Ordinance.] \r\n4 Inserted by the Finance Act, 2022. \r\n5 Semi colon substituted and explanation added by the Finance Act, 2021. \r\n6The words “an amount equal  to one percent of the person’s turnover for the year” substituted by  the \r\nwords “minimum tax  computed on the basis of rates as specified in Division IX of Part I of First \r\nSchedule”, by the Finance Act, 2014. \r\nChapter IX – Minimum Tax ______________________________ \r\n \r\n218 \r\n \r\n(c) where tax paid under sub -section (1) exceeds the actual tax \r\npayable under Part I, 1[clause (1) of Division I, or]  Division II of \r\nthe First Schedule, the excess amount of tax paid shall be  \r\ncarried forward for adjustment against tax liability under the  \r\naforesaid Part of the subsequent tax year: \r\n \r\n2[Provided that if tax is paid under sub -section (1) due to \r\nthe fact that no tax is payable or paid for the year, the entire \r\namount of tax paid under sub -section (1) shall be carried \r\nforward for adjustment in the manner stated aforesaid:  \r\n \r\nProvided further that the amount under this clause shall \r\nbe carried forward and adjusted against tax liability for 3[  ] 4[two]  \r\ntax years immediately succeeding the tax year for which the \r\namount was paid.] \r\n    \r\n 5[Explanation. – For the removal of doubt it is clarified that the \r\naforesaid Part referred to in this clause means clause (1) of \r\nDivision I or Division II of Part I of the First Schedule.] \r\n \r\n(3) “turnover” means,- \r\n \r\n(a) the 6[gross sales or] gross receipts, exclusive of Sales Tax and \r\nFederal Excise duty or any trade discounts shown on invoices, \r\nor bills, derived from the sale of goods, and also excluding any \r\namount taken as deemed income and is assessed as final \r\ndischarge of the tax liability for which tax is already paid or \r\npayable; \r\n \r\n(b) the gross fees for the rendering of services for giving benefits \r\nincluding commissions; except covered by final discharge of tax \r\nliability for which tax is separately paid or payable; \r\n \r\n(c) the gross receipts from the execution of contracts; exc ept \r\ncovered by final discharge of tax liability for which tax is \r\nseparately paid or payable; and \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2013. \r\n2 The proviso substituted by the Finance Act, 2021. The substituted proviso read as follows: \r\n“Provided that the amount under this clause shall be carried forward and adjusted against \r\ntax liability for 2[five] tax years immediately succeeding the tax year for which the amount was paid.” \r\n3 The word “five” substituted by the Finance Act, 2022. \r\n4 The word “three” substituted by the Finance Act, 2025.  \r\n5 The explanation added by the Finance Act, 2023.  \r\n6Inserted by the Finance Act, 2011. \r\nChapter IX – Minimum Tax ______________________________ \r\n \r\n219 \r\n \r\n(d) the company’s share of the amounts stated above of any \r\nassociation of persons of which the company is a member.] \r\n \r\n1[2[  ] ]  \r\n \r\n3[  ] \r\n                                            \r\n1Section 113A substituted by the Finance Act, 2013. The substituted section 113A read as follows:- \r\n“113A. Tax on Income of certain persons. — (1) Subject to this Ordinance, where a retailer being \r\nan individual or an association of persons has turnover upto rupees five million for any tax year, such \r\nperson may opt for payment of tax as a final tax at the rates specified in Division IA of Part I of the \r\nFirst Schedule. \r\n(2) For the purposes of this section, — \r\n(a)  “retailer” means a person selling goods to gen eral public for the purpose of \r\nconsumption; \r\n(b)  “turnover” shall have the same meaning as assigned to it in sub -section (3) of \r\nsection 113. \r\n (3) The tax paid under this section shall be a final tax on the income arising from the turnover \r\nas specified in sub-section (1). The retailer shall not be entitled to claim any adjustment of withholding \r\ntax collected or deducted under any head during the year.” \r\n2 Section 113A omitted by the Finance Act, 2016. The omitted section 113a reads as follows:-  \r\n“113A.    Minimum tax on builders.— (1) Subject to this Ordinance, where a person derives income \r\nfrom the business of construction and sale of residential, commercial or other buildings, he shall pay \r\nminimum tax at the rates as the Federal Government may notify in th e official Gazette. The Federal \r\nGovernment may also specify the mode, manner and time of payment of such amount of tax. \r\n (2)  The tax paid under this section shall be minimum tax on the income of the builder \r\nfrom the sale of such residential, commercial or other building.] \r\n 2[“(3) This section shall not have effect till the 30th June, 2018.”]” \r\n3Section 113B substituted by the Finance Act, 2013. The substituted section 113B read as follows:- \r\n“113B.   Taxation of income of certain retailers.  — Subject to this  Ordinance, a retailer being an \r\nindividual or association of persons,-  \r\n  (a)  whose turnover exceeds five million rupees; and \r\n(b)  who is subject to special procedure for payment of sales tax  under Chapter II \r\nof the Sales Tax Special Procedures Rules, 2007, \r\nshall pay final tax at the following rates which shall form part of single stage sales tax as envisaged in \r\nthe aforesaid rules;________________________________________________________________ \r\nS.No. Amount of turnover Rate of tax \r\n________________________________________________________________ \r\n1. Where turnover Rs.25,000 plus  \r\n exceeds Rs.5,000,000  0.5% of the \r\n but does not exceed turnover exceeding \r\n Rs. 10,000,000 Rs.5 ,000,000 \r\n \r\n2. Where turnover Rs. 50,000 plus \r\n exceeds 0.75% of the \r\n Rs.10,000,000 turnover exceeding \r\n   Rs.10,000,000. \r\n(c)  The retailer shall not be entitled to claim any adjustment of withholding tax \r\ncollected or deducted under any head during the year: \r\n  Provided that turnover chargeable to tax under this section shall not include the sale of \r\ngoods on which tax is deducted or deductible under clause (a) of sub -section (1) of section \r\n153.” \r\nChapter IX – Minimum Tax ______________________________ \r\n \r\n220 \r\n \r\n1[  ] \r\n \r\n2[113C. Alternative Corporate Tax .- (1) Notwithstanding anything contained in \r\nthis Ordinance, for tax year 2014 and onwards, tax payable by a company 3[in \r\nrespect of income which is subject to tax under Division II of Part I  of the First \r\nSchedule or minimum tax under any  of the provisions of this Ordinance”] shall be \r\nhigher of the Corporate Tax or Alternative Corporate Tax. \r\n \r\n(2) For the purposes of this section.- \r\n \r\n(a) “Accounting Income” means the accounting profit before tax for \r\nthe tax year, as disclosed in the financial st atements or as \r\nadjusted under sub -section (7) or sub -section (11) excluding \r\nshare from the associate recognized under equity method of \r\naccounting; \r\n(b) \"Alternative Corporate Tax\" means the tax at a rate of \r\nseventeen per cent of a sum equal to accounting income  less \r\nthe amounts, as specified in sub-section (8), and determined in \r\naccordance with provisions of sub-section (7) hereinafter; \r\n \r\n4[“(c) “corporate tax” means higher of tax payable by the company  \r\nunder Division II of Part I of the First Schedule and minimu m \r\ntax payable under any of the provisions of this Ordinance.”]  \r\n \r\n(3) The sum equal to accounting income, less any amount to be excluded \r\nthere from under sub -section (8), shall be treated as taxable income for the \r\npurpose of this section. \r\n \r\n(4) The excess of Alternative Corporate Tax paid over the Corporate Tax \r\npayable for the tax year shall be carried forward and adjusted against the tax \r\npayable under Division II of Part I of the First Schedule, for following year. \r\n \r\n                                            \r\n1Section 113B omitted by the Finance Act, 2016. The omitted section reads as follows:- \r\n“113B.   Minimum tax on land developers.— (1) Subject to this Ordinance, where a person derives \r\nincome from the business of development and sale of residential, commercial or other plots, he shall \r\npay minimum tax1[at the rate of two per cent of the value of land notified by any authority for the purpose \r\nof stamp duty]. The Federal Government may also specify the mode, manner and time of payment of \r\nsuch amount of tax. \r\n (2)  The tax paid under this section shall be minimum tax on the income of the developer \r\nfrom the sale of such residential, commercial or other plots sold or booked.\"] \r\n2Section 113C inserted by the Finance Act, 2014. \r\n3Inserted by the Finance Act, 2015 \r\n4 Clause (c) Substituted by the Finance Act, 2015. The substituted clause (c) read as follows: -\r\n“Corporate Tax” means total tax payable by the company, includi ng tax payable on account of \r\nminimum tax and final taxes payable, under any of the provisions of this Ordinance but not including \r\nthose mentioned in sections 8, 161 and 162 and any amount charged or paid on account of default \r\nsurcharge or penalty and the tax payable under this section. \r\nChapter IX – Minimum Tax ______________________________ \r\n \r\n221 \r\n \r\n(5) If the excess tax, as mentioned in sub -section (4), is not wholly \r\nadjusted, the amount not adjusted shall be carried forward to the following tax year \r\nand adjusted as specified in sub -section (4) in that year, and so on, but the said \r\nexcess cannot be carried forward to more than ten tax years immediately \r\nsucceeding the tax year for which the excess was first computed. \r\n \r\nExplanation.- For the purpose of this sub -section the mechanism for \r\nadjustment of excess of Alternative Corporate Tax over Corporate Tax, specified \r\nin this section, shall not prejudice or affect the entitlement of the taxpayer regarding \r\ncarrying forward and adjustment of minimum tax referred to in section 113 of this \r\nOrdinance. \r\n(6) If Corporate Tax or Alternative Corporate Tax is enhanced or reduced \r\nas a result of any amendment, or as a result of any order under the Ordinance, the \r\nexcess amount to be carried forward shall be reduced or enhanced accordingly.  \r\n(7) For the purposes of determining the “Accounting Income”, expenses \r\nshall be apportioned between the amount to be excluded from accounting income \r\nunder sub-section (8) and the amount to be treated as taxable income under sub -\r\nsection (2).  \r\n(8) The following amounts shall be excluded from accounting income for \r\nthe purposes of computing Alternative Corporate Tax:- \r\n(i) exempt income; \r\n \r\n1[“(ii)  income which is subject to tax other than under Division II of \r\nPart I of the First Schedule or minimum tax under any of the \r\nprovisions of this Ordinance;”;] \r\n \r\n(xii) income subject to tax credit under section 65D 2[,65E and 100C] \r\n \r\n3[    ] \r\n \r\n(9) The provisions of this section shall not apply to taxpayers chargeable \r\nto tax in accordance with the provisions contained in the Fourth, Fifth and Seventh \r\nSchedules. \r\n \r\n                                            \r\n1Sub-Clause (ii) substituted by Finance Act, 2015. The substituted clause read as follows:- \r\n (ii) income subject to tax under section 37A and final tax chargeable under sub -section (7) of \r\n section 148, section 150, sub -section (3) of section 153, sub -section (4) of sections 154, 156 \r\n and sub-section (3) of section 233;”  \r\n2The word and figure “and 65E” substituted by the Finance Act, 2015 \r\n3 Sub-clause (iv) and (v) omitted by Finance Act, 2015. The omitted clause read as follows:-  \r\n“(iv) income subject to tax credit under section 100C;” \r\n “(v) income of the company subject to clause (18A) of Part-II of the Second Schedule;” \r\nChapter IX – Minimum Tax ______________________________ \r\n \r\n222 \r\n \r\n(10) Tax credit under 1[sections 64B and]  65B shall be allowed against \r\nAlternative Corporate Tax. \r\n \r\n(11) The Commissioner may make adjustments and proceed to compute \r\naccounting income as per historical accounting pattern after providing an \r\nopportunity of being heard.”;] \r\n \r\n 2[Explanation.— For the removal of doubt, it is clarified that taxes paid or \r\npayable other than payable under Division II of Part I of the First Schedule shall \r\nremain payable in accordance with the mode or manner prescribed under the \r\nrespective provisions of this Ordinance.] \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n                                            \r\n1The words “section” substituted by Finance Act, 2015. \r\n2Added by Finance Act, 2015. \r\nChapter X – Procedure__________________________________ \r\n \r\n223 \r\nCHAPTER X \r\nPROCEDURE \r\n \r\nPART I  \r\nRETURNS \r\n \r\n114. Return of income.  — (1) Subject to this Ordinance, the following persons \r\nare required to furnish a return of income for a tax year, namely:– \r\n \r\n1[(a)    every company;] \r\n \r\n2[(ab) every person (other than a company) whose taxable income for the \r\nyear exceeds the maximum amount that is not chargeable to tax \r\nunder this Ordinance for the year;3[or]] \r\n \r\n4[(ac)  any non-profit organization as defined in clause (36) of section 2; 5[ ]  \r\n \r\n6[    ]  \r\n7[    ] \r\n \r\n8[(ae) every person whose income for the year is subject  to final taxation \r\nunder any provision of this Ordinance;]    \r\n \r\n                                            \r\n1Clause (a) substituted by the Finance Act, 2003. The substituted clause (a) read as follows:  \r\n“(a) Every company and any other person whose taxable income for the year exceeds the \r\nmaximum amount that is not chargeable to tax under this Ordinance for the year; and” \r\n2 Inserted by the Finance Act, 2003. \r\n3Inserted by the Finance Act, 2011. \r\n4 Inserted by the Finance Act, 2006. \r\n5The word “and” omitted by the Finance Act, 2011. \r\n6Clause (ad) Inserted by the Finance Act, 2006. \r\n7 Clause (ad) omitted by the Finance Act, 2021. The omitted clause read as follows: \r\n    “(ad)  any welfare institution approved under clause (58) of Part I of the Second Schedule;” \r\n8Added through Finance Act, 2020 \r\nChapter X – Procedure__________________________________ \r\n \r\n224 \r\n \r\n \r\n1[(b)  any person not covered by clause 2[(a), (ab), (ac) or (ad)] who,— \r\n \r\n(i)  has been charged to tax in respect of any of the two preceding \r\ntax years; \r\n \r\n(ii)  claims a loss carried forward un der this Ordinance for a tax \r\nyear;  \r\n \r\n(iii)  owns immovable property with a land area of 3[five hundred] \r\nsquare yards or more or owns any flat located in areas falling \r\nwithin the municipal limits existing immediately before the \r\ncommencement of Local Government laws in the provinces; or \r\nareas in a Cantonment; or the Islamabad Capital Territory 4[;] ] \r\n \r\n5[(iv)  owns immoveable property with a land area of five hundred \r\nsquare yards or more located in a rating area;] \r\n \r\n6[(v) owns a flat having covered area of two thousand square feet or \r\nmore located in a rating area;] \r\n \r\n7[(vi) owns a motor vehicle having engine capacity above 1000 CC; \r\n8[ ] ] \r\n \r\n  9[(vii) has obtained National Tax Number10[; or] ] \r\n \r\n                                            \r\n1Clause (b) substituted by the Finance Act, 2005. The substituted clause (b) read as follows:  \r\n(b) any person not covered by clause (a) or (ab) who – \r\n(i) has been charged to tax in respect of any of the four preceding tax years;  \r\n(ii) claims a loss carried forward under this Ordinance for a tax year;  \r\n(iii) owns immovable property, with a land area of two hu ndred and fifty square yards or more, \r\nlocated in areas falling in the limits of a Metropolitan/Municipal Corporation, a Cantonment \r\nBoard, or the Islamabad Capital Territory or owns any flat; \r\n(iv) owns a motor vehicle (other than a motor cycle) in Pakistan; \r\n(v) subscribes for a telephone including a mobile phone in Pakistan; \r\n(vi) has undertaken foreign travel in the tax year other than travel by a non -resident person or \r\nany travel for the purposes of the Haj, Umrah, or Ziarat; or \r\n(vii) is member of a club wh ere the monthly subscription exceeds five hundred rupees or the \r\nadmission fee exceeds twenty-five thousand rupees. \r\n2The letters and word “(a) or (ab)” substituted by the Finance Act, 2006. \r\n3The words “two hundred and fifty” substituted by “five hundred” through Finance Act, 2019.  \r\n4Full stop substituted by the Finance Act, 2009. \r\n5Inserted by the Finance Act, 2009. \r\n6Inserted by the Finance Act, 2009. \r\n7Inserted by the Finance Act, 2009. \r\n8The word “and” omitted by the Finance Act, 2011. \r\n9Inserted by the Finance Act, 2009. \r\n10Full stop substituted by the Finance Act, 2011. \r\nChapter X – Procedure__________________________________ \r\n \r\n225 \r\n \r\n1[(viii)  is the holder of commercial or industrial connection of \r\nelectricity where the amount of annual bill exceeds rupees \r\n2[five hundred thousand] 3[; 4[ ] ] \r\n \r\n5[(ix)  is 6[a resident person]  registered with any chamber of \r\ncommerce and industry or any trade or business association \r\nor any market committee or any professional b ody including \r\nPakistan Engineering Council, Pakistan Medical and Dental \r\nCouncil, Pakistan Bar Council or any Provincial Bar Council, \r\nInstitute of Chartered Accountants of Pakistan or Institute of \r\nCost and Management Accountants of Pakistan 7[; or] \r\n \r\n8[(x)    9[is a] resident person being an individual required to file foreign \r\nincome and assets statement under section 116A.] \r\n \r\n10[(c)  persons or classes of persons notified by the Board with the approval    \r\nof the Minister in-charge.] \r\n \r\n11[(1A) Every individual wh ose income under the head ‘Income from \r\nbusiness’ exceeds rupees three hundred thousand but does not exceed rupees \r\n12[four hundred thousand] in a tax year is also required to furnish return of income \r\nfrom the tax year.] \r\n \r\n13[(2) A return of income - \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2011. \r\n2The words “one million” substituted by the Finance Act, 2013. \r\n3Full stop substituted by the Finance Act, 2013. \r\n4The word “or” omitted by the Finance Act, 2018. \r\n5Added by the Finance Act, 2013.  \r\n6The words “a resident person” inserted by the Finance Act, 2014. \r\n7Full stop substituted by the Finance Act, 2018. \r\n8Added by the Finance Act, 2018. \r\n9The word “every” substituted through Finance Act, 2020 dated 30th June, 2020 \r\n10 Clause (c) inserted by the Finance, Act 2021. \r\n11Inserted by the Finance Act, 2011. \r\n12The words “three hundred and fifty thousand” substituted by the Finance Act, 2013. \r\n13Sub-section (2) substituted by the Finance Act, 2003. The substituted sub-section (2) read as follows:  \r\n “(2) A return of income – \r\n(a) shall be in the prescribed form; \r\n(b) shall state the information required by the form, including a declaration of the \r\nrecords kept by the taxpayer; \r\n(c) in the case of a person carrying on a business, s hall include an income \r\nstatement, balance sheet, and any other document as may be prescribed for \r\nthe tax year; and \r\n(d) shall be signed by the person or the person’s representative.” \r\nChapter X – Procedure__________________________________ \r\n \r\n226 \r\n \r\n(a)  shall be in the prescribed f orm and shall be accompanied by \r\nsuch annexures, statements or documents as may be \r\nprescribed 1[: \r\n  \r\n  Provided that the Board may prescribe different returns \r\nfor different cla sses of income or persons including persons \r\nsubject to final taxation;]  \r\n \r\n(b)  shall fully state all the relevant particulars or information as \r\nspecified in the form of return, including a declaration of the \r\nrecords kept by the taxpayer; 2[ ] \r\n \r\n(c)  shall be signed by the person, being an individual, or the \r\nperson’s representative where section 172 applies 3[;] ] \r\n \r\n4[(d)  shall be accompanied with evidence of payment of due tax as \r\nper return of income; 5[ ] \r\n \r\n6[(e)  shall be accompanied with a wealth statement as required \r\nunder section 116 7[; and] \r\n8[(f)   shall be ac companied with a foreign income and assets \r\nstatement as required under section 116A.] \r\n \r\n9[(2A)  A return of income filed electronically on the web or any magnetic \r\nmedia or any other computer readable media as may be specified by the Board \r\nshall also be deem ed to be a return for the purpose of sub -section (1); and the \r\nBoard may, by notification in the official Gazette, make rules for determining \r\neligibility of the data of such returns and e-intermediaries who will digitise the data \r\nof such returns and transmit the same electronically to the Income Tax Department \r\nunder their digital signatures 10[and other matters relating to electronic filing of \r\nreturns, statements or documents, etc.]] \r\n \r\n (3) The Commissioner may, by notice in writing, require a person, or a \r\nperson’s representative, as the case may be, to furnish a return of income by the \r\ndate specified in the notice for a period of less than twelve months, where - \r\n \r\n                                            \r\n1Proviso added through Finance Act, 2020 dated 30th June, 2020 \r\n2The word “and” omitted by the Finance Act, 2011. \r\n3Full stop substituted by the Finance Act, 2011. \r\n4Inserted by the Finance Act, 2011. \r\n5The word “and” omitted by the Finance Act, 2018. \r\n6Inserted by the Finance Act, 2011. \r\n7 Full stop substituted by the Finance Act, 2018. \r\n8 Added by the Finance Act 2018.  \r\n9Inserted by the Finance Act, 2005. \r\n10Inserted by the Finance Act, 2007. \r\nChapter X – Procedure__________________________________ \r\n \r\n227 \r\n \r\n(a) the person has died; \r\n \r\n(b) the person has become bankrupt or gone into liquidation; \r\n \r\n(c) the person is about to leave Pakistan permanently; \r\n \r\n1[  ] \r\n \r\n(e) the Commissioner otherwise considers it appropriate to require \r\nsuch a return to be furnished.  \r\n(4) Subject to sub-section (5), the Commissioner may, by notice in writing, \r\nrequire any person who, in the Commissioner’s opinion, is required to file a return \r\nof income under this section for a tax year 2[or assessment year] but who has failed \r\nto do so to furnish a return of income for that year within thirty days from the date \r\nof service of such notice or such longer 3[or shorter] period as may be specified in \r\nsuch notice or as the Commissioner may allow. \r\n \r\n (5) A notice under sub -section (4) may be issued 4[in respect of one or \r\nmore] 5[of the] last five completed tax years 6[or assessment years] 7[:] \r\n \r\n \r\n8[Provided that in case of a person who has not filed return for any \r\nof the last five completed tax years, notice under sub-section (4) may be \r\nissued in respect of one or more of the last ten completed tax years] 9[: \r\n \r\nProvided further that the time-limitation provided under this sub-\r\nsection shall not apply if the Commissioner is satisfied on the basis of \r\nreasons to be recorded in writing that a person who failed to furnish \r\nhis return has foreign income or owns foreign assets.] \r\n \r\n                                            \r\n1 Clause (d) omitted by the Finance Act, 2003. Earlier this was omitted by S.R.O. 633(I)/2002 dated \r\n14.09.2002 which stands rescinded by SRO 608(I )/2003, dated 24.06.2003 with effect from \r\n01.07.2003. The omitted clause (d) read as follows: \r\n“(d) the person is otherwise about to cease carrying on business in Pakistan; or “ \r\n2 Inserted by the Finance Act, 2003. \r\n3Inserted by the Finance Act, 2013. \r\n4 The words “only in respect of the” substituted by Finance Act, 2003. Earlier these were substituted by \r\nS.R.O. 633(I)/2002 dated 14.09.2002 which stands rescinded by SRO 608(I)/2003, dated \r\n24.06.2003 with effect from 01.07.2003. \r\n5Inserted by the Finance Act, 2005. \r\n6Inserted by the Finance Act, 2004. \r\n7Full stop substituted by the Finance Act, 2016. \r\n8 Added by the Finance Act, 2016. \r\n9 Added by the Finance Act, 2021. \r\nChapter X – Procedure__________________________________ \r\n \r\n228 \r\n \r\n  1[(6)  Subject to sub -section (6 A), any person who, having furnished a \r\nreturn, discovers any omission or wrong statement therein, may file revised return \r\nsubject to the following conditions, namely: — \r\n \r\n(a) it is accompanied by the revised accounts or revised audited \r\naccounts, as the case may be [:] 2[  ] \r\n \r\n3[Provided that Commissioner may waive this condition if the \r\nCommissioner is satisfied that filing of revised accounts or audited \r\naccounts is not necessary;] \r\n \r\n(b) the reasons for revision of return, in writing, duly signed, by the \r\ntaxpayers are filed with the return4[; 5[ ] ] \r\n \r\n6[(ba) it is accompanied by approval of the Commissioner in writing for \r\nrevision of return; and] \r\n \r\n7[(c)  taxable income declared is not less than and loss declared is not more \r\nthan income or loss, as the case may be , determined by an order \r\nissued under sections 121, 122, 122A, 8[ ] 129, 132, 133 or 221:- \r\n \r\nProvided that if any of the above conditions is not fulfilled, the \r\nreturn furnished shall be treated as an invalid return as if it had not \r\nbeen furnished] 9[:] \r\n \r\n                                            \r\n1 Sub-section (6) substituted by the Finance Act, 2010. The substituted provision has been made effective \r\nfrom 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \r\nmade through Finance (Amendment) Ordinance, 2009 which was re -promulgated as Finance \r\n(Amendment) Ordinance, 2010 and remained effective till 05.06. 2010. The substituted sub-section \r\n(6) read as follows: \r\n “(6) Subject to sub-section (6A), any person who, having furnished a return, discovers any omission or \r\nwrong statement therein, may file revised return subject to the following conditions, namely:- \r\n(a) it is accompanied by the revised accounts or revised audited accounts, as the case may \r\nbe; and \r\n(b) the reasons for revision of return, in writing, duly signed, by the taxpayers are filed with \r\nthe return.” \r\n2The word “and” omitted by the Finance Act, 2012. \r\n3 Added by the Finance Act, 2021. \r\n4Substituted by the Finance Act, 2012. \r\n5The word “and” omitted by the Finance Act, 2013. \r\n6Inserted by the Finance Act, 2013. \r\n7Added by the Finance Act, 2012. \r\n8The expression “122C,” omitted by the Finance Act, 2017. \r\n9 Substituted by Finance Act, 2015. \r\nChapter X – Procedure__________________________________ \r\n \r\n229 \r\n \r\n1[Provided further that the condition specified in clause (ba) \r\nshall not apply if revised return is filed within sixty days of filing of \r\nreturn: \r\n \r\nProvided also that where the Commissioner has not made an \r\norder of approval in writing, for revision of return, before the expiration \r\nof sixty days from the date when the revision of return was sought, the \r\napproval required under clause (ba) shall be deemed to have been \r\ngranted by the Commissioner, and condition specified in clause (ba) \r\nshall not apply: \r\n \r\n2[Provided also that condition specified in clause (ba) shall not \r\napply and the approval required thereunder shall be deemed to have \r\nbeen granted by the Commissioner, if- \r\n \r\n(a) the Commissioner has not made an order of approval in \r\nwriting, for revision of return, before th e expiration of sixty days from \r\nthe date when the revision of return was sought; or \r\n \r\n(b) taxable income declared is more than or the loss declared \r\nis less than the income or loss, as the case may be, determined under \r\nsection 120] 3[: \r\n \r\n“Provided also that the C ommissioner shall grant approval in \r\ncase of a bonafide omission or wrong statement.] \r\n \r\n4[(6A) If a taxpayer 5[files]  a revised return voluntarily along with deposit of \r\nthe amount of tax short paid or amount of tax  sought to be evaded along with the \r\ndefault surcharge, whenever it comes to his notice, before receipt of notice under \r\nsections 177 or sub-section(9) of 122, no penalty shall be recovered from him: \r\n \r\nProvided that in case the taxpayer 6[deposits] the amount of tax as \r\npointed out by the Commissioner during the audit or before the issuance of \r\nnotice under sub-section (9) of section 122, he shall deposit the amount of \r\ntax sought to be evaded, the default surcharge and twenty -five per cent of \r\nthe penalties leviable under the Ordinance along with the revised return: \r\n \r\n                                            \r\n1Added by Finance Act, 2015. \r\n2 Proviso substituted by the Finance Act, 2016. Substituted proviso reads as follows:- \r\n“ Provided further that the mode and manner for seeking the revision shall be as prescribed by the Board.”  \r\n3 Proviso added through Finance Act, 2020 \r\n4 Added by the Finance Act, 2010. \r\n5The words “wishes to file” substituted by the Finance Act, 2011. \r\n6The words “wishes to deposit” substituted by the Finance Act, 2011. \r\nChapter X – Procedure__________________________________ \r\n \r\n230 \r\n \r\nProvided further that in case the taxpayer 1[revises] the return after  \r\nthe issuance of a show cause notice under sub -section (9) of section 122, \r\nhe shall deposit the amount of tax sought to be evaded, default surcharge \r\nand fifty per cent of the leviable penalties under the Ordinance along with \r\nthe revised return and thereafter, the show cause notice shall stand abated.] \r\n \r\n (7) Every return purporting to be made or signed by, or on behalf of a \r\nperson shall be treated as having been duly made by t he person or with the \r\nperson’s authority until the person proves the contrary. \r\n2[   ]  \r\n 3[114A. Business bank account. — (1) Every taxpayer shall declare to the \r\nCommissioner the bank account utilized by the taxpayer for business transactions.  \r\n  (2)  Busine ss bank account shall be declared through original or modified \r\nregistration form prescribed under section 181.] \r\n                                            \r\n1 The words “wishes to revise” substituted by the Finance Act, 2011. \r\n2New section 114A added through Finance Act, 2020 dated 30th June, 2020 \r\n3 Section 114A substituted by the Finance Act, 2021. The substituted section read as follows: \r\n“114A. Taxpayer’s profile.-(1) Subject to this Ordinance, the following persons shall furnish a profile,  \r\nnamely:- \r\n(a) every person applying for registration under section 181; \r\n(b) every person deriving income chargeable to tax under the head, “Income from \r\nbusiness”; \r\n(c) every person whose income is subject to final taxation; \r\n(d) any non-profit organization as defined in clause (36) of section 2; \r\n(e) any trust or welfare institution; or \r\n(f) any other person prescribed by the Board. \r\n(2) A taxpayer’s profile- \r\n(a) shall be in the prescribed form and shall be accompanied by such annexures, \r\nstatements or documents as may be prescribed; \r\n(b) shall fully state, in the specified form and manner, the relevant particulars of – \r\n(i) bank accounts; \r\n(ii) utility connections; \r\n(iii) business premises including all manufacturing, storage or retail outlets \r\noperated or leased by the taxpayer; \r\n(iv) types of businesses; and \r\n(v) such other information as may be prescribed; \r\n(c) shall be signed by the person being an individual, or the person’s representative \r\nwhere section 172 applies; and \r\n(d) shall be filed electronically on the web prescribed by the Board. \r\n (3) A taxpayer’s profile shall be furnished,- \r\n(a) on or before the 31 st day of December, 2020 in case of a person registered \r\nunder section 181 before the 30th day of September, 2020; and \r\n(b) within ninety days registration in case of a person not registered under section \r\n181 before the 30th day of September, 2020. \r\n(4) A taxpayer’s profile shall be updated within ninety days of change in any of the relevant  \r\nparticulars of information as mentioned in clause (b) of sub-section (2).] \r\nChapter X – Procedure__________________________________ \r\n \r\n231 \r\n \r\n1[114B. Powers to enforce filing of returns. — (1) Notwithstanding anything \r\ncontained in any other law for the time being in force, the Board sha ll have the \r\npowers to issue income tax general order in respect of persons who are not \r\nappearing on active taxpayers’ list but are liable to file return under the provisions \r\nof the Ordinance. \r\n \r\n(2) The income tax general order issued under sub -section (1) m ay entail any \r\nor all of the following consequences for the persons mentioned therein, namely: – \r\n \r\n(a) disabling of mobile phones or mobile phone SIMS; \r\n(b) discontinuance of electricity connection; 2[  ]   \r\n(c) discontinuance of gas connection3[; or \r\n(d)  restriction on foreign travel from the country for a citizen of Pakistan, \r\nexcluding persons holding National Identity Card for Overseas \r\nPakistanis (NICOP), minors, students, persons proceeding abroad for \r\nHajj or Umrah  and such other classes of persons as notifi ed by the \r\nBoard.] \r\n  \r\n(3) The Board or the Commissioner having jurisdiction over the person \r\nmentioned in the income tax general order may order restoration of mobile phones, \r\nmobile phone SIMS and connections of electricity and gas, in cases where he is \r\nsatisfied that —  \r\n \r\n(a) the return has been filed; or  \r\n(b) person was not liable to file return under the provisions of the \r\nOrdinance.  \r\n(4) No person shall be included in the general order under sub -section (1) \r\nunless following conditions have been met with, namely:– \r\n  \r\n(a) notice under sub-section (4) of section 114 has been issued; \r\n(b) date of compliance of the notice under sub -section (4) of section 114 \r\nhas elapsed; and  \r\n(c) the person has not filed the return. \r\n  \r\n(5) The action under this section shall not preclude any oth er action \r\nprovided under the provisions of the Ordinance.] \r\n \r\n4[114C. Restriction on economic transactions by certain persons. — (1) \r\nNotwithstanding anything contained in any law for the time being in force, —  \r\n                                            \r\n1 New section 114B added through Finance Act, 2022. \r\n2 The word “or” omitted by the Finance Act, 2024. \r\n3 Full stop substituted and clause (d) added by the Finance Act, 2024. \r\n4 Section 114C inserted by Finance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n232 \r\n \r\n(a) any application, by any ineligible person, for booking, purchase or \r\nregistration of a motor vehicle of the value exceeding the threshold given in \r\nFifteenth Schedule, shall not be accepted or processed by any manufacturer \r\nof a motor vehicle or vehicle registering authority of Excise and Taxation \r\nDepartment, as the case may be;  \r\n \r\n(b) any application or request by any ineligible person, to any authority \r\nresponsible for registering, recording or attesting transfer of any immovable \r\nproperty, of the value exceeding the threshold given in Fifteenth Schedul e, \r\nshall not be accepted or processed by such authority;  \r\n \r\n(c) Any person authorized to open and maintain an account in respect of \r\nsecurities, units of mutual fund or similar investment, shall not open an \r\naccount or maintain such account if the total inves tment by an ineligible \r\nperson in any such account exceeds the threshold specified in Fifteenth \r\nSchedule; and  \r\n \r\n(d) a banking company shall not allow cash withdrawal from any of the bank \r\naccount of any person, exceeding the threshold as specified in Fifteen th \r\nSchedule.  \r\n \r\n(2) The provisions of sub -section (1), shall not apply on transactions \r\nmade by a non -resident person or a public company except that mentioned in \r\nclause (d) of sub-section (1).  \r\n \r\n(3) The sources of investment and expenditure statement filed by the \r\nperson and sufficient resources mentioned in sub -section (5), shall not be \r\nconstrued as nature and source of income for the purposes of section 111.  \r\n \r\n(4) For the purposes of this section, –  \r\n \r\n(a) “eligible person” shall mean a person who has filed –  \r\n \r\n(i) a return of income for the tax year immediately preceding \r\nthe year of transaction mentioned in sub -section (1) and \r\nhas sufficient resources in the wealth statement in case \r\nof an individual, or financial statement in case of a \r\ncompany or an associat ion of persons, as the case may \r\nbe, for such transaction; or  \r\n \r\n(ii) sources of investment and expenditure statement \r\ndeclaring sufficient resources and furnishing explanation \r\nthereof for a particular purchase or investment \r\ntransaction covered in clauses (a) , (b) and (c) of sub -\r\nsection (1):  \r\nChapter X – Procedure__________________________________ \r\n \r\n233 \r\n \r\nProvided that in case of an individual, the eligible person \r\nshall include his immediate family members.;  \r\n \r\n(b)  “immediate family members ” in respect of an individual, shall \r\ninclude his parents, spouse and dependent children;  \r\n \r\n(c) “ineligible person” shall mean a person who is not an eligible \r\nperson as defined in clause (a) of this sub-section;  \r\n \r\n(d) “sources of investment and expenditure statement ” shall mean \r\na declaration by a person filed on the Board‘s web portal, \r\nspecifying the sources of funds for making such transaction; \r\nand  \r\n \r\n(e) ”sufficient resources” shall mean one hundred and thirty percent \r\nof the cash and equivalent assets comprising cash \r\ndenominated in local or foreign currency, fair market value of \r\ngold, net realizable value of stocks, bonds, receivables or any \r\nother cash equivalent asset as may be prescribed, declared by \r\na person either in his sources of investment and expenditure \r\nstatement, or wealth statement filed for the latest tax year and \r\nin the case of  a company or association of persons, cash  and \r\nequivalent assets, declared in the financial statements attached \r\nwith the income tax return for the latest tax year:  \r\n \r\nProvided that where an asset mentioned in sub -section \r\n(1), other than clause (d) of this s ub-section, has been \r\npurchased by way of exchange of capital assets already \r\ndeclared in the wealth statement, or financial statement, or \r\nsources of investment and expenditure statement, the disposal \r\nof such capital assets shall be treated to be part of cas h \r\nequivalent assets to the extent of the value mentioned in the \r\nagreement.  \r\n \r\n(5) All or any of the restrictions or limitations imposed on the ineligible \r\nperson under this section shall come into force on such date as the Federal \r\nGovernment may, by notifica tion in official Gazette, appoint with such reductions \r\nand enhancements in the thresholds specified in the Fifteenth Schedule as \r\ndeemed appropriate.] \r\n115. Persons not required to furnish a return of income. —1[  ] \r\n                                            \r\n1Sub-section (1) and the proviso there under omitted by the Finance Act, 2013. The omitted sub-\r\nsection (1) and the proviso read as follows:  \r\n “(1) Where the entire income of a taxpayer in a tax year consists of income chargeable under \r\nthe head “Salary”, Annual Statement of Deduction of Income Tax from Salary, filed by the employer \r\nChapter X – Procedure__________________________________ \r\n \r\n234 \r\n \r\n1[   ] \r\n \r\n (3) The following persons shall n ot be required to furnish a return of \r\nincome for a tax year solely by reason of 2[sub-clause (iii) 3[, (iv),(v) and (vi)] ] of \r\nclause (b) of sub-section (1) of section 114 – \r\n \r\n \r\n(a) A widow; \r\n \r\n(b) an orphan below the age of twenty-five years; \r\n \r\n(c) a disabled person; or \r\n \r\n(d) in the case of ownership of immovable property, a non-resident \r\nperson. \r\n \r\n \r\n 4[  ] \r\n \r\n 5[  ] \r\n 6[  ] \r\n 7[  ] \r\n                                            \r\nof such taxpayer, in prescribed form, the same shall, for the purposes of this Ordinance, be treated \r\nas a return of income furnished by the taxpayer under section 114: \r\nProvided that where salary income, for the tax year is five hundred thousand \r\nrupees or more, the taxpayer shall file return of income electronically in the prescribed \r\nform and it shall be accompanied by the proof of deduction or payment of tax and wealth \r\nstatement as required under section 116.” \r\n1 Sub-section (2) omitted by the Finance Act, 2004. Omitted sub-section (2) read as follows:  \r\n  “(2) Clause (b) of sub-section (1) shall not apply to a person whose declared income for the \r\ntax year, or whose last declared or assessed income, is less than two hundred thousand rupees.” \r\n2The words, brackets and figures “sub-clauses (iii) through (vii)” substituted by the Finance Act, 2008. \r\n3Inserted by the Finance Act, 2017 \r\n4Sub-section (4) omitted by Finance Act, 2020. The omitted sub-section  (4) read as follows:  \r\n (4)  Any person who is not obliged to furnish a return for a tax year because all the person’s income is subject \r\nto final taxation under sections 5, 6, 7, 148, 151 and 152, sub-section (3) of section 153, sections 154, 156 \r\nand 156A, sub-section (3) of section 233 or sub-section (3) of section 234A shall furnish to the Commissioner \r\na statement showing such particulars relating to the person’s income for the tax year in such form and verified \r\nin such manner as may be prescribed. \r\n5Sub-section(4A) omitted through Finance Act, 2020. The omitted sub-section (4A) read as follows: \r\n(4A)  Any person who, having furnished a statement, discovers any omission or wrong statement \r\ntherein, he may, without prejudice to any other liability which he may incur under this Ordinance, \r\nfurnish a revised statement for that tax year, at any time within five years from the end of the \r\nfinancial year in which the original statement was furnished. \r\n6 Sub-section (4B) omitted by the Finance Act, 2010. The omitted sub-section (4B) read as follows: \r\n   “(4B)  Every person (other than a company) filing statement under sub -section (4), falling \r\nunder final tax regime (FTR) and has paid tax amounting to twenty thousand rupees or more for the \r\ntax year, shall file a wealth statement along with reconciliation of wealth statement.” \r\n7Sub section (5) and (6) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted sub-\r\nsections read as follows: \r\n \r\n \r\n \r\n \r\nChapter X – Procedure__________________________________ \r\n \r\n235 \r\n \r\n116. Wealth statement. — (1)  1[The] Commissioner may, by notice in writing, \r\nrequire any person 2[being an individual] to furnish, on the dat e specified in the \r\nnotice, a statement (hereinafter referred to as the \"wealth statement\") in the \r\nprescribed form and verified in the prescribed manner giving particulars of — \r\n \r\n(a) the person’s total assets  and liabilities  3[assets including foreign \r\nassets and liabilities including foreign liabilities] as on the date or dates \r\nspecified in such notice; \r\n(b) the total assets  and liabilities  4[assets including foreign assets and \r\nliabilities including foreign liabilities]  of the person’s spouse, minor \r\nchildren, and other dependents as on the date or dates specified in \r\nsuch notice; \r\n5[Explanation. – For removal of doubt, it is clarified that assets of spouse \r\nshall only be included in the wealth statement of the person if the spouse is \r\ndependent;] \r\n \r\n(c) any assets 6[including foreign assets] transferred by the person \r\nto any other person during the period or periods specified in \r\nsuch notice and the consideration for the transfer; 7[ ] \r\n \r\n(d) the total expenditures incurred by the person, and the person’s \r\nspouse, minor children, and other dependents during the period \r\nor periods specified in the notice and t he details of such \r\nexpenditures 8[; and] \r\n \r\n  9[(e)  the reconciliation statement of wealth.] \r\n                                            \r\n \r\n \r\n \r\n(5)     Subject to sub-section (6), the Commissioner may, by notice in writing, require any person  who, \r\nin his opinion, is required to file a prescribed statement under this section for a tax year but who has failed to do so, \r\nto furnish a prescribed statement for that year within thirty days from the date of service of such notice or such longer \r\nperiod as may be specified in such notice or as he may, allow.  \r\n(6)    A notice under sub-section (5) may be issued in respect of one or more of the last five \r\ncompleted tax years. \r\n1 The words, brackets, figure, comma and word “Subject to sub-section (2)”. The” substituted by the \r\nFinance Act, 2007. \r\n2 Inserted by the Finance Act, 2013. \r\n3 The words “assets and liabilities” substituted by the Finance Act, 2024. \r\n4 The words “assets and liabilities” substituted by the Finance Act, 2024. \r\n5 The words “assets and liabilities” substituted by the Finance Act, 2024. \r\n6 Words inserted by the Finance Act, 2024. \r\n7The word “and” omitted by the Finance Act, 2009. \r\n8Full stop substituted by the Finance Act, 2009. \r\n9Inserted by the Finance Act, 2009. \r\nChapter X – Procedure__________________________________ \r\n \r\n236 \r\n \r\n (2) Every resident taxpayer1[being an individual] filing a return of income \r\nfor any tax year 2[  ]  shall furnish a wealth statement 3[and wealth reconciliation \r\nstatement] for that year along with such return 4[:] \r\n \r\n5[Provided that every member of an association of persons 6[  ] \r\nshall also furnish wealth statement and wealth reconciliation statement \r\nfor the year along with return of income of the association.] \r\n \r\n7[8[  ]  ]  \r\n 9[(3) Where a person, who has furnished a wealth statement, discovers any \r\nomission or wrong statement therein, he may, without prejudice to any liability \r\nincurred by him under any provision of this Ordinance, furnish a revised wealth \r\nstatement 10[along with the revised wealth reconciliation and the reasons for filing \r\nrevised wealth statement,] 11[under intimation to the Commissioner in the \r\nprescribed form and manner,]at any time before 12[the receipt of notice under sub-\r\nsection (9) of section 122, for the tax year to which it relates 13[:] \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2011. \r\n2The words and comma “whose last declared or assessed income or the declared income for the year, \r\nis one million rupees or more” omitted by the Finance Act, 2013. Note: This amendment shall be \r\neffective for the tax year 2013 and onwards. \r\n3Inserted by the Finance Act, 2009. \r\n4Full stop substituted by the Finance Act, 2011. \r\n5Inserted by the Finance Act, 2011. \r\n6The words and commas “ whose share from the income of such association of persons, before tax, \r\nfor the year is one million rupees or more” omitted by the Finance Act, 2013. Note: This amendment \r\nshall be effective for the tax year 2013 and onwards. \r\n7 Sub-section (2A) substituted by the Finance Act, 2011. The substituted sub-section (2A) read as \r\nfollows: \r\n“(2A) Where a person files a return in  response to a provisional assessment under section \r\n122C, he shall furnish a wealth statement for that year along with that return and such wealth \r\nstatement shall be accompanied by a wealth reconciliation statement and an explanation of sources \r\nof acquisition of assets specified therein.” \r\n8Section (2A) omitted by Finance Act 2017,the omitted section is read as under \r\n“(2A)  “Where a person, being an individual or an association of persons, files a return in response to \r\na provisional assessment order under section 122C, such return shall be accompanied by wealth \r\nstatement along with a wealth reconciliation statement and an explanation of source of acquisition \r\nof assets specified therein in the case of an individual and wealth statements of all members in the \r\ncase of an association of persons and such wealth statements shall be accompanied by wealth \r\nreconciliation statements and explanation of source of acquisition of assets specified therein.” \r\n9Added by the Finance Act, 2003.  \r\n10 Inserted by the Finance Act, 2013. \r\n11The expressions inserted through Finance Act, 2020 dated 30th June, 2020 \r\n12The expression “an assessment, for the tax year to which it relates, is made under sub-section (1) \r\nor sub-section (4) of section 122”substituted by the Finance Act, 2017. \r\n13Full stop substituted by colon and provision and explanation inserted through Finance Act, 2020 \r\ndated 30th June, 2020 \r\nChapter X – Procedure__________________________________ \r\n \r\n237 \r\n \r\n Provided that where the Commissioner is of the opinion that the revision \r\nunder this sub-section is not for the purpose of correcting a bona fide omission or \r\nwrong statement, he may declare such revision as void through an order in writing \r\nafter providing an opportunity of being heard. \r\n \r\n Explanation.- For the removal of doubt it is clarified that wealth statement \r\ncannot be revised after the expiry of five years from the due date of filing of return \r\nof income for that tax year.]  \r\n 1[  ] \r\n \r\n2[116A.   Foreign income and assets statement. – (1) Every resident taxpayer \r\nbeing an individual having foreign income of not less than ten thousand United   \r\nStates dollars or having foreign assets with a value of  not less than one hundred \r\nthousand United States dollars shall furnish a statement, hereinafter referred to  as \r\nthe foreign income and assets statement, in the prescribed form and verified  in \r\nthe prescribed manner giving particulars of— \r\n \r\n(a) the person’s total foreign assets and liabilities as on the last day of the \r\ntax year; \r\n \r\n(b) any foreign assets transferred by the person to any other person \r\nduring the tax year and the consideration for the said transfer; and \r\n \r\n(c) complete particulars of foreign income, the expenditure derived during \r\nthe tax year and the expenditure wholly and necessarily for the \r\npurposes of deriving the said income. \r\n \r\n(2) The Commissioner may by a notice in writing require any person being \r\nan individual who, in the opinion of the Commissioner on the basis of  reasons to \r\nbe recorded in writing, was required to furnish a foreign income and assets \r\nstatement under sub-section (1) but who has failed to do so to furnish the foreign \r\nincome and assets statement on the date specified in the notice.] \r\n \r\n117. Notice of discontinued business. — (1) Any person discontinuing a \r\nbusiness shall give the Commissioner a notice in writing to that effect within fifteen \r\ndays of the discontinuance. \r\n \r\n (2) The person discontinuing a business shall, under the provisions of this \r\nOrdinance or on being required by the Commissioner by notice, in writing, furnish \r\na return of income for the period commencing on the first day of the tax year in \r\nwhich the discontinuance occurred and ending on the date of discontinuance and \r\nthis period shall be treated as a separate tax year for the purposes of this \r\nOrdinance. \r\n                                            \r\n1 Sub section (4) omitted through Finance Act, 2020 dated 30th June 2020 omitted sub-section read \r\nas follows; \r\n(4) Every person (other than a company5 [or an association of persons])filing statement under \r\nsub-section (4) of section 115, falling under final tax regime (FTR) 6 [ ] shall file a wealth statement \r\nalong with reconciliation of wealth statement.] \r\n2 Inserted by the Finance Act 2018. \r\nChapter X – Procedure__________________________________ \r\n \r\n238 \r\n \r\n (3) Where no notice has been given under sub -section (1) but the \r\nCommissioner has reasonable grounds to believe  that a business has \r\ndiscontinued or is likely to discontinue, the Commissioner may serve a notice on \r\nthe person who has discontinued the business or is likely to discontinue the \r\nbusiness to furnish to the Commissioner within the time specified in the noti ce a \r\nreturn of income for the period specified in the notice. \r\n \r\n (4) A return furnished under this section shall be treated for all purposes \r\nof this Ordinance as a return of income, including the application of Section 120.  \r\n \r\n118. Method of furnishing return s and other documents.  — (1) A return of \r\nincome under section 114, 1[  ] 2[  ] 3[,] a wealth statement under section 116 4[or a \r\nforeign income and assets statement under 116A,  if applicable] shall be furnished \r\nin the prescribed manner. \r\n \r\n (2) A return of i ncome 5[under section 114  6[  ] ] of a company shall be \r\nfurnished — \r\n \r\n(a) in the case of a company with a tax year ending any time \r\nbetween the first day of January and the thirtieth day of June, \r\non or before the thirty -first day of December next following t he \r\nend of the tax year to which the return relates; or \r\n \r\n(b) in any other case, on or before the thirtieth day of September next \r\nfollowing the end of the tax year to which the return relates. \r\n7[(2A) Where salary income for the tax year is five hundred thousand rupees \r\nor more, the taxpayer shall file return of income electronically in the prescribed \r\nform and it shall be accompanied by the proof of deduction or payment of tax and \r\nwealth statement as required under section 116  8[or a foreign income and assets \r\nstatement under 116A, if applicable”] ] 9[:]  \r\n \r\n                                            \r\n1The words, figure and comma “an employer’s certificate under section 115,” omitted by the Finance \r\nAct, 2013.  \r\n2The expressions “ a statement required under sub-section (4) of section 115” omitted through \r\nFinance Act, 2020 dated 30th June, 2020 \r\n3The word ‘or” ssubstituted by Finance Act, 2018. \r\n4 Inserted by the Finance Act, 2018. \r\n5Inserted by the Finance Act, 2003. \r\n6 The expressions “or a statement required under sub-section (4) of section 115” omitted through \r\nFinance Act, 2020 dated 30th June, 2020 \r\n7Inserted by the Finance Act, 2013. \r\n8Added the Finance Act, 2018. \r\n9Substituted by Finance Act, 2015 \r\nChapter X – Procedure__________________________________ \r\n \r\n239 \r\n \r\n1[“Provided that the Board may amend the condition specified in this \r\nsub-section or direct that the said condition shall not apply for a tax year.”;] \r\n \r\n2[ *  ]  \r\n 3[(3) A return of income for any person (other than a company) 4[  ] 5[  ] shall \r\nbe furnished as per the following schedule, namely:— \r\n \r\n6[(a)  in the case of 7[ ]  a return required to be filed through e -portal \r\nin the case of a salaried individual, on or before the 8[30th day of \r\nSeptember] next following the end of the tax year to which the \r\nstatement or return relates; or] \r\n \r\n(b) in the case of a return of income for any person (other than a \r\ncompany), as described under clause (a), on or before the 30th \r\nday of September next following the end of the tax year to which \r\nthe return relates.]  \r\n \r\n (4) A wealth statement shall be furnished by the due date specified in the \r\nnotice requiring the person to furnish such statement or, where the person is \r\nrequired to furnish the wealth statement for a tax year under sub -section (2) of \r\nsection 116, by the due date for furnishing the return of income for that year.  \r\n \r\n                                            \r\n1Substituted by Finance Act, 2015 \r\n2Inserted by the S.R.O. 791(I)/2015 dated 10.08.2015. \r\n “ *Notification \r\nIn exercise of the powers conferred by the proviso to sub -section (2A) of section 118 of the Income Tax \r\nOrdinance, 2001 (XLIX of 2001), the Federal Government is pleased to direct that all individuals earning taxable \r\nsalary income shall be liable to file their Income Tax returns electronically from Tax Year 2015 onwards . The \r\ncondition of five hundred thousand rupees or more, as provided in the said sub -section shall not be applicable \r\nuntil further orders.”] \r\n3Sub-section (3) substituted by the Finance Act, 2010. The substituted sub-section (3) read as follows: \r\n“(3) A return of income for any person (other than a company), an employer certificate of an \r\nindividual or a statement required under sub-section (4) of section 115 shall be furnished on or before \r\nthe thirtieth day of September next following the end of the tax year to which the return, certificate or \r\nstatement relates.” \r\n4The words and comma “an Annual Statement of deduction of income tax from salary, filed by the \r\nemployer of an individual” omitted by the Finance Act, 2013.  \r\n5 The expressions “or a statement required under sub-section (4) of section 115” omitted through \r\nFinance Act, 2020 dated 30th June, 2020 \r\n6Clause (a) substituted by the Finance Act, 2013. The substituted clause (a) read as follows:  \r\n“(a)  in the case of an Annual statement of deduction of income tax from salary, filed by the \r\nemployer of an individual, return of income through e -portal in the case of a salaried \r\nperson or a statement required under sub -section (4) of section 115, on or before the \r\n31st day of August next following the end of the tax yea r to which the return, Annual \r\nStatement of deduction of income tax from salary, filed by the employer or statement \r\nrelates.” \r\n7 The expression “a statement required under sub-section (4) of section 115 or” omitted through \r\nFinance Act, 2020 dated 30th June, 2020 \r\n8The expression “31stday of August” substituted through Finance Act, 2019. \r\nChapter X – Procedure__________________________________ \r\n \r\n240 \r\n \r\n (5) A return required to be furnished by a notice issued under section 117 \r\nshall be furnished by the due date specified in the notice. \r\n \r\n (6) Where a taxpayer is n ot borne on the National Tax Number Register \r\nand fails to file an application in the prescribed form and manner with the taxpayer’s \r\nreturn of income 1[  ], such return 2[  ] shall not be treated as a return  3[  ] furnished \r\nunder this section. \r\n \r\n119. Extension of time for furnishing returns and other documents.— (1)  A \r\nperson required to furnish — \r\n \r\n(a) a return of income under section 114 or 117; \r\n \r\n  4[  ] \r\n \r\n5[  ]  \r\n \r\n(d) a wealth statement under section 116, \r\n \r\nmay apply, in writing, to the Commissioner for an ex tension of time to furnish the \r\nreturn, 6[  ] or statement, as the case may be. \r\n \r\n (2) An application under sub -section (1) shall be made by the due date \r\nfor furnishing the return of income, 7[  ] or 8[  ] statement to which the application \r\nrelates. \r\n (3) Where an application has been made under sub -section (1) and the \r\nCommissioner is satisfied that the applicant is unable to furnish the return of \r\nincome, 9[ ]  or 10[ ] statement to which the application relates by the due date \r\nbecause of — \r\n \r\n(a) absence from Pakistan;  \r\n(b) sickness or other misadventure; or \r\n(c) any other reasonable cause, \r\n                                            \r\n1The words “or employer’s certificate” omitted by the Finance Act, 2013. \r\n2The words “or certificate” omitted by the Finance Act, 2013. \r\n3The words “or certificate” omitted by the Finance Act, 2013. \r\n4 Clause (b) omitted by the Finance Act, 2013. The omitted clause (b) read as follows: \r\n“(b) an employer’s certificate under section 115;” \r\n5 Clause (c) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted clause read as \r\nfollows:” (c) a statement required under sub-section (4) of section 115; or”. \r\n6The word and comma “certificate,” omitted by the Finance Act, 2013. \r\n7The words and comma “employer’s certificate,” omitted by the Finance Act, 2013.  \r\n8The word “wealth” omitted by the Finance Act, 2002 \r\n9The words and comma “employer’s certificate,” omitted by the Finance Act, 2013.  \r\n10 The word “wealth” omitted by the Finance Act, 2002 \r\nChapter X – Procedure__________________________________ \r\n \r\n241 \r\n \r\nthe Commissioner may, by 1[order], in writing, grant the applicant an extension of \r\ntime for furnishing the return, 2[  ] or statement, as the case may be. \r\n \r\n (4) An extension of time under sub-section (3) should not exceed fifteen \r\ndays from the due date for furnishing the return of income, employer’s certificate, \r\nor 3[ ] statement, as the case may be, unless there are exceptional circumstances \r\njustifying a longer extension of time4[:] \r\n \r\n5[Provided that where the Commissioner has not granted extension for \r\nfurnishing return under sub-section (3) or sub-section (4), the Chief Commissioner \r\nmay on an application made by the taxpayer for extension or further extension, as \r\nthe case may be,  grant extension or further extension for a period not exceeding \r\nfifteen days unless there are exceptional circumstances justifying a longer \r\nextension of time.] \r\n \r\n 6[  ] \r\n (6) An extension of time granted under sub-section (3) shall not 7[, for the \r\npurpose o f charge of 8[default surcharge ]under sub -section (1) of section \r\n205,]change the due date for payment of income tax under section 137. \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n                                            \r\n1 Substituted for the word “notice” by the Finance Act, 2002 \r\n2The word and comma “certificate,” omitted by the Finance Act, 2013. \r\n3The word “wealth” omitted by the Finance Ordinance, 2002 \r\n4Full stop substituted by the Finance Act, 2017. \r\n5Added by the Finance Act, 2017. \r\n6Sub-section (5) omitted by the Finance Act, 2002. The omitted sub-section (5) read as follows: \r\n“(5)  An applicant dissatisfied with a decision under sub -section (3) may challenge the \r\ndecision only under the Part III of this Chapter.” \r\n7 Inserted by the Finance Act, 2002 \r\n8The words “additional tax” substituted by the Finance Act, 2010. Th e substituted provision has been \r\nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \r\nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re -promulgated \r\nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010.  \r\nChapter X – Procedure__________________________________ \r\n \r\n242 \r\n \r\nPART II \r\nASSESSMENTS \r\n1[120. Assessments.—(1) Where a taxpayer has furnished a complete return of \r\nincome (other than a revised return under sub-section (6) of section 114) for a tax \r\nyear ending on or after the 1st day of July, 2002,— \r\n \r\n(a)  the Commissioner shall be taken to have made an assessment of \r\ntaxable income for that tax year, and the tax due thereon  2[equal to \r\nthe respective amounts adjusted under sub-section (2A)] 3[  ] ; and  \r\n \r\n(b)  the return shall be taken for all purposes of this Ordinance to be an \r\nassessment order issued to the taxpayer by the Commissioner on the \r\nday the 4[adjustments were made under sub-section (2A)] 5[  ] 6[return \r\nwas furnished] 7[: \r\n \r\n  Provided that until the date specified under the fourth proviso to \r\nsub-section (2A) is notified, this subsection shall be in force as if sub-\r\nsection (2A) is not in operation: \r\n \r\nProvided further that once t he date under the fourth proviso to \r\nsub-section (2A) is notified, clauses (a) and (b) shall only apply when \r\nthe provisions of sub-section (2A), if invoked, are first complied with: \r\n \r\nProvided further once compliance is made under the second \r\nproviso,—  \r\n \r\n(i) the adjusted amount under sub-section (2A) shall be construed \r\nto be the tax payable and due under clause (a); and  \r\n                                            \r\n1 Section 120 substituted by the Finance Act, 2003. The substituted section 120 read as follows:  \r\n“120. Assessments.- Where a taxpayer has furnished a return of income (other than a revised return \r\nunder sub-section (6) of section 114) for a tax year ending on or after the 1st day of July, 2002, – \r\n(a) the Commissioner shall be taken to have made an assessment of the taxable \r\nincome of the taxpayer for the year and the tax due thereon, equal to those \r\nrespective amounts specified in the return; and \r\n(b) the taxpayer’s return shall be taken for all purposes of this Ordinance to be an \r\nassessment order issued to the taxpayer by the Commissioner on the day the \r\nreturn was furnished.” \r\n2 The expression inserted by the Finance Act, 2025. \r\n3 The expression “, equal to the respective amounts adjusted under sub -section (2A)” omitted by the \r\nFinance Act, 2021. Earlier this omission was made through Income Tax (Amendment) Ordinance, \r\n2021. \r\n4 The expression inserted by the Finance Act, 2025. \r\n5 The expressions “return was furnished” substituted through Finance Act, 2020 \r\n6 The expression “ adjustments were made under sub -section (2A)” substituted by the Finance Act, \r\n2021. ” substituted by the Finance Act, 2021. Earlier the substitution was made through Income Tax \r\n(Amendment) Ordinance, 2021. \r\n7 Full stop substituted and provisos added by the Finance Act, 2021. Earlier the substitution and \r\naddition was made through Income Tax (Amendment) Ordinance, 2021. \r\n \r\nChapter X – Procedure__________________________________ \r\n \r\n243 \r\n \r\n  \r\n(ii) the date of the compliance under sub -section (2A) shall be the \r\ndate for the purposes of clause (b).] \r\n \r\n1[(1A) Notwithstanding the provi sions of sub-section (1), the Commissioner \r\nmay 2[conduct audit of the income tax affairs of a person] under section 177 and \r\nall the provisions of that section shall apply accordingly.] \r\n \r\n (2)  A return of income shall be taken to be complete if it is in accordance \r\nwith the provisions of sub-section (2) of section 114. \r\n \r\n 3[(2A) A return of income furnished under sub-section (2) of section 114 shall \r\nbe processed through automated system to arrive at correct amounts of total \r\nincome, taxable income and tax payable by making adjustments for-  \r\n \r\n (i) any arithmetical error in the return; \r\n \r\n(ii) any incorrect claim, if such incorrect claim is apparent from any \r\ninformation in the return; \r\n \r\n(iii) disallowance of any loss, deductible allowance or tax credit under \r\nParts VIII, IX and X respectively of Chapter III; and \r\n \r\n(iv) disallowance of carry forward of any loss under clause (b) of sub -\r\nsection (I)of section 182A:  \r\n \r\n  Provided that no such adjustments shall be made unless a \r\nsystem generated notice is given to the taxpayer  specifying the \r\nadjustments intended to be made: \r\n  \r\n  Provided further that the response received from the taxpayer, \r\nif any, shall be considered before making any adjustment, and in a \r\ncase where no response is received within th irty days of the issue of \r\nsuch notice, adjustments shall be made. \r\n \r\n  Provided also that where no such adjustments have been made \r\nwithin six month of filing of return, the amounts specified in the return \r\nas declared by the taxpayer shall be deemed to have been taken as \r\n                                            \r\n1 Inserted by the Finance Act, 2005. \r\n2The words “select a person for an audit of his income tax affairs” substituted by the Finance Act, 2010. \r\nThe substituted provision has been made effective from 05.06.2010 by sub -clause (77) of clause 8 \r\nof the Finance Act, 2010. Earlier the substitution was made through Finance (Amendment) \r\nOrdinance, 2009 which was re -promulgated as Finance (Amendment) Ordinance, 2010 and \r\nremained effective till 05.06.2010. \r\n3New sub-section (2A) inserted through Finance Act, 2020 dated 30th June, 2020 \r\nChapter X – Procedure__________________________________ \r\n \r\n244 \r\n \r\nadjusted amou nts on the day the return was filed and the taxpayer \r\nshall be intimated automatically through Iris] 1[: \r\n \r\n  Provided also that the provisions of this sub-section shall apply \r\nfrom the date notified by the Federal Board of Revenue in the official \r\nGazette.]  \r\n  \r\n (3)  Where the return of income furnished is not complete, the \r\nCommissioner shall issue a notice to the taxpayer informing him of the deficiencies \r\n(other than incorrect amount of tax payable on taxable income, as specified in the \r\nreturn, or short paymen t of tax payable) and directing him to provide such \r\ninformation, particulars, statement or documents by such date specified in the \r\nnotice. \r\n \r\n (4)  Where a taxpayer fails to fully comply, by the due date, with the \r\nrequirements of the notice under sub -section (3), the return furnished shall be \r\ntreated as an invalid return as if it had not been furnished. \r\n \r\n (5)  Where, in response to a notice under sub -section (3), the taxpayer \r\nhas, by the due date, fully complied with the requirements of the notice, the return \r\nfurnished shall be treated to be complete on the day it was furnished and the \r\nprovisions of sub-section (1) shall apply accordingly. \r\n \r\n (6)  No notice under sub -section (3) shall be issued after the 2[expiry of \r\none hundred and eighty days from the end of the financial year in which return was \r\nfurnished], and the provisions of sub-section (1) shall apply accordingly.]  \r\n \r\n 3[(7) For the purposes of this section,- \r\n \r\n(a) “arithmetical error” includes any wrong or incorrect calculation \r\nof tax payable including any minimum or final tax payable. \r\n \r\n(b) “an incorrect claim apparent from any information in the return” \r\nshall mean a claim, on the basis of an entry, in the return,- \r\n \r\n(i) of an item, which is inconsistent with another entry of the \r\nsame or some other item in such return; \r\n(ii) regarding any tax payment which is not verified from the \r\ncollection system; or \r\n(iii) in respect of a deduction, where such deduction exceeds \r\nspecified statutory limit which may have been expressed \r\nas monetary amount or percentage or ratio or fraction.] \r\n                                            \r\n1 Full stop substituted and proviso added by the Finance Act, 2021. Earlier the substitution and   \r\naddition was made through Income Tax (Amendment) Ordinance, 2021. \r\n2The words “end of the financial year in which return was furnished”  the Finance Act, 2012. \r\n3 New sub-section 7 added through Finance Act, 2020 \r\nChapter X – Procedure__________________________________ \r\n \r\n245 \r\n \r\n1[  ]  \r\n \r\n2[120B. Restriction of proceedings. - (1) Where any person entitled to declare \r\nundisclosed assets, expenditure and undisclosed sales under the Assets \r\nDeclaration Act, 2019 declares such assets, expenditures or sales to pay tax, no \r\nproceedings shall be undertaken under this Ordinance in respect of such \r\ndeclaration. \r\n \r\n (2) Notwithstanding anything contained in any other law, for the time \r\nbeing in force, sub-section (3) of section 216, except the provisions of clauses (a) \r\nand (g) of sub -section (3) of section 216, particulars of the persons making \r\ndeclaration under the Assets Declaration Act, 2019 or any information received in \r\nany declaration made under the said Act shall be confidential.] \r\n \r\n3[121. Best judgement assessment.— (1) Where a person fails to — \r\n                                            \r\n1 Section 120A omitted by the Finance Act, 2013. The omitted section 120A read as follows:  \r\n“120A.Investment Tax on income.—  (1) Subject to this Ordinance, the Board may make a scheme \r\nof payment of investment tax in respe ct of undisclosed income, representing any amount or \r\ninvestment made in movable or immovable assets. \r\n  (2)  Where any person declares undisclosed income under sub-section (1) in accordance with \r\nthe scheme and the rules, the tax on such income called investment tax shall be charged at such rate \r\nas may be prescribed. \r\n  (3)  Where a person has paid tax on his undisclosed income in accordance with the scheme \r\nand the rules, he shall –  \r\n(a) be entitled to incorporate in his books of account such undisclosed income in tangible form; \r\nand \r\n(b) not be liable to pay any tax, charge, levy, penalty or prosecution in respect of such income \r\nunder this Ordinance. \r\n(4)  For the purposes of this section — \r\n(i) “undisclosed income” means any income, including any investment to be deemed \r\nas income under section 111 or any other deemed income, for any year or years, \r\nwhich was chargeable to tax but was not so charged; and \r\n(ii) “investment tax” means tax chargeable on the undisclosed income under the \r\nscheme under sub-section (1) and shall have the same meaning as given in clause \r\n(63) of section 2 of the Income Tax Ordinance, 2001.” \r\n2New Section (120B) inserted though Finance Act, 2019. \r\n3Section 121 substituted by the Finance Act, 2003. The substituted section 121 read as follows: \r\n“121. Assessment of persons who have not furnished a return. - (1)  Where a person \r\nrequired by the Commissioner through a notice] to furnish a return of income for a tax year fails to \r\ndo so by the due date, the Commissioner may, based on any available information and to the best \r\nof the Commissioner’s judgement, make an assessment of the taxable income of the person and \r\nthe tax due thereon for the year.  \r\n(2) As soon as possible after making an assessment under this section, the Commissioner \r\nshall issue, in writing, an assessment order to the taxpayer stating – \r\n(a) the taxable income of the taxpayer for the year; \r\n(b) the amount of tax due; \r\n(c) the amount of tax paid, if any; and \r\n(d) the time, place, and manner of appealing the assessment order. \r\n(3) An assessment order shall only be issued within five years after the end of the tax year, \r\nor the income year, to which it relates.” \r\nChapter X – Procedure__________________________________ \r\n \r\n246 \r\n \r\n1[ ] \r\n \r\n2[  ] \r\n \r\n3[(ab) furnish return of income in response to notice under sub - \r\nsection (3) or sub-section (4) of section 114; or”;]  \r\n \r\n4[(ac) furnish return of income in response to notice under sub-section \r\n(3) of section 117; or] \r\n \r\n(b)  furnish a return as required under section 143 or section 144; \r\nor \r\n \r\n  (c)  furnish the statement as required under section 116; or  \r\n \r\n(d)  produce before the Commissioner, or 5[a special audit panel \r\nappointed under sub-section (11) of section 177 or] any person \r\nemployed by a firm of chartered accountants 6[or a firm of cost \r\nand management accountants] under section 177, accounts, \r\ndocuments and records required to be maintained under section \r\n174, or any other relevant document or evidence that may be \r\nrequired by him for the purpose of making assessment of \r\nincome and determination of tax due thereon, \r\n \r\nthe Commissioner may, based on any available information or material and to the \r\nbest of his judgement, make an assessment of the taxable income 7[or income] of \r\nthe person and the tax due thereon 8[and the assessment, if any, treated t o have \r\nbeen made on the basis of return or revised return filed by the taxpayer shall be of \r\nno legal effect]. \r\n \r\n                                            \r\n1Omitted by the Finance Act, 2010. The omitted clause (a) read as follows: \r\n“(a)  furnish a return of income as required by a notice under sub -section (3) or sub-section (4) \r\nof section 114; or  \r\n2Clause “(aa)” omitted through Finance Act, 2020 dated 30th June, 2020 the omitted clause read as \r\nfollows: “(aa)  furnish a statement as required by a notice under sub-section (5) of section 115; or” \r\n3Inserted by the Finance Act, 2017. \r\n4 Clause (ac) inserted by the Finance Act, 2024. \r\n5Inserted by the Finance Act, 2015 \r\n6 Inserted by the Finance Act, 2010. \r\n7Inserted by the Finance Act, 2010.  \r\n8Inserted by the Finance Act, 2012. \r\nChapter X – Procedure__________________________________ \r\n \r\n247 \r\n \r\n 1[(1A) For the purposes of making a best judgment assessment under sub -\r\nsection ( 1), the Commissioner may determine taxable income on the basis of \r\nsectoral benchmark ratios prescribed by the Board.  \r\n \r\nExplanation.- The expression “sectoral benchmark ratios” means standard \r\nbusiness sector ratios notified by the Board on the basis of comparative cases and \r\nincludes financial ratios, 102 production ratios, gross profit ratio, net profit ratio, \r\nrecovery ratio, wastage ratio and such other ratios in respect of such sectors as \r\nmay be prescribed.] \r\n  \r\n(2)  As soon as possible after making an asses sment under this section, \r\nthe Commissioner shall issue the assessment order to the taxpayer stating — \r\n \r\n  (a)  the taxable income; \r\n  (b)  the amount of tax due; \r\n  (c)  the amount of tax paid, if any; and  \r\n(d)  the time, place and manner of appealing the assessment order. \r\n \r\n (3)  An assessment order under this section shall only be issued within       \r\n2[six] years after the end of the tax year or the income year to which it relates 3[:] \r\n \r\n4[Provided that where notice for furnishing a return of income under \r\nsub-section (4) of section 114 is issued in respect of one or more of the last \r\nten completed tax years in pursuance of proviso to sub-section (5) of section \r\n114 an assessment order under this section shall only be issued  within two \r\nyears from the end of tax year in which such notice is issued.] \r\n \r\n122. Amendment of assessments. — (1) Subject to this section, the \r\nCommissioner may amend an assessment order treated as issued under section \r\n120 or issued under section 121 5[, 6[ ]  7[or 8[ ] , by making such alterations or  \r\nadditions as the Commissioner considers necessary 9[  ].  \r\n \r\n                                            \r\n1 Sub-section (1A) inserted by the Finance Act, 2024. \r\n2 The word “five” substituted by the Finance Act, 2022. \r\n3Full stop substituted by the Finance Act 2018. \r\n4Added by the Finance Act, 2018. \r\n5 Inserted by the Finance Act, 2012. \r\n6The expression “or issued under section 122C,”omitted by the Finance Act, 2017 \r\n7 Inserted by the Finance Act, 2002 \r\n8The words, commas and the figures “issued under section 59, 59A, 62, 63 or 65 of the repealed \r\nOrdinance “  omitted by the Finance Act, 2012. \r\n9The words “to ensure that the taxpayer is liable for correct amount of tax for the tax year to which the \r\nassessment order relates” omitted by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n248 \r\n \r\n 1[(2)  No order under sub -section (1) shall be amended by the \r\nCommissioner after the expiry of five years from the end of the financial year in \r\nwhich the Commissioner has issued or treated to hav e issued the assessment \r\norder to the taxpayer.] \r\n \r\n (3) Where a taxpayer furnishes a revised return under sub -section (6)  \r\n2[or (6A)] of section 114 — \r\n \r\n(a) the Commissioner shall be treated as having made an amended \r\nassessment of the taxable income and tax pa yable thereon as \r\nset out in the revised return; and \r\n \r\n(b) the taxpayer’s revised return shall be taken for all purposes of \r\nthis Ordinance to be an amended assessment order issued to \r\nthe taxpayer by the Commissioner on the day on which the \r\nrevised return was furnished. \r\n \r\n (4) Where an assessment order (hereinafter referred to as the “original \r\nassessment”) has been amended under sub -section (1) 3[,] (3) 4[or (5A)] , the \r\nCommissioner may further amend, 5[as many times as may be necessary,] the \r\noriginal assessment within the later of — \r\n \r\n(a) five years 6[from the end of the financial year in which] the \r\nCommissioner has issued or is treated as having issued the \r\noriginal assessment order to the taxpayer; or \r\n \r\n(b) one year 7[from the end of the financial year in which] the \r\nCommissioner has issued or is treated as having issued the \r\namended assessment order to the taxpayer. \r\n \r\n                                            \r\n1Sub-section (2) substituted by the Finance Act, 2009. The substituted sub-section (2) read as \r\nfollows: \r\n“(2) An assessment order shall only be amended  under subsection (1) within five years after the \r\nCommissioner has issued or is treated as having issued the assessment order on the taxpayer.” \r\n2 Substituted by the Finance Act, 2010. The substituted provision has been made effective from \r\n05.06.2010 by sub -clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \r\nmade through Finance (Amendment) Ordinance, 2009 which was re -promulgated as Finance \r\n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \r\n3The word “or” substituted by the Finance Act, 2010. \r\n4 Inserted by the Finance Act, 2010. Amendment made in sub-section (4) has been validated through \r\nsub-clause (18)(b) of clause (8) of Finance Act, 2010, with effect from the first day of July, 2003. \r\n5Inserted by the Finance Act, 2002 \r\n6The word “after” substituted by the Finance Act, 2009. \r\n7The word “after” substituted by the Finance Act, 2009. \r\nChapter X – Procedure__________________________________ \r\n \r\n249 \r\n \r\n1[(4A) In respect of an assessment made under the repealed Ordinance, \r\nnothing contained in sub-section (2) or, as the case may be, sub -section (4) shall \r\nbe so construed as to have extended or curtailed the time limit specified in section \r\n65 of the aforesaid Ordinance in respect of an assessment order passed under \r\nthat section and the time-limit specified in that section shall apply accordingly.] \r\n \r\n2[(5) An assessment order in respect of tax year, or an assessment year, \r\nshall only be amended under sub-section (1) and an amended assessment for that \r\nyear shall only be further amended under sub -section (4) where, on the basis of \r\n3[audit or on the basis of definite information] the Commissioner is satisfied that — \r\n(i)  any income chargeable to tax has escaped assessment; or \r\n \r\n(ii)  total income has been under -assessed, or assessed at too low \r\na rate, or has been the subject of excessive relief or refund; or  \r\n \r\n(iii)  any amount under a head of income has been mis-classified.] \r\n \r\n4[(5A) Subject to sub-section (9), the Commissioner may 5[, ] 6[  ] amend, or \r\nfurther amend, an assessment order, if he considers that the assessment order is \r\nerroneous in so far it is prejudicial to the interest of revenue.] \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2003. Earlier sub-section (4A) was inserted by S.R.O. 633(I)/2002, dated \r\n14.09.2002 which stands rescinded  by SRO 608(I)/2003, dated 24.06.2003 with effect from \r\n01.07.2003. The said sub-section (4A) read as follows: \r\n      “(4A)  An amended assessment shall only be made within six years of the date of original \r\nassessment.” \r\n2 Sub-section (5) substituted by the Finance Act, 2003. The substituted sub-section (5) read as follows:  \r\n“(5) An assessment order shall only be amended under sub -section (1) and an amended \r\nassessment shall only be amended under subsection (4) where the Commissioner – \r\n(a) is of the view that this Ordinance or the repealed Ordinance] has been incorrectly \r\napplied in making the assessment (including the misclassification  of  an amount  \r\nunder  a  head  of income, incorrect payment of tax with the return of income, an \r\nincorrect claim for tax relief  or rebate, an incorrect claim for exemption of any \r\namount or an incorrect claim for a refund); or \r\n(b) has definite information acquired from an audit or otherwise that the income has \r\nbeen concealed or inaccurate particulars of income have been furnished or th e \r\nassessment is otherwise incorrect.” \r\n3Expressions “definite information acquired from an audit or otherwise,” substituted through Finance \r\nAct, 2020 dated 30th June, 2020 \r\n4Inserted by the Finance Act, 2003. Earlier sub-section (5A) was inserted by S.R.O. 633(I)/2002, dated \r\n14.09.2002 which stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from \r\n01.07.2003. The said sub-section (5A) read as follows:  \r\n“(5A) Where a person does not produce accounts and records, or details of expenditure, \r\nassets and liabilities or any other information required for the purposes of audit under section177, \r\nor does not file wealth statement under section 116, the Commissioner may, based on any available \r\ninformation and to the best of Commissioner’s judgement; make an amended assessment.”  \r\n5Added by Finance Act, 2012. \r\n6 The expression “ after making, or causing to be made, such enquiries as he deems necessary,” \r\nomitted by the Finance Act, 2021. \r\nChapter X – Procedure__________________________________ \r\n \r\n250 \r\n \r\n1[(5AA) In respect of any subject matter which was not in dispute in an appeal the \r\nCommissioner shall have and shall be deemed always to have had the powers to amend \r\nor further amend an assessment order under sub-section (5A).] \r\n \r\n2[(5B) Any amended assessment order under sub-section (5A) may be passed \r\nwithin the time-limit specified in sub-section (2) or sub-section (4), as the case may be.] \r\n \r\n (6) As soon as possible after making an amended assessment under 3[sub-\r\nsection (1), sub-section (4) or sub -section (5A)], the Commissioner shall issue an \r\namended assessment order to the taxpayer stating – \r\n \r\n(a) the amended taxable income of the taxpayer; \r\n \r\n(b) the amended amount of tax due; \r\n \r\n(c) the amount of tax paid, if any; and \r\n \r\n(d) the time, place, and manner of appealing the amended assessment. \r\n \r\n (7) An amended assessment order shall be treated in all respects as an \r\nassessment order for the purposes of this Ordinance, other than for the purposes \r\nof sub-section (1). \r\n \r\n (8) For the purposes of this section, “definite information” includes information \r\non sales or purchases of any goods made by the taxpayer, 4[receipts of the taxpayer \r\nfrom services rendered or any other receipts that may be chargeable to tax under this \r\nOrdinance,]and on the acquisition, possession or disposal of any money, asset, valuable \r\narticle or investment made or expenditure incurred by the taxpayer. \r\n \r\n5[(9) No assessment shall be amended, or further amended, under this section \r\nunless the taxpayer has been provided with an opportunity of being heard] 6[: \r\n \r\n 7[Provided that order under this section shall be made within one year of issuance \r\nof show cause notice or within such extended period as the Commissioner may, for \r\n                                            \r\n1 Added by the Finance Act, 2010. \r\n2 Inserted by the Finance Act, 2003. \r\n3 The words, brackets and figures “sub-section (1) or (4)” substituted by the Finance Act, 2003. \r\n4 Inserted by the Finance Act, 2002 \r\n5 Added by the Finance Act, 2002 \r\n6 Full stop substituted and two provisos added by the Finance Act, 2021. \r\n7 Provisos substituted by the Finance Act, 2025.Substituted provisos read as follows: \r\n   “Provided that order under this section shall be made within one hundred and 7[eighty] days of issuance of \r\nshow cause notice or within such extended period as the Commissioner may, for reasons to be recorded in \r\nwriting, so however, such extended period shall in no case exceed ninety days. This proviso shall be applicable \r\nto a show cause notice issued on or after the first day of July, 2021. \r\nProvided further that any period during which the proceedings are adjourned on account of a stay order or \r\nAlternative Dispute Resolution proceedings or agreed assessment proceedings under section 122D or the \r\ntime taken through adjournment by the taxpayer not exceeding sixty days shall be excluded from the \r\ncomputation of the period specified in the first proviso.]” \r\nChapter X – Procedure__________________________________ \r\n \r\n251 \r\n \r\nreasons to be recorded in writing, so however, such extended period shall in no case \r\nexceed ninety days. This proviso shall be applicable to a show cause notice issued on \r\nor after the first day of July, 2021:  \r\n \r\nProvided further that any period during which the proceedings are adjourned on \r\naccount of a stay or der or Alternative Dispute Resolution proceedings or agreed \r\nassessment proceedings under section 122D or the time taken through adjournment by \r\nthe taxpayer not exceeding sixty days shall be excluded from the computation of the \r\nperiod specified in the first proviso.] ] \r\n \r\n1[122A. Revision by the Commissioner.—(1) The Commissioner may 2[ 3[, suomoto,] \r\n] call for the record of any proceeding under this Ordinance or under the repealed \r\nOrdinance in which an order has been passed by any 4[Officer of Inland Revenue] 5[ ] .  \r\n \r\n (2)  Subject to sub -section (3), where, after making such inquiry as is \r\nnecessary, Commissioner considers that the order requires revision, the Commissioner \r\nmay 6[suomoto] make such revision to the order as the Commissioner deems fit. \r\n \r\n (3)  An order under sub-section (2) shall not be prejudicial to the person to \r\nwhom the order relates. \r\n \r\n (4)  The Commissioner shall not revise any order under sub-section (2) if— \r\n \r\n(a)  an appeal against the order lies to the Commissioner (Appeals) or \r\nto the Appellate Tribunal, the time within which such appeal may be \r\nmade has not expired; or  \r\n \r\n(b)  the order is pending in appeal before the Commissioner (Appeals) \r\nor has been made the subject of an appeal to the Appellate \r\nTribunal.] \r\n \r\n7[(5) If any order is remanded back to any lower authority by the Commissioner \r\nfor modification, alteration, implementation of directions or de novo proceedings, the \r\norder giving effect to the directions of the Commissioner shall be issued within one \r\nhundred and twenty days.] \r\n \r\n \r\n                                            \r\n1Added by the Finance Act, 2003. \r\n2Inserted by the Finance Act, 2004. \r\n3The word “suomoto” substituted by the Finance Act, 2005. \r\n4The words “Taxation Officer” substituted by the Finance Act, 2010. The substituted provision has been \r\nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \r\nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re -promulgated \r\nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010.  \r\n5 The expression “other than the Commissioner (Appeals) 5[if the value of the assessment or, as the \r\ncase may be, refund of the tax does not exceed twenty million rupees,]” omitted by the Finance Act, \r\n2024. \r\n6 Words added by Finance Act, 2004. \r\n7 Added by the Finance Act, 2021. \r\nChapter X – Procedure__________________________________ \r\n \r\n252 \r\n \r\n1[122B. Revision by the 2[Chief Commissioner].—(1) The 3[Chief Commissioner] \r\nmay, either of his own motion or on an application made by the taxpayer for \r\nrevision, call for the record of any proceedings relating to issuance of an exemption \r\nor lower rate certificate with regard to collection or deduction of tax at source under \r\nthis Ordinance, in which an order has been passed by any authority subordinate \r\nto him. \r\n \r\n (2)  Where, after making such inquiry as is necessary, 4[Chief Commissioner] \r\nconsiders that the order requ ires revision, the  5[Chief Commissioner] may, after \r\nproviding reasonable opportunity of being heard to the taxpayer, make such order as \r\nhe may deem fit in the circumstances of the case.]  \r\n \r\n6[7[  ]  ]  \r\n                                            \r\n1 Added by the Finance Act, 2006. \r\n2 The words “Regional Commissioner” Substituted by “Chief Commissioner” by Finance Act, 2014. \r\n3The words “Regional Commissioner” Substituted by “Chief Commissioner” by Finance Act, 2014. \r\n4The words “Regional Commissioner” Substituted by “Chief Commissioner” by Finance Act, 2014 \r\n5 The words “Regional Commissioner” Substituted by “Chief Commissioner” by Finance Act, 2014 \r\n6Substituted by the Finance Act, 2010. The substituted provision has been made effective from 05.06.2010 by \r\nsub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was made through Finance \r\n(Amendment) Ordinance, 2009 which was re-promulgated as Finance (Amendment) Ordinance, 2010 and \r\nremained effective till 05.06.2010. The substituted section “122C” read as follows: \r\n“122C. Provisional assessment. —  (1) Where in response to a notice under sub-section (3) or sub-section \r\n(4) of section 114 a person fails to furnish return of income for any tax year, the Commissioner may, based \r\non any available information or material and to the best of his judgment, make a provisional assessment of \r\nthe taxable income of the person and issue a provisional assessment order specifying the taxable income \r\nassessed and the tax due thereon.  \r\n(2)  Notwithstanding anything contained in this Ordinance, the provisional assessment completed \r\nunder sub-section (1) shall be treated as the final assessment after the expiry of sixty days from the date of \r\nservice of order of provisional assessment and the provisions of this Ordinance shall apply accordingly: \r\nProvided that the provisions of sub-section (2) shall not apply if return of income along with wealth \r\nstatement, wealth reconciliation statement and other documents required under sub-section (2A) of \r\nsection 116 are filed by the person for the relevant tax year during the said period of sixty days.” \r\n7Section 122C omitted by Finance Act 2017,the omitted section 122C is read as under: \r\n“122C. Provisional assessment.—  (1) Where in response to a notice under sub-section (3) or sub-section (4) \r\nof section 114 a person fails to furnish return of income for any tax year, the Commissioner may, based on any \r\navailable information or material and to the best of his judgment, make a provisional assessment of the taxable \r\nincome or income of the person and issue a provisional assessment order specifying the taxable income or \r\nincome assessed and the tax due thereon. \r\n(2)  Notwithstanding anything contained in this Ordinance, the provisional assessment order completed \r\nunder sub-section (1) shall be treated as the final assessment order after the expiry of 7[forty-five] days from the \r\ndate of service of order of provisional assessment and the provisions of this Ordinance shall apply accordingly: \r\n7[“Provided that the provisions of this sub-section shall not apply, if— \r\n(a) return of income along with wealth statement, wealth reconciliation statement and other \r\ndocuments required under sub-section (2A) of section 116 are filed by the person being an \r\nindividual or an association of persons for the relevant tax year during the said period of forty-\r\nfive days; and \r\n(b) the individual or an association of persons presents accounts and documents for \r\nconducting audit of income tax affairs for that tax year: \r\nProvided further that the provisions of sub-section (2) shall not apply— \r\nChapter X – Procedure__________________________________ \r\n \r\n253 \r\n \r\n1[122D. Agreed assessment in certain cases. - (1) Where a taxpayer, in \r\nresponse to a notice under sub -section (9) of section 122, intends to settle his \r\ncase, he may file offer of settlement in the prescribed form before the assessment \r\noversight committee, hereinafter referred to as the Committee, in addition to  filing \r\nreply to the Commissioner. \r\n(2) The Committee after examining the aforesaid offer may call for the \r\nrecord of the case and after affording opportunity of being heard to the taxpayer, \r\nmay decide to accept or modify the offer of the taxpayer through co nsensus and \r\ncommunicate its decision to the taxpayer. \r\n \r\n(3) Where the taxpayer is stratified with the decision of the Committee,- \r\n \r\n(a) the taxpayer shall deposit the amount of tax payable including any \r\namount of penalty and default surcharge as per decision of the \r\nCommittee; \r\n \r\n(b) the Commissioner shall amend assessment in accordance with the \r\ndecision of the Committee after tax payable including any amount of \r\npenalty and default surcharge as per decision of the Committee has \r\nbeen paid; \r\n \r\n(c) the taxpayer shall waive the right to prefer appeal against such amended \r\nassessment; and \r\n \r\n(d) no further proceeding s shall be undertaken under this Ordinance in \r\nrespect of issues decided by the Committee unless the tax as per clause \r\n(c) has not been deposited by the taxpayer. \r\n \r\n(4) Where the Committee has not been able to arrive at a consensus or \r\nwhere the taxpayer is not satisfied with the decision of the Committee, the case \r\nshall be referred back to the Commissioner for decision on the basis of reply of the \r\ntaxpayer in response to notice u nder sub -section (9) of section 122 \r\nnotwithstanding proceedings or decision, if any, of the Committee. \r\n \r\n(5) The Committee shall comprise the following income tax authorities \r\nhaving jurisdiction over the taxpayer, namely:- \r\n \r\n(a) the Chief Commissioner Inland Revenue; \r\n(b) the Commissioner Inland Revenue; and \r\n(c) the Additional Commissioner Inland Revenue. \r\n                                            \r\n(a) to a company, if return of income tax alongwith audited accounts or final accounts, as the \r\ncase may be, for the relevant tax year are filed by the company electronically during the \r\nsaid period of forty-five days; and  \r\n(b) if the company presents accounts and documents for conducting audit of its income tax \r\naffairs for that tax year.” \r\n1 New Section 122D inserted through Finance Act, 2020 dated 30th June, 2020 \r\nChapter X – Procedure__________________________________ \r\n \r\n254 \r\n \r\n \r\n(6) This section shall not apply in cases involving concealment of income \r\nor where interpretation of question of law is involved having effect on other cases. \r\n(7) The Board may make rules regulating the procedure of the Committee \r\nand for any matter connected with, or incidental to the proceedings of the \r\nCommittee.]  \r\n \r\n123. Provisional assessment in certain cases.— (1)  Where a concealed asset \r\nof any person is impounded by any department or agency of the Federal Government \r\nor a Provincial Government, the Commissioner may, at any time before issuing any \r\nassessment order under section 121 or any amended assessment order under section \r\n122, issue to the person a provisional ass essment order or provisional amended \r\nassessment order, as the case may be, for the last completed tax year of the person \r\ntaking into account the concealed asset. \r\n \r\n1[(1A) Where an offshore asset of any person, not declared earlier, is \r\ndiscovered by the Comm issioner or any department or agency of the Federal \r\nGovernment or a Provincial Government, the Commissioner may at any time \r\nbefore issuing any assessment order under sect ion 121 or amended assessment \r\norder under section 122, issue to the person a provision al assessment order or \r\nprovisional amended assessment order, as the case may be, for the last completed \r\ntax year of the person taking into account the offshore asset  discovered.] \r\n \r\n (2) The Commissioner shall finalise a provisional assessment order or a \r\nprovisional amended assessment order as soon as practicable 2[  ].  \r\n \r\n (3) In this section, “concealed asset” means any property or asset which, \r\nin the opinion of the Commissioner, was acquired from any income subject to tax \r\nunder this Ordinance.  \r\n \r\n124. Assessment giving effect to an order.  —  (1)  Except where sub -section \r\n(2) applies, where, in consequence of, or to give effect to, any finding or direction \r\nin any order made under Part III of this Chapter by the Commissioner (Appeals),    \r\n3[if the value of the assessment or, as the case may be, refund of the tax does not \r\nexceed twenty million rupees, ] Appellate Tribunal, High Court, or Supreme Court \r\nan assessment order or amended assessment order is to be issued to any person, \r\nthe Commissioner shall issue the or der within two years from the end of the \r\nfinancial year in which the order of the Commissioner (Appeals),  4[if the value of \r\nthe assessment or, as the case may be, refund of the tax does not exceed twenty \r\nmillion rupees,] Appellate Tribunal, High Court or Supreme Court, as the case may \r\nbe, was served on the Commissioner. \r\n \r\n                                            \r\n1 New subsection 1A inserted through Finance Supplementary (Second Amendment) Act, 2019 \r\n2 The words “after making it” omitted by the Finance Act, 2003. \r\n3 Inserted through The Tax Laws (Amendment) Act, 2024. \r\n4 Inserted through The Tax Laws (Amendment) Act, 2024. \r\nChapter X – Procedure__________________________________ \r\n \r\n255 \r\n \r\n (2) Where, by an order made under Part III of this Chapter by the 1[  ]  \r\nAppellate Tribunal, High Court, or Supreme Court, an assessment order is set \r\naside 2[wholly or partly,] and the Comm issioner 3[or Commissioner (Appeals), as \r\nthe case may be,] 4[if the value of the assessment or, as the case may be, refund \r\nof the tax does not exceed twenty million rupees, ] is directed to 5[pass] a new \r\nassessment order, the Commissioner 6[or Commissioner (Appeals), as the case \r\nmay be,] 7[if the value of the assessment or, as the case may be, refund of the tax \r\ndoes not exceed twenty million rupees, ] shall 8[pass] the new order within 9[one \r\nyear from the end of the financial year in which] the Commissioner 10[or \r\nCommissioner (Appeals), as the case may be,] 11[if the value of the assessment \r\nor, as the case may be, refund of the tax does not exceed twenty million rupees, ] \r\nis served with the order 12[:] \r\n \r\n13[Provided that limitation under this sub -section shall not \r\napply, if an appeal or reference has been preferred, against the order \r\n14[ ], passed by 15[ ] Appellate Tribunal or a High Court.] \r\n \r\n (3) Where an assessment order has been set aside or modified, the \r\nproceedings may commence from the stage next preceding the s tage at which \r\nsuch setting aside or modification took place and nothing contained in this \r\nOrdinance shall render necessary the re -issue of any notice which had already \r\nbeen issued or the re -furnishing or re -filing of any return, statement, or other \r\nparticulars which had already been furnished or filed. \r\n \r\n (4) Where direct relief is provided in an order under section 129 or 132, \r\nthe Commissioner shall issue appeal effect orders within two months of the date \r\nthe Commissioner is served with the order. \r\n \r\n                                            \r\n1 The words “Commissioner (Appeals)” omitted by the Finance Act, 2010. \r\n2Inserted by the Finance Act, 2003. \r\n3Inserted by the Finance Act, 2008. \r\n4 Inserted through The Tax Laws (Amendment) Act, 2024. \r\n5The word “make” substituted by the Finance Act, 2010. \r\n6Inserted by the Finance Act, 2008. \r\n7 Inserted through The Tax Laws (Amendment) Act, 2024. \r\n8The word “make” substituted by the Finance Act, 2010. \r\n9 The words “six months from the date” substituted by the Finance Act, 2002. \r\n10Inserted by the Finance Act, 2008. \r\n11 Inserted through Tax Laws (Amendment) Act, 2024. \r\n12 The full stop substituted by the Finance Act, 2005. \r\n13Inserted by the Finance Act, 2005. \r\n14 The words “setting aside the assessment” omitted by the Finance Act, 2010. \r\n15 The words “a Commissioner (Appeals)” omitted by the Finance Act, 2010. \r\nChapter X – Procedure__________________________________ \r\n \r\n256 \r\n \r\n 1[(4A)    Where the Commissioner (Appeals), Appellate Tribunal, High Court \r\nor Supreme Court has confirmed the tax payable as determined in the order \r\nappealed against no appeal effect order will be required to be issued and the \r\nCommissioner shall proceed to effect recovery.  \r\n \r\n(4B)   Subject to the provisions of sub -section (2) where the Appellate \r\nTribunal, High Court or Supreme Court has partly set aside the order and \r\nconfirmed or modified the order on some other issues that were subject matter of \r\nthe appeal, the Commissioner shall issue an appeal effect order on the prescribed \r\nform determining the tax payable as a result of the confirmation or modification by \r\nthe Appellate Tribunal, High Court or Supreme Court and excluding the tax payable \r\non the matters that have been set aside or remanded and the tax payable on the \r\nbasis of the issues that have been confirmed or modified shall be paid or recovered \r\nunder the provisions of the Ordinance.] \r\n \r\n (5) Where, by any order referred to in sub -section (1), any income is \r\nexcluded — \r\n \r\n(a) from the computation of the taxable income of a taxpayer for \r\nany year and held to be included in the computation of the \r\ntaxable income of the taxpayer for another year; or \r\n \r\n(b) from the computation of the taxable income of one taxpayer and \r\nheld to be included in the computation of the taxable income of \r\nanother taxpayer, \r\n \r\nthe assessment or amended assessment relating to that other tax year or other \r\ntaxpayer, as the case may be, shall be treated as an assessment or amended \r\nassessment to be made in c onsequence of, or to give effect to, a finding or \r\ndirection contained in such order. \r\n \r\n (6) Nothing in this Part shall prevent the issuing of an assessment order \r\nor an amended assessment order to give effect to an order made under Part III of \r\nthis Chapter by the Commissioner (Appeals),  2[if the value of the assessment or, \r\nas the case may be, refund of the tax does not exceed twenty million rupees, ] \r\nAppellate Tribunal, High Court, or Supreme Court.  \r\n \r\n3[(7) The provisions of this section shall in like manner a pply to any order \r\nissued by any High Court or the Supreme Court in exercise of original or appellate \r\njurisdiction.] \r\n \r\n                                            \r\n1 Sub-sections (4A) and (4B) inserted by the Finance Act, 2025. \r\n2 Inserted through Tax Laws (Amendment) Act, 2024. \r\n3Added by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n257 \r\n \r\n1[124A. Powers of tax authorities to modify orders, etc.—(1) Where a question \r\nof law has been decided by a High Court or the Appellate Tribunal in the case of a \r\ntaxpayer, on or after first day of July 2002, the Commissioner may, notwithstanding \r\nthat he has preferred an appeal against the decision of the High Court or made an \r\napplication for reference against the order of the Appellate Tribuna l, as the case \r\nmay be, follow the said decision in the case of the said taxpayer in so far as it \r\napplies to said question of law arising in any assessment pending before the \r\nCommissioner until the decision of the High Court or of the Appellate Tribunal is \r\nreversed or modified.  \r\n \r\n (2)  In case the decision of High Court or the Appellate Tribunal, referred \r\nto in sub -section (1), is reversed or modified, the Commissioner may, \r\nnotwithstanding the expiry of period of limitation prescribed for making any \r\nassessment or order, within a period of one year from the date of receipt of \r\ndecision, modify the assessment or order in which the said decision was applied \r\nso that it conforms to the final decision.] \r\n \r\n125.  Assessment in relation to disputed property.— Where the ownership of \r\nany property the income from which is chargeable to tax under this Ordinance is \r\nin dispute in any Civil Court in Pakistan, an assessment order or amended \r\nassessment order in respect of such income may be issued at any time within one \r\nyear after the end of the financial year in which the decision of the Court is made.  \r\n \r\n126.  Evidence of assessment. — (1)  The production of an assessment order \r\nor a certified copy of an assessment order shall be conclusive evidence of the due \r\nmaking of the assessment and, except in proceedings under Part III of this Chapter \r\nrelating to the assessment, that the amount and all particulars of the assessment \r\nare correct. \r\n \r\n (2) Any 2[order] of assessment or other document purporting to be made, \r\nissued, or executed under this Ordinance may not be – \r\n \r\n(a) quashed or deemed to be void or voidable for want of form; or \r\n \r\n(b) affected by reason of any mistake, defect, or omission therein, \r\n \r\nif it is, in substance and effect, in conformity with this Ordinance and the person \r\nassessed, or intended to be assessed or affected by the document, is designated \r\nin it according to common understanding. \r\n \r\n  \r\n                                            \r\n1 Inserted by the Finance Act, 2002. \r\n2The word “notice” substituted by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n258 \r\n \r\nPART III \r\nAPPEALS \r\n1[  ]  \r\n2[   ] \r\n \r\n127. Appeal to the Commissioner (Appeals). — 3[(1) 4[ ] 5[Any person, other than \r\nState-Owned Enterprise (SO E),] dissatisfied with any order passed by a \r\nCommissioner or an6[Officer of Inland Revenue] under 7[sub-section (2A) of section \r\n120,] section 121,122, 143, 144, 8[162,] 170, 182, 9[  ] 10[or 205], or an order under sub-\r\nsection (1) of section 161 holding a person to be personally liable to pay an amount of \r\ntax, or an order under clause (f) of sub-section (3) of section 172 11[declaring] a person \r\nto be the representative of a non-resident person [or an order giving effect to any finding \r\n                                            \r\n1 Inserted through The Tax Laws (Amendment) Act, 2024. \r\n2 Section 126A omitted by the Finance Act, 2025. The omitted section read as follows: \r\n   “126A. Pecuniary jurisdiction in appeals. — (1) 2[Notwithstanding anything contained in any \r\nother provision of this Ordinance,– ] \r\n(a) an appeal to the Commissioner (Appeals) shall lie where the value of assessment of tax or, \r\nas the case may be, refund of tax does not exceed twenty million rupees; or \r\n(b) an appeal to the Appellate Tribunal Inland Revenue shall lie where the value of assessment \r\nof tax or, as the case may be, refund of tax exceeds twenty million rupees \r\n2[Explanation. – For the purposes of this section value of assessment of tax means the net increase \r\nin tax liability of a person as a result of order sought to be assailed and value of refund means net \r\nreduction in refund as a result of order sought to be assailed.]  \r\n(2) A person or, as the case may be, officer of Inland Revenue aggrieved by an order of \r\nthe Commissioner (Appeals) in Cases under clause (a) of sub-section (1) may file a reference before \r\nthe High Court in accordance with section 133.  \r\n(3) A person or, as the case may be, officer of Inland Revenue aggrieved by an order of \r\nthe Appellate Tribunal in cases under clause (b) of sub -section (1) may file a reference before the \r\nHigh Court in accordance with section 133. \r\n(4) The cases pending before the Commissioner (Appeals) having the value of assessment \r\nof tax or, as the case may be, refund of tax exceeding twenty million rupees shall on 2[or before the \r\n31st day of December], 2024 2[and shall be deemed to have taken effect on and from the 16th day \r\nof June, 2024] stand transferred to the Appellate Tribunal Inland Revenue. \r\n(5) All cases transferred from the Commissioner (Appeals) to the Appellate Tribunal under \r\nsub-section (4) shall be decided by the Appellate Tribunal within the period provided for under section \r\n132 which period shall commence from 2[the date of transfer under sub-section (4).]” \r\n3 Sub-section (1) substituted by the Finance Act, 2002. The substituted sub-section (1) read as follows: \r\n“(1) Any person dissatisfied with any proceeding under this Ordinance in which an order has \r\nbeen issued by a Commissioner of Income Tax (other than the Commissioner (Appeals)) or a \r\ntaxation officer may prefer an appeal to the Commissioner (Appeals) against the order.”  \r\n4 Expression inserted by the Finance Act, 2024. \r\n5 The expression “Subject to section 126A, any] person” substituted by the Finance Act, 2025. \r\n6  The words “Taxation officer” substituted by the Finance Act, 2014. \r\n7 The expressions inserted through Finance Act, 2020 dated 30th June, 2020 \r\n8Inserted by the Finance Act, 2004. \r\n9  The figures and commas “183, 184, 185, 186, 187, 188 and 189” omitted by the Finance Act, 2010. \r\n10The word and figure “or 189” substituted by the Finance Act, 2009. \r\n11The word “treating” substituted by the Finance Act, 2003 \r\nChapter X – Procedure__________________________________ \r\n \r\n259 \r\n \r\nor directions in any ord er made under this Part by the Commissioner (Appeals), \r\nAppellate Tribunal, High Court or Supreme Court], or an order under section 221 refusing \r\nto rectify the mistake, either in full or in part, as claimed by the taxpayer or an order having \r\nthe effect of enhancing the assessment or reducing a refund or otherwise increasing the \r\nliability of the person 1[, 2[ 3[ ] ]may prefer an appeal to the Commissioner (Appeals) \r\nagainst the order] 4[: \r\n \r\n Provided that an aggrieved person under sub-section (1) may have the option to \r\neither file appeal before Commissioner Inland Revenue (Appeals) directly or may \r\nsurrender his right of appeal before Commissioner Inland Revenue (Appeals) and avail \r\nthe next statutory appellate forum by filing the appeal directly before the Appellate \r\nTribunal Inland Revenue.] \r\n  \r\n5[  ]  \r\n \r\n6[(2) No appeal under sub-section (1), shall be made by a taxpayer against \r\nan order of assessment unless the taxpayer has paid the amount of tax due under \r\nsub section (1) of section 137.]  \r\n  \r\n(3) An appeal under sub-section (1) shall — \r\n \r\n(a) be in the prescribed form; \r\n \r\n(b) be verified in the prescribed manner;  \r\n \r\n(c) state precisely the grounds upon which the appeal is made;  \r\n \r\n(d) be accompanied by the prescribed fee specified in sub -section \r\n(4); and \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2011. \r\n2The words “a provisional” substituted by the word “an” by the Finance Act, 2012. \r\n3The expression “except an assessment order under section 122C,” omitted by the Finance \r\nOrdinance, 2017. \r\n4 Full stop substituted and new proviso added by the Finance Act, 2025. \r\n5 Sub-section (2) substituted by the Finance Ordinance, 2002. The substituted sub-section (2) read as \r\nfollows:  \r\n “No appeal may be made by a taxpayer against an assessment unless the amount of tax due under \r\nthe assessment that is not in dispute and fifteen percent of the disputed tax has been paid by the \r\ntaxpayer.”   \r\n6 Sub-section (2) substituted by the Finance Act, 2021. The substituted sub-section (2) read as follows: \r\n“(2) No appeal under sub -section (1), shall be made by a taxpayer against an order of  \r\nassessment unless the taxpayer has paid,— \r\n(a) the amount of tax due under sub-section (1) of section 137 and \r\n(b) no appeal  under sub -section (1) shall be made by a taxpayer against] an order of \r\nassessment unless the taxpayer has paid the amount of tax due under sub-section (1) \r\nof section 137.” \r\nChapter X – Procedure__________________________________ \r\n \r\n260 \r\n \r\n(e) be lodged with the Commissioner (Appeals) within the time set \r\nout in sub-section (5). \r\n \r\n 1[(3A) The Board may prescribe mechanism for electronic filing of the \r\nappeals.] \r\n \r\n (4) The prescribed fee 2[shall be] — \r\n \r\n3[(a) in the case of appeal against an assessment- \r\n \r\n(i) where the appellant is a company, five thousand rupees; or \r\n \r\n(ii) where the appellant is not a company, two thousand and five \r\nhundred rupees; or] \r\n \r\n(b) in any other case — \r\n \r\n (i) where the appellant is a company, 4[five] thousand rupees; or \r\n \r\n(ii) where the appellant is not a company,  5[one thousand] \r\nrupees. \r\n \r\n6[(5)  An appeal shall be preferred to the Commissioner (Appeals) within \r\nthirty days of the following— \r\n \r\n(a)  where the appeal relates to any assessment or penalty, the date \r\nof service of the notice of demand relating to the said assessment \r\nor penalty, as the case may be; and  \r\n \r\n(b)  in any other case, the date on which the order to be appealed \r\nagainst is served.] \r\n \r\n (6) The Commissioner (Appeals) may, upon application in writing by the \r\nappellant, admit an appeal aft er the expiration of the period specified in  \r\nsub-section (5) if the Commissioner (Appeals) is satisfied that the appellant was \r\nprevented by sufficient cause from lodging the appeal within that period. \r\n \r\n                                            \r\n1 Sub-section (3) inserted by the Finance Act, 2021.  \r\n2The word “is” substituted by the Finance Act, 2002 \r\n3 Clause (a) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted clause read \r\nas follows: “(a) in the case of an appeal against an assessment, 3[one thousand rupees]3[ ]; or”   \r\n4 The word “one” substituted through Finance Act, 2020 dated 30th June, 2020 \r\n5 The word “two hundred” substituted through Finance Act, 2020 dated 30th June, 2020 \r\n6Sub-section (5) substituted by the Finance Act, 2002. The substituted sub-section (5) read as follows: \r\n“ \r\n“(5)   An appeal shall be lodged with the Commissioner (Appeals) – \r\n(a) where the appeal relates to an assessment order, within thirty days of the date \r\nof service of the demand relating to the assessment; or \r\n(b) in any other case, within thirty days of the date of service of th e notice of the \r\ndecision or determination appealed against.” \r\nChapter X – Procedure__________________________________ \r\n \r\n261 \r\n \r\n128. Procedure in appeal.— (1)  The Commissioner (Appeals) shall give notice \r\nof the day fixed for the hearing of the appeal to the appellant and to the \r\nCommissioner against whose order the appeal has been made. \r\n \r\n 1[(1A) Where in a particular case, the Commissioner (Appeals) is of the \r\nopinion that the recovery  of tax levied under this Ordinance, shall cause undue \r\nhardship to the taxpayer, he, after affording opportunity of being heard to the \r\nCommissioner against whose order appeal has been made, may stay the recovery \r\nof such tax for a period not exceeding thirty days in aggregate.] \r\n \r\n 2[“(1AA) The Commissioner (Appeals), after affording opportunity of being \r\nheard to the Commissioner against whose order appeal has been made, may stay \r\nthe recovery of such tax for a further period of thirty days, provided that the o rder \r\non appeal shall be passed within the said period of thirty days.”] \r\n \r\n (2) The Commissioner (Appeals) may adjourn the hearing of the appeal \r\nfrom time to time. \r\n \r\n (3) The Commissioner (Appeals) may, before the hearing of an appeal, \r\nallow an appellant to file any new ground of appeal not specified in the grounds of \r\nappeal already filed by the appellant where the Commissioner (Appeals) is \r\nsatisfied that the omission of the ground from the form of the appeal was not wilful \r\nor unreasonable. \r\n \r\n (4) The Commissioner (Appeals) may, before disposing of an appeal, call \r\nfor such particulars as the Commissioner (Appeals) may require respecting the \r\nmatters arising in the appeal or cause further enquiry to be made by the \r\nCommissioner. \r\n \r\n (5) The Commissioner (Appeals) sha ll not admit any documentary \r\nmaterial or evidence which was not produced before the Commissioner unless the \r\nCommissioner (Appeals) is satisfied that the appellant was prevented by sufficient \r\ncause from producing such material or evidence before the Commiss ioner. \r\n \r\n129. Decision in appeal.— (1)  In disposing of an appeal lodged under section \r\n127, the Commissioner (Appeals) may – \r\n \r\n3[(a)  make an order to confirm, modify or annul the assessment order \r\nafter examining such evidence as required by him respecting \r\n                                            \r\n1Inserted by the Finance Act, 2012. \r\n2Inserted by the Finance Act, 2015 \r\n3Clause (a) substituted by the Finance Act, 2005. The original clause (a) read as follows:  \r\n (a) in the case of an appeal against an assessment order – \r\n(i) make an order to set aside the assessment order and direct the Commissioner to make a \r\nnew assessment order in accordance with any directions or recommendations of the \r\nCommissioner (Appeals); or \r\n(ii) make an order to confirm, modify or annul the assessment order; or \r\nChapter X – Procedure__________________________________ \r\n \r\n262 \r\n \r\nthe matters arising in appeal or causing such further enquires to \r\nbe made as he deems fit; or] \r\n \r\n(b) in any other case, make such order as the Commissioner \r\n(Appeals) thinks fit. \r\n \r\n (2) The Commissioner (Appeals) shall not increase the amount of any \r\nassessment order or decrease the amount of any refund unless the appellant has \r\nbeen given a reasonable opportunity of showing cause against such increase or \r\ndecrease, as the case may be. \r\n \r\n (3) Where, as the result of an appeal, any change is made in the \r\nassessment of an association of persons or a new assessment of an association \r\nof persons is ordered to be made, the Commissioner (Appeals) may authorise the \r\nCommissioner to amend accordingly any assessment order made on a member of \r\nthe association and the time limit i n sub-section (2) of section 122 shall not apply \r\nto the making such amended assessment. \r\n \r\n (4) As soon as practicable after deciding an appeal, the Commissioner \r\n(Appeals) shall 1[specify in the order the amount of tax upheld and]  serve 2[  ] his \r\norder on the appellant and the Commissioner 3[:] \r\n \r\n4[Provided that such order shall be passed not later than one hundred and \r\ntwenty days from the date of filing of appeal or within an extended period of sixty \r\ndays, for reasons to be recorded in writing by the Commissioner (Appeals): \r\n \r\nProvided further that any period during which the hearing of an appeal is \r\nadjourned at the request o f the appellant or is postponed due to any appeal or \r\nproceedings or stay order, remand or alternative dispute resolution proceedings or \r\nfor any other reason, shall be excluded in the computation of the aforementioned \r\nperiods.] \r\n \r\n 5[  ] \r\n 6[  ] \r\n \r\n                                            \r\n1The words inserted through Finance Act, 2020 dated 30th June, 2020 \r\n2 The words  “notice of” omitted by the Finance Act, 2002 \r\n3 Full stop substituted by the Finance Act, 2009. \r\n4 Inserted by the Finance Act, 2009. \r\n5Sub-section (5) omitted by the Finance Act, 2012. The omitted sub-section (5) read as follows: \r\n“(5) Where the Commissioner (Appeals) has not made an order on an appeal before the \r\nexpiration of 5[four] months from the end of the month in which the appeal wa s lodged, the relief \r\nsought by the appellant in the appeal shall be treated as having been given and all the provisions of \r\nthis Ordinance shall have effect accordingly. \r\n6Sub-section (6) omitted by the Finance Act, 2012. The omitted sub-section (6) read as follows: \r\n“(6) For the purposes of sub-section (5), any period during which the hearing of an appeal \r\nis adjourned on the request of the appellant shall be excluded in the computation of the period of \r\nfour months referred to in that sub-section.” \r\nChapter X – Procedure__________________________________ \r\n \r\n263 \r\n \r\n 1[  ] \r\n \r\n2[  ] \r\n                                            \r\n1 Sub-section (7) omitted by the Finance Act, 2012. The omitted sub-section (7) read as follows: \r\n“(7) The provisions of sub-section (5) shall not apply unless a notice by the appellant stating \r\nthat no order under sub -section (1) has been made is personally served by the appellant on the \r\nCommissioner (Appeals) not less than thirty days before the expiration of the period of four months.” \r\n2 Section 130 substituted through Tax Laws (Second Amendment) Ordinance, 2019 dated 26 th \r\nDecember, 2019, the substituted section read as follows: \r\n  “130. Appointment of the Appellate Tribunal.—2[(1) There shall be established an Appellate Tribunal to \r\nbe called the Appellate Tribunal Inland Revenue to exercise the powers and perform the functions conferred \r\non the Appellate Inland Revenue tribunal by this Ordinance, \r\n (2) The Inland Revenue Appellate Tribunal shall consist of a chairman and such other judicial \r\nand accountant members as are appointed in such numbers and in the manner as the Prime Minister may \r\nprescribe by the rules.]    \r\n (3) A person may be appointed as a judicial member of the Appellate Tribunal if the person \r\n– \r\n(a)  has exercised the powers of a District Judge and is qualified to be a Judge of the  \r\nHigh Court; 2[ 2[or]  ] \r\n(b)   is or has been an advocate of a High Court and is qualified to be a Judge of the \r\nHigh Court 2[ 2[.]  ] \r\n2[ 2[  ]   ] \r\n 2[(4)  A person may be appointed as an accountant member of an appellate tribunal if,— \r\n(a)  he is an officer of Inland Revenue 2[Service] equivalent to the rank of Regional \r\nCommissioner; 2[  ] \r\n(b)  a Commissioner Inland Revenue or Commissioner Inland Revenue (Appeals) \r\nhaving at least 2[three] years experience as Commissioner or Collector 2[; 2[ ] ]  \r\n2[(c)  a person who has, for a period of not less than ten years, practiced \r\nprofessionally as a chartered accountant within the meaning of the Chartered \r\nAccountants Ordinance, 1961 (X of 1961)2[;or] \r\n2[(d) a person who has, for a period of not less than ten years, practiced \r\nprofessionally as a cost and management accountant within the meaning of  \r\nCost and Management Accountants Act,1966 (XIV of 1966).] \r\n (5) The Federal Government shall appoint a member of the Appellate Tribunal as \r\nChairperson of the Tribunal2[and, except in special circumstances, the person appointed should be a \r\njudicial member]2[ ]. \r\n  (6) The powers and functions of the Appellate Tribunal shall be exercised and discharged \r\nby Benches constituted from members of the Tribunal by the Chairperson of the Tribunal. \r\n \r\n (7) Subject to sub-section (8), a Bench shall consist of not less than two members of the \r\nAppellate Tribunal and shall be constituted so as to contain an equal number of judicial and accountant \r\nmembers, or so that the number of members of one class does not exceed the number of members of \r\nthe other class by more than one.  \r\n  (8) The Federal Government may direct that all or any of the powers of the Appellate \r\nTribunal shall be exercised by — \r\n(a) any one member; or \r\n(b) more members than one, jointly or severally. \r\n2[(8A) Notwithstanding anything contained in sub-sections (7) and (8), the 2[Chairperson] may \r\nconstitute as many benches consisting of a single member as he may deem necessary to hear such \r\ncases or class of cases as the Federal Government may by order in writing, specify.] \r\n2[(8AA) The 2[Chairperson] or other member of the Appellate Tribunal authorized, in this behalf by \r\nthe 2[Chairperson] may, sitting singly, dispose of any case where the amount of tax or penalty involved does \r\nnot exceed 2[one] million rupees.] \r\nChapter X – Procedure__________________________________ \r\n \r\n264 \r\n \r\n1[130. Appellate Tribunal.— (1) There shall be established an Appellate Tribunal \r\nInland Revenue hereinafter called as the Appellate Tribunal to exercise jurisdiction, \r\nconferred on it under this Ordinance:  \r\n \r\nProvided that the existing members including Chairman of the Appellate \r\nTribunal shall continue to hold office, on the same terms and conditions as \r\napplicable to them prior to the commencement of the Tax Laws (Amendment) Act, \r\n                                            \r\n  (9) Subject to sub-section (10), if the members of a Bench differ in opinion on any point, \r\nthe point shall be decided according to the opinion of the majority. \r\n (10)  If the members of a 2[Bench] are equally divided on a point, they shall state the point \r\non which they differ and the case shall be referred by the Chairperson for hearing on that point by one \r\nor more other members of the Appellate Tribunal, and the point shall be decided according to the \r\nopinion of the majority of the members of the Tribunal who have heard the case including those who \r\nfirst heard it. \r\n(11)  If there are an equal number of members of the Appellate Tribunal, the Federal \r\nGovernment may appoint an additional member for the purpose of deciding the case on which there is \r\na difference of opinion. \r\n (12)  Subject to this Ordinance, the Appellate  Tribunal shall have the power to regulate its \r\nown procedure, and the procedure of Benches of the Tribunal in all matters arising out of the discharge \r\nof its functions including the places at which the Benches shall hold their sittings.” \r\n \r\n1 Section 130 substituted through The Tax Laws (Amendment) Act, 2024. The Substituted section \r\nread as follows: \r\n“130.  Appellate Tribunal.- (1) There shall be established an Appellate Tribunal to be called the \r\nAppellate Tribunal Inland Revenue to exercise the powers and perform the functions conferred on the \r\nAppellate Tribunal Inland Revenue by this Act. \r\n(2) The Appellate Tribunal Inland Revenue shall consist of a chairman and such other judicial and \r\naccountant members who shall be appoints in such numbers and in such manner as the Prime Minister \r\nmay prescribe by rules, which may be made and shall take effect notwithstanding anything contained \r\nin section 237 or any other law or rules for the time being in force. \r\n(3) No person shall be appointed as judicial member of an Appell ate Tribunal Inland Revenue \r\nunless he -   \r\n(a) has been a Judge of a High Court; \r\n(b) is or has been a District Judge; or  \r\n(c) is an advocate of a High Court with a standing of not less than ten years; or  \r\n(d) possesses such other qualification as may be prescribed under su b-section (2) of this \r\nsection. \r\n(4) No person shall be appointed as an accountant member of a Appellate Tribunal Inland Revenue \r\nunless he - \r\n (a) is an officer of the Inland Revenue Service equivalent in rank to that of 1[Chief \r\nCommissioner Inland Revenue]; \r\n(b) is a Commissioner Inland Revenue or Commissioner Inland Revenue (Appeals) having \r\nnot less than three years experience as Commissioner 1[  ]; \r\n(c) has for a period of not less than ten years practiced professionally as a chartered \r\naccountant within the m eaning of the Chartered Accountants’ Ordinance, 1961 (X of \r\n1961); or \r\n(d) has for a period of not less than ten years practiced professionally as a cost and \r\nmanagement accountant within the meaning of the Cost and Management Accountant’ \r\nAct, 1966 (XIV of 1966). \r\n(5) The constitution, functioning of benches and procedure of the Appellate Tribunal Inland \r\nRevenue shall be regulated by rules which the Prime Minister may prescribe. \r\n \r\n(6) The rules in respect of the matters covered under this section made prior to commencement of \r\nthe Tax Laws (Second Amendment) Ordinance, 2019 shall continue in force unless amended or \r\nrepealed.]” \r\nChapter X – Procedure__________________________________ \r\n \r\n265 \r\n \r\n2024 ( of 2024), till the completion of their term of office unless resigned or \r\nremoved earlier on the grounds provided in the proviso to sub-section (5).  \r\n \r\n(2) The Appellate Tribunal shall consist of members who shall  be \r\nappointed by the Federal Government in such numbers, in accordance with such \r\nprocedure and on such terms and conditions as the Federal Government may \r\nprescribe by rules, which shall be made and take effect notwithstanding anything \r\ncontained in section 237 of this Ordinance or the Federal Public Service \r\nCommission Ordinance, 1977 (XLV of 1977) or any other law or rules, for the time \r\nbeing in force.  \r\n \r\n(3) A person shall be eligible to be appointed as a member of the \r\nAppellate Tribunal, if he — \r\n \r\n(a) is an advocate of a High Court for not less than fifteen years and \r\npossesses such other qualifications as may be prescribed by rules \r\nunder this section; \r\n  \r\n 1[(b)  has, for an aggregate period of not less than ten years, been –  \r\n \r\n(i) in practice as a chartered accountant, either individually or in a \r\nfirm of the chartered accountants, within the meaning of \r\nChartered Accountants Ordinance, 1961 (X of 1961); or  \r\n \r\n(ii) a chartered accountant, within the meaning of the Chartered \r\nAccountants Ordinance, 1961 (X of 1961),  and has been in \r\nemployment of a chartered accountant in practice as specified \r\nin sub-clause (i) above at least for a period of ten years;] \r\n \r\n(c) has for a period of not less than ten years practiced professionally as \r\na cost and management accountant within  the meaning of the Cost \r\nand Management Accountants Act, 1966 (XIV of 1966);   \r\n(d) is an officer of the Inland Revenue in BS-21 or above; or  \r\n \r\n(e) is an officer of the Inland Revenue in BS -20, having served in such \r\ngrade for three years or more. \r\n \r\n(4) The F ederal Government shall appoint any member possessing \r\nqualifications provided in clauses (a), (13) and (c) of sub -section (3) as Chairman \r\nof the Appellate Tribunal. The Chairman shall hold office for a period of three years \r\nprovided that the Federal Govern ment may reappoint the Chairman for such \r\nfurther term or terms as it may deem appropriate.  \r\n \r\n                                            \r\n1 Clause (b) substituted by the Finance Act, 2025. The substituted clause read as follows: \r\n   “(b) has for a period of not less than ten ye ars practiced professionally as a chartered accountant \r\nwithin the meaning of the Chartered Accountants’ Ordinance, 1961 (X of 1961);”  \r\nChapter X – Procedure__________________________________ \r\n \r\n266 \r\n \r\n(5) The members including the Chairman shall cease to hold office on \r\nattaining the age of sixty -two years provided that the members falling under \r\nclauses (c) and (d) of sub-section (3) shall cease to hold office on attaining the age \r\nof superannuation, under the law regulating their service: \r\n  \r\nProvided that a member including the Chairman may resign or may be \r\nremoved by the Federal Government, on the recommendation o f performance \r\nreview committee, to be constituted by the rules made under sub -section (2), at \r\nany time before the expiry of his term or attaining the age of superannuation, as \r\nthe case may be, on grounds, interalia, of inefficiency or misconduct, as prescribed \r\nby the rules made under sub-section (2).  \r\n \r\n(6) The procedure of the Appellate Tribunal Inland Revenue including \r\nconstitution of benches, case management system, distribution of cases and other \r\nmatters ancillary or incidental thereto shall be regulated  by the rules made under \r\nsub-section (2).] \r\n \r\nChapter X – Procedure__________________________________ \r\n \r\n267 \r\n \r\n1[131. Appeal to the Appellate Tribunal. — 2[(1) Where the taxpayer, or the \r\nCommissioner objects to an order passed by the Commissioner (Appeals), the \r\ntaxpayer or Commissioner may appeal to the Appellate Tribunal against such order \r\nwithin thirty days of the receipt of such order:  \r\n \r\nProvided that the taxpayer may directly appeal against the order of the \r\nOfficer Inland Revenue or the Commissioner as the case may be to the Appellate \r\nTribunal by exercising the option as provided in sub-section (1) of section 127.]  \r\n \r\n(2) An appeal under sub-section (1) shall be — \r\n \r\n(a)  in the prescribed form;  \r\n(b)   verified in the prescribed manner;  \r\n                                            \r\n1 Section 131 substituted through The Tax Laws (Amendment) Act, 2024. The Substituted section \r\nread as follows: \r\n“131. Appeal to the Appellate Tribunal.— (1)  Where the 1[taxpayer] or Commissioner objects to an order \r\npassed by the Commissioner (Appeals), the 1[taxpayer] or Commissioner may appeal to the Appellate \r\nTribunal against such order. \r\n (2) An appeal under sub-section (1) shall be –  \r\n (a)    in the prescribed form; \r\n(b)    verified in the prescribed manner;  \r\n(c) accompanied 1[, except in case of an appeal preferred by the Commissioner,] by the \r\nprescribed fee specified in sub-section (3); and \r\n1[(d) preferred to the Appellate Tribunal within sixty days of the date of service of order of the \r\nCommissioner (Appeals) on the taxpayer or the Commissioner, as the case may be.] \r\n 1[(3)  The prescribed fee shall be five thousand rupees in case of a company and two \r\nthousand rupees in case other than a company.]  \r\n (4) The Appellate Tribunal may, upon application in writing, admit an appeal after the \r\nexpiration of the period specified in clause (d) of sub-section (2) if it is satisfied that the person appealing \r\nwas prevented by sufficient cause from filing the appeal within that period. \r\n 1[(5)  Notwithstanding that an appeal has been filed under this section, tax shall, unless \r\nrecovery thereof has been stayed by the Appellate Tribunal, be payable in accordance with the \r\nassessment made in the case:  \r\n1[Provided that if on filing of application in a particular case, the Appellate Tribunal is of the \r\nopinion that the recovery of tax levied under this Ordinance and upheld by the Commissioner (Appeals), \r\nshall cause undue hardship to the taxpayer, the Tribunal, after affording opportunity of being heard to \r\nthe Commissioner, may stay the recovery of such tax for a period not exceeding one hundred and \r\neighty days in aggregate 1[:] \r\n1[Provided further that where recovery of tax has been stayed under this  section, such stay \r\norder shall cease to have effect on expiration of the said period of one hundred and eighty days \r\nfollowing the date on which the stay order was made and the Commissioner shall proceed to recover \r\nthe said tax: ] \r\n Provided further that in  computing the aforesaid period of one hundred and eighty days, the \r\nperiod, if any, for which the recovery of tax was stayed by a High Court, shall be excluded.]”. \r\n2 Sub-section (1) substituted by the Finance Act, 2025. The substituted sub-section read as follows: \r\n“(1) Subject to section 126A, any person, other than an SOE, aggrieved by any order passed by an \r\nofficer of Inland Revenue or Commissioner or Chief Commissioner or the Board 2[ ] under this \r\nOrdinance or the rules made thereunder may, within thirty  days of the receipt of such order, prefer \r\nan appeal to the Appellate Tribunal or, as the case may be, a reference to the High Court:  \r\nProvided that where sub-section (11) of section 134A apply, an SOE may prefer an appeal \r\nunder this sub-section.” \r\nChapter X – Procedure__________________________________ \r\n \r\n268 \r\n \r\n(c)   accompanied, by the prescribed fee specified in sub-section (3); and  \r\n(d)  prefe rred to the Appellate Tribunal within thirty days of the date of    \r\nservice of order on the taxpayer. \r\n \r\n(3) The prescribed fee shall be twenty thousand rupees in case of a \r\ncompany and five thousand rupees in case other than a company.  \r\n \r\n(4) The Appellate Tr ibunal may, upon application in writing, admit an \r\nappeal after the expiration of the period specified in clause (d) of sub-section (2) if \r\nit is satisfied that the person preferring appeal was prevented by sufficient cause \r\nfrom filing the appeal within that period.  \r\n \r\n(5) Notwithstanding that an appeal has been filed under this section, tax \r\nshall, unless recovery thereof has been stayed by the Appellate Tribunal, be \r\npayable in accordance with the assessment made in the case:  \r\n \r\nProvided that on filing of appli cation in a particular case, the Appellate \r\nTribunal may after affording an opportunity of being heard to the Commissioner \r\nhaving jurisdiction, for reasons to be recorded, stay the recovery of tax for ninety \r\ndays:  \r\n \r\nProvided further that the stay order shal l cease to have effect, and the \r\nCommissioner shall be entitled to recover tax, if the taxpayer does not adhere to \r\nthe hearing schedule for the appeal, as determined by the Appellate Tribunal in \r\naccordance with the rules made under sub-section (2) of section 130:  \r\n \r\nProvided also that where an appeal is not decided within the statutory \r\nperiod by the Appellate Tribunal, the stay order under the second proviso shall not \r\ncease to have effect till finalization of the appeal by the Appellate Tribunal.] \r\n \r\n1[132. Dec ision of appeals by the Appellate Tribunal. — (1) The Appellate \r\nTribunal shall decide the appeal within ninety days of its filing:  \r\n                                            \r\n1 Section 132 substituted through The Tax Laws (Amendment) Act, 2024. The Substituted section read \r\nas follows: \r\n“132. Disposal of appeals by the Appellate Tribunal. — (1)  The Appellate Tribunal may, before \r\ndisposing of an appeal, call for such particulars as it may  require in respect of the matters arising on \r\nthe appeal or cause further enquiry to be made by the Commissioner. \r\n1[(2) The Appellate Tribunal shall afford an opportunity of being heard to the parties to the appeal \r\nand, in case of default by any of the party on the date of hearing, the Tribunal 1[ ] may proceed ex parte \r\nto decide the appeal on the basis of the available record.] \r\n1[(2A) The Appellate Tribunal shall decide the appeal within six months of its filing;] \r\n(3) Where the appeal relates to an assessm ent order, the Appellate Tribunal may, 1[without \r\nprejudice to the powers specified in sub-section (2),]  make an order to — \r\n(a) affirm, modify or annul the assessment order; or \r\n1[  ] \r\n1[(c) remand the case to the Commissioner or the Commissioner (Appeals) for making such \r\nenquiry or taking such action as the Tribunal may direct.] \r\nChapter X – Procedure__________________________________ \r\n \r\n269 \r\n \r\nProvided that appeals pending before the Appellate Tribunal on the date \r\nof commencement of the Tax Laws (Amendment) Act, 2024 (ACT NO. V of 2024), \r\nshall be decided within one hundred and eighty days:  \r\n \r\nProvided further that where an appeal is not decided within the aforesaid \r\nperiod, the Appellate Tribunal shall seek condonation from the Minister of Law and \r\nJustice and such condonation shall not extend beyond ninety days.  \r\n \r\n(2)   At the first hearing of appeal, the Appellate Tribunal shall — \r\n  \r\n(a) bring to the notice of the taxpayer, the provisions relating to \r\nalternative dispute resolution under section 134A of this Ordinance; \r\nand  \r\n \r\n(b) if the taxpayer declines the option of alternative dispute resolution \r\nand wishes to continue with the appeal, fix date or dates for hearing \r\nand decision of the appeal in consultation with the taxpayer and \r\nCommissioner and in accordance with the rules.  \r\n \r\n(3) The Appellate Tribunal shall ensure strict adherence by the taxpayer \r\nand the Commissioner, to the hearing schedule as prescribed, and shall hear and \r\ndecide the appeal on the date or dates fixed, and no adjournment shall be granted, \r\nexcept — \r\n  \r\n(a) where there are compelling reasons for adjournment, to be recorded \r\nby the Appellate Tribunal; and   \r\n(b)  on mandatory payment of such cost as the Appellate Tribunal may \r\ndeem fit, which shall not be less than fifty thousand rupees.  \r\n \r\n(4) Where the appeal relates to an assessment order, the Appellate \r\nTribunal may, without prejudice to the powers specified in sub -section (3), make \r\nan order to —  \r\n                                            \r\n(4) The Appellate Tribunal shall not increase the amount of any assessment 1[or penalty] or \r\ndecrease the amount of any refund unless the taxpayer has been given a reasonable opportun ity of \r\nshowing cause against such increase or decrease, as the case may be.  \r\n(5) Where, as the result of an appeal, any change is made in the assessment of an association of \r\npersons or a new assessment of an association of persons is ordered to be made, th e Appellate \r\nTribunal may authorise the Commissioner to amend accordingly any assessment order made on a \r\nmember of the association and the time limit in sub -section (2) of section 122 shall not apply to the \r\nmaking of such amended assessment. \r\n(6) Where the appeal relates to a decision other than in respect of an assessment, the Appellate \r\nTribunal may make an order to affirm, vary or annul the decision, and issue such consequential \r\ndirections as the case may require. \r\n1[(7) The Appellate Tribunal shall communicate its order to the taxpayer and the Commissioner.] \r\n1[  ] \r\n1[  ] \r\n(10) Save as provided in section 133, the decision of the Appellate Tribunal on an appeal shall be \r\nfinal.” \r\nChapter X – Procedure__________________________________ \r\n \r\n270 \r\n \r\n \r\n(a) affirm, modify or annul the assessment order; \r\n  \r\n(b) remand the case to the Commissioner for making such enqui ry or \r\ntaking such action as the Tribunal may direct; or  \r\n \r\n(c)  make such order as the Appellate Tribunal may deem fit. \r\n \r\n(5)     The Appellate Tribunal shall not increase the amount of any \r\nassessment or penalty or decrease the amount of any refund unless th e taxpayer \r\nhas been given a reasonable opportunity of showing cause against such increase \r\nor decrease, as the case may be.  \r\n \r\n(6)   Where, as the result of an appeal, any change is made in the \r\nassessment of an association of persons or a new assessment of a n association \r\nof persons is ordered to be made, the Appellate Tribunal may authorize the \r\nCommissioner to amend accordingly any assessment order made on a member of \r\nthe association and the time limit in sub -section (2) of section 122 shall not apply \r\nto the making of such amended assessment. \r\n \r\n(7)    Where the appeal relates to a decision other than in respect of an \r\nassessment, the Appellate Tribunal may make an order to affirm, vary or annul the \r\ndecision, and issue such consequential directions as the case ma y require.  \r\n \r\n(8)   The Appellate Tribunal shall communicate its order to the taxpayer \r\nand the Commissioner.  \r\n \r\n(9)  Save as provided in section 133, the decision of the Appellate \r\nTribunal on an appeal shall be final.] \r\n \r\n1[   ] \r\n                                            \r\n1Section 133 substituted by the Finance Act, 2005. The original section 133 read as follows:  \r\n133.  Reference to High Court.- (1)  Where the Appellate Tribunal has made an order on an appeal under \r\nsection132, the taxpayer or Commissioner may, by application in such form and accompanied by such \r\ndocuments as may be prescribed, require the Appellate Tribunal to refer any question of law arising out of such \r\norder to the High Court.  \r\n(2) An application under sub-section (1) shall be made within ninety days of the date on which the taxpayer \r\nor Commissioner, as the case may be, was served with the Appellate Tribunal’s order.  \r\n(3) Where, on an application under sub-section (1), the Appellate Tribunal is satisfied that a question of law \r\narises out of its order, it shall, within ninety days of receipt of the application, draw up a statement of the case \r\nand refer it to the High Court. \r\n(4) Where, on an application under sub-section (1), the Appellate Tribunal refuses to state the case on the \r\nground that no question of law arises, the taxpayer or the Commissioner, as the case may be, may apply to the \r\nHigh Court and the High Court may, if it is not satisfied with the correctness of the decision of the Appellate \r\nTribunal, frame a question of law for its consideration.  \r\n(5) An application under sub-section (4) shall be made within one-hundred and twenty days from the date \r\non which the taxpayer or Commissioner, as the case may be, was served with order of the refusal.  \r\n(6) Sub-sections (10) through (14) shall apply to a question of law framed by the High Court in the same \r\nmanner as they apply to a reference made under sub-section (1). \r\nChapter X – Procedure__________________________________ \r\n \r\n271 \r\n \r\n                                            \r\n(7) If, on an application under sub-section (1), the Appellate Tribunal rejects the application on the ground \r\nthat it is time-barred, the taxpayer or Commissioner may apply to the High Court and, if the High Court is not \r\nsatisfied with the correctness of the Appellate Tribunal’s decision, the Court may require the Appellate Tribunal \r\nto treat the application as made within the time allowed under sub-section (2). \r\n(8) An application under sub-section (7) shall be made within ninety days from the date on which the \r\ntaxpayer or Commissioner, as the case may be, was served with order of the rejection.  \r\n(9) If the High Court is not satisfied that the statement in a case referred under sub-section (3) is sufficient \r\nto enable it to determine the question raised thereby, the Court may refer the case back to the Appellate Tribunal \r\nto make such modification therein as the Court may direct. \r\n(10) A reference to the High Court under this section shall be heard by a Bench of not less than two Judges \r\nof the High Court and, in respect of the reference, the provisions of section 98 of the Code of Civil Procedure, \r\n1908 (V of 1908) shall apply, so far as may be, notwithstanding anything contained in any other law for the time \r\nbeing in force. \r\n(11) The High Court upon hearing a reference under this section shall decide the questions of law raised by \r\nthe reference and deliver judgment thereon containing the grounds on which such decision is founded. \r\n(12) A copy of the judgment of the High Court shall be sent under the seal of the Court and the signature of \r\nthe Registrar to the Appellate Tribunal which shall pass such orders as are necessary to dispose of the case \r\nconformably to such judgment. \r\n(13) The costs of a reference to the High Court under this section shall be at the discretion of the Court. \r\n(14) Where a reference relates to an assessment, the tax due under the assessment shall be payable in \r\naccordance with the assessment, unless recovery of the tax has been stayed by the High Court. \r\n(15) Section 5 of the Limitation Act, 1908 (IX of 1908) shall apply to an application under sub-section \r\n(1). \r\n(16) An application under sub -section (1) by a person other than the Commissioner shall be \r\naccompanied by a fee of one hundred rupees.” \r\nChapter X – Procedure__________________________________ \r\n \r\n272 \r\n \r\n1[133. Reference to High Court.  — (1) 2[ ] 3[Within sixty ] days of the \r\ncommunication of the order of the Appellate Tribunal 4[ ], the aggrieved person or \r\nthe Commissioner may file a reference, in the prescribed form along with a \r\nstatement of the case, before the High Court, stating any question of law 5[ ] arising \r\nout of such order: \r\n \r\nProvided that the applicant shall also file complete record of the Appellate \r\nTribunal 6[ ] 7[ ] within fifteen days of preferring an application under this section. \r\n \r\n                                            \r\n1 Section 133 substituted through The Tax Laws (Amendment) Act, 2024. The Substituted section \r\nread as follows: \r\n“133. Reference to High Court .— (1) Within ninety days of the communication of the order of the \r\nAppellate Tribunal under sub -section (7) of section 132, the aggrieved person or the Commissioner \r\nmay prefer an application, in the prescribed form along with a statement of the case, to the High Court, \r\nstating any question of law arising out of such order. \r\n(2)  The statement to the High Court referred to in sub -section (1), shall set out the facts, the \r\ndetermination of the Appellate Tribunal and the question of law which arises out of its order. \r\n(3)  Where, on an application made under sub-section (1), the High Court is satisfied that a question \r\nof law arises out of the order referred to in sub-section (1), it may proceed to hear the case. \r\n(4)  A reference to the High Court under this section shall be heard by a Bench of not less than two \r\njudges of the High Court and, in respect of the reference, the provisions of section 98 of the Code  of \r\nCivil Procedure, 1908 (Act V of 1908), shall apply, so far as may be, notwithstanding anything contained \r\nin any other law for the time being in force. \r\n(5)  The High Court upon hearing a reference under this section shall decide the question of law \r\nraised by the reference and pass judgment thereon specifying the grounds on which such judgment is \r\nbased and the Tribunal’s order shall stand modified accordingly. The Court shall send a copy of the \r\njudgment under the seal of the Court to the Appellate Tribunal. \r\n(6)  Notwithstanding that a reference has been made to the High Court, the tax shall be payable in \r\naccordance with the order of the Appellate Tribunal: \r\nProvided that, if the amount of tax is reduced as a result of the judgment in the reference by the \r\nHigh Court and the amount of tax found refundable, the High Court may, on application by the \r\nCommissioner within thirty days of the receipt of the judgment of the High Court that he wants to prefer \r\npetition for leave to appeal to the Supreme Court, make an o rder authorizing the Commissioner to \r\npostpone the refund until the disposal of the appeal by the Supreme Court. \r\n(7)  Where recovery of tax has been stayed by the High Court by an order, such order shall cease \r\nto have effect on the expiration of a period of six months following the day on which it was made unless \r\nthe appeal is decided or such order is withdrawn by the High Court earlier. \r\n(8)  Section 5 of the Limitation Act, 1908 (IX of 1908), shall apply to an application made to the High \r\nCourt under sub-section (1). \r\n(9)  An application under sub -section (1) by a person other than the Commissioner shall be \r\naccompanied by a fee of one hundred rupees.” \r\n2 The word “Within” substituted by the Finance Act, 2024. \r\n3 The expression “Subject to section 126A, within thirty” substituted by the Finance Act, 2025. \r\n4 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \r\n2025. \r\n5 The expression “or a mixed question of law and facts” omitted by the Finance Act, 2025. \r\n6 Expression inserted by the Finance Act, 2024. \r\n7 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \r\n2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n273 \r\n \r\n1[ ] 2[ ]  \r\n \r\n(2) The statement to the High Court referred to in sub-section (1), shall set \r\nout the facts, the determination of the Appellate Tribunal 3[ ] 4[ ] and the question \r\nof law 5[ ] which arises out of its order.  \r\n \r\n(3) Where, on an application made under sub -section (1), the High Court \r\nis satisfied that a question of law 6[ ] arises out of such order referred to in sub -\r\nsection (1), it may proceed to hear the case.  \r\n \r\n(4) A reference to the High Court under this section shall be heard by \r\nSpecial Bench or the Special Benches, as the case may be , to be constituted by \r\nthe Chief Justice, as deemed necessary for hearing cases under this section, \r\ncomprising of not less than two judges of the High Court and, in respect of the \r\nreference, the provisions of section 98 of the Code of Civil Procedure, 1908 (Act V \r\nof 1908), shall apply, so far as may be, notwithstanding anything contained in any \r\nother law for the time being in force.  \r\n \r\n(5) The Special Bench shall decide a reference within six months from the \r\ndate of its filing. \r\n \r\n(6) The High Court shall esta blish a case management system to ensure \r\nthat sufficient number of Special Benches are constituted, so as to ensure that a \r\nreference filed under this section is decided within the stipulated six months.  \r\n \r\n(7) The High Court upon hearing a reference under t his section shall \r\ndecide the question of law 7[ ] raised by the reference and pass judgment thereon \r\nspecifying the grounds on which such judgment is based and the Appellate \r\nTribunal's order 8[ ] 9[ ] shall stand modified accordingly.  \r\n \r\n                                            \r\n1 Explanation added by the Finance Act, 2024. \r\n2 Explanation omitted by the Finance Act, 2025. The omitted Explanation read as follows: \r\n“Explanation.– For the removal of doubt it is clarified that reference against order of the Commissioner \r\n(Appeals), communicated after the date of commencement of the Tax Laws (Amendment) Act, 2024 \r\n(V of 2024), shall lie before the High Court notwithstanding the proceedings pending prior to the date \r\nof commencement of the said Act.]” \r\n3 Expression inserted by the Finance Act, 2024. \r\n4 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \r\n2025. \r\n5 The expression “or a mixed question of law and facts” omitted by the Finance Act, 2025. \r\n6 The expression “or a mixed question of law and facts” omitted by the Finance Act, 2025. \r\n7 The expression “or a mixed question of law and facts” omitted by the Finance Act, 2025. \r\n8 Expression inserted by the Finance Act, 2024. \r\n9 The expression “or, as the case may be, the Commissioner (Appeals)’s order” omitted by the \r\nFinance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n274 \r\n \r\n(8) The High Court shall send a copy of the judgment under the seal of the \r\nHigh Court to the Appellate Tribunal 1[ ]. \r\n \r\n(9) Notwithstanding that a reference has been made to the High Court, the \r\ntax shall be payable in accordance with the order of the Appellate Tribunal 2[ ]:  \r\n \r\nProvided that the tax recovery shall not be made by the Commissioner for \r\nthirty days from the date of communication of the order of the Appellate Tribunal \r\n3[ ]:  \r\n \r\nProvided further that, if the amount of tax is reduced as a result of the \r\njudgment in the re ference by the High Court and some amount of tax is found to \r\nbe refundable, the High Court may, on application by the Commissioner within \r\nthirty days of the receipt of the judgment of the High Court that he wants to prefer \r\npetition for leave to appeal to t he Supreme Court, make an order authorizing the \r\nCommissioner to postpone the refund until the disposal of the appeal by the \r\nSupreme Court.  \r\n \r\n(10) On an application filed in a particular reference and after affording an \r\nopportunity of being heard to the Commissioner, the High Court may stay recovery \r\nof tax, subject to deposit with the assessing authority of not less than thirty percent \r\nof the tax determined by the Appellate Tribunal 4[ ] 5[ ]. Where recovery of tax has \r\nbeen stayed by the High Court by an ord er, such order shall cease to have effect \r\non the expiration of a period of six months following the day on which it was made \r\nunless the reference is decided or such order is withdrawn by the High Court \r\nearlier. \r\n \r\n(11) Section 5 of the Limitation Act, 1908 ( IX of 1908), shall apply to an \r\napplication made to the High Court under sub-section (1).  \r\n \r\n(12) An application under sub-section (1) 6[, by the aggrieved person other \r\nthan the Commissioner,] shall be accompanied by a fee of fifty thousand rupees.  \r\n \r\n                                            \r\n1 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \r\n2025. \r\n2 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \r\n2025. \r\n3 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \r\n2025. \r\n4 Expression inserted by the Finance Act, 2024. \r\n5 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \r\n2025. \r\n6 Expression inserted by the Finance Act, 2024. \r\nChapter X – Procedure__________________________________ \r\n \r\n275 \r\n \r\n(13) No application filed by the Commissioner under subsection (1) shall \r\nbe entertained unless it is accompanied by a written authorization by the relevant \r\nChief Commissioner.] \r\n \r\n1[  ] \r\n2[   ] \r\n                                            \r\n1Section 134 omitted by the Finance Act, 2005. The omitted section 134 read as follows:  \r\n“134.  Appeal to Supreme Court.- (1)  An appeal shall lie to the Supreme Court from any judgment \r\nof the High Court delivered on a reference made or question of law framed under section 133 in any \r\ncase which the High Court certifies to be a fit one for appeal to the Supreme Court. \r\n (2) The provisions of the Code of Civil Procedure, 1908 (V of 1908), relating to appeals to \r\nthe Supreme Court shall apply, so far as may be, in the case of an appeal under this section in like \r\nmanner as they apply in the case of an appeal from decrees of a High Court. \r\n (3) Where the judgment of the High Court is varied or reversed in appeal under this section, \r\neffect shall be given to the order of the Supreme Court in the manner provided in sub-section (12) of \r\nsection 133 in the case of a judgment of the High Court. \r\n (4) The provisions of sub-sections (11), (12) and (13) of section 133 shall apply in the case \r\nof an appeal to the Supreme Court made under this section as they apply to an appeal to the High \r\nCourt under section 133.” \r\n2The section 134A substituted by the Finance Act 2020 dated 30th June, 2020, the substituted section \r\nread as follows: 134A. Alternative Dispute Resolution. — (1) Notwithstanding any other provision of this \r\nOrdinance, or the rules made thereunder, an aggrieved person in connection with any dispute pertaining to— \r\n(a) the liability of tax against the aggrieved person, or admissibility of refunds, as the case may be;  \r\n(b) the extent of waiver of default surcharge and penalty; or  \r\n(c) any other specific relief required to resolve the dispute, \r\nmay apply to the Board for the appointment of a committee for the resolution of  any hardship or dispute mentioned \r\nin detail in the application, which is under  litigation in any court of law or an Appellate Authority, except where criminal \r\nproceedings have been initiated or where interpretation of question of law is involved having effect on other cases.  \r\n(2) The Board may, after examination of the application of an aggrieved person, appoint a committee, \r\nwithin sixty days of receipt of such application in the Board, comprising,— \r\n(i) an officer of Inland Revenue not below the rank of a Commissioner; \r\n(ii) person to be nominated by the taxpayer from a panel notified by the Board comprising, — \r\n(a) 2[  ] chartered accountants, 2[cost and man agement accountants] and 2[  ] \r\nadvocates having 2[minimum ten years] experience in the field of taxation; and  \r\n(b) reputable businessmen as nominated by Chambers of Commerce and  industry:  \r\nProvided that the taxpayer shall not nominate a Chartered Accountant  2[or cost and \r\nmanagement accountant] or an advocate if the said Chartered Accountant 2[or cost and \r\nmanagement accountant] or the advocate is or has been an auditor or an authorized \r\nrepresentative of the taxpayer; and \r\n(iii) a retired Judge not below the ra nk of District and Sessions Judge, to be nominated through \r\nconsensus by the members appointed under clauses (i) and (ii).  \r\n(3) The aggrieved person, or the Commissioner, or both, as the case may be, shall withdraw the appeal \r\npending before any court of law or an Appellate Authority, after constitution of the committee by the Board under sub-\r\nsection (2). \r\n(4) The committee shall not commence the proceedings under          sub-section (5) unless the order of \r\nwithdrawal by the court of law or the Appellate Authority is communicated to the Board: \r\nProvided that if the order of withdrawal is not communicated within seventy five days of the \r\nappointment of the committee, the said  committee  shall  be  dissolved  and  provisions  of  this  section shall \r\nnot apply. \r\n(5) The Committee appointed under sub -section (2) shall examine the issue and may, if it deems \r\nnecessary, conduct inquiry, seek expert opinion, direct any officer of the Inland Revenue or any other person to \r\nconduct an audit and shall decide the dispute by majority, within one hundred and twenty days of its appointment:  \r\nProvided that in computing the aforesaid period of one hundred and twenty days, the period, if any, \r\nfor communicating the order of withdrawal under sub-section (4) shall be excluded. \r\n(6) The recovery of tax payable by a taxpayer in connection with any dispute for which a Committee \r\nhas been appointed under sub - section (2) shall be deemed to have been stayed on withdrawal of appeal up to the \r\ndate of decision by the Committee. \r\n(7) The decision of the committee under sub-section (5) shall be binding on the Commissioner and the \r\naggrieved person. \r\nChapter X – Procedure__________________________________ \r\n \r\n276 \r\n \r\n                                            \r\n(8) If the Committee fails to decide within the period of one hundred and  twenty days under sub-section \r\n(5), the Board shall dissolve the committee by an or der in writing and the matter shall be decided by the court of law \r\nor the  Appellate Authority which issued the order of withdrawal under sub-section (4) and the appeal shall be treated \r\nto be pending before such court of law or the Appellate Authority as i f the appeal had never been withdrawn. \r\n(9) The Board shall communicate the order of dissolution to the court of law or the Appellate Authority \r\nand the Commissioner. \r\n \r\n(10) The aggrieved person, on receipt of the order of dissolution, shall communicate it to the court of law \r\nor the Appellate Authority, which shall decide the appeal within six months of the communication of said order.  \r\n(11) The aggrieved person may make the payment of income tax and other taxes as decided by the \r\ncommittee under sub-section (5) and all decisions, orders and judgments made or passed shall stand modified to that \r\nextent. \r\n(12) The Board may prescribe the amount to be paid as remuneration for the services of the members \r\nof the Committee, other than the member appointed under clause ( i) of sub-section (2). \r\n(13) The Board may, by notification in the official Gazette, make rules for carrying out the purposes of \r\nthis section. \r\nChapter X – Procedure__________________________________ \r\n \r\n277 \r\n \r\n1[134A. Alternative Dispute Resolution. – 1[(1) Notwithstanding any othe r \r\nprovision of this Ordinance, or the rules made thereunder, an aggrieved person in \r\nconnection with any dispute pertaining to — \r\n                                            \r\n1 Section 134A substituted by the Finance Act, 2023. The Substituted section read as follows: \r\n“134A. Alternative Dispute Resolution. — (1) Notwithstanding any other provision of the Ordinance, \r\nor the rules made thereunder, an aggrieved person in connection with any dispute pertaining to— \r\n(a) the liability of tax of one hundred million and above against the aggrieved p erson or \r\nadmissibility of refund, as the case may be; \r\n(b) the extent of waiver of default surcharge and penalty; or \r\n(c) any other specific relief required to resolve the dispute; may apply to the Board for the \r\nappointment of a committee for the resolution of any hardship or dispute mentioned in \r\ndetail in the application, which is under litigation in any court of law or an Appellate \r\nAuthority, except where criminal proceedings have been initiated. \r\n   (2) The application for dispute resolution shall be accompanied by an initial proposition for \r\nresolution of the dispute, including an offer of tax payment, from which, the applicant would not be \r\nentitled to retract. \r\n(3) The Board may, after examination of the application of an aggrieved person, appoint a \r\ncommittee, within forty five days of receipt of such application in the Board, comprising,— \r\n(i) Chief Commissioner Inland Revenue having jurisdiction over the case; \r\n(ii) person to be nominated by the taxpayer from a panel notified by the Board comprising \r\n– \r\n(a) chartered accountants, cost and management accountants and advocates having \r\na minimum of ten years’ experience in the field of taxation; \r\n(b) officers of the Inland Revenue Service who have retired in BS 21 or above; or \r\n(c) reputable businessmen as nominated by Chambers of Commerce and Industry: \r\nProvided that the taxpayer shall not nominate a Chartered Accountant or an \r\nadvocate if the said Chartered Accountant or the advocate is or has been an \r\nauditor or an authorized representative of the taxpayer; and \r\n(d) person to be nomina ted through consensus by the members appointed under (i) \r\nand (ii) above, from the panel as notified by the Board in clause (ii) above: \r\nProvided that where the member under this clause cannot be appointed \r\nthrough consensus, the Board may nominate a member proposed by the taxpayer \r\neligible to be nominated as per clause (ii). \r\n(4) The aggrieved person, or the Commissioner, or both, as the case may be, shall \r\nwithdraw the appeal pending before any court of law or an Appellate Authority, after constitution of \r\nthe committee by the Board under sub-section (3), in respect of dispute as mentioned in sub-section \r\n(1). \r\n(5) The committee shall not commence the proceedings under sub -section (6) unless the \r\norder of withdrawal by the court of law or the Appellate Authority is communicated to the Board:  \r\nProvided that if the order of withdrawal is not communicated within seventy five days of \r\nthe appointment of the committee, the said committee shall be dissolved and provisions of this \r\nsection shall not apply. \r\n(6) The Committee appointed under sub-section (3) shall examine the issue and may, if it \r\ndeems necessary, conduct inquiry, seek expert opinion, direct any officer of the Inland Revenue or \r\nany other person to conduct an audit and shall decide the dispute by majority, within one hundred and \r\ntwenty days of its appointment:  \r\nProvided that in computing the aforesaid period of one hundred and twenty days, the period, if \r\nany, for communicating the order of withdrawal under sub-section (5) shall be excluded. \r\n(7) The decision by the Committee under sub-section (6) shall not be cited or taken as a \r\nprecedent in any other case or in the same case for a different tax year. \r\n(8) The recovery of tax payable by a taxpayer in connection with any dispute for which a \r\nCommittee has been appointed  under sub -section (3) shall be deemed to have been stayed on \r\nwithdrawal of appeal up to the date of decision by the Committee or the dissolution of the Committee \r\nwhichever is earlier. \r\nChapter X – Procedure__________________________________ \r\n \r\n278 \r\n \r\n   \r\n(a) the liability of tax of fifty million rupees or above against the aggrieved \r\nperson or admissibility of refund, as the case may be;  \r\n \r\n(b)  the extent of waiver of default surcharge and penalty; or  \r\n \r\n(c)  any other specific relief required to resolve the dispute,  \r\n \r\nmay apply, except where criminal proceedings have been initiated, to the Board \r\nfor the appointment of a committee  for the resolution of any hardship or dispute \r\nmentioned in detail in the application:  \r\n \r\nProvided that where the aggrieved person is a state -owned enterprise \r\n(SOE), the limit of tax liability of fifty million rupees or above mentioned in clause \r\n(a) of sub-section (1) shall not apply and it shall be mandatory for such aggrieved \r\nSOE to apply to the Board for the appointment of a committee for the resolution \r\nof any dispute under this section: \r\n  \r\nProvided further that no suit, prosecution, or other legal proceedings shall \r\nlie against the SOE or the committee in relation to the dispute resolved under this \r\nsection. \r\n                                            \r\n(9) The decision of the committee under sub -section (6) shall be bindin g on the \r\nCommissioner and the aggrieved person. \r\n(10) If the Committee fails to decide within the period of one hundred and twenty days under \r\nsub-section (6), the Board shall dissolve the committee by an order in writing and the matter shall be \r\ndecided by the court of law or the Appellate Authority which issued the order of withdrawal under sub-\r\nsection (5) and the appeal shall be treated to be pending before such court of law or the Appellate \r\nAuthority as if the appeal had never been withdrawn. \r\n(11) The Board shall communicate the order of dissolution to the court of law or the Appellate \r\nAuthority and the Commissioner. \r\n(12) The aggrieved person, on receipt of the order of dissolution, shall communicate it to the \r\ncourt of law or the Appellate Authority, which shall decide the appeal within six months of the \r\ncommunication of said order. \r\n(13) The aggrieved person may make the payment of income tax and other taxes as decided \r\nby the committee under sub-section (6) and all decisions, orders and judgments made or passed shall \r\nstand modified to that extent. \r\n(14) The Board may prescribe the amount to be paid as remuneration for the services of the \r\nmembers of the Committee, other than the member appointed under clause (i) of sub-section (3).  \r\n(15) The Board may, by notif ication in the official Gazette, make rules for carrying out the \r\npurposes of this section.] \r\n1 Sub-sections (1) and (2) substituted through The Tax Laws (Amendment) Act, 2024. The substituted \r\nsub-sections read as follows: \r\n“(1) Notwithstanding any other prov ision of this Ordinance, or the rules made thereunder, an \r\naggrieved person in connection with any dispute pertaining to –  \r\n(a) the liability of tax of one hundred million rupees or above against the aggrieved person or \r\nadmissibility of refund, as the case may be;  \r\n(b) the extent of waiver of default surcharge and penalty; or  \r\n(c) any other specific relief required to resolve the dispute, may apply to the Board for the \r\nappointment of a committee for the resolution of any hardship or dispute mentioned in deta il in the \r\napplication, which is under litigation in any court of law or an appellate authority, except where \r\ncriminal proceedings have been initiated.  \r\n(2) The application for dispute resolution under sub-section (1) shall be accompanied by an initial \r\nproposition for resolution of the dispute, including an offer of tax payment.” \r\nChapter X – Procedure__________________________________ \r\n \r\n279 \r\n \r\n Explanation.—State-owned enterprise shall have the same meaning as \r\nassigned thereto in the State -Owned Enterprises (Governance and Operations) \r\nAct, 2023 (VII of 2023). \r\n \r\n(2)     The application for dispute resolution under sub-section (1) shall be \r\naccompanied by —  \r\n \r\n(a)  an initial proposition for resolution of the dispute, including an offer \r\nof tax payment; and \r\n  \r\n(b) an undertaking that the applicant sha ll accept the decision of the \r\nCommittee which shall be binding on him in all respects and shall \r\non receipt of the decision immediately withdraw any and all pending \r\nlitigation or cases of any kind in respect of the dispute, mentioning \r\ndetails thereof: \r\n \r\nProvided that if the applicant is an SOE, it shall withdraw any and all such \r\npending litigation and cases immediately and mention the details thereof in the \r\nundertaking: \r\n \r\nProvided further that the SOE may file an appeal to the Appellate Tribunal \r\nor a reference  to the High Court or a petition for leave to appeal the Supreme \r\nCourt, as the case may be, where subsection (11) is applicable.] \r\n \r\n(3) The Board may, after examination of the application of an aggrieved \r\nperson, appoint a committee, within fifteen days of r eceipt of such application in \r\nthe Board, comprising, –  \r\n \r\n(i) a retired judge not below the rank of a judge of a High Court, \r\nwho shall also be the Chairperson of the Committee, to be \r\nnominated by the Board from a panel notified by the Law and \r\nJustice Division for such purpose;  \r\n \r\n(ii) the Chief Commissioner Inland Revenue having jurisdiction \r\nover the case; and \r\n  \r\n(iii) a person to be nominated by the taxpayer from a panel notified \r\nby the Board comprising –  \r\n \r\n(a) chartered accountants, cost and management \r\naccountants and advocates having a minimum of ten \r\nyears’ experience in the field of taxation;  \r\n \r\n(b)  officers of the Inland Revenue Service who stood retired \r\nin BS 21 or above; or \r\n  \r\n(c)  reputable businessmen as nominated by the Chambers \r\nof Commerce and Industry:  \r\n \r\nChapter X – Procedure__________________________________ \r\n \r\n280 \r\n \r\nProvided that the taxpayer shall not nominate a chartered \r\naccountant or an advocate if the said chartered accountant or \r\nthe advocate is or has been an auditor or an authorized \r\nrepresentative of the taxpayer. \r\n  \r\n(4)  The Board shall communicate the order of appointment of Committee \r\nto the aggrieved person, court of law or the appellate authority where the dispute \r\nis pending and to the concerned Commissioner.  \r\n \r\n(5)  The Committee appointed under sub -section (3) shall examine the \r\nissue and may, if it deems necessary, conduct inquiry, seek expert opinion, direct \r\nany officer of the Inland Revenue or any other person to conduct an audit and shall \r\ndecide the dispute by majority, within forty-five days of its appointment extendable \r\nby another fifteen days for the reasons to be recorded in writing.  \r\n \r\n(6)  The decision by the Committee under sub-section (5) shall not be cited \r\nor taken as a precedent in any other case or in the same case for a different tax \r\nyear.  \r\n \r\n(7)  The recovery of tax payable by a taxpayer in c onnection with any \r\ndispute for which a Committee has been appointed under sub-section (3) shall be \r\ndeemed to have been stayed on the constitution of Committee till the final decision \r\nor dissolution of the Committee, whichever is earlier.  \r\n \r\n(8)  The decision of the Committee under sub-section (5) shall be binding \r\non the Commissioner when the aggrieved person, being satisfied with the decision, \r\nhas withdrawn the appeal pending before the court of law or any appellate authority \r\nin respect of dispute as mention ed in sub-section (1) and has communicated the \r\norder of withdrawal to the Commissioner:  \r\n \r\nProvided that if the order of withdrawal is not communicated to the \r\nCommissioner within sixty days of the service of decision of the Committee upon \r\nthe aggrieved pers on, the decision of the Committee shall not be binding on the \r\nCommissioner.  \r\n \r\n(9) Subject to sub-section (10), the Commissioner shall also withdraw the \r\nappeal, if any, pending before any court of law or an appellate authority in respect \r\nof dispute as mentioned in sub-section (1) within thirty days of the communication \r\nof the order of withdrawal by the aggrieved person to the Commissioner.  \r\n \r\n(10)  The aggrieved person shall make the payment of income tax and \r\nother taxes and within such time as decided by the  Committee under sub-section \r\n(5) and all decisions and orders made or passed shall stand modified to that extent.  \r\n \r\n(11)  1[Subject to sub-section (11A), if] the Committee fails to decide within \r\nthe period of sixty days under sub -section (5), the Board sha ll dissolve the \r\n                                            \r\n1 The word “If” substituted by the Finance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n281 \r\n \r\nCommittee by an order in writing and the matter shall be decided by the court of \r\nlaw or the appellate authority where the dispute is pending under litigation.  \r\n \r\n1[(11A) In the case of a state -owned enterprise, if the Committee fails to \r\ndecide within a period of sixty days, the Board shall reappoint a Committee under \r\nsub-section (3), that shall decide the dispute in accordance with sub-section (5) of \r\nthis section. \r\n \r\n(11B) Sub-section (11) shall apply, in case of a state -owned enterprise, if \r\nthe reappointed Committee fails to decide the matter within a further period of sixty \r\ndays.] \r\n \r\n(12)  The Board shall communicate the order of dissolution to the aggrieved \r\nperson, court of law or the appellate authority and to the Commissioner.  \r\n \r\n2[(13)   On receipt of the order of dissolution, the court of law or the Appellate \r\nTribunal shall decide the appeal within ninety days of the communication of the \r\nsaid order.] \r\n \r\n(14)  The Board may prescribe the amount to be paid as remuneration for \r\nthe services of the members of the Committee, other than the member appointed \r\nunder clause (ii) of sub-section (3).  \r\n \r\n(15)  The Board may, by notification in the official Gazette, make rules for \r\ncarrying out the purposes of this section.] \r\n \r\n3[ ] \r\n                                            \r\n1 Sub-sections (11A) and (11B) inserted by the Finance Act, 2025. \r\n2 Sub-section (13) substituted through Tax Laws (Amendment) Act, 2024. The substituted sub-section \r\nread as follows: \r\n“(13)  On receipt of the order of dissolution, the court of law or the appellate authority shall decide the \r\nappeal within six months of the communication of the said order.” \r\n3Section 135 omitted by the Finance Act, 2002. The omitted section 135 read as follows:  \r\n“135. Revision by the Commissioner.- (1)  The Commissioner may either of the Commissioner’s own motion or \r\non application in writing by a person for revision, call for the record of any proceeding under this Ordinance in which \r\nan order has been passed by any taxation officer other than the Commissioner (Appeals).  \r\n(2) Subject to sub -section (3), where, after making such inquiry as is necessary, Commissioner \r\nconsiders that the order requires revisio n, the Commissioner may make such revision to the order as the \r\nCommissioner thinks fit. \r\n(3) An order under sub-section (2) shall not be prejudicial to the person to whom the order relates.  \r\n(4) The Commissioner shall not revise any order under sub-section (2) if – \r\n(a) where an appeal against the order lies to the Commissioner (Appeals) or to the Appellate \r\nTribunal, the time within which such appeal may be made has not expired, or the person \r\nhas not waived their right of appeal; \r\n(b) the order is pending on ap peal before the Commissioner (Appeals) or has been made the \r\nsubject of an appeal to the Appellate Tribunal; or \r\n(c) in the case of an application made by a person, the application has not been made within \r\nninety days of the date on which such order was serv ed on the person, unless the \r\nCommissioner is satisfied that the person was prevented by sufficient cause from making \r\nthe application within the time allowed. \r\n(5)  No application for revision of an assessment order may be made under sub-section (1) unless the amount \r\nof tax due under the assessment that is not in dispute has been paid by the taxpayer.  \r\nChapter X – Procedure__________________________________ \r\n \r\n282 \r\n \r\n136.  Burden of proof. — In any appeal 1[by a taxpayer] under this Part, the \r\nburden shall be on the taxpayer to prove, on the balance of probabilities — \r\n \r\n(a) in the case of an assessment order, the extent to which the order does \r\nnot correctly reflect the taxpayer’s tax liability for the tax year; or \r\n \r\n(b) in the case of any other decision, that the decision is erroneous. \r\n                                            \r\n(6)  An application under sub-section (1) shall be accompanied by – \r\n(a) in relation to an assessment order, a fee of the lesser of two thousand five hundred rupees \r\nor ten per cent of the tax assessed; or \r\n(b) in any other case – \r\n(i) where the applicant is a company, a fee of two thousand rupees; or  \r\n(ii) where the applicant is not a company, a fee of five hundred rupees.  \r\n(7)  An order by the Commissioner declining to interfere shall not be treated as an order prejudicial to the \r\napplicant.” 1 Inserted by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n283 \r\n \r\nPART IV \r\nCOLLECTION AND RECOVERY OF TAX \r\n \r\n137.  Due date for payment of tax.— (1)  The tax payable by a taxpayer on the \r\ntaxable income of the taxpayer 1[including the tax p ayable under 2[ ] ] 3[section \r\n4[113 or] 113A] for a tax year shall be due on the due date for furnishing the \r\ntaxpayer’s return of income for that year. \r\n \r\n5[(2) Where any tax is payable under an assessment order or an amended \r\nassessment order or any other or der issued by the Commissioner under this \r\nOrdinance, a notice shall be served upon the taxpayer in the prescribed form \r\nspecifying the amount payable and thereupon the sum so specified shall be paid \r\nwithin 6[ 7[thirty]  ] days from the date of service of the notice 8[:] 9[ ] \r\n \r\n10[Provided that the due date for payment of tax payable under sub- section \r\n(7) of section 147 shall be the date specified in sub-section (5) or sub-section (5A) \r\nor first proviso to sub-section (5B) of section 147.] \r\n \r\n11[ 12[ ]  ] \r\n \r\n13[ 14[ ]  ] \r\n                                            \r\n1 Inserted by the Finance Act, 2003. Earlier this was inserted by S.R.O. 633(I)/2002, dated 14.09.2002 \r\nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. \r\n2The words and figure “section 113 or” omitted by the Finance Act, 2008. \r\n3 Inserted by the Finance Act, 2004. \r\n4 Inserted by the Finance Act, 2009. \r\n5 Substituted by the Finance Act, 2003. The substituted sub-section (2) read as follows:  \r\n“(2) Where an assessment order or amended assessment order is issued by the  \r\nCommissioner, the tax payable under the order shall be payable within fifteen days from the date of \r\nthe assessment order is issued. “ \r\n6The word “thirty” substituted by the Finance Act, 2008. \r\n7The word “fifteen” substituted by the Finance Act, 2015. \r\n8 Full stop substituted by the Finance Act, 2018 \r\n9Colon substituted by the Finance Act, 2017. \r\n10Added by the Finance Act, 2018. \r\n11Added by the Finance Act, 2010. \r\n12 Proviso omitted by the Finance Act, 2017. The omitted provision read as follows: \r\n  “Provided that the tax payable as a result of provisional assessment order under section 122C, \r\nas specified in the notice under sub-section (2) shall be payable immediately after a period of forty-\r\nfive days from the date of service of the notice” \r\n13Added by the Finance Act, 2012. \r\n14Proviso omitted by the Finance Act, 2017. The omitted provision read as follows: \r\n  “Provided further that the taxpayer may pay the tax payable prior to expiry of the period of forty-\r\nfive days specified in the first proviso.” \r\nChapter X – Procedure__________________________________ \r\n \r\n284 \r\n \r\n (3) Nothing in sub -section (2) 1[or (4)] shall affect the operation of sub -\r\nsection (1). \r\n \r\n (4) Upon written application by a taxpayer, the Commissioner may, where \r\ngood cause is shown, grant the taxpayer an extension of time for payment of tax \r\ndue 2[under sub-section (2)] or allow the taxpayer to pay 3[such tax] in instalments \r\nof equal or varying amounts as the Commissioner may determine having regard \r\nto the circumstances of the case. \r\n \r\n (5) Where a taxpayer is permitted to pay tax by instalments and the \r\ntaxpayer defaults in payment of any instalments, the whole balance of the tax \r\noutstanding shall become immediately payable. \r\n \r\n (6) The grant of an extension of time to pay tax due or the grant of \r\npermission to pay tax due by instalments shall not preclude the liability for 4[default \r\nsurcharge] arising under section 205 from the due date of the tax under sub -\r\nsection 5[(2)]. \r\n \r\n6[  ] \r\n \r\n7[138. Recovery of tax out of property and through arrest of taxpayer. — (1) \r\nFor the purpose of recovering any tax due by a taxpaye r, the Commissioner may \r\nserve upon the taxpayer a notice in the prescribed form requiring him to pay the \r\nsaid amount within such time as may be specified in the notice. \r\n \r\n (2)  If the amount referred to in the notice issued under sub -section (1) is \r\nnot paid within the time specified therein or within the further time, if any, allowed \r\n                                            \r\n1Inserted by the Finance Act, 2003. Earlier this was inserted by S.R.O. 633(I)/2002, dated 14.09.2002 \r\nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. \r\n2 Inserted by the Finance Act, 2003. \r\n3The words “any tax due” substituted by the Finance Act, 2003. \r\n4The word s “additional tax” substituted by the Finance Act, 2010. \r\n5The brackets and figure “(1)” substituted by the Finance Act, 2003. \r\n6Sub-section (7) omitted by the Finance Act, 2002. The omitted sub-section (7) read as under: \r\n“(7) A taxpayer dissatisfied with a decision under sub-section (4) may challenge the decision \r\nonly under Part III of this Chapter.” \r\n7Section 138 substituted by Finance Act, 2002. The substituted section 138 read as follows: \r\n“138. Tax as a debt due to the Federal Government.- (1)  Any tax due under this Ordinance by a \r\ntaxpayer shall be a debt due to the Federal Government and shall be payable in the manner and at \r\nthe place prescribed. \r\n(2) Any tax that has not been paid by the due date may be sued for and recovered in any \r\ncourt of competent jurisdiction by the Commissioner acting in the Commissioner’s official name. \r\n(3) In any suit under sub -section (2), the production  of a certificate signed by the \r\nCommissioner stating the name and address of the taxpayer and the amount of tax due shall be \r\nconclusive evidence of the amount of tax due by such taxpayer.”  \r\nChapter X – Procedure__________________________________ \r\n \r\n285 \r\n \r\nby the Commissioner, the Commissioner may proceed to recover from the \r\ntaxpayer the said amount by one or more of the following modes, namely:— \r\n \r\n(a)  attachment and sale of any m ovable or immovable property of \r\nthe taxpayer; \r\n \r\n(b)  appointment of a receiver for the management of the movable \r\nor immovable property of the taxpayer; 1[  ]  \r\n \r\n(c)  arrest of the taxpayer and his detention in prison for a period not \r\nexceeding six months 2[; and \r\n \r\n(d) as specified under clauses (a), (ca) and (d) of sub-section (I) of \r\nsection 48 of the Sales Tax Act, 1990.] \r\n \r\n (3)  For the purposes of recovery of tax under sub -section (2), the \r\nCommissioner shall have the same powers as a Civil Court has under the Code of \r\nCivil Procedure, 1908 (Act V of 1908), for the purposes of the recovery of any \r\namount due under a decree. \r\n \r\n3[(3A) Notwithstanding anything contained in this Ordinance or any other law \r\nor any rule, any decision or judgment of any court, forum or a uthority, the tax \r\npayable under any provision of this Ordinance or any assessment order shall \r\nbecome immediately payable subject to the following conditions —  \r\n \r\n(a) that the case has been decided in the favor of the department at three \r\nappellate forums including the High Court;  \r\n \r\n(b) that the recovery under this section shall only be made to the extent \r\nof lowest amount of demand which has been confirmed by any of the \r\nthree appellate forums; and  \r\n \r\n(c) that the tax payable exceeds rupees two hundred million,  \r\n \r\nand the Commissioner shall proceed to recover the said amount irrespective of the \r\ntime provided under any other provision or the said decision or judgment.] \r\n \r\n(4) The 4[Board] may make rules regulating the procedure for the \r\nrecovery of tax under this sect ion and any other matter connected with, or \r\nincidental to, the operation of this section.] \r\n \r\n                                            \r\n1 The word “and” omitted through Finance Act, 2020 dated 30th June, 2020  \r\n2 Full stop substituted by “semi colon” and the word “and” thereafter new clause (d) added through \r\nFinance Act, 2020 dated 30th June, 2020  \r\n3 Sub-section (3A) inserted by the Finance Act, 2025. \r\n4 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\nChapter X – Procedure__________________________________ \r\n \r\n286 \r\n \r\n1[138A. Recovery of tax by District Officer (Revenue).— (1) The Commissioner \r\nmay forward to the District Officer (Revenue) of the district in which the taxpayer \r\nresides or carries on business or in which any property belonging to the taxpayer \r\nis situated, a certificate specifying the amount of any tax due from the taxpayer, \r\nand, on receipt of such certificate, the District Officer (Revenue) shall proceed to \r\nrecover from the taxpayer the amount so specified as, it were an arrear of land \r\nrevenue. \r\n \r\n (2)  Without prejudice to any other power of the District Officer (Revenue) \r\nin this behalf, he shall have the same powers as a Civil Court has under the Code \r\nof Civil Procedu re, 1908 (Act V of 1908), for the purpose of the recovery of the \r\namount due under a decree.] \r\n \r\n2[138B. Estate in bankruptcy. —(1) If a taxpayer is declared bankrupt, the tax \r\nliability under this Ordinance shall pass on to the estate in bankruptcy. \r\n \r\n (2)  If tax liability is incurred by an estate in bankruptcy, the tax shall be \r\ndeemed to be a current expenditure in the operations of the estate in bankruptcy \r\nand shall be paid before the claims preferred by other creditors are settled.] \r\n \r\n139.  Collection of tax in the case of private companies and associations of \r\npersons.—(1) Notwithstanding anything in the 3[Companies Act, 2017 (XIX of \r\n2017)], where any tax payable by a private company (including a private company \r\nthat has been wound up or gone into liquidation) in respect of any tax year cannot \r\nbe recovered from the company, every person who was, at any time in that tax \r\nyear — \r\n \r\n(a) a director of the company, other than an employed director; or \r\n \r\n(b) a shareholder in the company owning not less than ten per cent of \r\nthe paid-up capital of the company, \r\n \r\nshall be jointly and severally liable for payment of the tax due by the company.  \r\n \r\n (2)     Any director who pays tax under sub -section (1) shall be entitled to \r\nrecover the tax paid from the company or a share of the tax from any other director. \r\n \r\n (3) A shareholder who pays tax under sub-section (1) shall be entitled to \r\nrecover the tax paid from the company or from any other shareholder to whom \r\nclause (b) of sub-section (1) applies in proportion to the shares owned by that other \r\nshareholder. \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2002. \r\n2Added by the Finance Act, 2010. \r\n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \r\nChapter X – Procedure__________________________________ \r\n \r\n287 \r\n \r\n (4) Notwithstanding anything in any law, where any tax payable by a \r\nmember of an association of persons in respect of the member’s share of the \r\nincome of the association in respect of any tax year cannot be recovered from the \r\nmember, the association shall be liable for the tax due by the member.  \r\n \r\n 1[(5) Notwithstanding anything contained in any other law, for the time \r\nbeing in force, where any tax payable by an association of persons in respect of \r\nany tax year cannot be recovered from the association of persons, every person \r\nwho was, at any time in that year, a member of the association of persons, shall \r\nbe jointly and severally liable for payment of the tax due by the association of \r\npersons. \r\n \r\n (6) Any member who pays tax under sub -section (5) shall be entitled to \r\nrecover the tax paid from the association of persons or a share of the tax from any \r\nother member.]  \r\n \r\n 2[(7)] The provisions of this Ordinance shall apply to any amount due under \r\nthis section as if it were tax due under an assessment order. \r\n \r\n140. Recovery of tax from persons holding money on behalf of a taxpayer.— \r\n(1)  For the purpose of recovering any tax due by a taxpayer, the Commissioner \r\nmay, by notice, in writing, require any person – \r\n \r\n(a) owing or who may owe money to the taxpayer; or \r\n \r\n(b) holding or who may hold money for, or on account of the taxpayer; \r\n \r\n(c) holding or who may hold money on account of some other person for \r\npayment to the taxpayer; or \r\n \r\n(d) having authority of some other person to pay money to the taxpayer, \r\n \r\nto pay to the Commissioner so much of the money as set out in the notice by the \r\ndate set out in the notice3[:] \r\n \r\n4[Provided that the Commissioner shall not issue notice under this \r\nsub-section for recovery of any tax due from a taxpayer if the said taxp ayer \r\nhas filed an appeal under section 127 in respect of the order under which \r\nthe tax sought to be recovered has become payable and the appeal has not \r\nbeen decided by the Commissioner (Appeals), subject to the condition that \r\n5[ten] per cent of the said amount of tax due has been paid by the taxpayer.] \r\n \r\n                                            \r\n1New sub-sections (5) and (6) inserted through Finance Act, 2019. \r\n2Sub-section (5) re-numbered as sub-section (7) through Finance Act, 2019.  \r\n3 Full-stop substituted by the Finance Act, 2016. \r\n4 Added by the Finance Act,  2016. \r\n5The expression “twenty-five” substituted by the Finance Act, 2018 \r\nChapter X – Procedure__________________________________ \r\n \r\n288 \r\n \r\n (2) Subject to sub-section (3), the amount set out in a notice under sub -\r\nsection (1) — \r\n \r\n(a) where the amount of the money is equal to or less than the \r\namount of tax due by the taxpayer, shall not exceed the amount \r\nof the money; or \r\n \r\n(b) in any other case, shall be so much of the money as is sufficient \r\nto pay the amount of tax due by the taxpayer.  \r\n \r\n (3) Where a person is liable to make a series of payments (such as salary) to \r\na taxpayer, a notice under sub-section (1) may specify an amount to be paid out of each \r\npayment until the amount of tax due by the taxpayer has been paid.  \r\n \r\n (4) The date for payment specified in a notice under sub-section (1) shall \r\nnot be a date before the money becomes payable to the ta xpayer or held on the \r\ntaxpayer’s behalf.  \r\n (5) The provisions of sections 160, 161, 162 and 163, so far as may be, \r\nshall apply to an amount due under this section as if the amount were required to \r\nbe deducted from a payment under Division III of Part V of this Chapter. \r\n \r\n (6)  Any person who has paid any amount in compliance with a notice \r\nunder sub -section (1) shall be treated as having paid such amount under the \r\nauthority of the taxpayer and the receipt of the Commissioner constitutes a good \r\nand sufficient discharge of the liability of such person to the taxpayer to the extent \r\nof the amount referred to in such receipt. \r\n \r\n 1[(6A) Notwithstanding anything contained in this Ordinance or any other law \r\nor any rule, any decision or judgment of any court, forum or a uthority, the tax \r\npayable under any provision of this Ordinance or any assessment order shall \r\nbecome immediately payable subject to the following conditions —  \r\n \r\n(a) that the case has been decided in the favor of the department at three \r\nappellate forums including the High Court;  \r\n \r\n(b) that the recovery under this section shall only be made to the extent \r\nof lowest amount of demand which has been confirmed by any of the \r\nthree appellate forums; and  \r\n \r\n(c) that the tax payable exceeds rupees two hundred million,  \r\n \r\nand the Commissioner shall proceed to recover the said amount irrespective of the \r\ntime provided under any other provision or the said decision or judgment.] \r\n \r\n                                            \r\n1 Sub-section (6A) inserted by the Finance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n289 \r\n \r\n 1[  ] \r\n 2[  ] \r\n 3[  ] \r\n \r\n (10)  In this section, \"person\" includes any Court, Tribunal or any other  \r\nauthority. \r\n141. Liquidators.— (1)  Every person (hereinafter referred to as a “liquidator”) \r\nwho is – \r\n(a) a liquidator of a company; \r\n(b) a receiver appointed by a Court or appointed out of Court; \r\n(c) a trustee for a bankrupt; or \r\n(d) a mortgagee in possession, \r\nshall, within fourteen days of being appointed or taking possession of an asset in \r\nPakistan, whichever occurs first, give written notice thereof to the Commissioner.  \r\n (2) The Commissioner shall, within three months of being notified under \r\nsub-section (1), notify the liquidator in writing of the amount which appears to the \r\nCommissioner to be sufficient to provide for any tax which is or will become \r\npayable by the person whose assets are in the possession of the liquidator.  \r\n (3) A liquidator shall not, without leave of the Commissioner, part with any \r\nasset held as liquidator until the liquidator has been notified under sub-section (2). \r\n (4) A liquidator — \r\n(a) shall set aside, out of the proceeds of sale of any asset by the \r\nliquidator, the amount notified by the Commissioner under sub-\r\nsection (2), or such lesser amount as is subsequently agreed to \r\nby the Commissioner;  \r\n(b) shall be liable to the extent of the amount set aside for the tax \r\nof the person who owned the asset; and  \r\n                                            \r\n1 Sub-section (7) omitted by the Finance Act, 2003. The omitted sub-section (7) read as follows:  \r\n“(7) Where an amount has been paid under sub -section (1), the taxpayer shall be allowed \r\na tax credit for the amount (unless the amount paid represents a final tax on the taxpayer’s income) \r\nin computing the tax due by the taxpayer on the taxpayer’s taxable income for the tax year in which \r\nthe amount was paid.” \r\n2Sub-section (8) omitted by the Finance Act, 2003. The omitted sub-section (8) read as follows: \r\n“(8) The tax credit allowed under this section shall be applied in accordance with sub-section \r\n(3) of section 4.” \r\n3 Sub-section (9) omitted by the Finance Act, 2003. The omitted sub-section (9) read as follows:  \r\n“(9) A tax credit or par t of a tax credit allowed under this section for a tax year that is not \r\nable to be credited under sub-section (3) of section 4 for the year must be refunded to the taxpayer \r\nin accordance with section 170.” \r\nChapter X – Procedure__________________________________ \r\n \r\n290 \r\n \r\n(c) may pay any debt that has priority over the tax referred to in this \r\nsection notwithstanding any provision of this section. \r\n (5) A liquidator shall be personally liable to the extent of any amount \r\nrequired to be set aside under sub-section (4) for the tax referred to in sub-section \r\n(2) if, and to the extent that, the liquidator fails to comply with the requirements of \r\nthis section. \r\n (6) Where the proceeds of sale of any asset are less than the amount \r\nnotified by the Commissioner under sub-section (2), the application of sub-sections \r\n(4) and (5) shall be limited to the proceeds of sale. \r\n \r\n (7) This section shall have effect notwithstanding anything contained in \r\nany other law for the time being in force. \r\n \r\n (8) The provisions of this Ordinance shall apply to any amount due under \r\nthis section as if it were tax due under an assessment order. \r\n \r\n142. Recovery of tax due by non -resident member of an association of \r\npersons.— (1)  The tax due by a non -resident member of an association of \r\npersons in respect of the member’s share of the profits of the association shall be \r\nassessable in the name of the association or of any resident member of the \r\nassociation and may be recovered out of the assets of the association or from the \r\nresident member personally. \r\n \r\n (2) A person making a payment under this secti on shall be treated as \r\nacting under the authority of the non -resident member and is hereby indemnified \r\nin respect of the payment against all proceedings, civil or criminal, and all \r\nprocesses, judicial or extra-judicial, notwithstanding any provisions to the contrary \r\nin any written law, contract or agreement. \r\n \r\n (3) The provisions of this Ordinance shall apply to any amount due under \r\nthis section as if it were tax due under an assessment order. \r\n \r\n143.  Non-resident ship owner or charterer. — (1)  Before the dep arture of a \r\nship owned or chartered by a non -resident person from any port in Pakistan, the \r\nmaster of the ship shall furnish to the Commissioner a return showing the gross \r\namount specified in sub-section (1) of section 7 in respect of the ship. \r\n \r\n (2) Where the master of a ship has furnished a return under sub -section \r\n(1), the Commissioner shall 1[, after calling for such particulars, accounts or \r\ndocuments as he may require,]  determine the amount of tax due under section 7 \r\nin respect of the ship and, as soon as possible, notify the master, in writing, of the \r\namount payable. \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2002. \r\nChapter X – Procedure__________________________________ \r\n \r\n291 \r\n \r\n (3) The master of a ship shall be liable for the tax notified under sub -\r\nsection (2) and the provisions of this Ordinance shall apply to such tax as if it were \r\ntax due under an assessment order.  \r\n \r\n (4) Where the Commissioner is satisfied that the master of a ship or non-\r\nresident owner or charterer of the ship is unable to furnish the return required under \r\nsub-section (1) before the departure of the ship from a port in Pakistan, the \r\nCommissioner may allow the return to be furnished within thirty days of departure \r\nof the ship provided the non -resident owner or charterer has made satisfactory \r\narrangements for the payment of the tax due under section 7 in respect of the ship. \r\n \r\n (5) The Collector of Customs or other authorised officer shall not grant a \r\nport clearance for a ship owned or chartered by a non -resident person until the \r\nCollector or officer is satisfied that any tax due under section 7 in respect of the \r\nship has been paid or that arra ngements for its payment have been made to the \r\nsatisfaction of the Commissioner. \r\n \r\n (6) This section shall not relieve the non -resident owner or charterer of \r\nthe ship from liability to pay any tax due under this section that is not paid by the \r\nmaster of the ship. \r\n \r\n144.  Non-resident aircraft owner or charterer.  — (1)  A non-resident owner or \r\ncharterer of an aircraft 1[  ] liable for tax under section 7, or an agent authorised by the \r\nnon-resident person for this purpose, shall furnish to the Commissioner, within forty-\r\nfive days from the last day of each quarter of the financial year, a return, in respect of \r\nthe quarter, showing the gross amount specified in sub-section (1) of section 7 of the \r\nnon-resident person for the quarter.  \r\n \r\n (2) Where a return has been furnished under sub -section (1), the \r\nCommissioner shall 2[, after calling for such particulars, accounts or documents as \r\nhe may require,] determine the amount of tax due under section 7 by the non -\r\nresident person for the quarter and notify the non-resident person, in writing, of the \r\namount payable. \r\n \r\n (3) The non-resident person shall be liable to pay the tax notified under \r\nsub-section (2) within the time specified in the notice and the provisions of this \r\nOrdinance shall apply to such tax as if it were tax due under an assessment order. \r\n \r\n (4) Where the tax referred to in sub -section (3) is not paid within three \r\nmonths of service of the notice, the Commissioner may issue to the authority by \r\nwhom clearance may be granted to the aircraft operated by the non -resident \r\nperson a certificate specifying the name of the non-resident person and the amount \r\nof tax due. \r\n \r\n                                            \r\n1 The words “shall be” omitted by the Finance Act, 2003. \r\n2 Inserted by the Finance Act, 2002 \r\nChapter X – Procedure__________________________________ \r\n \r\n292 \r\n \r\n (5) The authority to whom a certificate is issued under sub -section (4) \r\nshall refuse clearance from any airport in Pakistan to any aircraft owned or \r\nchartered by the non-resident until the tax due has been paid. \r\n \r\n1[145. Assessment of persons about to leave Pakistan.— (1) Where any person is \r\nlikely to leave Pakistan during the currency of tax year or shortly after its expiry with no \r\nintention of returning to Pakistan, he shall give to the Commissioner a notice to that \r\neffect not less than fifteen days before the probable date of his departure (hereinafter \r\nin this section referred to as the ‘said date’). \r\n \r\n (2)  The notice under sub-section (1) shall be accompanied by a return or \r\nreturns of taxable income in respect of the period commencing from the end of the \r\nlatest tax year for which an assessment has been or, where no such assessment \r\nhas been made, a return has been made, as the case may be, and ending on the  \r\nsaid date, or where no such assessment or return has been made, the tax year or \r\ntax years comprising the period ending on the said date; and the period \r\ncommencing from the end of the latest tax year to the said date shall, for the \r\npurposes of this section , be deemed to be a tax year (distinct and separate from \r\nany other tax year) in which the said date falls. \r\n \r\n (3) Notwithstanding anything contained in sub -sections (1) and (2), the \r\nCommissioner may serve a notice on any person who, in his opinion, is likely to leave \r\nPakistan during the current tax year or shortly after its expiry and has no intention of \r\nreturning to Pakistan, to furnish within such time as may be specified in such notice, a \r\nreturn or returns of taxable income for the tax year or tax years for which the taxpayer \r\nis required to furnish such return or returns under sub-section (2). \r\n \r\n (4) The taxable income shall be charged to tax at the rates applicable to \r\nthe relevant tax year and all the provisions of this Ordinance shall, so far as may \r\nbe, apply accordingly.] \r\n \r\n2[(5) Notwithstanding anything contained in any other law, for the time \r\nbeing in force, where on the basis of information received from any offshore \r\n                                            \r\n1Section 145 substituted by the Finance Act, 2003. The substituted section 145 read as follows:  \r\n“145. Collection of tax from persons leaving Pakistan permanently. - (1)  Where the \r\nCommissioner has reasonable grounds to believe that a person may leave Pakistan permanently \r\nwithout paying tax due under this Ordinance, the Commissioner may issue a certificate containing \r\nparticulars of the tax due to the Commissioner of Immigration a nd request the Commissioner of \r\nImmigration to prevent that person from leaving Pakistan until that person - \r\n(a) makes payment of tax in full; or \r\n(b) makes an arrangement satisfactory to the Commissioner for payment of the tax \r\ndue. \r\n(2) A copy of a certificate issued under sub-section (1) shall be served on the person named \r\nin the certificate if it is practicable to do so. \r\n(3) Payment of the tax specified in the certificate to a customs or immigration officer or the \r\nproduction of a certificate signed by the C ommissioner stating that the tax has been paid or \r\nsatisfactory arrangements for payment have been made shall be sufficient authority for allowing the \r\nperson to leave Pakistan.” \r\n2New sub-section (5) added through Finance Act, 2019. \r\nChapter X – Procedure__________________________________ \r\n \r\n293 \r\n \r\njurisdiction, the Commissioner has reason to believe that such person who is likely \r\nto leave Pakistan may be involved in offshore tax evasion or such person is about \r\nto dispose of any such  asset, the Commissioner may freeze any domestic asset \r\nof the person including any asset beneficially owned by the person for a period of \r\none hundred and twenty days or till the finalization of proceeding including but not \r\nlimited to recovery proceedings under this Ordinance whichever is earlier.]  \r\n \r\n146.  Recovery of tax from persons assessed in Azad Jammu and Kashmir  \r\n1[and Gilgit-Baltistan.]— (1)  Where any person assessed to tax for any tax year \r\nunder the law relating to income tax in the Azad Jammu and Kashmir  2[or  Gilgit-\r\nBaltistan] has failed to pay the tax and the income tax authorities of the Azad Jammu \r\nand Kashmir 3[or Gilgit-Baltistan] cannot recover the tax because — \r\n \r\n(a) the person’s resi44dence is in Pakistan; or \r\n \r\n(b) the person has no movable or immovable property in the Azad \r\nJammu and Kashmir4[or Gilgit-Baltistan], \r\n \r\nthe Deputy Commissioner in the Azad Jammu and Kashmir 5[or Gilgit-Baltistan] \r\nmay forward a certificate of recovery to the Commissioner and, on receipt of such \r\ncertificate, the Commissioner shall recover the tax referred to in the certificate in \r\naccordance with this Part. \r\n \r\n (2) A certificate of recovery under sub -section (1) shall be i n the \r\nprescribed form specifying — \r\n \r\n(a) the place of residence of the person in Pakistan; \r\n \r\n(b) the description and location of movable or immovable property \r\nof the person in Pakistan; and \r\n \r\n(c) the amount of tax payable by the person. \r\n \r\n6[146A. Initiation, validity, etc., of recovery proceedings.— (1) Any proceedings \r\nfor the recovery of tax under this Part may be initiated at any time. \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2017. \r\n2Inserted by the Finance Act 2017. \r\n3Inserted by the Finance Act 2017. \r\n4Inserted by the Finance Act 2017. \r\n5Inserted by the Finance Act 2017. \r\n6 Inserted by the Finance Act, 2002. \r\nChapter X – Procedure__________________________________ \r\n \r\n294 \r\n \r\n (2) The Commissioner may, at any time, amend the certificate issued \r\nunder section 138A, or recall such certificate and issu e fresh certificate, as he \r\nthinks fit. \r\n \r\n (3) It shall not be open to a taxpayer to question before the District Officer \r\n(Revenue) the validity or correctness of any certificate issued under section 138A, \r\nor any such certificate as amended, or any fresh cer tificate issued, under sub -\r\nsection (2). \r\n \r\n (4) The several modes of recovery provided in this Part shall be deemed \r\nto be neither mutually exclusive nor affect in any way any other law for the time \r\nbeing in force relating to the recovery of debts due to the Government and the \r\nCommissioner may have recourse to any such mode of recovery notwithstanding \r\nthat the tax due is being recovered from a taxpayer by any other mode.]  \r\n \r\n1[146B. Tax arrears settlement incentives scheme. — (1) Subject to provisions \r\nof this Ord inance, the Board may make scheme in respect of recovery of tax \r\narrears or withholding taxes and waiver of 2[default surcharge ]or penalty levied \r\nthereon.  \r\n (2) The Board may make rules under section 237 for implementation of such \r\nscheme.] \r\n \r\n3[146C. Assistance in the recovery and collection of taxes. — The provisions \r\nof sections 138, 138A, 138B, 139, 140, 141, 142, 143, 144, 145, 146, 146A, and \r\n146B shall mutatis mutandis apply in respect of assistance in collection and \r\nrecovery of taxes in pursuance of a request from a foreign jurisdiction under a tax \r\ntreaty, a multilateral convention, an intergovernmental agreement or similar \r\narrangement or mechanism.] \r\n \r\n4[146D. Recovery of liability outstanding under other laws. – (1) Where any \r\noutstanding liability in or under any other statute or law for the time being in force \r\nenacted through an Act of Parliament, in respect of any defaulter is –  \r\n \r\n(a)  treated as Income Tax arrears in that law;  \r\n \r\n(b) required to be recovered or collected by Commissioner (Inland \r\nRevenue); or  \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2008. \r\n2The word “additional tax”  subs tituted by the Finance Act, 2010.  The substituted provision has been \r\nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \r\nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re -promulgated \r\nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \r\n3 Section 146C inserted by the Finance Act, 2021. \r\n4 Section 146D inserted by the Finance Act, 2023. \r\nChapter X – Procedure__________________________________ \r\n \r\n295 \r\n \r\n(c)  is referred to Commissioner (Inland Revenue) for the recovery –  \r\n \r\nthe Commissioner (Inland Revenue) shall recover the said liability and deposit the \r\nreceipts in the designated account specified in that law.] \r\n \r\n \r\n \r\n \r\nChapter X – Procedure__________________________________ \r\n \r\n296 \r\n \r\nPART V \r\nADVANCE TAX AND DEDUCTION OF TAX AT SOURCE \r\n \r\nDivision I \r\nAdvance Tax Paid by the Taxpayer \r\n \r\n147. Advance tax paid by the taxpayer.— (1) Subject to sub-section (2), every \r\ntaxpayer 1[whose income was charged to tax for the latest tax year under this \r\nOrdinance or latest assessment year under the repealed Ordinance] other than – \r\n \r\n  2[  ] \r\n \r\n(b) income chargeable to tax under sections 5, 6 and 7;  \r\n \r\n  3[  ] \r\n \r\n(c) income subject to deduction of tax at source under section 149; \r\n4[and] \r\n \r\n  5[  ] \r\n \r\n(d) income from which tax has been collected under Di vision II or \r\ndeducted under Division III 6[or deducted or collected under \r\nChapter XII]  and for which no tax credit is allowed as a result of \r\nsub-section (3) of section 168, \r\n \r\nshall be liable to pay advance tax for the year in accordance with this section.  \r\n \r\n (2) This section does not apply to an individual  where the individual’s 7[] \r\nlatest assessed taxable income excluding income referred to in clauses 8[(b),] (c) \r\nand (d) of sub-section (1) is less than 9[ 10[ 11[one million] ] rupees. \r\n                                            \r\n1 The words “who derives or expects to derive income chargeable to tax under this Ordinance in a tax \r\nyear” substituted by the Finance Act, 2003. \r\n2Clause (a) omitted by the Finance Act, 2010. Omitted clause (a) read as follows: \r\n    “(a) income chargeable to tax under the head “Capital Gains”; \r\n3 Clause (ba) omitted by the Finance Act, 2013. The omitted clause (ba) read as follows: \r\n“(ba)   income chargeable to tax under section 15;” \r\n4The word “or” substituted by the Finance Act, 2009. \r\n5Clause (ca) omitted by the Finance Act, 2009. The omitted clause (ca) read as follows: \r\n“(ca)  income chargeable to tax under section 233 and clauses (a) and (b) of sub-section (1) of \r\nsection 233A;” \r\n6Inserted by the Finance Act, 2009. \r\n7The words “or association of persons” omitted by the Finance Act, 2010. \r\n8 The words “(a), (b),(ba)” substituted by (b) through Finance Act, 2020 dated 30th June, 2020 \r\n9 The words “one hundred and fifty thousand” substituted by the Finance Act, 2003. \r\n10The word “two” substituted by the Finance Act, 2010. \r\n11The words “five hundred thousand” substituted by the Finance Act, 2017. \r\nChapter X – Procedure__________________________________ \r\n \r\n297 \r\n \r\n 1[  ] \r\n \r\n 2[(4)  Where the taxpayer is 3[an association of persons or] a company, the \r\namount of advance tax due for a quarter shall be computed according to the \r\nfollowing formula, namely:- \r\n \r\n(A x B/C) –D \r\n \r\n  Where –  \r\n \r\n   A  is the taxpayer’s turnover for the quarter 4[:] \r\n \r\n5[Provided that where the taxpayer fails to provide \r\nturnover or the turnover for the quarter is not known, it \r\nshall be taken to be one -fourth of one hundred and \r\n6[twenty] percent of the turnover of the latest tax year for  \r\nwhich a return has been filed;] \r\n \r\nB  is the tax assessed to the taxpayer for the latest tax year  \r\n7[.] \r\n \r\n                                            \r\n1 Sub-section (3) omitted by the Finance Act, 2004. The omitted sub-section (3) read as follows:  \r\n“(3) Advance tax shall be payable by a taxpayer in respect of the following periods, namely:– \r\n(a) 1st of July to 30th September (referred to as the “September quarter”); \r\n(b) 1st October to 31st December (referred to as the “December quarter”); \r\n(c) 1st January to 31st March (referred to as the “March quarter”); and \r\n(d) 1st April to 30th June (referred to as the “June quarter”).” \r\n2 Sub-section (4) substituted by the Finance Act, 2009. The substituted sub-section (4) read as \r\nfollows:  \r\n“(4) where the taxpayer is a company, the amount of advance tax due for a quarter shall be \r\ncomputed according to the following formula, namely:-  \r\n \r\n(A/4)  - B \r\nWhere – \r\nA is the tax assessed to the taxpayer for the latest tax year or latest assessment year under the \r\nrepealed Ordinance; and  \r\nB is the tax paid in the quarter for which a tax credit is allowed under section 168, other than \r\ntax deducted under section 149 or 155.” \r\n3Inserted by the Finance Act, 2010. \r\n4The semi colon substituted by the Finance Act, 2018 \r\n5Added by the Finance Act, 2018. \r\n6 The word “ten” substituted by the Finance Act, 2024. \r\n7 Semicolon substituted by the Finance Act, 2016. \r\nChapter X – Procedure__________________________________ \r\n \r\n298 \r\n \r\n1[“Explanation.- For removal of doubt it is clarified \r\nthat tax assessed includes  tax under sections 2[4C,] 113 \r\nand 113C.”] \r\n \r\n   C  is the taxpayer’s turnover for the latest tax year; and  \r\n \r\nD  is th e tax paid in the quarter for which a tax credit is \r\nallowed under section 1683[  ].] \r\n \r\n 4[(4A) Any taxpayer 5[including a banking company] who is required to make \r\npayment of advance tax in accordance with sub-section (4), shall estimate the tax \r\npayable for the relevant tax year, at any time before the second installment is due. \r\nIn case the tax payable is likely to be more than the amount that the taxpayer \r\n6[including a banking company] is required to pay under sub -section (4), the \r\ntaxpayer 7[including a banking company]  shall furnish to the Commissioner on or \r\nbefore the due date of the second quarter an estimate of the amount of tax payable \r\nby the taxpayer 8[including a banking company] and thereafter pay fifty per cent of \r\nsuch amount by the due date of the second quarter of the tax year after making \r\nadjustment for the amount, if any, already paid in terms of sub -section (4). The \r\nremaining fifty per cent of the estimate shall be paid after the second quarter in two \r\nequal installments payable by the due date o f the third and f ourth quarter of the \r\ntax year.”] \r\n   \r\n 9[(4AA) Tax liability under 10[sections 11[4C,] 113 and 113C] shall also be \r\ntaken into account while working out payment of advance tax liability under this \r\nsection.] \r\n \r\n                                            \r\n1Added by the Finance Act, 2016. \r\n2 Expression inserted by the Finance Act, 2023. \r\n3The words, comma and figure “, other than tax deducted under section 155” omitted by the Finance \r\nAct, 2013.   \r\n4Sub-section (4A) omitted by Finance Act, 2015. The substituted sub-section read as follows:- \r\n “(4A) Any taxpayer who is required to make payment of advance tax in accordance with sub-\r\nsection (4), shall estimate the tax payable by him for the relevant tax year, at any time before \r\nthe last instalment is due. In case the tax payable is likely to be more than the amount he is \r\nrequired to pay under sub -section (4), the taxpayer shall furnish to the Commissioner an \r\nestimate of the amount of tax payable by him and thereafter pay such amount after making \r\nadjustment for the amount (if any) already paid in terms of sub-section (4)”. \r\n5Inserted by the Finance Act, 2018 \r\n6Inserted by the Finance Act, 2018. \r\n7Inserted by the Finance Act, 2018. \r\n8Inserted by the Finance Act, 2018. \r\n9Inserted by the Finance Act, 2009. \r\n10The expression “section 113” substituted by the Finance Act, 2016. \r\n11 Expression inserted by the Finance Act, 2023. \r\nChapter X – Procedure__________________________________ \r\n \r\n299 \r\n \r\n 1[(2[4B]) Where the taxpayer is an individual 3[  ] having latest assessed \r\nincome of 4[ 5[one million] rupees or more as determined under sub-section (2), the \r\namount of advance tax due for a quarter shall be computed according to the \r\nfollowing formula, namely: - \r\n“(A/4) - B \r\nWhere – \r\n \r\nA is the  tax assessed to the taxpayer for the latest tax year or latest \r\nassessment year under the repealed Ordinance; and \r\n \r\nB is the tax paid in the quarter for which a tax credit is allowed under section \r\n168, other than tax deducted under section 149 6[  ].] \r\n \r\n7[Explanation. – For removal of doubt, it is clarified that tax assessed \r\nincludes tax liability under section 4C.] \r\n \r\n (5) Advance tax is payable by 8[an individual 9[]] to the Commissioner— \r\n \r\n(a) in respect of the September quarter, on or 10[before] the 11[15th \r\nday of September]; \r\n \r\n(b) in respect of the December quarter, on or before the 12[15th day \r\nof December]; \r\n \r\n(c) in respect of the March quarter, on or before the 13[15th day of \r\nMarch]; and \r\n \r\n(d) in respect of the June quarter, on or before the 14[15th day of June]. \r\n \r\n                                            \r\n1 Inserted by Finance Act, 2003. \r\n2 Sub-section (4A) re-numbered by the Finance Act, 2006. \r\n3The words “or an association of persons” omitted by the Finance Act, 2010. \r\n4The word “two” substituted by the Finance Act, 2010. \r\n5The word “five hundred thousand” substituted by the Finance Act 2017. \r\n6The words and figure “or 155” omitted by the Finance Act, 2013. \r\n7 Explanation added by the Finance Act, 2023. \r\n8The words “a taxpayer” substituted by the Finance Act, 2009. \r\n9The words “or an association of persons” omitted by the Finance Act, 2010. \r\n10 The word “by” substituted by the Finance Act, 2005. \r\n11 The figure and words “7th day of October” substituted by the Finance Act, 2004. \r\n12 The figure and words “7th day of January” substituted by the Finance Act, 2004. \r\n13The figure and words “7th day of April” substituted by the Finance Act, 2004. \r\n14 The figure and words “21st day of June” substituted by the Finance Act, 2004. \r\nChapter X – Procedure__________________________________ \r\n \r\n300 \r\n \r\n 1[(5A) Advance tax shall be payable by an association of persons or a \r\ncompany to the Commissioner — \r\n \r\n(a)  in respect of the September quarter, on or before the 25 th day \r\nof September; \r\n \r\n(b) in respect of the December quarter, on or before the 25th day of \r\nDecember; \r\n \r\n(c)  in respect of the March quarter, on or before the 25 th day of \r\nMarch; and  \r\n \r\n(d)  in respect of the June quarter, on or before the 15th day of June.] \r\n \r\n 2[(5B) Adjustable advance tax on capital gain from sale of securities shall be \r\nchargeable as under, namely:— \r\n \r\n \r\nTABLE \r\n________________________________________________________________  \r\nS.No.                      Period                             Rate of Advance Tax \r\n----------------------------------------------------------------------------------------------------------- \r\n            1                               2                                                 3 \r\n-----------------------------------------------------------------------------------------------------------  \r\n1. Where holding period of a \r\nsecurity is less than six months. \r\n \r\n2% of the capital gains \r\nderived during the quarter. \r\n2. Where holding period of a \r\nsecurity is more than six months \r\nbut less than twelve months. \r\n1.5% of the capital gains \r\nderived during the quarter: \r\n------------------------------------------------------------------------------------------------------------ \r\nProvided that such advance tax shall be payable to the \r\nCommissioner within a period of 3[twenty-one] days after the close of \r\neach quarter: \r\n \r\nProvided further that the provisions of this sub-section shall not \r\nbe applicable to individual investors.] \r\n \r\n                                            \r\n1Sub-section (5A) substituted by the Finance Act, 2010. The substituted sub-section (5A) read as \r\nfollows: \r\n  “(5A)  Advance tax is payable by a company to the Commissioner –  \r\n(a)  in respect of the September quarter, on or before the 15 th day of \r\nOctober; \r\n(b)  in respect of the December quarter, on or before the 15th day of January; \r\n(c)   in respect of the March quarter, on or before the 15th day of April; and \r\n(d)  in respect of the June quarter, on or before the 15th day of June.” \r\n2 Inserted by the Finance Act,  2010. \r\n3The word “seven” substituted by the Finance Act, 2011. \r\nChapter X – Procedure__________________________________ \r\n \r\n301 \r\n \r\n 1[(5C) Notwithstanding anything contained in this section, every person \r\nderiving income from the business of –  \r\n \r\n(i) construction and disposal of residential, commercial or o ther \r\nbuildings; or  \r\n \r\n(ii)  development and sale of residential, commercial or other plots for \r\nitself or otherwise, shall be liable to pay adjustable advance tax on \r\nProject-by-Project basis, as may be prescribed, for the tax year as per \r\nthe rates specified in Part IIB of the First Schedule in four equal \r\ninstallments:  \r\n \r\nProvided that such advance tax shall be payable to the \r\nCommissioner in accordance with sub-sections (5) and (5A):  \r\n \r\nProvided further that the provisions of sub -sections (7) to (10 ) \r\nshall mutatis mutandis apply.] \r\n \r\n 2[(6)  If any taxpayer who is required to make payment of advance tax under \r\nsub-section (1) estimates at any time before the last installment is due, that the tax \r\npayable by him for the relevant tax year is likely to be less than the amount he is \r\nrequired to pay under sub -section (1), the taxpayer may furnish to the \r\nCommissioner an estimate of the amount of the tax payable by him, and thereafter \r\npay such estimated amount, as reduced by the amount, if any, already paid under \r\nsub-section (1), in equal installments on such dates as have not expired 3[:] \r\n \r\n4[Provided that an estimate of the amount of tax payable shall contain \r\nturnover for the completed quarters of the relevant tax  year, estimated turnover  \r\nof the remaining quarters along with reasons for any decline in estimated turnover,  \r\ndocumentary  evidence  of  estimated  expenses  or deductions  which  may result \r\nin lower payment of advance tax and the computation of the estimated taxable \r\nincome of the relevant tax year 5[.] \r\n \r\n6[    ]  ] \r\n                                            \r\n1 Sub-section (5C) inserted by the Finance Act, 2023. \r\n2Sub-section (6) substituted by the Finance Act, 2004. The substituted sub-section (6) read as \r\nfollows:  \r\n“(6) The turnover of a taxpayer for the period from 16th to 30th June of the June quarter shall \r\nbe taken to be equal to the turnover for the period from 1st to 15th June of that quarter.” \r\n3 Full stop substituted by the Finance Act, 2018. \r\n4 Added by the Finance Act 2018. \r\n5 Colon substituted by the Finance Act, 2021. \r\n6 Second proviso omitted by the Finance Act, 2021. The omitted proviso read as follows: \r\n“Provided further that where the Commissioner is not satisfied with the  documentary \r\nevidence provided or where an estimate of the amount of tax payable is not accompanied by \r\ndetails mentioned in the first proviso, the Commissioner may reject the estimate after providing an \r\nopportunity of being  heard to the taxpayer and the taxpayer shall pay advance tax according to \r\nthe  formula contained in sub-section (4).” \r\nChapter X – Procedure__________________________________ \r\n \r\n302 \r\n \r\n 1[(6A) Notwithstanding anything contained in this section, where the \r\ntaxpayer is a company or an association of persons, advance tax shall be payable \r\nby it in the absence of last assessed income or declared turnover also. The \r\ntaxpayer shall estimate the  amount of advance tax payable on the basis of \r\nquarterly turnover of the company or an association of persons, as the case may \r\nbe, and thereafter pay such amount after, — \r\n \r\n(a)  taking into account tax payable under 2[sections 113 and 113C] \r\nas provided in sub-section (4AA); and \r\n \r\n  (b)  making adjustment for the amount (if any) already paid.] \r\n \r\n  3[  ] \r\n \r\n4[  ] \r\n \r\n  \r\n 5[(6B) Where an estimate of the amount of tax payable has been filed by the \r\ntaxpayer under sub -section (6) as the case may be, the estimate shall con tain \r\nturnover for the completed quarters of the relevant tax year, estimated turnover for \r\nthe remaining quarters, supporting evidence of expenses or deductions in \r\ncomputing income, evidence of tax payments and tax credits and computation of \r\nestimated taxable income:  \r\n \r\nProvided that where the Commissioner is not satisfied with the documentary \r\nevidence provided or where an estimate of the amount of tax payable is not \r\naccompanied by details mentioned in this sub -section, the Commissioner may \r\nreject the estimat e after providing an opportunity of being heard to the taxpayer \r\nand the taxpayer shall pay advance tax according to the formula set out in sub -\r\nsection (4) or sub-section (4B), as the case may be. \r\n \r\n(6C) Notwithstanding anything contained in this Ordinance, the persons \r\nspecified in sub -sections (1), (3), (3A), (3B) and (3C) of section 154 shall, at the \r\ntime of realization of foreign exchange proceeds, or realization of the proceeds on \r\naccount of sale of goods, or export of goods, or at the time of making paym ent to \r\n                                            \r\n1Sub-section (6A) substituted by the Finance Act, 2009. The substituted sub-section (6A) read as \r\nfollows: \r\n“(6A) Notwithstanding anything contained in this section, where the taxpayer is a company, \r\nadvance tax shall be payable by it in the absence of last assessed income also. The taxpayer shall \r\nestimate the amount of advance tax payable on the basis of estimated Inserted by the Finance Act, \r\n2009.” \r\n2 The expression “section 113” substituted by the Finance Act, 2016. \r\n3 Clause (a) omitted by the Finance Act, 2008. The omitted clause (a) read as follows: \r\n“(a) taking into account tax payable under section 113 as provided in sub-section (4AA);” \r\n4Clause (b) omitted by the Finance Act, 2008. The omitted clause (b) read as follows: \r\n“(b) making adjustment for the amount (if any) already paid.” \r\n5 New sub-sections (6B) and (6C) inserted by the Finance Act, 2024. \r\nChapter X – Procedure__________________________________ \r\n \r\n303 \r\n \r\nan indirect exporter, or clearing of goods exported, respectively, deduct or collect, \r\nas the case may be, advance income tax under this section at the rate of one \r\npercent of such foreign exchange proceeds, or export proceeds, or exports, or \r\npayment, in addition to tax collectable or deductible under section 154 of this \r\nOrdinance.] \r\n \r\n(7) The provisions of this Ordinance shall apply to any advance tax due \r\nunder this section as if the amount due were tax due under an assessment order.  \r\n \r\n 1[(7A) The Board may prescribe the manner for furnishing of the estimate \r\nand calculation of the amount of tax payable under this section through Iris or any \r\nother automated system specified by the Board.] \r\n \r\n (8) A taxpayer who has paid advance tax under this section for a tax year \r\nshall be allowed a tax credit for that tax in computing the tax due by the taxpayer \r\non the taxable income of the taxpayer for that year. \r\n \r\n (9)  A tax credit allowed for advance tax paid under this section shall be \r\napplied in accordance with sub-section (3) of section 4. \r\n \r\n (10)  A tax credit or part of a tax credit allowed under this section for a tax \r\nyear that is not able to be credited under sub -section (3) of section 4 for the year \r\nshall be refunded to the taxpayer in accordance with section 170. \r\n \r\n 2[  ] \r\n \r\n3[147A. Advance tax from provincial sales tax registered person. - (1) Every \r\nprovincial sales tax registered person shall be liable to pay adjustable advance tax \r\nat the rate of three per cent of the turnover declared before the provincial revenue \r\nauthority. \r\n \r\n(2) The advance tax under sub -section (1) shall be paid monthly at the \r\ntime when sales tax return is to be filed with the provincial revenue authority.  \r\n \r\n(3) Advance tax paid under this section may be taken into account while \r\nworking out advance tax payable under section 147. \r\n \r\n(4) The provisions of this Ordinance shall apply to any advance tax due \r\nunder this section as if the amount due were tax due under an assessment order.  \r\n \r\n                                            \r\n1New sub-section (7A) inserted through Finance Act, 2020 dated 30th June, 2020 \r\n2Sub-section (11) omitted by the Finance Act, 2004. The omitted sub-section (11) read as follows:  \r\n“(11)  In this section, “turnover” shall not include amounts referred to in clauses (a), (b), (ba), (c) and \r\n(d) of sub-section (1).” \r\n3Inserted by the Finance Act, 2016. \r\nChapter X – Procedure__________________________________ \r\n \r\n304 \r\n \r\n(5) A taxpayer who has paid advance tax under this section for a tax year \r\nshall be allowed a tax credit for that tax in computing the tax due by the taxpayer \r\non the taxable income of the taxpayer for that year. \r\n \r\n(6) A tax credit allowed for advance tax paid under this section shall be \r\napplied in accordance with sub-section (3) of section 4. \r\n \r\n(7) A tax credit or part of a tax credit allowed under this section for a tax \r\nyear that is not able to be credited under sub -section (3) of section 4 for the year \r\nshall be refunded to the taxpayer in accordance with section 170. \r\n \r\n(8) This section shall not apply to a person 1[whose name was appearing \r\nin the active taxpayers’ list] on the thirtieth day of June of the previous tax year.] \r\n \r\nDivision II \r\nAdvance Tax Paid to a Collection Agent \r\n \r\n148.  Imports.— (1)  The Collector of Customs shall c ollect advance tax from \r\nevery importer of goods on the value of the goods at the rate specified in Part II of \r\nthe First Schedule  2[in respect of goods classified in Parts I to III of the Twelfth \r\nSchedule] 3[: \r\n  \r\n Provided that the Board may, by a notificati on in the official Gazette, add in \r\nthe Twelfth Schedule any entry thereto or omit any entry therefrom or amend any \r\nentry therein: \r\n  \r\n Provided further that in case of goods classified under Part III of the Twelfth \r\nSchedule which are used both as raw material and finished goods, the Board may, \r\nby notification in the official Gazette, specify that goods imported by a person or \r\nclass of persons as raw material for its own use shall be treated as classified under \r\nPart II of the Twelfth Schedule, subject to such conditions and procedure as may \r\nbe prescribed] 4[: \r\n \r\nProvided also that the Collector of Customs, shall not collect tax under this \r\nsection, where the recipient of goods is also liable under the Digital Presence \r\nProceeds tax, Act, 2025 and same has been collected by the payment intermediary \r\nas defined in section 153.] \r\n                                            \r\n1Words “who was filer” substituted from Finance Act, 2019 \r\n2 The expression inserted through Finance Act, 2020 dated 30th June, 2020 \r\n3 The “full stop” substituted by “colon” and thereafter proviso added through Finance Act, 2020 dated \r\n30th June, 2020 \r\n4 Full stop substituted and a new proviso inserted by the Finance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n305 \r\n \r\n 1[ 2[    ]  ]  \r\n  \r\n3[(2A) Notwithstanding omission of sub -section (2), any notification issued \r\nunder the said sub-section and for the time being in force, shall continue to remain \r\nin force, unless 4[amended or] rescinded by the Board through notification in the \r\nofficial Gazette.”;] \r\n \r\n 5[  ] \r\n 6[  ] \r\n \r\n 7[  ] \r\n  \r\n(5) Advance tax shall be collected in the same manner and at the same \r\ntime as the customs -duty payable in respect of the import or, if the good s are \r\nexempt from customs-duty, at the time customs-duty would be payable if the goods \r\nwere dutiable. \r\n \r\n                                            \r\n1 Sub-section (2) substituted by the Finance Act, 2007. The substituted sub-section (2) read as \r\nfollows:  \r\n“(2) This section shall not apply to – \r\n(a) the re-importation of re-usable containers for re -export qualifying for customs-\r\nduty and sales tax exemption on temporary import under the Customs \r\nNotification No. S.R.O. 344(1)/95, dated the 25th day of April, 1995; or \r\n(b) the importation of the following petroleum products – \r\n“Motor Spirit (MS), Furnace Oil (FO), JP-1 and MTBE”.” \r\n2 Omitted by Finance act, 2015. The omitted sub-section (2) read as follows:- \r\n“(2)Nothing contained in sub-section (1) shall apply to any goods or class of goods or persons or \r\nclass of persons importing such goods or class of goods as may be specified by the Board.” \r\n3 Inserted by Finance Act, 2015. \r\n4Inserted by the Finance Act, 2018. \r\n5Sub-section (3) omitted by the Finance Act, 2007. The omitted sub-section (3) read as follows: \r\n“(3) Where a manufacturer imports raw materials (other than edible oils) exclusively for the \r\nmanufacturer’s own use, the Commissioner may certify a reduction (of up to seventy five per cent) \r\nof the rate of advance tax applicable under this section if the aggregate of tax paid or collected in a \r\ntax year equals the amount of tax paid by the manufacturer in the immediately preceding year.” \r\n6 Sub-section (4) omitted by the Finance Act, 2007. The omitted sub-section (4) read as follows: \r\n“ (4)  Notwithstanding the provisions of sub-section (3), a person being a manufacturer who is liable \r\nto pay advance tax under section 147, imports raw materials ( other than edible oils) exclusively for \r\nhis, or as the case may be, its own use, the Commissioner shall upon application in writing by such \r\nperson, issue an exemption certificate effective from the date on which the certificate is issued to the \r\n30th day of June next falling: \r\n Provided that where the person to whom an exemption certificate has been issued fails to \r\npay any instalment due, the Commissioner may cancel the certificate.” \r\n7Sub-section (4A) omitted by the Finance Act, 2008. The omitted sub-section (4A) read as follows:- \r\n“(4A) Where, in the case of a person whose income is not subject to final taxation, the Commissioner \r\nis satisfied that such person is not likely to pay any tax (other than tax under section 113), the \r\nCommissioner shall, upon applicat ion in writing made by such person, issue certificate allowing \r\npayment of tax collectable under this section at a reduced rate of 0.5%” \r\nChapter X – Procedure__________________________________ \r\n \r\n306 \r\n \r\n (6) 1[Subject to sub-section (6A), the] provisions of the Customs Act, 1969 \r\n(IV of 1969), in so far as relevant, shall apply to the collection of tax un der this \r\nsection. \r\n \r\n2[(6A) The Board may, by notification in the official Gazette, determine the \r\nminimum value of goods for the purpose of collection of advance tax under this \r\nsection.] \r\n \r\n3[(7)  The tax 4[required to be] collected under this section shall be  \r\n5[minimum] tax 6[  ] on the income of the importer arising from the imports subject \r\nto sub -section (1) and this sub -section shall not apply in the case of impor t of  \r\n7[goods on which tax is required to be collected under this section 8[   ] by an \r\nindustrial undertaking for its own use.] 9[  ] \r\n \r\n                                            \r\n1 The word “The” substituted by the Finance Act, 2024. \r\n2 Sub-section (6A) inserted by the Finance Act, 2024. \r\n3Sub-section (7) substituted by the Finance Act, 2006. The substituted sub-section (7) read as \r\nfollows: \r\n“(7) Except in the case of an industrial undertaking importing goods as raw materials, plant, \r\nmachinery and equipment for its own use, the tax collected under this section shall be a final tax on \r\nthe income of the importer arising from the imports subject to sub-section (1).” \r\n4Inserted by  the Finance Act, 2012. \r\n5Words “a final” substituted through Finance Act, 2019.  \r\n6Expression “except as provided under sub-section (8)” omitted through Finance Act, 2019. \r\n7The expression inserted through Finance Act, 2020 dated 30th June, 2020 \r\n8 Words “at the rate of 1% or 2%” omitted by the Finance Act, 2022.  \r\n9The hyphen and clauses (a),(c),(d)and (e) omitted through Finance Act 2 020 dated 30th June, 2020      \r\n— (a)  raw material, plant, machinery, equipment and parts by an industrial  undertaking for its own \r\nuse; \r\n[ ] \r\n(c)   [motor vehicles] in CBU condition by manufacturer of [motor vehicles] [;] \r\n[(d)  large import houses, who,— \r\n(i) have paid-up capital of exceeding Rs. [250] million; \r\n(ii) have imports exceeding Rs.500 million during the tax year; \r\n(iii) own total assets exceeding Rs [350] million at the close of the tax year; \r\n(iv) is single object company; \r\n(v) maintain computerized records of imports and sale of goods;  \r\n(vi) maintain a system for issuance of 100% cash receipts on sales; \r\n(vii) present accounts for tax audit every year; \r\n(viii) is registered9[under the Sales Tax Act, 1990] and \r\n(ix) make sales of industrial raw material of manufacturer registered [Under the Sales Tax \r\nAct,1990] [; and] ] \r\n [(e)  a foreign produced film imported for the purposes of screening and viewing.] \r\nChapter X – Procedure__________________________________ \r\n \r\n307 \r\n \r\n1[(7A) Notwithstanding anything contained in sub-section (7), the tax required \r\nto be collected under this section shall be minimum tax on the income every person \r\narising from imports of following goods – \r\n \r\n(i) edible oil;  \r\n \r\n(ii) packaging material; \r\n \r\n(iii) paper and paper board; or \r\n \r\n(iv) plastics:  \r\n  \r\n  Provided that the Board with the approval of Minister in -charge may, by a \r\nnotification in the official Gazette, add any entry thereto or omit any entry therefrom \r\nor amend any entry therein this sub-section.]  \r\n \r\n2[  ] \r\n (9) In this section – \r\n \r\n“Collector of Customs” means the person appointed as Collector of \r\nCustoms under section 3 of the Customs Act, 1969 (IV of 1969), and \r\nincludes a Deputy Collector of Customs, an Additional Collector of \r\nCustoms, or an officer of customs appointed as such under the \r\naforesaid section; 3[  ] \r\n \r\n4[Value of goods means – \r\n \r\n(a) in case of goods chargeable to tax at retail price under the Third \r\nSchedule of the Sales Tax Act, 1990, the retail price of such goods \r\nincreased by s ales tax payable in respect of the import and \r\ntaxable supply of the goods; 5[  ] ] \r\n \r\n                                            \r\n1 The sub-section (7A) inserted by the Finance Act, 2022. \r\n2 Sub-section (8) and (8A) omitted through Finance Act, 2020 dated 30th June 2020 the omitted sub-\r\nsection read as follows: \r\n[ ]  [(8) The tax required to be collected from a person under this section shall be minimum tax \r\nfor a tax year on the import of─ \r\n [(a)]  \r\n(b) edible oil; \r\n(c) packing material; and \r\n(d) plastic raw material imported by an industrial undertaking falling   under PCT \r\nheadings 39.01 to 39.12.] \r\n  [(8A) The tax collected under this section at the time of import of ships   by ship-breakers shall \r\nbe  [minimum] tax.] \r\n \r\n3The word “and” omitted by the Finance Act, 2004. \r\n4 The expressions substituted by the Finance Act, 2020 dated 30th June, 2020 the substituted \r\nexpressions read as follows:  \r\n“value of the goods means the value of the goods as determined under the Customs Act, 1969 (IV of \r\n1969), as if the goods were subject to ad valorem duty increased by the customs-duty, federal excise \r\nduty and sales tax, if any, payable in respect of the import of the goods.”  \r\n5 The word “and” omitted by the Finance Act, 2024. \r\nChapter X – Procedure__________________________________ \r\n \r\n308 \r\n \r\n(b) in case of 1[goods other than those specified in clauses (a) and \r\n(c)]; the value of the goods as determined under the Customs Act, \r\n1969 (IV of 1969), as if the goods were subject to ad valorem duty \r\nincreased by the custom -duty, federal excise duty and sales tax, \r\nif any, payable in respect of the import of the goods 2[; and] ; and]] \r\n \r\n3[(c)  minimum value as notified by the Board under subsection (6A) as \r\nif such goods were subject to ad valorem duty as increased by the \r\ncustom-duty, federal excise duty and sales tax, payable in respect \r\nof the import of the goods.] \r\n4[  ] \r\n \r\n5[  ] \r\n \r\nDivision III \r\nDeduction of Tax at Source \r\n \r\n149.  Salary. — (1)  Every 6[person responsible for] paying salary to an employee \r\nshall, at the time of payment, deduct tax from the amount paid at the employee’s \r\naverage rate of tax computed at the rates specified in Division I of Part I of the First \r\nSchedule on the estimated income of the employee chargeable under  the head \r\n“Salary” for the tax year in which the payment is made 7[including tax under section \r\n4AB] after making 8[adjustment of tax withheld from employee under other heads \r\nand tax credit admissible under section 61  9[and 63] during the tax year after \r\nobtaining documentary evidence], as may be necessary, for 10[:] \r\n \r\n                                            \r\n1 The words “all other goods” substituted by the Finance Act, 2024. \r\n2 The word “and” omitted by the Finance Act, 2024. \r\n3 Clause (c) added by the Finance Act, 2024. \r\n4The Explanation omitted through Finance Act, 2020 dated 30th June, 2020 the omitted explanation \r\nread as follows: \r\n“Explanation.- For the purpose of this section the expression “edible   oils” includes crude oil, \r\nimported as raw material for manufacture of ghee or cooking oil” \r\n5Section 148(A) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted section read as \r\nfollows: \r\n“148A. Tax on local purchase of cooking oil or vegetable ghee by certain persons. — (1)The \r\nmanufacturers of cooking oil or vegetable ghee, or both, shall be chargeable to tax at the rate of two \r\npercent on purchase of locally produced edible oil. \r\n (2) The tax payable under sub-section (1) shall be final tax in respect of income accruing from \r\nlocally produced edible oil.” \r\n6 The word “employer” substituted by the Finance Act, 2013. \r\n7 Expression inserted by the Finance Act, 2024. \r\n8The words “such adjustment” substituted by the Finance Act, 2007. \r\n9The expression “62, 63 and 64” substituted by the Finance Act, 2022. \r\n10Inserted by the Finance Act, 2007. \r\nChapter X – Procedure__________________________________ \r\n \r\n309 \r\n \r\n1[(i)    tax withheld from the employee under this Ordinance during the tax \r\nyear; \r\n(ii) any excess deduction or deficiency arising out of any previous \r\ndeduction; or \r\n(iii)     failure to make deduction during the year;] \r\n \r\n2[(1A) Notwithstanding the provisions of sub -section (1), any person \r\nresponsible for paying pension to a former employee who is below the age of \r\nseventy years and deriving pension income during a tax year in which the payment \r\nexceeds rupees ten million, shall at the time of payment, deduct tax from the \r\namount which is over and above rupees ten million at the rate provided in Division \r\nI of Part I of the First Schedule of the Ordinance, along with tax deducted under \r\nsection 4AB after making adjustment of tax withheld from former employee under \r\nother heads and tax credit admissible under sections 61 and 63 of the Ordinance \r\nduring the tax year after obtaining documentary evidence, as may be necessary, \r\nfor –  \r\n \r\n(i) tax withheld from the for mer employee under this Ordinance during the tax \r\nyear; or  \r\n(ii)    any excess deduction or deficiency arising out of any previous deduction; or  \r\n(iii)   failure to make deduction during the year.] \r\n \r\n(2) The average rate of tax of an employee for a tax year for the purposes \r\nof sub -section (1) shall be computed in accordance with the following formula, \r\nnamely:– \r\n \r\nA/B \r\nwhere – \r\n \r\nA is the tax that would be payable if the amount referred to in component B of \r\nthe formula were the employee’s taxable income for that year; and \r\n \r\nB is the employee’s estimated income under the head “Salary” for that year  \r\n3[plus tax chargeable under section 4AB]. \r\n \r\n4[(3) Notwithstanding anything contained in sub -sections (1) and (2), every \r\nperson responsible for making payment for directorshi p fee or fee for attending \r\nboard meeting or such fee by whatever name called, shall at the time of payment, \r\ndeduct tax at the rate of twenty percent of the gross amount payable. \r\n \r\n(4) Tax deductible under sub-section (3) shall be adjustable.] \r\n                                            \r\n1The words “any excess deduction or deficiency arising out of any previous deduction or failure to make \r\na deduction during the year.” substituted by the Finance Act, 2007. \r\n2 Sub-section (1A) inserted by the Finance Act, 2025. \r\n3 Expression inserted by the Finance Act, 2024. \r\n4 Sub-section (3) and (4) added by the Finance Act, 2014. \r\nChapter X – Procedure__________________________________ \r\n \r\n310 \r\n \r\n150.  Dividends. — Every 1[person] paying a dividend shall deduct tax from the \r\ngross amount of the dividend paid 2[or collect tax from the amount of dividend in \r\nspecie]  3[  ] at the rate specified in 4[Division I of Part III] of the First Schedule. \r\n \r\n5[   ]  \r\n6[   ]  \r\n \r\n151. Profit on debt. — (1)  Where – \r\n \r\n7[(a) a person pays yield on an account, deposit or a certificate    under the \r\nNational Savings Scheme or Post Office Savings Account;] \r\n \r\n  (b) a banking company 8[or] financial institution pays any profit on a debt, \r\nbeing an account or deposit maintained with the company or institution; \r\n9[  ] \r\n10[(c) the Federal Government, a Provincial Government or a 11[Local \r\nGovernment] pays to any person 12[ ] profit on any security 13[other than \r\nthat referred to in clause (a)] issued by su ch Government or authority; \r\nor]  \r\n \r\n14[(d)   a banking company, a financial institution,  a company referred  \r\n                                            \r\n1The words “resident company” substituted by the Finance Act, 2009. \r\n2 Inserted by the Finance Act, 2021. \r\n3The words “or collect tax from the shareholder in the case of bonus shares,” omitted by the Finance \r\nAct, 2002. \r\n4The expression “Division III of Part I” substituted by the expression “Division I of Part III” by the Finance \r\nAct, 2014. \r\n5 Inserted by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016. \r\n6 Section 150A omitted by the Finance Act, 2021. The omitted section read as follows: \r\n “150A. Return on investment in Sukuks— Every special purpose vehicle, or a company, at the time \r\nof]making payment of a return on investment in sukuks to a sukuk holder shall deduct tax from the \r\ngross amount of return on investment at the rate specified in Division IB of Part III of the First \r\nSchedule.”] \r\n7Clause (a) substituted by the Finance Act, 2003. The substituted clause (a) read as follows:  \r\n“(a) a person pays yield on a National Savings Deposit Certificate, including a Defence Savings \r\nCertificate, under the National Savings Scheme;” \r\n8 The word “and” substituted by the Finance Act, 2003. \r\n9The word “or” omitted by the Finance Act, 2002. \r\n10 Clause (c) substituted by the Finance Act, 2002. The substituted clause (c) read as follows: \r\n“(c)  the Federal Government, a Provincial Government, a local authority,  banking company, \r\nfinancial institution, company referred to in clauses (a) and (b) of the definition of “company” in sub -\r\nsection (2) of section 80, or finance society pays any profit on any bond, certificate, debenture, security \r\nor instrument of any kind (other than a loan agreement between a borrower and a banking company \r\nor a development finance institution) to any person other than a financial institution, “  \r\n11The words “local authority” substituted by the Finance Act, 2008. \r\n12The commas and words “, other than a financial institution,” omitted by the Finance Act, 2003. \r\n13 Inserted by the Finance Act, 2003. \r\n14Added by the Finance Act, 2002. \r\nChapter X – Procedure__________________________________ \r\n \r\n311 \r\n \r\nto in 1[sub-clauses (i) and (ii) of clause (b)] of sub-section (2) of section \r\n80, or a finance society pays any profit on any bond, certificate, \r\ndebenture, security or instrument of any kind (other than a loan \r\nagreement between a borrower and a banking company or a \r\ndevelopment finance institution) to any person other than financial \r\ninstitution.] \r\n \r\nthe payer of the profit shall deduct tax at the rate specified in Division IA of Part III \r\nof the First Schedule from the gross amount of the yield or profit paid as reduced \r\nby the amount of Zakat, if any, paid by the recipient under the Zakat and Ushr \r\nOrdinance, 1980 (XVII of 1980), at the time the profit is paid to the recipient. \r\n \r\n 2[(1A)  Every special purpose vehicle or a company, at the time of making \r\npayment of a return on investment in sukuks to a sukuk holder shall deduct tax \r\nfrom the gross amount of return on investment at the rate specified in Division IB \r\nof Part III of the First Schedule.]  \r\n  \r\n(2) This section shall not apply to any profit on debt that is subject to sub-\r\nsection (2) of section 152. \r\n \r\n3[(3) Tax deductible under this section shall be a 4[minimum] tax on the profit \r\non debt arising to a taxpayer, except where — \r\n \r\n(a) taxpayer is a company; or \r\n  (b) profit on debt is taxable under section 7B.] \r\n \r\n5[151A. Gain arising on disposal of certain debt securities.  — (1) Every \r\ncustodian of debt securities including a banking company responsible to maintain \r\nInvestor Portfolio Securities (IPS) Account on behalf of holder of a debt security \r\nshall at the time of disposal of debt securities including government securities \r\ndeduct tax at the rate specified in Division IIIAA of Part III of the First Schedule on \r\nthe gross amount of capital gain arising to such holder and deposit the same in \r\ngovernment treasury:  \r\n \r\nProvided that this section shall not apply on disposal of debt securities made \r\nthrough registered stock exchange and which are settled through NCCPL.  \r\n                                            \r\n1The words, letters and brackets “clauses (a) and (b)” substituted by the Finance Act, 2003. \r\n2 Sub-section (1A) inserted by the Finance Act, 2021. \r\n3 Substituted by the Finance Act, 2015. The substituted sub-section (3) read as follows:- \r\n “(3)  Tax deductible under this section shall be a final tax on the profit on debt arising to a \r\ntaxpayer other than a company:  \r\n  Provided that in the case of a non-filer other than a company the final tax shall be equal \r\nto the tax deductible in the case of filer and the tax deducted in excess of that shall be advance \r\nincome tax adjustable against tax liability.” \r\n4The word “final” substituted through Finance Act, 2019. \r\n5 Section 151A inserted by the Finance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n312 \r\n \r\n \r\n(2) The capital gain arising to the holder on disposal of debt security \r\nmentioned in sub -section (1) shall be computed in accordance with the formula \r\nprovided in sub-section (1A) of section 37A of the Ordinance.] \r\n \r\n152. Payments to non -residents.— (1) Every pers on paying an amount of \r\n1[royalty] or fees for technical services to a non-resident person that is chargeable \r\nto tax under section 6 shall deduct tax from the gross amount paid at the rate \r\nspecified in Division IV of Part I of the First Schedule. \r\n \r\n 2[(1A) Every person making a payment in full or part (including a payment \r\nby way of advance) to a non-resident person on the execution of –  \r\n \r\n(a)  a contract or sub -contract under a construction, assembly or  \r\ninstallation project in Pakistan, including a contract for the supply of \r\nsupervisory activities in relation to such project; or \r\n \r\n(b)  any other contract for construction or services rendered relating  \r\nthereto; or \r\n \r\n(c)  a contract for advertisement services rendered by T.V. Satellite  \r\nChannels, \r\n \r\nshall deduct ta x from the gross amount payable under the contract at the rate \r\nspecified in Division II of Part III of the First Schedule.] \r\n \r\n3[(1AA) Every person making a payment of insurance premium or re -\r\ninsurance premium to a non -resident person shall deduct tax from t he gross \r\namount paid at the rate specified in Division II of Part III of the First Schedule .]  \r\n \r\n 4[(1AAA)Every person making a payment for advertisement services to a \r\nnon-resident media person relaying from outside Pakistan shall deduct tax from \r\nthe gross amount paid at the rate specified in  5[Division II] of Part III of the First \r\nSchedule.] \r\n \r\n 6[   ] \r\n \r\n                                            \r\n1Substituted for the word  “royalties” by the Finance Act, 2002. \r\n2Inserted by the Finance Act, 2006. \r\n3 Inserted by the Finance Act, 2008. \r\n4Inserted by the Finance Act, 2012. \r\n5The expression “Division IIIA” substituted by the Finance Act, 2017. \r\n6Sub-section (1B) inserted by the Finance Act, 2006. \r\nChapter X – Procedure__________________________________ \r\n \r\n313 \r\n \r\n 1[(1B)  The tax deductible under sub-sections (1A), (1AA) and (1AAA) shall \r\nbe a minimum tax on the income of the non -resident persons in respect of \r\npayments mentioned therein.  \r\n \r\n(1BA) Every person responsible for making payment directly or through an \r\nagent or intermediary to a non -resident person for foreign produced commercial \r\nfor advertisement on any television channel or any other media, shall deduct tax \r\nat the rate of twenty percent from the gross amount paid. The tax deductible under \r\nthis sub-section shall be final tax on the income of non-resident person arising out \r\nof such payment.]  \r\n \r\n2[  ]  \r\n \r\n 3[  ]   \r\n4[   ]  \r\n \r\n5[(1C) Every banking company or a financial  institution remitting outside  \r\nPakistan an amount of fee for offshore digital services, chargeable to tax under  \r\nsection 6, to a non -resident person on behalf of any resident or a permanent  \r\nestablishment of a non-resident in Pakistan shall deduct tax from the gross amount \r\npaid at the rate specified in Division IV of Part I of the First Schedule] 6[: \r\n \r\nProvided that the banking company and financial institution shall not deduct \r\nthe tax under this sub-section where the recipient is also liable to Digital Presence \r\nProceeds tax and same has been collected.] \r\n \r\n7[(1D) Every banking company or a financial institution maintaining  8[, for a \r\nperiod not less than six months, ] special convertible rupee account (SCRA) of a \r\n                                            \r\n1 Sub-sections (1B), (1BB) and (1BBB) substituted by the Finance Act, 2021. The substituted sub -\r\nsections read as follows: \r\n  “(1B) The tax 1[deductible] under sub-section (1A) shall be a 1[minimum] tax on the income of a non-\r\nresident person arising from a contract 1[.] \r\n    (1BB) The tax 1[deductible] under sub-section (1AA) shall be a 1[minimum] tax on the income of the   \r\nnon-resident person arising out of such payment.] \r\n    (1BBB) The tax deductible under sub -section (1AAA) shall be minimum tax on the income of non -  \r\nresident person arising out of such payment.” \r\n2Proviso omitted by the Finance Act, 2019 omitted proviso read as follow:  \r\nProvided that the provisions of this sub-section shall not apply in respect of a non-resident person \r\nunless he opts for the final tax regime. \r\n3 Sub-section (1BB) inserted by the Finance Act, 2008. \r\n4The new Sub-section (1BBB) inserted through Finance Act, 2020 dated 30th June, 2020.  \r\n5 Inserted by the Finance Act, 2018. \r\n6 Full stop substituted with a colon and thereafter a new proviso added by the Finance Act, 2025. \r\n7 New sub-sections (1D) and (1E) inserted through Tax Laws (Second Amendment), 2019 dated 26th \r\nDecember, 2019. \r\n8 Words inserted by the Finance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n314 \r\n \r\nnon-resident company having no permanent establi shment in Pakistan shall \r\ndeduct tax from capital gain arising on the disposal of debt instruments and \r\nGovernment securities including treasury bills and Pakistan investment bo nds \r\ninvested through SCRA at the rate specified in Division II of Part III of the  First \r\nSchedule] 1[: \r\n \r\nProvided that in case of holding period of debt instruments and Government \r\nsecurities including treasury bills and Pakistan investment bonds is less than six \r\nmonths, the capital gain arising on the disposal of such securities to the n on-\r\nresident person shall be taxed at the rates provided in paragraph (2) of Division II \r\nof Part III of the First Schedule of the Ordinance.] \r\n \r\n2[(1DA) Every banking company maintaining a Foreign Currency Value \r\nAccount (FCVA) or a non -resident Pakistani Rupe e Value Account (NRVA) of a \r\nnon-resident individual holding Pakistan Origin Card (POC) or National ID Card for \r\nOverseas Pakistanis (NICOP) or Computerized National ID Card (CNIC) shall \r\ndeduct tax from capital gain arising on the disposal of debt instrument s and \r\ngovernment securities and certificates (including Shariah compliant variant) \r\ninvested through aforesaid accounts at the rate specified in Division II of Part III of \r\nthe First Schedule.]  \r\n \r\n3[(1DB) Every special purpose vehicle or a company, at the tim e of making \r\npayment of a return on investment in sukuks to a non -resident sukuk holder shall \r\ndeduct tax from the gross amount of return on investment at the rate specified in \r\nDivision IB of Part III of the First Schedule.] ] \r\n \r\n4[(1DC) Every exchange company  licensed by the State Bank of Pakistan \r\nshall deduct tax at the time of making payment of service charges or commission \r\nor fee, by whatever name called, to the global money transfer operators, \r\ninternational money transfer operators or such other persons en gaged in \r\ninternational money transfers or cross -border remittances for facilitating outward \r\nremittances, at the rates given in Division IV, Part I of the First Schedule: \r\n \r\nProvided that where such person retains service charges or \r\ncommission or fee, by whatever name called from the amount payable to the \r\nexchange company on any account, the exchange company shall be \r\ndeemed to have paid the service charges or commission or fee, by whatever \r\nname called and the exchange company shall collect the tax accordingly.  \r\n  \r\n                                            \r\n1 Full stop substituted with a colon and thereafter a new proviso added by the Finance Act, 2025. \r\n2 Sub-section (1DA) inserted by the Finance Act, 2021. Earlier this insertion was made through Tax \r\nLaws (Amendment) Ordinance, 2021. \r\n3  Sub-section (1DB) inserted by the Finance Act, 2021. \r\n4  Sub-sections (1DC) and (1DD) inserted by the Finance Act, 2022. \r\nChapter X – Procedure__________________________________ \r\n \r\n315 \r\n \r\n(1DD) Every banking company while making payment to card network \r\ncompany or payment gateway or any other person, of any transaction fee or \r\nlicensing fee or service charges or commission or fee by whatever name called \r\nor interbank financial telecommunica tion services, shall deduct tax at the rates \r\ngiven in Division IV, Part I of the First Schedule: \r\n \r\nProvided that where card network company or payment gateway or \r\nany other person retains money in relation to aforementioned services from \r\nthe amount payable to the banking company on any account, the banking \r\ncompany shall be deemed to have paid the amount and the banking \r\ncompany shall collect the tax accordingly] \r\n \r\n1[(1E) The tax deductible under sub-sections (1D), (1DA) 2[(IDB), (1DC) and \r\n(IDD)] shall be a final tax in respect of persons and income mentioned therein.]    \r\n \r\n(2) Subject to sub -section (3), every person paying an amount to a             \r\nnon-resident person (other than an amount to which sub -section (1)  3[or sub-\r\nsection (1A) 4[, (1AA)] 5[, (1AAA), 6[(1C)] or (2A)] applies)] shall deduct tax from \r\nthe gross amount paid at the rate specified in Division II of Part III of the First \r\nSchedule. \r\n \r\n 7[(2A) Every prescribed person making a payment in full or part including a \r\npayment by way of advance to a permanent establishment in Pakistan of a    non-\r\nresident person— \r\n \r\n8[(a)] for the sale of goods  9[except where the sale is made by the \r\nimporter of the goods and tax under section 148 in respect of \r\nsuch goods has been paid and the goods are sold in the same \r\ncondition as they were when imported]; \r\n \r\n10[(b)] for the rendering of or providing services; and \r\n \r\n                                            \r\n1  Sub-section (1E) substituted by the Finance Act, 2021. Earlier an amendment was made through \r\nTax Laws (Amendment) Ordinance, 2021. The substituted sub-section read as follows: \r\n“(1E) The tax deductible under sub-section (1D) shall be a final tax on the income of the non-\r\nresident company arising out of such capital gain.” \r\n2  The expression “and (1DB)” substituted by the Finance Act, 2022. \r\n3Inserted by the Finance Act, 2007. \r\n4Inserted by the Finance Act, 2010. \r\n5 Inserted by the Finance Act, 2012. \r\n6Inserted by the Finance Act, 2019 \r\n7 Added by the Finance Act, 2012. \r\n8Clause (i) re-numbered by Finance Act 2017. \r\n9Added by the Finance Act, 2016. \r\n10Clause (ii) re-numbered by Finance Act 2017. \r\nChapter X – Procedure__________________________________ \r\n \r\n316 \r\n \r\n1[(c)] on the execution of a contract, other than a contract for the sale \r\nof goods or the rendering of or providing services, shall, at the \r\ntime of making the payment, deduct tax from the gross amount \r\npayable (including sales tax, if any) at the rate specified in \r\nDivision II of Part III of the First Schedule.] \r\n \r\n2[(2AA)  sub-section (1AA) shall not apply to an amount, with the written \r\napproval of the Commissioner,  hat i s taxable to a permanent establishment in \r\nPakistan of the non-resident person.] \r\n \r\n3[(2B) the tax deductible under sub-section (2A) shall be minimum tax: \r\n  \r\n Provided that tax deductible under clause (a) of sub -section (2A) \r\nshall not be minimum tax where paym ents are received for sale of goods by a \r\ncompany being a manufacturer of such goods.] \r\n \r\n(3) Sub-section (2) does not apply to an amount — \r\n \r\n(a) that is subject to deduction of tax under section 149, 150, 4[  ] 5[  \r\n] 156 6[or 233]; \r\n \r\n(b) with the written approval of the Commissioner, that is taxable to \r\na permanent establishment in Pakistan of the non -resident \r\nperson; \r\n \r\n(c) that is payable by a person who is liable to pay tax on the \r\namount as representative of the non-resident person under sub-\r\nsection (3) of section 172; or \r\n \r\n(d) where the non -resident person is not chargeable to tax in \r\nrespect of the amount. \r\n \r\n (4) Where a person claims to be a representative of a non -resident \r\nperson for the purposes of clause (c) of sub -section (3), the person shall file a \r\ndeclaration to that effect with the Commissioner prior to making any payment to \r\nthe non-resident person.  \r\n \r\n                                            \r\n1Clause (iii) re-numbered  by Finance Act 2017. \r\n2 Added by the Finance Act, 2012. \r\n3Sub-section (2B) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted sub-\r\nsection read as follows: \r\n“(2B) The tax deductible under clause (b) of sub-section (2A) shall be a minimum tax and the provisions of \r\nsub-clauses (i), (ii) and (iii) of clause (b) of \r\nsub-section (3) 3[  ] of section 153 shall mutatis mutandis apply.” \r\n4 The figure and comma “153,” omitted by the Finance Act, 2012. \r\n5The figure and comma “155,” omitted by the Finance Act, 2013. \r\n6Inserted by the Finance Act, 2006. \r\nChapter X – Procedure__________________________________ \r\n \r\n317 \r\n \r\n1[2[(4A) The Commissioner may, on application made  3[in the prescribed \r\nform] by the recipient of payment referred to in sub-section (1A) having permanent \r\nestablishment in Pakistan, or by a recipient of payment referred to in sub -section \r\n(2A), as the case may be, and after making such inquiry as the Commissioner \r\nthinks fit, allow by order in writing, in cases where the tax deductable under sub -\r\nsection (1) or s ub-section (2A) is 4[not minimum tax] , any person to make the \r\npayment 5[after deduction of tax at a reduced rate but such reduction shall not \r\nexceed eighty percent of the rate specified in the said Division].] ] \r\n \r\n6[(4B) The Commissioner may, in case of payment that constitutes part of \r\nan overall arrangement of a cohesive business operation as referred to in \r\nparagraph (ii) of sub-clause (g) of clause (41) of section 2, on application made by \r\nthe person making payment and after making such inquiry, as the Com missioner \r\nthinks fit, allow by order in writing, the person to make payment after deduction of \r\ntax equal to 7[twenty] percent of the tax chargeable on such payment under sub -\r\nsection (1A): \r\n \r\n Provided that the credit of the tax so deducted shall be available to \r\nthe permanent establishment of the non -resident accounting for overall \r\nprofits arising on the overall cohesive business operation.] \r\n \r\n (5) Where a person intends to make a payment to a non-resident person \r\nwithout deduction of tax under this section,8[other than payments liable to reduced \r\nrate under relevant agreement for avoidance of double taxation,] the person shall, \r\nbefore making the payment, furnish to the Commissioner a notice in writing setting \r\nout — \r\n \r\n(a) the name and address of the non-resident person; 9[  ]   \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2015. \r\n2Sub-section (4A) substituted by the Finance Act, 2017. The substituted sub-section (4A) reads as \r\nfollows: \r\n “(4A) The Commissioner may, on application made by the recipient of a payment referred to in sub-section (2A) \r\nand after making such inquiry as the Commissioner thinks fit, may allow in cases where the tax deductable under \r\nsub-section (2A) is adjustable, by order in writing, any person to make the payment, without deduction of tax or \r\ndeduction of tax at a reduced rate.”;] \r\n3The words inserted through Finance Act, 2020 dated 30th June, 2020 \r\n4The word “adjustable” substituted through Finance Act, 2019. \r\n5 The expression “without deduction of tax or deduction of tax at a reduced rate” substituted by the \r\nFinance Act, 2024. \r\n6New sub-section (4B) inserted through Finance Act, 2019.  \r\n7The word “thirty” substituted by “twenty” through Finance Act, 2020 dated 30th June, 2020  \r\n8Inserted by the Finance Act, 2008. \r\n9The word “and” omitted through Finance Act, 2020 dated 30th June, 2020  \r\nChapter X – Procedure__________________________________ \r\n \r\n318 \r\n \r\n(b) the nature and amount of the payment 1[;and \r\n \r\n(c) such other particulars as may be prescribed.]  \r\n \r\n2[(5A) The Commissioner on receipt of notice shall 3[, within thirty days,] pass \r\nan order accepting the contention or making the order under sub-section (6)] 4[: \r\n \r\nProvided that the Commissioner shall be deemed to have issued the \r\nexemption certificate upon the expiry of thirty days and the certificate shall be \r\nautomatically processed and issued by Iris subject to the condition that in \r\ncomputing the said period of thirty days, there shall be excluded days taken for \r\nadjournment by the applicant:  \r\n \r\nProvided further that the Commissioner may modify or cancel the certificate \r\nissued automatically by Iris on the basis of reasons to be recorded in writi ng after \r\nproviding an opportunity of being heard.] \r\n  \r\n(6) Where a person has notified the Commissioner of a payment under \r\nsub-section (5) and the Commissioner has reasonable grounds to believe that the \r\nnon-resident person is chargeable to tax under this Ord inance in respect of the \r\npayment, the Commissioner may, by 5[order] in writing, direct the person making \r\nthe payment to deduct tax from the payment in accordance with sub-section (2). \r\n \r\n (7) Sub-section (5) shall not apply to a payment on account of – \r\n \r\n6[(a) an import of goods where title to the goods passes outside \r\nPakistan and is supported by import documents, except where — \r\n \r\n                                            \r\n1The “full stop” substituted by “semi colon” and the word “and” thereafter new clause (c) added \r\nthrough Finance Act, 2020 dated 30th June, 2020. \r\n2 Inserted by the Finance Act, 2003. \r\n3Inserted by the Finance Act, 2004. \r\n4 Full stop substituted with a colon and new provisos added by the Finance Act, 2023. \r\n5 The word “notice” substituted by the Finance Act, 2004. \r\n6Clause (a) substituted by the finance Act 2018, the substituted clause (a) is read as follows \r\n“(a) an import of goods where title to the goods passes outside Pakistan6[and is supported by \r\nimport documents], except an 6[ ] import that is part of an overall arrangement for the \r\nsupply of goods, their installation, and any commission and guarantees in respect of the \r\nsupply where – \r\n (i) the supply is made by the head office outside Pakistan of a person to a permanent \r\nestablishment of the person in Pakistan; \r\n (ii) the supply is made by a permanent establishment of the person outside Pakistan to a \r\npermanent establishment of the person in Pakistan; \r\n(iii) the supply is made between associates; or \r\n(iv) the supply is made by a resident person or a Pakistan permanent establishment of a non-\r\nresident person; or” \r\nChapter X – Procedure__________________________________ \r\n \r\n319 \r\n \r\n(i) the supply is made in connection with the overall arrangement \r\nfor the supply of goods, installation, construction, assembly, \r\ncommission, guarantees or supervisory activities and all or \r\nprincipal activities are undertaken or performed either by the \r\nassociates of the person supplying the goods or its \r\npermanent establishment, whether or not the title passes \r\noutside Pakistan and whether or not the goods are imported \r\nin the name of the associate or any other person; or \r\n \r\n(ii) the supply is made by a resident person or a Pakistan \r\npermanent establishment of a non -resident person in \r\nconnection with the overall arrangement as referred to  in \r\nsub-clause (i); or” ] \r\n \r\n(b) educational and medical expenses remitted in accordance with \r\nthe regulations of the State Bank of Pakistan. \r\n \r\n 1[(8)  In this section “prescribed person” means a prescribed person as \r\ndefined in sub-section (7) of section 153.] \r\n \r\n2[  ] \r\n \r\n 3[  ]  \r\n \r\n                                            \r\n1 Added by the Finance Act, 2012. \r\n2 Inserted by the Finance Act, 2016. \r\n3 Section 152A omitted by the Finance Act, 2021. The omitted section read as follows: \r\n  “152A. Payment for foreign produced commercials.─ (1) Every person responsible for making  \r\npayment directly or through an agent or intermediary to a non-resident person for foreign produced \r\ncommercial for advertisement on any television channel or any other media shall deduct tax at the \r\nrate of twenty percent from the gross amount paid. \r\n(2) The tax deductable under sub -section (1), shall be final tax on the income of non - \r\nresident person arising out of such payment.”  \r\nChapter X – Procedure__________________________________ \r\n \r\n320 \r\n \r\n1[153. Payments for goods, services and contracts. — (1) Every prescribed \r\nperson making a payment in full or part including a payment by way of advance to \r\na resident person 1[  ] 2[  ] — \r\n                                            \r\n1 Section 153 substituted by the Finance Act, 2011. The substituted section 153  read as follows: \r\n“153.  Payments for goods and services. — (1)  Every prescribed person making a payment in full \r\nor part including a payment by way of advance to a resident person or permanent establishment in \r\nPakistan of a non-resident person— \r\n(a) for the sale of goods;  \r\n(b) for the rendering of or providing of services;  \r\n(c) on the execution of a contract, other than a contract for the sale of  goods or the \r\nrendering of or providing of services, \r\nshall, at the time of making the payment, deduct tax from the gross amount payable at the rate specified \r\nin Division III of Part III of the First Schedule. \r\n (1A) Every exporter or an export house making a payment in full or part including a payment by \r\nway of advance to a resident person or permanent establishment in Pakistan of a non-resident person \r\nfor the rendering of or providing of services of stitching, dying, printing, embroidery, washing, sizing \r\nand weaving, shall at the time of making the payment, deduct tax from the gross amount payable at \r\nthe rate specified in Division IV of Part III of the First Schedule. \r\n (2) The gross amount payable for a sale of goods shall include the sales tax, if any, payable \r\nin respect of the sale. \r\n (3)  Omitted.  \r\n (4) The Commissioner may, on application made by the recipient of a payment referred to \r\nin sub-section (1) and after making such enquiry as the Commissioner thinks fit, allow, by order in \r\nwriting, any person to make the payment without deduction of tax. \r\n (5) Sub-section (1) shall not apply to – \r\n(a) a sale of goods where – \r\n  (i) the sale is made by the importer of the goods; \r\n (ii) the importer has paid tax under section 148 in respect of the goods; and \r\n(iii) the goods are sold in the same condition they were in when imported; \r\n(b) a refund of any security deposit;  \r\n(ba) a payment made by the Federal Government, a Provincial Government or a \r\nLocal Government] to a contractor for construction materials supplied to the \r\ncontractor by the said Government or the authority; \r\n(bb)  a cotton ginner who deposits in the Government Treasury, an amount equal to \r\nthe amount of tax deductible on the payment being made to him, and evidence \r\nto this effect is provided to the “prescribed person”; \r\n(c) the purchase of an asset under a lease and buy back agreement by a modaraba, \r\nleasing company, banking company or financial institution; or \r\n(d) any payment for securitization of receivables by a Special Purpose Vehicle to \r\nthe Originator.  \r\n  (e)  Omitted. \r\n  (6)  The tax deducted under this section shall be a final tax on the income of a resident \r\nperson arising from transactions referred to in sub-section (1) or (1A): \r\nProvided that sub -section (6) shall not apply to companies in respect of \r\ntransactions referred to in clause (b) of sub-section (1): \r\nProvided further that this sub -section shall not apply to payments  received on \r\naccount of— \r\n   (i) advertisement services, by owners of newspapers and magazines; \r\n(ii) sale of goods and execution of contracts by a public company listed on \r\na registered stock exchange in Pakistan; and \r\n(iii)  the rendering of or providing of services referred to in sub-clause (b) of \r\nsub-section (1): \r\nProvided that tax deducted under sub -clause (b) of sub -section (1) of section \r\n153 shall be minimum tax. \r\nChapter X – Procedure__________________________________ \r\n \r\n321 \r\n \r\n(a) for the sale of goods  3[including toll manufacturing]  4[, except \r\nwhere payment is less than seventy-five thousand Rupees in \r\naggregate, during a financial year];  \r\n \r\n(b)  for the rendering of or providing of services  5[except where \r\npayment is less than thirty thousand Rupees in aggregate, during \r\na financial year]; \r\n \r\n(c) on the execution of a contract,  6[including contract signed by a \r\nsportsperson] 7[but not including] a contract for the sale of goods \r\nor the rendering of or providing services,  shall, at the time of \r\n                                            \r\n (6A)  The provisions of sub -section (6) in so far as they relate to payments on account of \r\nsupply of goods from which tax is deductible under this section shall  not  apply in respect of a company \r\nbeing a manufacturer of such goods.  \r\n (6B) Omitted previously. \r\n (7) Omitted previously. \r\n (8) Where any tax is deducted by a person making a payment to a Special Purpose Vehicle, \r\non behalf of the Originator, the tax is credited to the Originator. \r\n (8A) Omitted previously. \r\n (9) In this section, – \r\n“prescribed person” means – \r\n(a) the Federal Government; \r\n(b) a company; \r\n(c) an association of persons constituted by, or under law;  \r\n  (cc)  a non-profit organization; \r\n(d) a foreign contractor or consultant;  \r\n(e) a consortium or joint venture;  \r\n(f)  an exporter or an export house for the purpose of sub-section  (1A); \r\n(g) an association of persons, having turnover of fifty million rupees or above in tax \r\nyear 2007 1[or in any subsequent tax year . \r\n(h)  an individual, having turnover of fifty million rupees or above in the tax year 2009 \r\nor in any subsequent year. \r\n“services” includes the services of accountants, architects, dentists, doctors, engineers, \r\ninterior decorators and lawyers, otherwise than as an employee. \r\n“sale of goods” includes a sale of goods for cash or on credit, whether under written \r\ncontract or not “manufacturer” for the purpose of this section means, a person who is \r\nengaged in production or manufacturing of goods, which includes- \r\n (a)  any process in which an article singly or in combination with other articles, \r\nmaterial, components, is either converted into another distinct article or produce \r\nis so changed, transferred, or reshaped that it becomes capable of being put to \r\nuse differently or distinctly; or  \r\n(b)  a process of assembling, mixing, cutting or preparation of goods in any other manner.” \r\n1 The word “or” omitted through Finance Act, 2020 dated 30th June, 2020 \r\n2 The words “permanent establishment in Pakistan of a non -resident person” omitted by the Finance \r\nAct, 2012. \r\n3 The words inserted through Finance Act, 2020 dated 30th June, 2020 \r\n4 Inserted by the Finance Act, 2018. \r\n5 Inserted by the Finance Act, 2018. \r\n6 Inserted by the Finance Act, 2014. \r\n7 The words “other than” substituted by the words “but not including” by the Finance Act, 2014. \r\nChapter X – Procedure__________________________________ \r\n \r\n322 \r\n \r\nmaking the payment, deduct tax from the gross amount payable \r\n(including sales tax, if any) at the rate specified in Division III of \r\nPart III of the First Schedule 1[;] \r\n \r\n   2[Provided that where the recipient of the payment under \r\nclause (b) receives the payment through an agent or any other \r\nthird person and the agent or, as the case may be, the third person \r\nretains service charges or fee, by whatever name called, from the \r\npayment remitted to the recipient, the agent or the third person \r\nshall be treated to have been paid the service charges or fee by \r\nthe recipi ent and the recipient shall collect tax along with the \r\npayment received.] \r\n \r\n (2)  Every exporter or an export house making a payment in full or part \r\nincluding a payment by way of advance to a resident person or permanent \r\nestablishment in Pakistan o f a non-resident person for rendering of or providing \r\nservices of stitching, dying, printing, embroider y, washing, sizing and weaving, \r\nshall at the time of making the payment, deduct tax from the gross amount payable \r\nat the rate specified in Division IV of Part III of the First Schedule. \r\n \r\n 3[(2A) Notwithstanding the provision of sub-section (1), –  \r\n \r\n(i) every payment intermediary at the time of processing payment \r\nthrough digital means, on behalf of a seller of digitally ordered \r\ngoods or services through locally oper ated e -commerce \r\nplatforms (including websites); and  \r\n \r\n(ii) every courier business providing courier services collecting \r\ncash from a buyer under Cash on Delivery (CoD) payment \r\nterms on behalf of a seller for the supply of digitally ordered \r\ngoods and service s through e -commerce platforms (including \r\nwebsites);  \r\n \r\nshall collect tax from the gross amount payable (including sales tax, if any) to the \r\nseller at the rate specified in Division IVA of Part I of the First Schedule to the \r\nOrdinance and deposit to government treasury.] \r\n  \r\n                                            \r\n1 Full stop substituted by the Finance Act, 2017. \r\n2 Added by the Finance Act, 2017. \r\n3 Sub-section (2A) inserted by the Finance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n323 \r\n \r\n(3)  The tax 1[deductible] under 2[ ]  sub-section (1) and under sub-section \r\n(2) of this section, on the income of a resident person or 3[  ], shall be 4[minimum] \r\ntax.  \r\n \r\n  Provided that,— \r\n \r\n(a)  tax deducted under clause (a) of sub -section (1) shall 5[not be \r\nminimum tax]  where payments are received on sale or supply \r\nof goods, by a, — \r\n \r\n   (i)  company being a manufacturer of such goods; or  \r\n \r\n(ii)  public company listed on a registered stock exchange in \r\nPakistan; \r\n \r\n6[  ] \r\n \r\n(c) tax deducted unde r clause (c) of sub -section (1) shall be \r\nadjustable if payments are received by a public company listed \r\non a registered stock exchange in Pakistan, on account of \r\nexecution of contracts7[  ] 8[     ] 9[. \r\n                                            \r\n1 The words “deducted” substituted by the Finance Act, 2012. \r\n2 The words “clauses (a) and (c) of” omitted through Finance Act, 2020 dated 30th June, 2020 \r\n3 The words “ permanent establishment in Pakistan of a non -resident person” omitted by the Finance \r\nAct, 2012. \r\n4 The word “final” substituted by the Finance Act, 2019  \r\n5 The words “be adjustable” substituted through Finance Act, 2019. \r\n6 Clause (b) omitted through Finance Act, 2020 dated 30 th June, 2020 the omitted clause reads as \r\nfollow:- \r\n“(b) tax deductible shall be a minimum tax on transactions referred to in clause (b) of sub-section (1).\" \r\n6[“(i)  where the aforesaid minimum tax for providing or rendering services, in respect of \r\nsectors as specified in clause (94) of Part IV of the Second Schedule is in excess of tax payable \r\nunder Division II of Part. I of the First Schedule, the excess amount of tax paid shall be carried \r\nforward for adjustment against tax liability under the aforesaid Part of the subsequent tax year;”] \r\n \r\n6[“(ii) where the excess tax is not wholly adjusted, the amount not adjusted shall be carried forward \r\nto the following tax year and adjusted against tax liability under the aforesaid Part for that \r\nyear, and so on, but the said excess shall not be carried forward to more than five tax years \r\nimmediately succeeding the tax year for which the excess was first paid; and”] \r\n \r\n6[“(iii) the said excess amount shall not be carried forward in case of a company for which \r\nprovisions of this clause are not applicable under clause (9 4) of Part IV of the Second \r\nSchedule; 6[   ] \";] \r\n \r\n7substituted “.” by the Finance Act, 2015 \r\n8The word “and” omitted by the Finance Act, 2016.  \r\n9 Semi colon substituted with  a full stop and new explanation added by the by the Finance \r\n(Supplementary) Act, 2022.  \r\nChapter X – Procedure__________________________________ \r\n \r\n324 \r\n \r\n \r\n \"Explanation.— For the removal of doubt, it is explained that the \r\nincome of resident person referred to in sub -section (3) means \r\nthe amount on which tax is deductible under sub -section (1) or \r\n(2) of this section.]   \r\n \r\n1[  ] \r\n \r\n2[  ] \r\n \r\n 3[(4) The Commissioner may, on application made by the recipient of a \r\npayment referred to in sub -section (1) and after making such inquiry as the \r\nCommissioner thinks fit, may allow in cases where tax deductible under sub -\r\nsection (1) is not minimum, by an order in writing, any person to make the payment \r\nafter deduction of tax at r educed rate but such reduction shall not exceed eighty \r\npercent of the rate specified in the said Division 4[except in cases of public limited \r\ncompanies where the Commissioner may allow payment without deduction of any \r\ntax]: \r\n \r\nProvided that the Commissioner shall issue reduced rate certificate within \r\nfifteen days of filing of application to a company if advance tax liability has been \r\ndischarged:  \r\n \r\nProvided further that the Commissioner shall be deemed to have issued the \r\nreduced rate certificate upon the expir y of fifteen days to the aforesaid company \r\nand the certificate shall be automatically processed and issued by Iris:  \r\n                                            \r\n1 Claude (d) omitted through Finance Act, 2020 dated 30 th June, 2020 the omitted clause read as \r\nfollows: “(d)tax deducted under clause (c) of sub -section (1) in respect of a sportsperson shall be \r\n1[minimum] tax 1[   ] 1[; and] “ \r\n2 Claude (e) omitted through Finance Act, 2020 dated 30 th June, 2020 the omitted clause read as \r\nfollows: “(e) tax deducted under clause (b) of sub -section (1) by person making payments to \r\nelectronic and print media for advertising services shall be 2[minimum] tax 2[  ].” \r\n3 Sub-section (4) substituted by the Finance Act, 2024. The substituted sub-section read as follows: \r\n“(4)  The Commissioner may, on application made by the recipient of a payment referred to in sub-\r\nsection (1) and after making such inquiry as the Commissioner thinks fit, may allow in cases where \r\ntax deductible under sub-section (1) is 3[not minimum], by an order in writing, any person to make \r\nthe payment,— \r\n  (a)  without deduction of tax; or \r\n  (b)  deduction of tax at a reduced rate 3[; \r\nProvided that the Commissioner shall issue certificate for payment under clause (a) of sub -section \r\n(1) without deduction of tax within fifteen days of filing of application to a 3[company] if advance tax \r\nliability has been discharged: \r\nProvided further that the Commissioner shall b e deemed to have issued the exemption certificate \r\nupon the expiry of fifteen days to the aforesaid 3[  ] company and the certificate shall be automatically \r\nprocessed and issued by Iris: \r\nProvided also that the Commissioner may modify or cancel the certifica te issued automatically by \r\nIris on the basis of reasons to be recorded in writing after providing an opportunity of being heard.]” \r\n4  Words inserted by the Finance Act, 2025.  \r\nChapter X – Procedure__________________________________ \r\n \r\n325 \r\n \r\nProvided also that the Commissioner may modify or cancel the certificate \r\nissued automatically by Iris on the basis of reasons to be recorde d in writing after \r\nproviding an opportunity of being heard.]  \r\n \r\n1[  ] \r\n \r\n (5)  Sub-section (1) shall not apply to — \r\n \r\n(a)  a sale of goods where the sale is made by the importer of the \r\ngoods and tax under section 148 in respect of such goods has \r\nbeen paid and the goods are sold in the same condition as they \r\nwere when imported;  \r\n \r\n2[   ]  \r\n  (c)  a refund of any security deposit; \r\n \r\n(d)  a payment made by the Federal Government, a Provincial \r\nGovernment or a Local Government to a contractor for \r\nconstruction materials  supplied to the contractor by the said \r\nGovernment or the authority; \r\n \r\n3[    ]  \r\n \r\n(f)  the purchase of an asset under a lease and buy back \r\nagreement by a modaraba, leasing company, banking company \r\nor financial institution; or \r\n \r\n(g)  any payment for securitiza tion of receivables  4[or issuance of \r\nsukuks] by a Special Purpose Vehicle to the Originator. \r\n \r\n (6)  Where any tax is deducted by a person making a payment for a \r\nSpecial Purpose Vehicle, on behalf of the Originator, the tax is credited to the \r\nOriginator. \r\n                                            \r\n1Sub-section (4A) omitted through Finance Act, 2019, omitted sub-section read as follows: \r\n(4A) The Commissioner, on an application made by the recipient of a payment referred to in \r\nclause (94) of Part IV of the Second Schedule, in cases where the said recipient has fulfilled the \r\nconditions as specified in the said clause, by an order in writing for a period of at least three months, \r\nmay allow any person to make the payment without deduction of tax in respect of payments as referred \r\nto in clauses (b) of sub-section (1) of section 153: \r\nProvided that the recipient of the payment has made advance payment of tax equal to two \r\npercent of the total turnover of the corresponding period of the immediately preceding tax year. \r\n2 Clause (b) omitted by the Finance Act, 2021. The omitted clause read as follows: \r\n   “(b)  payments made to traders of yarn by the taxpayers specified in the zero- rated regime of sales \r\ntax (as provided under clause (45A) of Part-IV of the Second Schedule);” \r\n3 Clause (e) omitted by the Finance Act, 2016. The omitted clause (e) read as follows:- \r\n“(e)  a cotton ginner who deposits in the Government Treasury, an amount equal to the amount of \r\ntax deductible on the payment being made to him, and evidence to this effect is provided to the \r\n“prescribed person”. \r\n4 Inserted by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016.  \r\nChapter X – Procedure__________________________________ \r\n \r\n326 \r\n \r\n (7)  In this section, — \r\n \r\n  (i)  “prescribed person” means— \r\n \r\n   (a)  the Federal Government; \r\n \r\n   (b)  a company; \r\n \r\n   (c)  an association of persons constituted by, or under law; \r\n \r\n   (d)  a non-profit organization; \r\n \r\n   (e)  a foreign contractor or consultant; \r\n \r\n   (f)  a consortium or joint venture; \r\n \r\n(g)  an exporter or an export house for the purpose of sub -\r\nsection (2); \r\n     \r\n(h)  an association of persons, having turnover of 1[one \r\nhundred] million rupees or above in 2[any of the preceding \r\ntax years]; 3[  ] \r\n \r\n(i)  an individual, having turnover of 4[one hundred] million \r\nrupees or above in 5[any of the preceding tax years]; 6[ ] \r\n \r\n[(j)  a person registered under the Sales Tax Act, 1990         \r\n7[having turnover of one hundred million rupees or more \r\nin any of the preceding tax years]; 8[ ] 9[ ] ]  \r\n \r\n10[(k) a person deriving income from the business of \r\nconstruction  and sale of residential, commercial or other \r\nbuildings (builder); 11[ ] \r\n \r\n                                            \r\n1 The word “fifty” substituted through Finance Act, 2020 dated 30th June, 2020 \r\n2 The expression “tax year 2007 or in any subsequent tax year” substituted by the finance Act 2018. \r\n3 The word “or” omitted by the Finance Act, 2013. \r\n4 The word “fifty” substituted through Finance Act, 2020 dated 30th June, 2020 \r\n5 The expression “the tax year 2009 or in any subsequent tax year” substituted by the finance Act 2018. \r\n6 The word “or” omitted by the finance Act 2018. \r\n7 The expression inserted through Finance Act, 2020 dated 30th June, 2020 \r\n8 Inserted by the finance Act 2018. \r\n9 The word “or” omitted by the Finance Act, 2025.  \r\n10Added by the Finance Act, 2018. \r\n11 The word “or” omitted by the Finance Act, 2025.  \r\nChapter X – Procedure__________________________________ \r\n \r\n327 \r\n \r\n(l) a person deriving income from the business of \r\ndevelopment and sale of residential, commercial or other \r\nplots (developer)] 1[;] \r\n \r\n2[(m) for the purpose of sub -section (2A), a payment \r\nintermediary; or  \r\n   \r\n  (n) for the purpose of sub-section (2A), a courier service.] \r\n \r\n(ii)  “services” includes the services of accountants, architects, \r\ndentists, doctors, engineers, interior decorators and lawyers, \r\notherwise than as an employee; \r\n \r\n3[(iia) “courier service ” means any specialized entity that provides \r\nfast, secure and often tracked transportation of documents, \r\npackages and small freight, typicall y offering door -to-door \r\ndelivery solutions of goods within specific timeframes and in \r\ncase of digitally ordered goods in e -commerce delivery and \r\ncollection of cash (CoD) on behalf of the seller and such delivery \r\nservice provider includes but not limited to –  \r\n \r\n(a) Logistics services;  \r\n \r\n(b) ride-haling services;  \r\n \r\n(c) food delivery platforms; and  \r\n \r\n(d) e-commerce services;  \r\n  \r\n(iib) “payment intermediary” means any third party entity including a \r\nbanking company, financial institution, a licensed foreign \r\nexchange company or payments gateways that facilitate the \r\ntransfer of funds or payment instructions between two or more \r\nparties to enable, process, route or settle payments in a \r\nfinancial transaction, without being the ultimate source or \r\nrecipient of the payment;] \r\n \r\n(iii)  “sale of goods” includes a sale of goods for cash or on credit, \r\nwhether under written contract or not; 4[and] \r\n \r\n                                            \r\n1 Full stop substituted by the Finance Act, 2025.  \r\n2 Sub-clauses (m) and (n) added by the Finance Act, 2025.  \r\n3 Sub-clauses (m) and (n) added by the Finance Act, 2025.  \r\n4 Word added by the Finance Act, 2025.  \r\nChapter X – Procedure__________________________________ \r\n \r\n328 \r\n \r\n(iv)  “manufacturer” means a person who is engaged in production \r\nor manufacturing of goods, which includes— \r\n \r\n(a)  any process in whic h an article singly  or in combination \r\nwith other articles, material, components, is either \r\nconverted into another distinct article or product is so \r\nchanged, transferred, or reshaped that it becomes \r\ncapable of being put to use differently or distinctly; or  \r\n \r\n(b)  a process of assembling, mixing, cutting or preparation of \r\ngoods in any other manner; and  \r\n \r\n  (v)  “turnover” means— \r\n \r\n(a)  the gross sales or gross receipts, inclusive of sales tax \r\nand federal excise duty or any trade discounts shown on \r\ninvoices, or bills, derived from the sale of goods;  \r\n \r\n(b)  the gross fees for the rendering of services for giving \r\nbenefits including commissions;  \r\n    \r\n   (c)  the gross receipts from the execution of contracts; and \r\n \r\n(d)  the company’s share of the amounts stated above of any \r\nassociation of persons of which the company is a \r\nmember.] \r\n \r\n1[  ] \r\n2[   ] \r\n 3[   ]  \r\n \r\n154.  Exports. — (1)  Every authorised dealer in foreign exchange shall, at the \r\ntime of realisation of foreign exchange proceeds on account of the export of goods \r\n                                            \r\n1 Section 153A omitted by the Finance Act, 2013. Earlier it was substituted by the Finance Act, 2012, \r\nwhich was inserted by the Finance Act, 2008. The omitted section 153A read as follows: \r\n“153A. Payment to traders and distributors. — (1) Every manufacturer, at the time of sale to \r\ndistributors, dealers and wholesalers, shall collect tax at the rate specified in P art IIA of the First \r\nSchedule, from the aforesaid persons, to whom such sales have been made. \r\n(2) Tax credit for the tax collected under sub-section (1) shall be allowed in computing the \r\ntax due by the person on the taxable income for the tax year in which the tax was collected.” \r\n2New section 153B inserted through Finance Act, 2019.  \r\n3 Section 153B omitted by the Finance Act, 2021. The omitted section read as follows: \r\n“153B. Payment of royalty to resident persons.- (1) Every person paying an amount of royalty, in \r\nfull or in part including by way of advance, to a resident person shall deduct tax from the gross amount \r\npayable (including Federal excise duty and provincial sales tax, if any) at the rate specified in Division \r\nIIIB of Part III of the First Schedule. \r\n (2) The tax deductible under sub-section (1) shall be adjustable.” \r\nChapter X – Procedure__________________________________ \r\n \r\n329 \r\n \r\nby an exporter, deduct tax 1[including advance tax] from the proceeds at the rate \r\nspecified in Division IV of Part III of the First Schedule.  \r\n \r\n 2[   ]    \r\n (3) Every banking company shall, at the time of realisation of the \r\nproceeds on account of a sale of go ods to an exporter under an inland back -to-\r\nback letter of credit or any other arrangement as prescribed by the 3[Board], deduct \r\ntax from the amount of the proceeds at the rate specified in Division IV of Part III \r\nof the First Schedule. \r\n \r\n4[(3A) The Export P rocessing Zone Authority established under the Export \r\nProcessing Zone Authority Ordinance, 1980 (VI of 1980), shall at the time of export of \r\ngoods by an industrial undertaking located in the areas declared by the Federal \r\nGovernment to be a Zone within the meaning of the aforesaid Ordinance, collect tax at \r\nthe rate specified in Division IV of Part III of the First Schedule.] \r\n \r\n5[(3B) Every direct exporter and an export house registered under the Duty \r\nand Tax Remission for Exports Rules, 2001 provided in Sub-Chapter 7 of Chapter \r\nXII of the Customs Rules, 2001 6[and Export Facilitation Scheme, 2021] s hall, at \r\nthe time of making payment for a firm contract to an indirect exporter defined under \r\nthe said rules, deduct tax at the rates specified in Division IV of Part III of the First \r\nSchedule.] \r\n \r\n 7[(3C) The Collector of Customs at the time of clearing of goods exported \r\nshall collect tax from the gross value of such goods at the rate specified in Division \r\nIV of Part III of the First Schedule.] \r\n \r\n (4) The tax 8[deductible] under 9[this section] shall be a 10[minimum] tax \r\non the income arising from the 11[transactions referred to in this section]. \r\n \r\n12[  ] \r\n                                            \r\n1  Words inserted by the Finance Act, 2024. \r\n2  Sub-sections (2) omitted by the Finance Act, 2022. The omitted sub-section read as follows: \r\n“(2) Every authorised dealer in foreign exchange shall, at the time of realisation of foreign exchange \r\nproceeds on account of the commission due to an indenting commission agent, deduct tax from the \r\nproceeds at the rate specified in Division IV of Part III of the First Schedule.” \r\n3 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n4 Inserted by the Finance Act, 2003. \r\n5 Inserted by the Finance Act, 2003. \r\n6 Expression inserted by the Finance Act, 2023. \r\n7 Inserted by the Finance Act, 2009. \r\n8The words “deducted” substituted by the Finance Act, 2012. \r\n9The word, figures, brackets and commas “sub-section (1), (3), (3A) or (3B)” substituted by the Finance \r\nAct, 2006. \r\n10 The word “final” substituted by the Finance Act, 2024. \r\n11The words ”export or sale to an exporter” substituted by the Finance Act, 2007. \r\n12 Sub-section (5) inserted by the Finance Act, 2015. \r\nChapter X – Procedure__________________________________ \r\n \r\n330 \r\n \r\n1[  ]  \r\n \r\n2[154A. Export of Services.  — (1) Every authorized dealer in foreign exchange \r\nshall, at the time of realization of foreign exchange proceeds on account of the \r\nfollowing, deduct tax from the proceeds at the rates specified in Division IVA of \r\nPart III of the First Schedule –   \r\n  \r\n(a)   exports of computer software or IT services or IT enabled services      \r\n3[where the e xporter is registered with and duly certified by the \r\nPakistan Software Export Board (PSEB).];  \r\n  \r\n(b) services or technical services rendered outside Pakistan or    \r\nexported from Pakistan; \r\n \r\n(c)   royalty, commission or fees derived by a resident company fro m a \r\nforeign enterprise in consideration for the use outside Pakistan of any \r\npatent,  invention, model, design, secret process or formula or similar \r\nproperty right, or information concerning industrial, commercial or \r\nscientific knowledge, experience or skil l made available or provided \r\nto such enterprise;   \r\n  \r\n(d) construction contracts executed outside Pakistan 4[: \r\n \r\n (da)  foreign commission due to an indenting commission agent;] \r\n  \r\n    \r\n(e)  other services rendered outside Pakistan as notified by the Board    \r\nfrom time to time;   \r\n  \r\n(2) The tax deductible under this section shall be a final tax on the income \r\narising from the transactions referred to in this section, upon fulfilment of the \r\nfollowing conditions –  \r\n  \r\n(a) return has been filed; \r\n \r\n                                            \r\n1 Sub-section (5) omitted by the Finance Act, 2024. The omitted sub-section read as follows: \r\n“[(5) The provisions of sub-section (4) shall not apply to a person who opts not to be subject to final \r\ntaxation: \r\nProvided that this sub -section shall be applicable from tax year 2015 and the option shall be \r\nexercised every year at the time of filing of return under section 114: \r\nProvided further that the tax deducted under this sub-section shall be minimum tax.]” \r\n” \r\n2 Section 154A inserted by the Finance Act, 2021. \r\n3 The expression “in case tax credit under section 65F is not available” substituted by the Finance Act, \r\n2022. \r\n4 The expression “; and“ substituted with colon and new clause (da) inserted by the Finance Act, 2022. \r\nChapter X – Procedure__________________________________ \r\n \r\n331 \r\n \r\n1[(b)  withholding tax statements for the relevant tax year have been filed if  \r\nrequired under the Ordinance;] and \r\n \r\n(c) sales tax returns under Federal or Provincial laws have been filed, if \r\nrequired under the law 2[: \r\n   Provided that this condition shall not apply in case of an \r\nexporter mentioned in clause (a) of sub-section (1) of this section.] \r\n   \r\n  (d)   no credit for foreign taxes paid shall be allowed.  \r\n  \r\n            (3) The provisions of sub-section (2) shall not apply to a person who does \r\nnot fulfill the specified conditions or who opts not to be subject to final taxation:  \r\n  \r\nProvided that the option shall be exercised every year at the time of \r\nfiling of return under section 114.  \r\n  \r\n3[  ] \r\n \r\n(5) The Board in consultation with State Bank of Pakistan shall prescribe \r\nmode, manner and procedure of payment of tax under this section.  \r\n  \r\n(6) The Board shall have power to include or exclude certain services for \r\napplicability of provisions of this section.] \r\n \r\n155. 4[Rent of immoveable] property.— (1) 5[Every]  prescribed person making \r\na payment in full or part (including a payment by way of advance) to any person \r\non account of rent of immovable property (including rent of furniture and fixtures, \r\nand amounts for services relating to such property) shall deduct tax from the gross \r\namount of ren t paid at the rate specified in Division V of Part III of the First \r\nSchedule. \r\n \r\n 6[Explanation.- “gross amount of rent” includes the amount referred to in sub-\r\nsection (1) or (3) of section 16, if any.] \r\n                                            \r\n1 Clause (b) substituted by the Finance Act, 2022. The substituted clause read as follows: \r\n“(b) withholding tax statements for the relevant  tax year have been filed;” \r\n2 Full stop substituted with a colon and proviso added by the Finance Act, 2023. \r\n3 Sub-section (4) omitted by the Finance Act, 2022. The omitted sub-section read as follows: \r\n“(4) Where a taxpayer, while explaining the nature and source of any amount, investment, money, \r\nvaluable article, expenditure, referred to in section 111, takes into account any source of income which \r\nis subject to final tax in accordance with the provisions of this section, he shall not be entitled to take \r\ncredit of a sum that can be reasonably attributed to the business activity or activities mentioned in sub-\r\nsection (1).]  \r\n4 The words “income from” substituted by the Finance Act, 2021. \r\n5 The words, brackets, figure and comma “Subject to sub-section (2), every” substituted by the Finance \r\nAct, 2006. \r\n6Inserted by the Finance Act, 2006. \r\nChapter X – Procedure__________________________________ \r\n \r\n332 \r\n \r\n \r\n1[Explanation.— For removal of doubt, it is clarified that the sub section (1) \r\nshall apply when a payment is made on account of rent of immoveable property \r\nirrespective of head of income] \r\n \r\n 2[  ] \r\n  \r\n 3[(3)  In this section, “prescribed person” means – \r\n  (i)  the Federal Government;  \r\n \r\n (ii)  a Provincial Government; \r\n \r\n (iii)  4[Local Government]; \r\n \r\n (iv)  a company; \r\n \r\n (v)  a non-profit organization5[or a charitable institution]; \r\n \r\n (vi)  a diplomatic mission of a foreign state; 6[  ] \r\n \r\n7[(via) a private educational institution, a boutique, a beauty parlour, a \r\nhospital, a clinic or a maternity home;] \r\n \r\n8[(vib)  individuals or association of persons paying gross rent of rupees one \r\nand a half million and above in a year; or] \r\n \r\n(vii)  any other person notified by the 9[Board] for the purpose of this \r\nsection.] \r\n \r\n156. Prizes and winnings.—(1)  Every person paying 10[prize on] a prize bond, \r\nor winnings from a raffle, lottery, 11[prize on winning a quiz, prize offered by \r\ncompanies for promotion of sale,] or cross -word puzzle shall deduct tax from the \r\n                                            \r\n1 Added by the Finance Act, 2021.  \r\n2 Sub-section (2) omitted by the Finance Act, 2010. The omitted sub-section (2) read as follows: \r\n “(2) The tax deducted under sub-section (1) shall be a final tax on the income from property.” \r\n3Sub-section (3) substituted  by the Finance Act, 2006. The substituted sub-section (3) read as follows: \r\n “(3) In this section, “prescribed person” means the Federal Government, a Provincial Government, \r\nlocal authority, a company, a non-profit organisation or a diplomatic mission of a foreign state.” \r\n4The words “local authority” substituted by the Finance Act, 2008. \r\n5Inserted by the Finance Act, 2013. \r\n6 The word “or” omitted by the Finance Act, 2013.  \r\n7 Inserted by the Finance Act, 2013. \r\n8 Inserted by the Finance Act, 2013. \r\n9 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n10 Inserted by the Finance Act, 2002. \r\n11Inserted by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n333 \r\n \r\ngross amount paid at the rate specified in Division VI of Part III of the First \r\nSchedule.  \r\n \r\n (2) Where a prize, referred to in sub -section (1), is not in cash, the person \r\nwhile giving the prize shall collect tax on the fair market value of the prize. \r\n \r\n1[(3) The tax 2[deductible] under sub-section (1) or collected under  \r\n3[sub-]section (2) shall be final tax on the income from prizes or winnings referred \r\nto in the said sub-sections.] \r\n \r\n4[156A. Petroleum Products.— (1) Every person selling petroleum products to a \r\npetrol pump operator shall deduct tax from the amount of commission or discount \r\nallowed to the operator at the rate specified in Division VIA of Part III of the First \r\nschedule. \r\n \r\n (2) The tax 5[deductible] under sub-section (1) shall be a final tax on the \r\nincome arising from the sale of petroleum products to which sub-section (1) applies.] \r\n \r\n6[  ] \r\n                                            \r\n1 Sub-section (3) substituted by the Finance Act, 2002. The substituted sub-section (3) read as follows: \r\n“(3) The tax deducted under sub-section (1) shall be a final tax on the prize bond or winnings.“  \r\n2 The words “deducted” substituted by the Finance Act, 2012. \r\n3Inserted by the Finance Act, 2014. \r\n4 Added by the Finance Act, 2004. \r\n5 The words “deducted” substituted by the Finance Act, 2012. \r\n6 Section 156B omitted through Finance Act, 2020 dated 30 th June, 2020 the omitted section read as \r\nfollows: 156B. Withdrawal of balance under Pension Fund.— (1) A pension fund manager making \r\npayment from individual pension accounts, maintained under any approved Pension Fund, shall deduct \r\ntax at the rate specified in sub-section (6) of section 12 from any amount – \r\n(a) withdrawn before the retirement age 6[:] \r\n6[Provided that the tax shall not be deducted in case of the eligible person suffering from any disability \r\nas mentioned in sub -rule (2) of rule 17 of the Voluntary Pension System Rules, 2005 which renders \r\nhim unable to continue with any employment at the age which he may so elect to be treated as the \r\nretirement age or the age as on the date of such disability if not so elected by him.] \r\n \r\n6[Provided further that the tax shall not be deducted on the share of the nominated survivor of the \r\ndeceased eligible person and would be treated as if the eligible person had reached the age of \r\nretirement.] \r\n(b)  withdrawn, if in excess of 6[fifty per cent] of his accumulated balance at or after the retirement \r\nage: \r\n \r\n6[Provided that the tax shall not be deducted in case, the balance in the eligible persons’ individual \r\npension account is invested in an approved income payment plan of a pension fund manager or paid \r\nto a life insurance company for the purchase of an approved annuity plan or is transferred to another \r\nindividual pension account of the eligible person or the survivors’ pension account in case of death of \r\nthe eligible person maintained with any other pension fund manager as specified in the Voluntary \r\nPension System Rules, 2005. \r\nChapter X – Procedure__________________________________ \r\n \r\n334 \r\n \r\n1[  ] \r\n \r\n2[158.Time of deduction of tax. — A person required to deduct tax from an  \r\namount paid by the person shall deduct tax — \r\n \r\n(a)  in the case of deduction under section 151, at the time the  \r\namount is 3[paid or] credited to the account of recipient 4[, \r\nwhichever is earlier]; and  \r\n \r\n(b)  in other cases, at the time the amount is actually paid 5[;and] \r\n \r\n6[“(c) amount actually paid shall have the meaning as may be \r\nprescribed.”;]  \r\n                                            \r\n1 Omitted by the Finance Act, 2002. The omitted section 157 read as follows: \r\n “157. Petroleum products.- (1)  Every person selling petroleum products to a petrol pump operator \r\nshall deduct tax from the amount of commission or discount allowed to the operator at the rate \r\nspecified in Division VII of Part III of the First Schedule.  \r\n (2) The tax deducted under sub-section (1) shall be a final tax on the income arising from \r\nthe sale of petroleum products to which sub-section (1) applies.”  \r\n2Substituted by the Finance Act, 2002. The substituted section 158 read as follows: \r\n “158. Time of deduction of tax.- A person required to deduct tax from an amount paid by the person \r\nshall deduct the tax at the earlier of – \r\n(a) the time the amount is credited to the account of the recipient; or \r\n(b) the time of amount is actually paid.” \r\n3 Inserted by the Finance Act, 2003. \r\n4 Inserted by the Finance Act, 2003. \r\n5Substituted “.” By Finance Act, 2015. \r\n6Added by the Finance Act, 2015. \r\nChapter X – Procedure__________________________________ \r\n \r\n335 \r\n \r\nDivision IV \r\nGeneral Provisions Relating to the Advance Payment of Tax or the \r\nDeduction of Tax at Source \r\n \r\n159.  Exemption or lower rate certificate. — (1)  Where the Commissioner is \r\nsatisfied that an amount 1[  ] to which Division II or III of this Part 2[or Chapter XII] \r\napplies is – \r\n \r\n(a) exempt from tax under this Ordinance; or \r\n \r\n(b) subject to tax at a rate lower than that specified in the First Schedule \r\n3[; or \r\n \r\n(c) is subject to hundred percent tax credit under 4[under this Ordinance],] \r\n \r\nthe Commissioner shall, upon applica tion in writing by the person, 5[in the \r\nprescribed form] issue the person with an exemption or lower rate certificate 6[: \r\n \r\n  Provided that in case of a company, the Commissioner shall issue \r\nexemption or lower rate certificate under this section within fifteen days of filing of \r\napplication by the company:  \r\n  \r\n   Provided further that the Commissioner shall be deemed to have issued \r\nthe  exemption certificate upon the expiry of fifteen days from filing of application \r\nby the aforesaid company and the certificate shall be automatically processed and \r\nissued by Iris:   \r\n  \r\n   Provided also that the Commissioner may modify or cancel the certificate \r\nissued automatically by Iris on the basis of reasons to be recorded in writing after \r\nproviding an opportunity of being heard.] \r\n \r\n7[(1A) The Commissioner shall, upon application from a person ,8[in the \r\nprescribed form] whose income is not likely to be chargeable to tax under 9[  ] this \r\nOrdinance, issue exemption certificate for the profit on debt referred to in clause \r\n(c) of sub-section (1) of section 151.] \r\n                                            \r\n1The words “paid to a person” omitted by the Finance Act, 2003. \r\n2Inserted by the Finance Act, 2002. \r\n3Comma substituted by a semi colon and a new clause (c) added by the Finance Act, 2014. \r\n4 The expression “section 100C” substituted by the Finance Act, 2021. \r\n5The words inserted through Finance Act, 2020 dated 30th June, 2020 \r\n6 Full stop substituted and three provisos added by the Finance Act, 2021.  \r\n7 Inserted by the Finance Act, 2003. \r\n8The words inserted through Finance Act, 2020 dated 30th June, 2020 \r\n9 The word “the” omitted by the Finance Act, 2004. \r\nChapter X – Procedure__________________________________ \r\n \r\n336 \r\n \r\n1[(1B) The Commissioner shall, upon application from a person, in the \r\nprescribed form whose income from capital gains is not chargeable to tax under \r\nsub-section (1A) of section 37, issue exemption certificate for collection of advance \r\ntax under section 236C, in respect of a residential immovable property, which —  \r\n \r\n(a) has been in the personal use for the last fifteen years;  \r\n \r\n(b) has been declared by the person in his wealth statement under \r\nsection 116 for the last fifteen years; and  \r\n \r\n(c) appears as residence for personal use in tax record of the person:  \r\n \r\nProvided that the exemption certificate under this section shall \r\nbe issued once in fifteen years.]  \r\n  \r\n(2) A person required to collect advance tax under Division II of this P art \r\nor deduct tax from a payment under Division III of this Part 2[or deduct or collect \r\ntax under Chapter XII] shall collect or deduct the full amount of tax specified in \r\nDivision II or III 3[or Chapter XII], as the case may be, unless there is in force a \r\ncertificate issued under sub -section (1) relating to the collection or deduction of \r\nsuch tax, in which case the person shall comply with the certificate.  \r\n \r\n 4[ 5[   ]  ] \r\n 6[  ] \r\n \r\n 7[  [   ] ] \r\n                                            \r\n1 Sub-section (1B) inserted by the Finance Act, 2025. \r\n2 Inserted by the Finance Act, 2003. \r\n3 Inserted by the Finance Act, 2003. \r\n4Sub-section (3) substituted  by the Finance Act, 2008. The substituted sub-section (3) read as follows: \r\n“(3) The Board may, from time to time, by notification in the official Gazette, amend the rates of \r\nwithholding tax prescribed under the Ordinance.”  \r\n5Omitted by Finance Act, 2015. The omitted sub-section (3) read as follows:-   \r\n“(3)  The Board may, from time to time, by notification in the official Gazette – \r\n(a)   amend the rates of withholding tax prescribed under this Ordinance; or   \r\n(b) exempt persons, class of persons, goods or class of goods from withholding tax \r\nunder this Ordinance.” \r\n6Omitted by Finance Act, 2015. The omitted sub-section (4) read as follows:-   \r\n“(4)All such amendments shall have effect in respect of any tax year beginningon any date \r\nbefore or after the commencement of the financial year in which the notification is issued and \r\nshall not be applicable in respect of income on which tax withheld is treated as discharge of \r\nfinal tax liability. \r\n7Omitted by Finance Act, 2015. The omitted sub-section (4) read as follows:-   \r\n“(5) The Board shall place all notifications issued under sub-section (3) in a financial \r\nyear before both Houses of Majlis-e-Shoora (Parliament).” \r\nChapter X – Procedure__________________________________ \r\n \r\n337 \r\n \r\n \r\n1[(6) Notwithstanding omission of sub -sections (3), (4) and (5),  any \r\nnotification issued under the said sub-sections and for the time being in force, shall \r\ncontinue to remain in force, unless rescinded by the Board through notific ation in \r\nthe official Gazette.] \r\n \r\n160.  Payment of tax collected or deducted.— Any tax that has been collected \r\nor purported to be collected under Division II of this Part or deducted or purported \r\nto be deducted under Division III of this Part 2[or deducted or collected, or \r\npurported to be deducted or collected under Chapter XII] shall be paid to  the \r\nCommissioner by the person making the collection or deduction within the time \r\nand in the manner as may be prescribed.  \r\n \r\n161.  Failure to pay tax collected or deducted.— (1)  Where a person– \r\n \r\n(a) fails to collect tax as required under Division II of this Part 3[or Chapter \r\nXII] or deduct tax from a payment as required under Division III of this \r\nPart 4[or Chapter XII] 5[or as required under section 50 of the repealed \r\nOrdinance]; or \r\n \r\n(b) having collected tax under Division II of this Part 6[or Chapter XII]  or \r\ndeducted tax under Division III of this Part 7[or Chapter XII] fails to pay \r\nthe tax to the Commissioner as required under section 160, 8[or having \r\ncollected tax under section 50 of the repealed Ordinance pay to the \r\ncredit of the Federal Government as r equired under sub-section (8) of \r\nsection 50 of the repealed Ordinance,] \r\n \r\nthe person shall be personally liable to pay the amount of tax to the Commissioner \r\n9[who may 10[pass an order to that effect and] proceed to recover the same.] \r\n \r\n11[(1A) No recovery unde r sub -section (1) shall be made unless the \r\nperson referred to in sub -section (1) has been provided with an opportunity of \r\nbeing heard.  \r\n                                            \r\n1Inserted by the Finance Act, 2015 \r\n2 Inserted by the Finance Act, 2002. \r\n3 Inserted by the Finance Act, 2003. \r\n4 Inserted by the Finance Act, 2002. \r\n5Inserted by the Finance Act, 2003. Earlier this was inserted by S.R.O. 633(I)/2002, dated 14.09.2002 \r\nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. \r\n6Inserted by the Finance Act, 2003. \r\n7 Inserted by the Finance Act, 2002. \r\n8 Inserted by the Finance Act, 2003. Earlier this was inserted by S.R.O. 633(I)/2002, dated 14.09.2002 \r\nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. \r\n9Inserted by the Finance Act, 2002. \r\n10 Inserted by the Finance Act, 2003. \r\n11New sub-sections “(1A) & (1B)” inserted by the Finance Act, 2002. \r\nChapter X – Procedure__________________________________ \r\n \r\n338 \r\n \r\n         (1B)  Where at the time of recovery of tax under sub -section (1) it is \r\nestablished that the tax that was to be deducted from the payment made to a \r\nperson or collected from a person has meanwhile been paid by that person, no \r\nrecovery shall be made from the person who had failed to collect or deduct the tax \r\nbut the said person shall be liable to pay 1[default surchar ge]at the rate of \r\n2[twelve”]per cent per annum from the date he failed to collect or deduct the tax to \r\nthe date the tax was paid.] \r\n \r\n (2) A person personally liable for an amount of tax under sub -section (1) \r\nas a result of failing to collect or deduct the t ax shall be entitled to recover the tax \r\nfrom the person from whom the tax should have been collected or deducted.  \r\n \r\n 3[(3) The Commissioner may, after making, or causing to be made, such \r\nenquiries as he deems necessary, amend or further amend an order of r ecovery \r\nunder sub-section (1), if he considers that the order is erroneous in so far it is \r\nprejudicial to the interest of revenue: \r\n \r\n  Provided that the order recovery shall not be amended, unless the \r\nperson referred to in sub -section (1) has been provided an opportunity of being \r\nheard.] \r\n \r\n162.  Recovery of tax from the person from whom tax was not collected or \r\ndeducted.— (1)  Where a person fails to collect tax as required under Division II \r\nof this Part 4[or Chapter XII] or deduct tax from a payment as requi red under \r\nDivision III of this Part 5[or Chapter XII,] the Commissioner may 6[pass an order to \r\nthat effect and] recover the amount not collected or deducted from the person from \r\nwhom the tax should have been collected or to whom the payment was made.  \r\n \r\n (2) The recovery of tax under sub-section (1) does not absolve the person \r\nwho failed to deduct tax as required under Division III of this Part          7[or Chapter \r\nXII] from any other legal action in relation to the failure, or from a charge of 8[default \r\nsurcharge] or the disallowance of a deduction for the expense to which the failure \r\nrelates, as provided for under this Ordinance.  \r\n \r\n                                            \r\n1The words  “additional tax”  substituted by the Finance Act, 2010. \r\n2The word “eighteen” substituted by Finance Act, 2015. \r\n3New sub-section (3) added through Finance Act, 2019.  \r\n4 Inserted by the Finance Act, 2003. \r\n5 Inserted by the Finance Act, 2002. \r\n6 Inserted by the Finance Act, 2003. \r\n7 Inserted by the Finance Act, 2002. \r\n8The words  “additional tax”  substituted by the Finance Act, 2010. The substituted provision has been made effective \r\nfrom 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was made through \r\nFinance (Amendment) Ordinance, 2009 which was re-promulgated as Finance (Amendment) Ordinance, 2010 and \r\nremained effective till 05.06.2010. \r\nChapter X – Procedure__________________________________ \r\n \r\n339 \r\n \r\n163.  Recovery of amounts payable under this Division. — The provisions of \r\nthis Ordinance shall apply to any amount required to be paid to the Commissioner \r\nunder this Division as if it were tax due under an assessment order. \r\n \r\n164.  Certificate of collection or deduction of tax.—(1) Every person collecting \r\ntax under Division II of this Part or deducting tax from a payment under Division III \r\nof this Part 1[or 2[deducting or collecting tax under] Chapter XII] shall, at the time \r\nof collection or deduction of the tax, furnish to the person from whom the tax has \r\nbeen collected or to whom the payment from which tax has been deducted has \r\nbeen made, 3[copies of the 4[Computerized Payment Receipt (CPR)] or any other \r\nequivalent document along with] a certificate setting out the amount of tax collected \r\nor deducted and such other particulars as may 5[  ] be prescribed6[: \r\n \r\n  Provided that in case  of persons or class of persons notified as \r\nSWAPS agent, SWAPS Payment Receipt (SPR) shall be replaced with \r\nComputerized Payment Receipt (CPR).] \r\n \r\n (2) A person required to furnish a return of taxable income for a tax year \r\nshall attach to the return 7[copies of the 8[Computerized Payment Receipt (CPR) \r\nor SWAPS Payment Receipt (SPR)] on the basis of which a certificate is] provided \r\nto the person under this section in respect of tax collected or deducted in that year \r\n9[  ].] \r\n \r\n10[164A. 11[Settlement of transactio ns liable to Withholding Tax by SWAPS \r\nagents]. – (1) Subject to the Ordinance, the Board may, by notification in the \r\nofficial gazette, notify any person or class of persons required to deduct or collect \r\ntax under the Ordinance to integrate with Synchronized Withholding Administration \r\nand Payment System and to act as SWAPS agent within the time and in the \r\nmanner as may be prescribed.  \r\n   \r\n(2) The tax collected or purported to be collected or deducted or \r\npurported to be deducted under the Ordinance by a notified S WAPS agent and \r\n                                            \r\n1 Inserted by the Finance Act, 2002. \r\n2 Inserted by the Finance Act, 2003. \r\n3 Inserted by the Finance Act, 2009. \r\n4 The words “challan of payment“ substituted by the Finance Act, 2022. \r\n5 The words “pass an order to that effect and” omitted by the Finance Act, 2004.  \r\n6 The Full stop substituted with colon and proviso added by the Finance Act, 2022. \r\n7 The words “any certificate” substituted by the Finance Act, 2009.  \r\n8 The words “challan of payment“ substituted by the Finance Act, 2022. \r\n9 The words and figure “and such certificate shall be treated as sufficient evidence of the collection or deduction for \r\nthe purposes of section 168”. \r\n10 Section 164A inserted by the Finance Act, 2022. \r\n11 The words “Payment of tax collected or deducted by SWAPS agents” substituted by the Finance Act,  \r\n2023 \r\nChapter X – Procedure__________________________________ \r\n \r\n340 \r\n \r\ncredited to the Commissioner through digital mode, shall be treated to have been \r\npaid under section 160 of the Ordinance. \r\n \r\n(3) Where tax has been paid by a notified SWAPS agent in accordance \r\nwith sub-section (2) of this section, copy or number o f SWAPS Payment Receipt \r\n(SPR) shall replace copy or number of Computerized Payment Receipts (CPR) for \r\nthe purposes of the Ordinance. \r\n \r\n(4) Any notified SWAPS agent shall not be eligible for tax credit under \r\nPart X of Chapter III of the Ordinance and exemption u nder any of the provisions \r\nof the Ordinance if notified SWAPS agent fails to integrate with Board.  \r\n \r\n(5) All persons from whom the tax has been collected or deducted by the \r\nnotified SWAPS agents shall be eligible for credit of tax withheld against SPR \r\nissued by SWAPS Agent. \r\n(6) All other provisions of the Ordinance, not specifically dealt with in this \r\nsection, shall, mutatis mutandis, apply to the notified SWAPS agents.] \r\n \r\n165.  Statements.— (1)  Every person collecting tax under Division II of this Part \r\n1[or Chapter XII 2[or the Tenth Schedule]] or deducting tax from a payment under \r\nDivision III of this Part 3[or Chapter XII 4[or the Tenth Schedule]] shall, 5[  ] furnish \r\nto the Commissioner a 6[quarterly] statement in the prescribed form setting out— \r\n \r\n(a) the name , 7[Computerized National Identity Card Number, National \r\nTax Number] and address of each person from whom tax has been \r\ncollected under Division II of this Part 8[or Chapter XII 9[or the Tenth \r\nSchedule]] or to whom payments have been made from which tax has \r\nbeen deducted under Division III of this Part 10[or Chapter XII 11[or the \r\nTenth Schedule]] in 12[each 13[quarter]] \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \r\n3Inserted by the Finance Act, 2002. \r\n4After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019. \r\n5The words  “within two months after the end of the financial year or within such further time as the Commissioner \r\nmay allow by order in writing, ”  omitted by the Finance Act, 2010.  \r\n6The word “biannual” substituted through Finance Act 2020 dated 30th June, 2020 \r\n7Inserted by the Finance Act, 2011. \r\n8 Inserted by the Finance Act, 2003. \r\n9After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019. \r\n10Inserted by the Finance Act, 2002. \r\n11After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \r\n12The words  “the year” substituted by the Finance Act, 2010. \r\n13 The word ”half year” substituted through Finance Act, 2020 dated 30th June, 2020 \r\n \r\nChapter X – Procedure__________________________________ \r\n \r\n341 \r\n \r\n(b) the total amount of payments made to a person from which tax has \r\nbeen deducted under Division III of this Part 1[or Chapter XII 2[or the \r\nTenth Schedule]] in 3[each 4[quarter]] \r\n \r\n(c) the total amount of tax collected from a person under Division II of this \r\nPart 5[or Chapter XII  6[or the Tenth Schedule] ] or deducted from \r\npayments made to a person under Division III of this Part 7[or Chapter \r\nXII 8[or the Tenth Schedule]] in9[each 10[quarter]]; and  \r\n \r\n(d) such other particulars as may be prescribed 11[:] \r\n \r\n12[Provided that every person as provided in sub -section (1) \r\nshall be required to file withholding statement even where no \r\nwithholding tax is collected or deducted during the period 13[:] \r\n \r\n   “Provided further that this section shall not apply where \r\ninformation required under sub -section (1) has been furnished under \r\nsection 165A.”;] \r\n \r\n      14[Explanation.— For the removal of doubt, it is clarified that thi s sub -\r\nsection overrides all conflicting provisions contained in the Protection of \r\nEconomic Reforms Act, 1992 (XII of 1992), the Banking Companies \r\nOrdinance, 1962 (LVII of 1962), the Foreign Exchange Regulation Act, 1947 \r\n(VII of 1947) and the regulations made under the State Bank of Pakistan Act, \r\n1956 (XXXIII of 1956), if any, on the subject, in so far as divulgence of \r\ninformation under section 165 is concerned.] \r\n \r\n15[(1A) Every person involved or engaged in economic transactions as \r\nprescribed by the Board sha ll furnish to the Commissioner a quarterly statement \r\nin the prescribed form and manner. ”;and] \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2002. \r\n2After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \r\n3The words  “the year” substituted by the Finance Act, 2010. \r\n4The word “half year” substituted through Finance Act, 2020 dated 30th June, 2020 \r\n \r\n5 Inserted by the Finance Act, 2003. \r\n6After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019. \r\n7Inserted by the Finance Act, 2002. \r\n8After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \r\n9The words  “the year” substituted by the Finance Act, 2010. \r\n10 The word “half year” substituted through Finance Act, 2020 dated 30th June, 2020 \r\n \r\n11Full stop substituted by the Finance Act, 2010. \r\n12Inserted by the Finance Act, 2010. \r\n13Full stop substituted by colon and thereafter new provision added through Finance Act 2020 dated \r\n30th June, 2020 \r\n14 Added by the Finance Act, 2013.  \r\n15New sub-section (1A) inserted through Finance Act, 2020 dated 30th June 2020. \r\nChapter X – Procedure__________________________________ \r\n \r\n342 \r\n \r\n1[(2) Every prescribed person collecting tax under Division II of this Part or \r\nChapter XII 2[or the Tenth Schedule] or deducting tax under Division III of this  \r\n \r\nPart of Chapter X II 3[or the Tenth Schedule] shall furnish statements under sub -\r\nsection (l) 4[or (1A)] as per the following schedule, namely:-  \r\n \r\n5[(a) in respect of quarter ending on the 31 st day of March, on or before the \r\n20th day of April; \r\n \r\n(b) in respect of quarter year ending on the 30 th day of June, on or before \r\nthe 20th day of July; \r\n \r\n(c) in respect of quarter ending on the 30 th day of September, on or before \r\nthe 20th day of October; and \r\n \r\n(d) in respect of quarter ending on or before the 31st day of December, on or \r\nbefore the 20th day of January.]    \r\n  \r\n 6[(2A)    Any person who, having furnished statement under sub -section (1) \r\nor sub-section (2), discovers any omission or wrong statement therein, may file a \r\nrevised statement within sixty days of filin g of statement under sub -section (1) or \r\nsub-section (2), as the case may be.] \r\n \r\n7[(2B) Notwithstanding anything contained in this section, the Commissioner \r\nas he deems lit may by notice in writing require any person, collecting or deducting \r\ntax under this O rdinance, to furnish a statement for any period specified in the \r\nnotice within such period of time as may be specified in the notice.] \r\n \r\n                                            \r\n1Sub-section (2) substituted through Finance Supplementary (Second Amendment) Act, 2019. \r\n2In section 165 expression “Chapter XII” wherever occurs the words “or the Tenth Schedule” inserted \r\nby the Finance Act, 2019.  \r\n3After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \r\n4The expression added through Finance Act, 2020 dated 30th June, 2020 \r\n5The clauses (a) and (b) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted \r\nclauses read as follows: \r\n(a) in respect of the half-year ending on the 30th June, on or before the 31st day of July; and  \r\n   (b) in respect of the half-year ending on the 31st December, on or before the 31st day of January. \r\n6Inserted by the Finance Act, 2017. \r\n \r\n7 Sub-section (2B) inserted through Finance Supplementary (Second Amendment) Act, 2019. \r\nChapter X – Procedure__________________________________ \r\n \r\n343 \r\n \r\n 1[(3) 2[Board] may prescribe a statement requiring any person to furnish \r\ninformation 3[  ] in respect of any transactio ns in the prescribed form and verifi ed \r\nin the prescribed manner 4[.] ] \r\n \r\n 5[(4) A person required to furnish a statement under sub-section 6[(1)], may \r\napply in writing, to the Commissioner for an extension of time to furnish the \r\nstatement after the due date  and the Commissioner if satisfied that a reasonable \r\ncause exists for non-furnishing of the statement by the due date may, by an order \r\nin writing, grant the applicant an extension of time to furnish the statement.] \r\n \r\n 7[(5)  The Board may make rules relatin g to electronic furnishing of \r\nstatements under this section including,-  \r\n \r\n  (a)  mandatory electronic filing of statements; and \r\n \r\n(b)  determination of eligibility of the data of such statements and e-\r\nintermediaries, etc.] \r\n \r\n 8[(6)  Every person deducting ta x from payment under section 149 shall \r\nfurnish to the Commissioner an annual statement in the prescribed form and \r\nmanner 9[.] \r\n \r\n 10[  ] \r\n \r\n11[(7) Every prescribed person collecting tax under Division II of this Part, \r\nChapter XII or the Tenth Schedule or deducting tax from a payment under Division \r\nIII of this Part, Chapter XII or the Tenth Schedule shall, e-file to the Commissioner \r\nan annual statement for the relevant tax year within thirty days of the end of tax \r\nyear in addition to statement to be filed under sub-section (6) of this section.  \r\n  \r\n                                            \r\n4Inserted by the Finance Act, 2006. \r\n5The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n6The word “periodically” omitted by the Finance Act, 2011. \r\n7Colon substituted by the Finance Act, 2011. \r\n9Inserted by the Finance Act, 2006. \r\n10The figure “(2)” substituted by the Finance Act, 2010. \r\n7Inserted by the Finance Act, 2006. \r\n8Added by the Finance Act, 2011. \r\n9Semi-colon substituted by the Finance Act, 2013.  \r\n10 Proviso omitted by the Finance Act, 2013. The omitted proviso read as follows: \r\n“Provided that annual statement shall also be filed where the income exceeds three \r\nhundred thousand rupees but does not e xceed three hundred and fifty thousand rupees in a \r\ntax year.” \r\n11 Sub-sections (7) and (8) added by the Finance Act, 2021.  \r\nChapter X – Procedure__________________________________ \r\n \r\n344 \r\n \r\n(8) Every prescribed person collecting tax under Division II of this Part or \r\nChapter XII, the Tenth Schedule or deducting tax from a payment under Division \r\nIII of this Part, Chapter XII or the Tenth Schedule shall also e -file to the \r\nCommissioner a statement in the prescribed form  reconciling the amounts \r\nmentioned in annual statement filed under sub -section (7) with the amounts \r\ndeclared in the return, audited accounts or financial statements by the due date of \r\nfiling of return of income as provided under section 118 of the Ordinance.] \r\n  \r\n1[165A.  Furnishing of information by banks. — (1) Notwithstanding anything \r\ncontained in any law for the time being in force including but not limited to the \r\nBanking Companies Ordinance, 1962 (LVII of 1962), the Protection of Economic \r\nReforms Act, 1992 (XII of 1992), the Foreign Exchange Regulation Act, 1947 (VII \r\nof 1947) and the regulations made under the State Bank of Pakistan Act, 1956 \r\n(XXXIII of 1956), if any, on the subject every banking c ompany shall make \r\narrangements to provide to the Board in the prescribed form and manner, — \r\n \r\n2[(a) a list of persons containing particulars of cash withdrawals exceeding \r\nfifty thousand Rupees in a day and tax deductions thereon  3[  ] , \r\naggregating to Rupees one million or more during each preceding \r\ncalendar month.\";] \r\n \r\n(b)  a list containing particulars of deposits aggregating rupees 4[ten]  \r\nmillion or more made during the preceding calendar month; \r\n \r\n(c)  a list of payments made by any person against bills rais ed in respect \r\nof a credit card issued to that person, aggregating to rupees 5[two] \r\nhundred thousand or more during the preceding calendar month; \r\n \r\n6[(d)  a list of persons receiving profit on debt 7[  ] 8[  ] and tax deductions \r\nthereon during preceding financial year] 9[; and \r\n                                            \r\n1Added by the Finance Act, 2013. \r\n2 Clause (a) substituted by the Finance Act, 2018 ,the substituted clause is read as follows:- \r\n“ (a) online access to its central database containing details of its account  holders and all transactions made in their \r\naccounts;” \r\n3 Words “for filers and non-filers” omitted through Finance Act, 2019. \r\n4The word  “one” substituted by the Finance Act, 2018. \r\n5The word  “one” substituted by the Finance Act, 2018. \r\n6 Clause (d) substituted by the Finance Supplementary (Amendment) Act, 2018. The substituted clause \r\n(d) read as follows: \r\n“a consolidated list of loans written off exceeding rupees one million during a calendar year” and \r\n7The expressions “exceeding 7[  ] five hundred thousand rupees” omitted through Finance Act, 2020 \r\ndated 30th June, 2020 \r\n8Words “for non-filers” omitted through Finance Act, 2019. \r\n9 Full stop substituted with semi colon and the word “and” an d a new clause added by the by the \r\nFinance (Supplementary) Act, 2022.  \r\nChapter X – Procedure__________________________________ \r\n \r\n345 \r\n \r\n1[  ] \r\n \r\n(f)  a list of persons containing particulars of their business accounts \r\nopened or re-designated during each preceding calendar month.]    \r\n \r\n (2)  Each banking company shall also make arrangements to nominate a \r\nsenior officer at t he head office to coordinate with the Board for provision of any \r\ninformation and documents in addition to those listed in sub-section (1), as may be \r\nrequired by the Board. \r\n \r\n (3) The banking companies and their officers shall not be liable to any \r\ncivil, criminal or disciplinary proceedings against them for furnishing information \r\nrequired under this Ordinance.  \r\n \r\n(4) Subject to section 216, all information received under this section shall \r\nbe used only for tax purposes and kept confidential.] \r\n \r\n2[165B. Furnishing of information by financial institutions including banks.— (1) \r\nNotwithstanding anything contained in any law for the time being in force including \r\nbut not limited to the Banking Companies  Ordinance, 1962 (LVII of 1962), the \r\nProtection of Economic Reform s Act,1992 (XII of 1992), the Foreign Exchange \r\nRegulation Act, 1947 (VII of1947) and any regulations made under the State Bank \r\nof Pakistan Act,1956 (XXXIII of 1956) on the subject, every financial institution \r\nshall make  arrangements to provide information regarding non -resident3[or any \r\nother reportable] persons to the Board in the prescribed form and manner for the \r\npurpose of automatic  exchange of information under bilateral agreement or \r\nmultilateral convention. \r\n \r\n(2) 4[All] information received under this s ection shall be used only for tax \r\nand related purposes and kept confidential.”] \r\n \r\n5[(3) For the purpose of this section, the terms \"reportable person\" and \r\n\"financial institution\" shall have the meaning as provided in Chapter XIIA of the \r\nIncome Tax Rules, 2002.] \r\n \r\n                                            \r\n1 Clause (e) omitted by the Finance Supplementary (Amendment) Act, 2018. The omitted clause (e) \r\nread as follows: \r\n “(e)  a copy of each currency transactions report and suspicious transa ctions report \r\ngenerated and submitted by it to the Financial Monitoring Unit under the Anti -Money \r\nLaundering Act, 2010 (VII of 2010).” \r\n2Inserted by the Finance Act, 2015. \r\n3Inserted by the Finance Act, 2017. \r\n4The word and figure “Subject to section 216, all” substituted by the Finance Act, 2016. \r\n5Added by the Finance Act, 2017 \r\nChapter X – Procedure__________________________________ \r\n \r\n346 \r\n \r\n1[165C. Furnishing of information by online marketplace, payment \r\nintermediary and courier service. – (1) Notwithstanding the provisions of section \r\n165 of the Ordinance, every payment intermediary and courier service responsible \r\nfor deducting tax under sub-section (2A) of section 153 of the Ordinance shall file \r\na quarterly withholding statement to the Commissioner for tax deduction regarding \r\nsale of digitally ordered goods and services for each quarter of a tax year in the \r\nprescribed form setting out –  \r\n \r\n(a) name, identification number (NTN/CNIC) and address of the seller;  \r\n \r\n(b) transaction date, unique identifier (invoice number) and total transaction \r\nvalue;  \r\n \r\n(c) the total amount of tax deducted at the time of payments to the seller; and  \r\n \r\n(d) any other particular may be prescribed.  \r\n \r\n(2) Every online marketplace in Pakistan shall submit a monthly \r\nstatement containing name, address, Sales Tax and Income Tax registration \r\nnumber of every vendor registered on its platform supplying digitally ordered goods \r\nand services in e -commerce, transactional and aggregated quantum of seller‘s \r\nmonthly turnover and the amount deposited into the vendor‘s bank account against \r\nsuch sale transactions.  \r\n \r\n(3) All the provisions of the section 165 excluding sub -sections (1), (1A) \r\nand (6) shall mutatis mutandis apply with respect to the due date of the filing of the \r\nwithholding statements, revision of the statements, power to call for statement by \r\nthe Commissioner, extension of time to furnish the statement after due date, power \r\nof the Board, filing of annual withholding statement and reconciliation of the \r\nwithholding statement with the annual income tax return.] \r\n \r\n166.  Priority of tax collected or deducted.  — (1) Tax collected by a person \r\nunder Division II 2[of this Part or Chap ter XII] or deducted from a payment under \r\nDivision III of this Part 3[or Chapter XII] shall be — \r\n \r\n(a) held by the person in trust for the 4[Federal] Government; and \r\n \r\n(b) not subject to attachment in respect of any debt or liability of the person. \r\n \r\n                                            \r\n1 Section 165C inserted by the Finance Act, 2025. \r\n2Inserted by the Finance Act, 2003. \r\n3Inserted by the Finance Act, 2002. \r\n4 Inserted by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n347 \r\n \r\n (2) In the event of the liquidation or bankruptcy of a person who has \r\ncollected 1[  ] or deducted tax from a payment under Division III of this Part 2[or \r\nChapter XII], the amount collected or deducted shall not form part of the estate of \r\nthe person in liquidation  or bankruptcy and the Commissioner shall have a first \r\nclaim for that amount before any distribution of property is made. \r\n \r\n (3) Every amount that a person is required to deduct from a payment \r\nunder Division III of this Part 3[or Chapter XII] shall be – \r\n \r\n(a) a first charge on the payment; and \r\n \r\n(b) deducted prior to any other amount that the person may be \r\nrequired to deduct from the payment by virtue of an order of any \r\nCourt or under any other law. \r\n \r\n167. Indemnity.— A person who has deducted tax from a paymen t under \r\n4[Division III of this Part] 5[or Chapter XII] and remitted the deducted amount to the \r\nCommissioner shall be treated as having paid the deducted amount to the recipient \r\nof the payment for the purposes of any claim by the recipient for payment of th e \r\ndeducted tax. \r\n \r\n168. Credit for tax collected or deducted.  — (1) For the purposes of this \r\nOrdinance — \r\n \r\n(a) the amount of any tax deducted from a payment under Division III of this \r\nPart 6[or Chapter XII] shall be treated as income derived by the person \r\nto whom the payment was made; and \r\n \r\n(b) the amount of any tax collected under Division II of this Part 7[or \r\nChapter XII] or deducted under Division III of this Part  8[or Chapter XII] \r\nshall be treated as tax paid by the person from whom the tax was \r\ncollected or deducted. \r\n \r\n (2) Subject to sub-sections 9[(2A), (2B),] (3) and (4), where an amount of \r\ntax has been collected from a person under Division II of this Part 10[or Chapter \r\nXII] or deducted from a payment made to a person under Division III of this Part \r\n                                            \r\n1 The words “tax under Division II of this Part” omitted by the Finance Act, 2003. \r\n2 Inserted by the Finance Act, 2002. \r\n3 Inserted by the Finance Act, 2003. \r\n4 Substituted for the words, figure and comma “Division II, Division III” by the Finance Act, 2003. \r\n5 Inserted by the Finance Act, 2002. \r\n6Inserted by the Finance Act, 2002. \r\n7Inserted by the Finance Act, 2003. \r\n8 Inserted by the Finance Act, 2002. \r\n9Inserted by the Finance Act, 2018. \r\n10 Inserted by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n348 \r\n \r\n1[or Chapter XII], the person shall be allowed a tax credit for that tax in computing \r\nthe tax due by the person on the taxable income of the person for the tax year in \r\nwhich the tax was collected or deducted. \r\n \r\n2[(2A) Where a company is a member of an association of persons which is \r\ntaxed in accordance with section 92 and an amount of tax has been collected from \r\nan association of persons under Division II of this Part or Chapter XII or  deducted \r\nfrom a payment made to the said association under Division III of thi s Part  or \r\nChapter XII, the company shall be allowed a tax credit, in respect of tax  collected \r\nor deducted from the association of persons, according to the following formula, \r\nnamely:— \r\n \r\n(A/B) x C \r\n \r\nWhere — \r\n \r\nA is the amount of share of profits before tax rec eived by the company \r\nas a member from the association of persons; \r\n \r\nB is the taxable income of the association of persons; and \r\n \r\nC is  the  amount  of  tax  withheld  in  the  name  of  the association of \r\npersons. \r\n \r\n(2B) No tax credit shall be allowed for any tax collected or deducted from an \r\nassociation of persons in respect of an amount for which credit has been  allowed \r\nunder sub-section (2A) to a company being a member of the association.]  \r\n \r\n3[(3)  No tax credit shall be allowed for any tax collected or deducted that is \r\na final tax under— \r\n \r\n  4[   ]     \r\n                                            \r\n1Inserted by the Finance Act, 2002. \r\n2Inserted by the Finance Act, 2018. \r\n3Sub-section (3) substituted by the Finance Act, 2011. The substituted sub-section (3) read as \r\nfollows: \r\n  “(3) No tax credit shall be allowed for any tax collected or deducted that is a final tax under \r\nclauses (a), (b) and (d) of sub-section (1) of section 151, sub-section (1B) of section 152,  sub-section \r\n(6)] of section 153, sub-section (4) of section 154, section 155 sub -section (3) of section 156, sub -\r\nsection (2) of section 156A, section 233, clauses (a) and (b) of sub -section (1) of section 233A or \r\nsub-section (5) of section 234 or section 234A. \r\n4 In section 168 in sub -section (3) clause (a) omitted by the Finance Act, 2019 . The omitted clause \r\nread as follows: (a) sub-section (7) of section 148;  \r\nChapter X – Procedure__________________________________ \r\n \r\n349 \r\n \r\n  1[   ]   \r\n  2[   ]   \r\n  3[(ca) sub-section (1E) of section 152; \r\n  (cb) sub-section (2) of section 152A;] \r\n4[   ]  5[  ] \r\n  6[   ]   \r\n  7[(ea) sub-section (2) of section 154A;] \r\n  (f)  sub-section (3) of section 156; \r\n  (g)  sub-section (2) of section 156A; \r\n  8[  ]  9[and] \r\n  10[  ] \r\n  11[(j)] ] \r\n  12[(k)    sub-section (7) of section 236Z.] \r\n (4) A tax credit allowed under this section shall be applied in accordance \r\nwith sub-section (3) of section 4. \r\n \r\n                                            \r\n1 In section 168 in sub-section (3) clause (b) omitted by the Finance Act, 2019 the omitted clause read \r\nas follows: (b) sub-section (3) of section 151; \r\n2 In section 168 in sub-section (3) clause (c) omitted by the Finance Act, 2019 the omitted clause read \r\nas follows: (c) sub-section (1B) and (1BB) of section 152; \r\n3 After omitted clause (c) new clauses (ca) and (cb) inserted through Finance Act, 2020 dated 30 th \r\nJune, 2020 \r\n4 In section 168 in sub-section (3) clause (d) omitted by the Finance Act, 2019 the omitted clause read \r\nas follows: [(d)] sub-section (3) of section 153;  \r\n5The words, comma and brackets “clauses (a), (c) and (d) of” omitted by the Finance Act, 2013. \r\n6 Clause (e) omitted by the Finance Act, 2024. The omitted clause read as follow: \r\n“(e) sub-section (4) of section 154;” \r\n7 Clause (ea) inserted by the Finance Act, 2021. \r\n8In section 168 in sub-section (3) clause (b) omitted by the Finance Act, 2019 the omitted clause read \r\nas follows: (h) sub-section (3) of section 233;2[and]  \r\n9Added by the Finance Act, 2013. \r\n10Clause (i) omitted by the Finance Act, 2013. The omitted clause (i) read as follows: \r\n “(i)  sub-section (5) of section 234; and” \r\n11 In section 168 in sub-section (3) clause (b) omitted by the Finance Act, 2019 the omitted clause \r\nread as follows: Sub-section (3) of section 234(A)  \r\n12 Clause (k) added by the Finance Act, 2023. \r\nChapter X – Procedure__________________________________ \r\n \r\n350 \r\n \r\n (5) A tax credit or part of a tax credit allowed under this section for a tax \r\nyear that is not able to be credited under sub -section (3) of section 4 for the year \r\nshall be refunded to the taxpayer in accordance with section 170. \r\n \r\n 1[(6)  Notwithstanding anything contained in  any other law or any rules for \r\nthe time being in force, no amount shall be deducted on account of service charges \r\nfrom the tax withheld or collected by any person under the provisions of this \r\nOrdinance.] \r\n \r\n 2[(7)  In case any amount is deducted on account of service charges, by the \r\nperson, the said person will be liable to pay the said amount to the Federal \r\nGovernment and all the provisions of this Ordinance shall apply in so far as they \r\napply to the recovery of tax.] \r\n \r\n169.  Tax collected or deducted as a f inal tax.— (1) This section shall apply \r\nwhere — \r\n \r\n3[  ] \r\n  \r\n(b) the 4[tax required to be deducted] is a final tax under  5[sub-\r\nsection (1E ) of section 152, 152A ], 6[  ] 7[sub-section (2) of \r\nsection 154A] 8[  ] sub-section (3) of section 156, 9[  ] 10[sub-\r\n                                            \r\n1 Added by the Finance Act, 2009. \r\n2 Added by the Finance Act, 2009. \r\n3 Clause (a) omitted through Finance Act, 2020 the substituted clause read as follows: “(a) the \r\n3[advance tax required to be collected 3[or paid]] is a final tax under sub-section (7) of section 148 \r\n3[,148A] 3[  ] 3[or section 234A]  on the income to which it relates; or”  \r\n \r\n4 The words “deduction of tax” substituted by the Finance Act, 2012. \r\n5 The expressions  “sub-section (3) of section 151], sub-section (1B) 5[or sub-section (1BB)] of \r\nsection 152, 5[ 5[  ] sub-section (3) of section 153], 5[ 5[sub-section (1AAA) of section \r\n152”substituted by Finance Act, 2020 dated 30th June, 2020 \r\n6  The expression “sub-section (4) of section 154,” omitted by the Finance Act, 2024. \r\n7 Inserted by the Finance Act, 2021. \r\n8 The word, digit and comma “section 155,” omitted by the Finance Act, 2010. \r\n9 The words, figures and brackets “or sub-section (2) of section 157” omitted by the Finance Act, \r\n2002 \r\n10 Inserted by the Finance Act, 2004. \r\nChapter X – Procedure__________________________________ \r\n \r\n351 \r\n \r\nsection (2) [or] 1section 156A or 2[sub-section (7) of section \r\n236Z] 3[  ]4[ ] ] on the income from which it 5[was deductible]. \r\n (2) Where this section applies — \r\n \r\n(a) the income shall not be chargeable to tax under any head of \r\nincome in computing the taxable income of the person; \r\n \r\n(b) no deduction shall be allowable under this Ordinance for any \r\nexpenditure incurred in deriving the income; \r\n \r\n(c) the amount of the income shall not be reduced by — \r\n \r\n (i) any deductible allowance under Part IX of Chapter III; or \r\n \r\n(ii) the set off of any loss; \r\n \r\n(d) the tax deducted shall not be reduced by any tax credit allowed \r\nunder this Ordinance; 6[  ] \r\n \r\n(e) there shall be no refund of the tax collected or deducted \r\n7[unless the tax so collected or deducted is in excess of the \r\namount fo r which the taxpayer is chargeable under this \r\nOrdinance8[; and].] \r\n \r\n9[(f)  tax deductible has not been deducted, or short deducted, the   \r\nsaid non-deduction or short deduction may be recovered under \r\nsection 162, and all the provisions of this Ordinance shall apply \r\naccordingly.] \r\n \r\n (3) Where all the income derived by a person in a tax year is subject to \r\nfinal taxation under the provisions referred to in sub -section (1) or under sections \r\n                                            \r\n1 The word “of” substituted by the word “or” by the Finance Act, 2014. \r\n2 Expression inserted by the Finance Act, 2023. \r\n3 The expressions omitted through Finance Act, 2020 dated 30th June, 2020 the omitted expressions \r\nread as follows: “sub-section 3[(1) and] (3) of section 233” \r\n4 The words, brackets, figure and letters “or clause (a) and clause (b) of sub-section (1) of section \r\n233A” omitted by the Finance Act, 2008. \r\n5 The words “has been deducted” substituted by the Finance Act, 2012. \r\n6The word “and” omitted by the Finance Act, 2012. \r\n7Added by the Finance Act, 2002. \r\n8Full stop substituted by the Finance Act, 2012. \r\n9Added by the Finance Act, 2008. \r\nChapter X – Procedure__________________________________ \r\n \r\n352 \r\n \r\n5, 6 1[and] 7 2[ ] 3[an assessment shall be treated to have been made under section \r\n120 4[  ]  \r\n \r\n5[Explanation.— The expression, “an assessment shall be treated to \r\nhave been made under section 120” means,— \r\n \r\n(a)  the Commissioner shall be taken to have made an assessment \r\nof income for that tax year, and the tax due thereon equal t o \r\nthose respective amounts specified in the return 6[  ] ; and \r\n \r\n(b)  the return 7[  ] shall be taken for all purposes of this Ordinance \r\nto be an assessment order.] \r\n \r\n 8[  ] \r\n \r\n9[(4) Where the tax collected or deducted is final tax under any provision of \r\nthis Ordinance and hundred percent higher tax rate has been prescribed for the \r\nsaid tax under the Tenth Schedule, the final tax shall be the tax rate prescribed in \r\nthe First Schedule and the excess tax collected under the Tenth Schedule \r\nspecified for persons not appearing in the active taxpayers’ list shall be adjustable \r\n                                            \r\n1Comma substituted by the  Finance Act, 2013. \r\n2The words, figure, comma and brackets “and 15, (other than dividend received by a company)” \r\nomitted by the Finance Act, 2013.  \r\n3Inserted by the Finance Act, 2002. \r\n4The expression omitted through Finance Act, 2020 dated 30th June, 2020 the omitted expressions \r\nread as follows: “and the person shall not be required to furnish a return of income under section \r\n114 for the year” \r\n5Inserted by the Finance Act, 2010. \r\n6 The expression omitted through Finance Act, 2020 dated 30th June, 2020 the omitted expressions \r\nread as follows: “or statement under “sub-section (4) of section 115” \r\n7 The expression omitted through Finance Act, 2020 dated 30th June, 2020 the omitted expressions \r\nread as follows: “or statement under “sub-section (4) of section 115” \r\n \r\n8 Omitted by the Finance Act, 2004. The omitted sub-section (4) read as follows:  \r\n “(4)  Where a taxpayer, while explaining the nature and source of any amount, investment, money, \r\nvaluable article, expenditure, referred to in section 111, takes into account any source of income \r\nwhich is subject to tax in accordance with the provisio ns of sections 148, 153, 154, 156 or sub -\r\nsection (5) of section 234, he shall not be entitled to take credit of any sum as is in excess of an \r\namount which if taxed at a rate or rates, other than the rate applicable to the income chargeable to \r\ntax under aforesaid sections 148, 153, 154, 156 or sub-section (5) of section 234 would have resulted \r\nin tax liability equal to the tax payable in respect of income under any of the aforesaid sections.” \r\n9 In section 169 for sub-section (4) substituted through Finance Act, 2019, substituted sub-section \r\nread as follows:  \r\n(4) Where the tax collected or deducted is final tax under any provision of the Ordinance and separate \r\nrates for filer and non-filer have been prescribed for the said tax, the final tax shall be the tax rate for \r\nfiler and the excess tax deducted or collected on account of higher rate of non-filer shall be adjustable \r\nin the return filed for the relevant tax year. \r\nChapter X – Procedure__________________________________ \r\n \r\n353 \r\n \r\nin case the return is filed before finalization of assessment as provided in rule 4 of \r\nthe Tenth Schedule.]  \r\nChapter X – Procedure__________________________________ \r\n \r\n354 \r\n \r\nPART VI \r\nREFUNDS \r\n \r\n170.  Refunds.— (1)  A taxpayer who has paid tax in excess of the amount which \r\nthe taxpayer is properly chargeable under this Ordinance may apply to the \r\nCommissioner for a refund of the excess. \r\n \r\n1[(1A) Where any advance or loan, to which sub-clause (e) of clause (19) of \r\nsection 2 applies, is repaid by a taxpayer, he shall be entitled to a refund of the \r\ntax, if any, paid by him as a result of such advance or loan having been treated as \r\ndividend under the aforesaid provision.] \r\n \r\n (2) An application for a refund under sub-section (1) shall be – \r\n \r\n(a) made in the prescribed form;  \r\n \r\n(b) verified in the prescribed manner; and \r\n \r\n(c) made within 2[three] years of the later of - \r\n \r\n (i) the date on which the Commissioner has issued the \r\nassessment order to the taxpayer for the tax year to which \r\nthe refund application relates; or \r\n \r\n(ii) the date on which the tax was paid. \r\n \r\n (3) Where the Commissioner is satisfied that tax has been overpaid, the \r\nCommissioner shall —  \r\n \r\n(a) apply the excess in reduction of any other tax due from the \r\ntaxpayer under this Ordinance;  \r\n \r\n(b) apply the balance of the e xcess, if any, in reduction of any \r\noutstanding liability of the taxpayer to pay other taxes; and \r\n \r\n(c) refund the remainder, if any, to the taxpayer. \r\n \r\n (4) The Commissioner shall, within 3[sixty] days of receipt of a refund \r\napplication under sub-section (1), serve on the person applying for the refund an \r\norder in writing of the decision 4[after providing the taxpayer an opportunity of being \r\nheard]. \r\n                                            \r\n1Inserted by the Finance Act, 2003. \r\n2The word “two” substituted by the Finance Act, 2016. \r\n3The word “forty five” substituted by the Finance Act, 2009. \r\n4Inserted by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n355 \r\n \r\n 1[(5)  A person aggrieved by— \r\n \r\n  (a)  an order passed under sub-section (4); or \r\n \r\n(b)  the failure of the Commi ssioner to pass an order under sub -\r\nsection (4) within the time specified in that sub-section,  \r\n \r\n  may prefer an appeal under Part III of this Chapter.] \r\n \r\n 2[(6) The Board may make rules regulating procedure for expeditious \r\nprocessing and automatic payment o f refund s through centralized processing \r\nsystem with effect from a date to be notified by the Board.]  \r\n \r\n3[170A. Electronic processing and electronic issuance of Refunds by the \r\nBoard.—Notwithstanding anything contained in section 170 of this Ordinance, \r\ncommencing from tax year 2021, the Board may process and issue refund to the \r\ntaxpayer who has filed the return of income without requiring refund application by \r\nthe taxpayer to the extent of tax credit verified by the Board’s computerized system \r\nas may be pres cribed. The refund amount sanctioned under this section shall be \r\nelectronically transferred in the taxpayer’s notified bank account.] \r\n \r\n171. Additional payment for delayed refunds. —(1) Where a refund due to a \r\ntaxpayer is not paid within three months of the date on which it becomes due, the \r\nCommissioner shall pay to the taxpayer a further amount by way of compensation \r\nat the rate of 4[ 5[KIBOR plus 0.5 per cent] ] per annum of the amount of the refund \r\ncomputed for the period commencing at the end of the three  month period and \r\nending on the date on which it was paid 6[:] \r\n \r\n 7[Provided that where there is reason to believe that a person has claimed \r\nthe refund which is not admissible to him, the provision regarding the payment of \r\nsuch additional amount shall not a pply till the investigation of the claim is \r\ncompleted and the claim is either accepted or rejected.] \r\n \r\n (2) For the purposes of this section, a refund shall be treated as having \r\nbecome due — \r\n \r\n                                            \r\n1 Sub-section (5) substituted by the Finance Act, 2003. The substituted sub-section (5) read as follows: \r\n“(5) A person dissatisfied with a decision referred to in s ub-section (4) may challenge the \r\ndecision only under Part III of this Chapter.” \r\n2New sub-section (6) added through Finance Act, 2020 dated 30th June,2020 \r\n3 Section 170A inserted by the Finance Act, 2021.  \r\n4The word “KIBOR” substituted by the Finance Act, 2012. \r\n5 The word “fifteen” substituted by Finance Act, 2015. \r\n6Full stop substituted by the Finance Act, 2009. \r\n7 Inserted by the Finance Act, 2009. \r\nChapter X – Procedure__________________________________ \r\n \r\n356 \r\n \r\n(a) in the case of a refund required to be made in consequence of  \r\nan order on an appeal to the Commissioner (Appeals), an \r\nappeal to the Appellate Tribunal, a reference to the High Court \r\nor an appeal to the Supreme Court, on the date of receipt of \r\nsuch order by the Commissioner; 1[or] \r\n \r\n(b) in the case of a refund require d to be made as a consequence \r\nof a revision order under section 2[122A], on the date the order \r\nis made by the Commissioner; or \r\n \r\n(c) in any other case, on the date the refund order is made.  \r\n  \r\n3[Explanation.—For the removal of doubt, it is clarified that \r\nwhere a refund order is made on an application under sub -\r\nsection (1) of section 170, for the purpose of compensation, the \r\nrefund becomes due from the date refund order is made and not \r\nfrom the date the assessment of income treated to have been \r\nmade by the Commissioner under section 120.] \r\n \r\n4[171A. Payment of refund through income tax refund bonds. - (1) \r\nNotwithstanding anything contained in sections 170 and 171, the income tax \r\nrefunds payable under this Ordinance may also be paid through income tax refund \r\nbonds to be issued by FBR Refund Settlement Company Limited, in book -entry \r\nform through an establishment licensed by the Securities and Exchange \r\nCommission of Pakistan as a central depository under the Securities Act, 2015 (III \r\nof 2015), in lieu of payment to be made through issuance of cheques or bank debit \r\nadvice. \r\n \r\n(2) The Board shall issue a promissory note to FBR Refund Settlement \r\nCompany Limited, hereinafter referred to as the company, incorporating the details \r\nof refund claimants and the amount of refund d etermined as payable to each for \r\nissuance of income tax refund bonds, hereinafter referred to as the bonds, of the \r\nsame amount. \r\n \r\n(3) The bonds shall be issued in value in multiples of one hundred \r\nthousand rupees. \r\n \r\n(4) The bonds so issued have maturity peri od of three years and shall \r\nbear annual simple profit at ten percent. \r\n \r\n(5) The bonds shall be traded freely in the country’s secondary markets. \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2 Substituted for the figure “135” by the Finance Act, 2003. \r\n3Added by the Finance Act, 2013. \r\n4New Section 171A inserted through Finance Act, 2019. \r\nChapter X – Procedure__________________________________ \r\n \r\n357 \r\n \r\n \r\n(4) The bonds shall be approved security for calculating the statutory \r\nliquidity reserve. \r\n \r\n(5) The bonds shall be accepted by the banks as collateral. \r\n \r\n(6) There shall be no compulsory deduction of Zakat against bonds and \r\nSahib-e-Nisab may pay Zakat voluntarily according to Shariah. \r\n \r\n(7) After period of maturity, the company shall return the promissory note \r\nto the Board and the Bo ard shall make the payment of amount due \r\nunder the bonds, along with profit due, to the bond holders. \r\n \r\n(8) The bonds shall be redeemable in the manner as in sub -section (9) \r\nbefore maturity only at the option of the Board along with simple profit \r\npayable at the  time of redemption in the light of general or specific \r\npolicy to be formulated by the Board. \r\n \r\n(9) The refund under sub-section (1) shall be paid in the aforesaid manner \r\nto the claimants who opt for payment in such manner. \r\n \r\n(10) The Federal Government may notify pr ocedure to regulate the \r\nissuance, redemption and other matters relating to the bonds, as may \r\nbe required.] \r\n \r\nChapter X – Procedure__________________________________ \r\n \r\n358 \r\n \r\nPART VII \r\nREPRESENTATIVES \r\n \r\n172.  Representatives.— (1)  For the purposes of this Ordinance and subject to \r\nsub-sections (2) and (3), “representative”  in respect of a person for a tax year, \r\nmeans – \r\n \r\n(a) where the person is an individual under a legal disability, the guardian \r\nor manager who receives or is entitled to receive income on behalf, or \r\nfor the benefit of the individual; \r\n \r\n(b) where the person is  a company (other than a trust, a Provincial \r\nGovernment, or 1[Local Government] in Pakistan), the principal officer \r\nof the company; \r\n \r\n(c) where the person is a trust declared by a duly executed instrument in \r\nwriting whether testamentary or otherwise (includ ing any Wakf deed \r\nwhich is valid under the MussalmanWakf Validation Act, 1913 (VI of \r\n1913)), any trustee of the trust; \r\n \r\n(d) where the person is a Provincial Government, or 2[Local Government] \r\nin Pakistan, any individual responsible for accounting for the r eceipt \r\nand payment of moneys or funds on behalf of the Provincial \r\nGovernment or3[Local Government]; \r\n \r\n(e) where the person is an association of persons, the principal officer of \r\nthe association or, in the case of a firm, any partner in the firm; \r\n \r\n(f) where the person is the Federal Government, any individual \r\nresponsible for accounting for the receipt and payment of moneys or \r\nfunds on behalf of the Federal Government; or \r\n \r\n(g) where the person is a public international organisation, or a foreign \r\ngovernment or political sub-Division of a foreign government, any \r\nindividual responsible for accounting for the receipt and payment of \r\nmoneys or funds in Pakistan on behalf of the organisation, \r\ngovernment, or political sub-Division of the government. \r\n \r\n (2) Where the Cou rt of Wards, the Administrator General, the Official \r\nTrustee, or any receiver or manager appointed by, or under, any order of a Court \r\nreceives or is entitled to receive income on behalf, or for the benefit of any person, \r\n                                            \r\n1The words “local authority” substituted by the Finance Act, 2008. \r\n2The words “local authority” substituted by the Finance Act, 2008. \r\n3The words “local authority” substituted by the Finance Act, 2008. \r\nChapter X – Procedure__________________________________ \r\n \r\n359 \r\n \r\nsuch Court of Wards, Administrator General, Official Trustee, receiver, or manager \r\nshall be the representative of the person for a tax year for the purposes of this \r\nOrdinance. \r\n \r\n (3) Subject to sub-sections (4) and (5), where a person is a non -resident \r\nperson, the representative of the perso n for the purposes of this Ordinance for a \r\ntax year shall be any person in Pakistan – \r\n \r\n(a) who is employed by, or on behalf of, the non-resident person; \r\n \r\n(b) who has any business connection with the non -resident \r\nperson1[:]  \r\n \r\n2[Explanation.— In this clause the expression “business \r\nconnection” includes transfer of an asset or business in Pakistan \r\nby a non-resident;] \r\n \r\n(c) from or through whom the non -resident person is in receipt of \r\nany income, whether directly or indirectly;  \r\n \r\n(d) who holds, or controls the r eceipt or disposal of any money \r\nbelonging to the non-resident person;  \r\n \r\n(e) who is the trustee of the non-resident person; or \r\n \r\n(f) who is declared by the Commissioner by 3[an order] in writing to \r\nbe the representative of the non-resident person. \r\n \r\n (4) A bo nafide independent broker in Pakistan who, in respect of any \r\ntransactions, does not deal directly with, or on behalf of, a non -resident principal \r\nbut deals with, or through a non -resident broker, shall not be treated as a \r\nrepresentative of the non-resident principal in respect of such transactions, if – \r\n \r\n(a) the transactions are carried on in the ordinary course of \r\nbusiness through the first-mentioned broker; and \r\n \r\n(b) the non-resident broker is carrying on such transactions in the \r\nordinary course of its business and not as a principal. \r\n \r\n (5) No person shall be declared 4[  ] as the representative of a non -\r\nresident person unless the person has been given an opportunity by the \r\nCommissioner of being heard. \r\n \r\n                                            \r\n1Semi-colon substituted by the Finance Act, 2013.  \r\n2 Added by the Finance Act, 2013. \r\n3 Substituted for the word “notice” by the Finance Act, 2003. \r\n4The words “or treated” omitted by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n360 \r\n \r\n173.  Liability and obligations of representatives.  — (1) Every representative \r\nof a person shall be responsible for performing any duties or obligations imposed \r\nby or under this Ordinance on the person, including the payment of tax. \r\n \r\n (2) Subject to sub-section (4), any tax that, by virtue of sub-section (1), is \r\npayable by a representative of a taxpayer shall be recoverable from the \r\nrepresentative only to the extent of any assets of the taxpayer that are in the \r\npossession or under the control of the representative. \r\n \r\n (3) Every representative of a taxpayer who pays any tax owing by the \r\ntaxpayer shall be entitled to recover the amount so paid from the taxpayer or to \r\nretain the amount so paid out of any moneys of the taxpayer that are in the \r\nrepresentative’s possession or under the representative’s control. \r\n \r\n1[(3A) Any representative, or any person who apprehends that he may be \r\nassessed as a representative, may retain out of any money payable by him to the \r\nperson on whose behalf he is liable to pay tax (hereinafter in this section referred \r\nto as the “principal”), a  sum equal to his estimated liability under this Ordinance, \r\nand in the event of disagreement between the principal and such a representative \r\nor a person as to the amount to be so retained, such representative or person may \r\nobtain from the Commissioner a ce rtificate stating the amount to be so retained \r\npending final determination of the tax liability, and the certificate so obtained shall \r\nbe his authority for retaining that amount.] \r\n \r\n (4) Every representative shall be personally liable for the payment of any \r\ntax due by the representative in a representative capacity if, while the amount \r\nremains unpaid, the representative - \r\n \r\n(a) alienates, charges or disposes of any moneys received or \r\naccrued in respect of which the tax is payable; or \r\n \r\n(b) disposes of or parts with any moneys or funds belonging to the \r\ntaxpayer that is in the possession of the representative or which \r\ncomes to the representative after the tax is payable, if such tax \r\ncould legally have been paid from or out of such moneys or \r\nfunds. \r\n \r\n (5) Nothing in this section shall relieve any person from performing any \r\nduties imposed by or under this Ordinance on the person which the representative \r\nof the person has failed to perform. \r\n                                            \r\n1Inserted by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n361 \r\n \r\nPART VIII \r\nRECORDS, INFORMATION COLLECTION AND AUDIT \r\n \r\n174.  Records.— (1)  Unless otherwise authorised by the Commissioner, every \r\ntaxpayer shall maintain in Pakistan such accounts, documents and records as may \r\nbe prescribed. \r\n \r\n (2) The Commissioner may disallow 1[or reduce] a taxpayer’s claim for a \r\ndeduction if the taxpayer is unable,  without reasonable 2[cause], to provide a \r\nreceipt, or other record or evidence of the transaction or circumstances giving rise \r\nto the claim for the deduction. \r\n \r\n (3) The accounts and documents required to be maintained under this \r\nsection shall be maintaine d for 3[six]years after the end of the tax year to which \r\nthey relate 4[:] \r\n \r\n5[Provided that where any proceeding is pending before any authority \r\nor court the taxpayer shall maintain the record till final decision of the \r\nproceedings.] \r\n \r\n6[Explanation.— Pending proceedings include proceedings for assessment \r\nor amendment of assessment, appeal, revision, reference, petition or \r\nprosecution and any proceedings before an Alternative  Dispute Resolution \r\nCommittee”] 7[: \r\n \r\nProvided that limitation prescribed under this s ub-section shall not \r\napply to the records pertaining to income, assets, expenses or transactions \r\nto which clause (ii) of sub-section (2) of section 111 applies.] \r\n \r\n8[(4) For the purpose of this section, the expression “deduction” means any \r\namount debited to trading account, manufacturing account, receipts and expenses \r\naccount or profit and loss account.] \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2003. \r\n2The word “excuse” substituted by the Finance Act, 2003. \r\n3The word “five”  substituted by the Finance Act, 2010. \r\n4Full stop substituted by the Finance Act, 2010. \r\n5Added by the Finance Act, 2010. \r\n6Added by the Finance Act, 2010. \r\n7Full stop substituted and proviso added by the Finance Act, 2022. \r\n8 Added by the Finance Act, 2003. \r\nChapter X – Procedure__________________________________ \r\n \r\n362 \r\n \r\n 1[(5) The Commissioner may require any person to install and use an \r\nElectronic Tax Register of such type and description as may be prescribed for the \r\npurpose of storing and accessing information regarding any transaction that has a \r\nbearing on the tax liability of such person.] \r\n \r\n175.  Power to enter and search premises. — (1)  In order to enforce any \r\nprovision of this Ordinance (including for the purpose of m aking an audit of a \r\ntaxpayer or a survey of persons liable to tax), the Commissioner or any officer \r\nauthorised in writing by the Commissioner for the purposes of this section – \r\n \r\n(a) shall, at all times and without prior notice, have full and free \r\naccess2[including real-time electronic access]to any premises, place, \r\naccounts, documents or computer; \r\n \r\n(b) may stamp, or make an extract or copy of any accounts, documents \r\nor computer -stored information to which access is obtained under \r\nclause (a); \r\n \r\n(c) may impound any accounts or documents and retain them for so long \r\nas may be necessary for examination or for the purposes of \r\nprosecution;  \r\n \r\n(d) may, where a hard copy or computer disk of information stored on a \r\ncomputer is not made available, impound and retain the computer for \r\nas long as is necessary to copy the information required; and \r\n \r\n(e) may make an inventory of any articles found in any premises or place \r\nto which access is obtained under clause (a). \r\n \r\n3[(2)  The Commissioner may authorize any valuer or expert t o enter any \r\npremises and perform any task assigned to him by the Commissioner.] \r\n \r\n (3) The occupier of any premises or place to which access is sought \r\nunder sub-section (1) shall provide all reasonable facilities and assistance for the \r\neffective exercise of the right of access. \r\n \r\n                                            \r\n1Added by the Finance Act, 2008. \r\n2The expression inserted through Finance Act, 2020 dated 30th June, 2020 \r\n3Sub-section (2) substituted by the Finance Act, 2003. The substituted sub-section (2) read as \r\nfollows:  \r\n“(2) The Commissioner may authorise any valuer to enter any premises or place to inspect such \r\naccounts and documents as may be necessary to enable the valuer to make a valuation of an asset \r\nfor the purposes of this Ordinance.” \r\nChapter X – Procedure__________________________________ \r\n \r\n363 \r\n \r\n (4) Any accounts, documents or computer impounded and retained under \r\nsub-section (1) shall be signed for by the Commissioner or an authorised officer.  \r\n \r\n (5) A person whose accounts, documents or computer have been \r\nimpounded and reta ined under sub -section (1) may examine them and make \r\nextracts or copies from them during regular office hours under such supervision as \r\nthe Commissioner may determine. \r\n \r\n (6) Where any accounts, documents or computer impounded and \r\nretained under sub-section (1) are lost or destroyed while in the possession of the \r\nCommissioner, the Commissioner shall make reasonable compensation to the \r\nowner of the accounts, documents or computer for the loss or destruction.  \r\n \r\n (7) This section shall have effect notwithstandin g any rule of law relating \r\nto privilege or the public interest in relation to access to premises or places, or the \r\nproduction of accounts, documents or computer-stored information. \r\n \r\n (8) In this section, “occupier” in relation to any premises or place, mea ns \r\nthe owner, manager or any other responsible person on the premises or place.  \r\n \r\n1[(9) For the purpose of clause (a) of sub-section (1), the Board may make \r\nrules relating to electronic real -time assess for audit or a survey of persons liable \r\nto tax.] \r\n \r\n2[175A. Real-time access to information and databases. - (1) \r\nNotwithstanding anything contained in any law for the time being in force, including \r\nbut not limited to the National Database and Registration Authority Ordinance, \r\n2000 (Ordinance VIII of 2000), and the Emigration Ordinance, 1979(Ordinance \r\nXVIII of 1979), arrangements shall be made to provide real -time access of \r\ninformation and database to the Board in the prescribed form and manner by- \r\n \r\n(a) the National Database and Registration Authority with respect to  \r\ninformation pertaining to National Identity Card, Pakistan Origin Card, \r\nOverseas Identity Card, Alien Registration Card, and other particulars \r\ncontained in the Citizen Database. \r\n \r\n(b) the Federal Investigation Agency and the Bureau of Emigration and \r\nOverseas Employment with respect to details of international travel; \r\n \r\n(c) the Federal Investigation Agency and the Bureau of Emigration and \r\nOverseas Employment with respect to details of international entry and \r\nexit of all persons and information pertaining to work perm its, \r\nemployment visas and immigration visas;  \r\n                                            \r\n1New sub-section (9) added through Finance Act, 2020 dated 30th June, 2020 \r\n2New section 175A inserted through Finance Act, 2020 dated 30th June, 2020  \r\nChapter X – Procedure__________________________________ \r\n \r\n364 \r\n \r\n(d) the Islamabad Capital Territory and provincial and local land record and \r\ndevelopment authorities with respect to record -of-rights including \r\ndigitized edition of record-of-rights, periodic record, record of muta tions \r\nand report of acquisition of right; \r\n \r\n(e) the Islamabad Capital Territory and provincial Excise and Taxation \r\nDepartments with respect to information regarding registration of \r\nvehicles, transfer of ownership and other associated record; \r\n \r\n(f) All electricity suppliers and gas transmission and distribution companies \r\nwith respect to particulars of a consumer, the units consumed and the \r\namount of bill charged or paid: \r\n \r\nProvided that where the connection is shared or is used by a \r\nperson other than the owner, the nam e and CNIC of the owner and the \r\nuser shall also be furnished: \r\n \r\nProvided further that all electricity suppliers and gas \r\ntransmission and distribution companies shall make arrangements by the \r\n1st day of January, 2021 for allowing consumers to update the rati o of \r\nsharing of a connection or the particulars of users, as the case may be; \r\nand \r\n \r\n(g) any other agency, authority, institution or organization notified by the \r\nBoard. \r\n \r\n(2) The Board shall make arrangements for laying the infrastructure for \r\nreal-time access to information and database under sub-section (1) and aligning it \r\nwith its own database in the manner as may be prescribed. \r\n \r\n(3) Until real-time access to information and database is made available \r\nunder sub-section (1), such information and data shall be pro vided periodically in \r\nsuch form and manner as may be prescribed. \r\n \r\n(4) Subject to section 216, all information received under this section shall \r\nbe used only for tax purposes and kept confidential.] \r\n   \r\n1[175AA. Exchange of banking and tax information relate d to high -risk \r\npersons. — (1) Notwithstanding anything contained in any law for the time being \r\nin force, including but not limited to the Banking Companies Ordinance, 1962 (LVII \r\nof 1962), section 216 of this Ordinance and any regulations made under the State \r\nBank of Pakistan Act,1956 (XXXIII of 1956), —  \r\n \r\n                                            \r\n1 Section 175AA inserted by the Finance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n365 \r\n \r\n(a) the Board may share information obtained from the tax declarations with \r\nscheduled banks in Pakistan, in respect of persons or classes of persons, \r\nfor the purpose of cross-matching with the bank data through the data-based \r\nalgorithms, as may be prescribed; and  \r\n \r\n(b) the Scheduled banks shall provide to the Board the final results where the \r\nbanking data is at variance with the algorithms provided under clause (a) of \r\nthis sub-section.  \r\n \r\n(2) All information received under this section shall be used only for tax \r\nand related purposes and kept confidential.] \r\n \r\n1[175B. National Database and Registration Authority (NADRA).  (1) The \r\nNational Database and Registration Authority shall, on its own motion or upon \r\napplication by the Board, share its records and any information available or held \r\nby it, with the Board, for broadening of the tax base or carrying out the purposes \r\nof the Ordinance. \r\n \r\n(2) The National Database and Registration Authority may — \r\n(i) submit proposal s and information to the Board with a view to \r\nbroadening the tax base; \r\n \r\n(ii) identify in relation to any person, whether a taxpayer or not –  \r\n \r\n(a) income, receipts, assets, properties, liabilities, \r\nexpenditures, or transactions that have escaped \r\nassessment or are under-assessed or have been assessed \r\nat a low rate, or have been subjected to excessive relief or \r\nrefund or have been misdeclared or misclassified under a \r\nparticular head of income or otherwise; \r\n \r\n(b) the value of anything mentioned in sub-clause (a) of clause \r\n(ii), if such value is at variance with the value notified by the \r\nBoard or the district authorities, as the case may be, or if no \r\nsuch value has been notified the true or market value; and \r\n \r\n(iii)  enter into a memorandum of understanding with the Board  for a \r\nsecure exchange and utilization of a person's information. \r\n \r\n(3) The Board may use and utilize any information communicated to it by \r\nthe National Database and Registration Authority and forward such information to \r\nan income tax authority having juris diction in relation to the subject matter \r\nregarding the information, who may utilize the information for the purposes of the \r\nOrdinance. \r\n                                            \r\n1New section 175B inserted through Finance Act, 2022. \r\nChapter X – Procedure__________________________________ \r\n \r\n366 \r\n \r\n \r\n(4) The National Database and Registration Authority may compute \r\nindicative income and tax liability of anyone mentione d under sub-sections (1) or \r\n(2) by use of artificial intelligence, mathematical or statistical modeling or any other \r\nmodern device or calculation method.  \r\n \r\n(5) The indicative income and tax liability computed by the National \r\nDatabase and Registration Authority under sub-section (4) shall be notified by the \r\nBoard to the person in respect of whom such indicative income and tax liability has \r\nbeen determined, who shall have the option to pay the determined amount on such \r\nterms, conditions, installments, discoun ts, reprieves pertaining to penalty and \r\ndefault surcharge, and time limits that may be prescribed by the Board.  \r\n \r\n(6) In case the person against whom a liability has been determined \r\nunder sub-section (4), does not pay such liability within the time prescrib ed under \r\nsub-section (5), the Board shall take action under the Ordinance, upon the basis \r\nof tax liability computed under sub-section (4). \r\n \r\n(7) If the person against whom the liability has been determined under \r\nsub-section (4) pays such liability in terms of sub-section (5), such payment shall \r\nbe construed to be an amended assessment order under section 120 or sub -\r\nsection (1) of section 122 or sub-section (4) of section 122, as the case may be. \r\n \r\n(8) For the purposes of sub-sections (4) and (5), the Board may prescribe \r\nthe extent of installments, reprieves pertaining to penalty and defa ult surcharge \r\nand time limits.] \r\n \r\n1[175C. Posting of officer of Inland Revenue. — Subject to such conditions and \r\nrestrictions, as deemed fit to be imposed, the Board or the Chie f Commissioner \r\nmay post an officer of Inland Revenue or such other officials with any designation \r\nworking under the control of the Board or the Chief Commissioner, to the business \r\npremises of any person or class of such persons, to monitor production, supp ly of \r\ngoods or rendering of services and the stock of goods not sold at any time for \r\ndetermining tax payable under this Ordinance.]  \r\n \r\n176.  Notice to obtain information or evidence.— (1)  The Commissioner may, \r\nby notice in writing, require any person, whet her or not liable for tax under this \r\nOrdinance – \r\n \r\n2[(a)   to furnish to the Commissioner or an authorised officer, any information \r\nrelevant to any tax leviable under this Ordinance or to fulfill any \r\n                                            \r\n1 Section 175C inserted by the Finance Act, 2025. \r\n2 Substituted by the Finance Act, 2015. The substituted clause (a) read as follows:-  \r\n“(a) to furnish to the Commissioner or an authorised officer, any information relevant to any \r\ntax 2[leviable] under this Ordinance as specified in the notice; or” \r\nChapter X – Procedure__________________________________ \r\n \r\n367 \r\n \r\nobligation under any agreement with foreign government or  \r\ngovernments or tax jurisdiction, as specified in the notice; or; and] \r\n \r\n(b) to attend at the time and place designated in the notice for the purpose \r\nof being examined on oath by the Commissioner or an authorised \r\nofficer concerning the tax affairs of that p erson or any other person \r\nand, for that purpose, the Commissioner or authorised officer may \r\nrequire the person examined to produce any accounts, documents, or \r\ncomputer-stored information in the control of the person 1[; “or”] \r\n \r\n2[(c)  the firm of chartered accountants 3[ 4[ ]  or a firm of cost and \r\nmanagement accountants as defined under the Cost and \r\nManagement Accountants Act, 1966 (XIV of 1966)] , as appointed by \r\nthe 5[Board or the Commissioner], to conduct audit under section 177, \r\nfor any tax year, may with  the prior approval of the Commissioner \r\nconcerned, enter the business premises of a taxpayer, 6[  ] to obtain \r\nany information, require production of any record, on which the \r\nrequired information is stored and examine it within such premises; \r\nand such firm may if specifically delegated by the Commissioner, also \r\nexercise the powers as provided in sub-section (4).] \r\n  \r\n7[(1A) A special audit panel appointed under sub-section (11)of section 177, \r\nfor any tax year, may, with the prior approval of the  Commissioner c oncerned, \r\nenter the business premises of a  taxpayer, to obtain any information, require \r\nproduction of any record, on which the required information is stored and examine \r\nit within such premises and such panel may if specifically delegated  by the \r\nCommissioner, also exercise the powers as provided in subsection(4).] \r\n  \r\n(2) The Commissioner may impound any accounts or documents \r\nproduced under sub-section (1) and retain them for so long as may be necessary \r\nfor examination or for the purposes of prosecution. \r\n \r\n (3) 8[The person from whom information is required, may at his option, \r\nfurnish the same electronically in any computer readable media.] Where a hard \r\n                                            \r\n1 Full stop substituted by the Finance Act, 2009. \r\n2 Inserted by the Finance Act, 2009. \r\n3 Inserted by the Finance Act, 2017. \r\n4 Comma omitted by the Finance Act, 2022.  \r\n5 The word “Board” substituted by the Finance Act, 2010.  The substituted provision has been made \r\neffective from 05.06.2010 by sub -clause (77) of clause 8 of the Finance Act, 2010. Earlier the \r\nsubstitution was made through Finance (Amendment) Ordinance, 2009 whi ch was re-promulgated \r\nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \r\n6 The words and comma “selected for audit,” omitted by the Finance Act, 2012. \r\n7 Added by the Finance Act, 2015. \r\n8Inserted by the Finance Act, 2005. \r\nChapter X – Procedure__________________________________ \r\n \r\n368 \r\n \r\ncopy or computer disk of information stored on a computer is not made available \r\nas required under sub -section (1), the Commissioner may require production of \r\nthe computer on which the information is stored, and impound and retain the \r\ncomputer for as long as is necessary to copy the information required. \r\n \r\n (4) For the purposes of this section, the Commissioner sha ll have the \r\nsame powers as are vested in a Court under the Code of Civil Procedure, 1908 \r\n(Act V of 1908), in respect of the following matters, namely: — \r\n \r\n(a) enforcing the attendance of any person and examining the \r\nperson on oath or affirmation; \r\n \r\n(b) compelling the production of any accounts, records, computer -\r\nstored information, or computer; \r\n \r\n(c) receiving evidence on affidavit; or \r\n \r\n(d) issuing commissions for the examination of witnesses. \r\n \r\n (5) This section shall have effect notwithstanding any 1[law or r ules]  \r\nrelating to privilege or the public interest in relation to the production of accounts, \r\ndocuments, or computer-stored information or the giving of information. \r\n \r\n                                            \r\n1The words “rule of law” substituted by the Finance Act, 2011. \r\nChapter X – Procedure__________________________________ \r\n \r\n369 \r\n \r\n1[177. Audit.— 2[(1) The Commissioner may call for any record or documents including \r\nbooks of accounts maintained under this Ordinance or any there law for the time being \r\nin force for conducting audit of the income tax affairs of the person and where such \r\nrecord or documents have been kept on electronic data, the person shall allow access \r\nto the Commissioner or the officer authorized by the Commissioner for use of machine \r\nand software on which such data is kept and the Commissioner or the officer may have \r\naccess to the  required information and data and duly attested hard copies of such \r\ninformation or data for the purpose of investigation and proceedings under this \r\nOrdinance in respect of such person or any other person: \r\n \r\n Provided that— \r\n \r\n(a)  the Commissioner may, after recording reasons in writing \r\ncall for record or documents including books of accounts \r\nof the taxpayer; and \r\n \r\n                                            \r\n1 Section 177 substituted by the Finance Act, 2004. The Substituted section 177 read as follows:- \r\n “177. Audit:- (1)  The commissioner may select any person for an audit of the person’s income tax \r\naffairs having regard to- \r\n(a) the person’s history of compliance or non-compliance with this Ordinance; \r\n(b) the amount of tax payable by the person; \r\n(c) the class of business conducted by the person; and \r\n(d) any other matter that the commissioner considers relevant. \r\n (1A)  After selection of a person for audit under sub-section (1), the Commissioner shall conduct an audit of \r\nthe income tax affairs (including examination of accounts and records, enquiry into expenditure, assets and \r\nliabilities) of that person. \r\n(1B) After completion of the audit under sub-section (1A) or sub-section (3), the Commissioner may, if \r\nconsidered necessary, after obtaining taxpayer’s explanation on all the issues raised in the audit, amend the \r\nassessment under sub-section (1) or sub-section (4) of section 122, as the case may be. \r\n (2) The fact that a person has been audited in a year shall not preclude the person from being \r\naudited again in the next and following years where there are reasonable grounds for such audits, \r\nparticularly having regard to the factors in sub-section (1). \r\n(3) The Central Board of Revenue may appoint a firm of Chartered Accountants as defined under \r\nthe Chartered Accountants Ordinance, 1961(X of 1961), to conduct an audit of the income tax affairs \r\nof any person and the scope of such audit shall be as determined by the Central Board of Revenue on \r\na case by case basis. \r\n(4) Any person employed by a firm referred to in sub -section (3) may  by authorised by the \r\ncommissioner, in writing, to exercise the powers in sections  175 and 176 for the purposes of the \r\nconducting audit under that subsection.”  \r\n2 Sub-section (1) substituted by the Finance Act, 2010. The substituted sub-section (1) read as follows:  \r\n“(1) The Commissioner may call for any record or documents including bo oks of accounts \r\nmaintained under this Ordinance or any other law for the time being in force for conducting audit of \r\nthe income tax affairs of the person and where such record or documents have been kept on \r\nelectronic data, the person shall allow access to  the Commissioner or the officer authorized by the \r\nCommissioner for use of machine and software on which such data is kept and the Commissioner \r\nor the officer may take into possession such machine and duly attested hard copies of such \r\ninformation or data for the purpose of investigation and proceedings under this Ordinance in respect \r\nof such person or any other person:  \r\nProvided that the Commissioner shall not call for record or documents of the taxpayer \r\nafter expiry of six years from the end of the tax year to which they relate.” \r\nChapter X – Procedure__________________________________ \r\n \r\n370 \r\n \r\n(b)  the reasons shall be communicated to the taxpayer while \r\ncalling record or documents including books of accounts \r\nof the taxpayer: \r\n \r\nProvided further that the Commissioner shall not call for record or \r\ndocuments of the ta xpayer after expiry of six years from the end of the tax \r\nyear to which they relate.] \r\n \r\n1[(2) After obtaining the record of a person under sub -section (1) or where \r\nnecessary record is not maintained, the Commissioner shall conduct an audit of \r\nthe income tax affairs (including examination of accounts and records, enquiry into \r\nexpenditure, assets and liabilities) of that person or any other person and may call \r\nfor such other information and documents as he may deem appropriate.] \r\n \r\n2[(2A) For the purpose of sub -section (2), the Commissioner may conduct \r\naudit proceedings electronically through video links, or any other facility as \r\nprescribed by the Board. \r\n  \r\n(2AA) Where a taxpayer— \r\n \r\n(a) has not furnished record or documents including books of \r\naccounts; \r\n \r\n(b) has furnished incomplete record or books of accounts; or \r\n \r\n(c) is unable provide sufficient explanation regarding the defect s in \r\nrecords, documents or books of accounts,  \r\n \r\nit shall be construed that taxable income has not been correctly declared and the \r\nCommissioner shall determine taxable income on the basis of sectoral benchmark \r\nratios prescribed by the Board. \r\n \r\nExplanation.—The expression “sectoral benchmark ratios” means standard \r\nbusiness sector ratios notified by the Board on the basis of comparative cases and \r\nincludes fina ncial ratios, production ratios, gross profit ratio, not profit ratio, \r\nrecovery ratio, wastage ratio and such other ratios in respect of such sectors as \r\nmay be prescribed.] \r\n \r\n                                            \r\n1Sub-section (2) substituted by the Finance Act, 2010. The substituted sub-section (2) read as follows: \r\n  “(2)  After obtaining the record of a person under sub-section (1) or where necessary record \r\nis not maintained, the Commissio ner shall conduct an audit of the income tax affairs (including \r\nexamination of accounts and records, enquiry into expenditure, assets and liabilities) of that person \r\nor any other person and may call for such other information and documents as he may deem \r\nappropriate.” \r\n2New sub-sections (2A) and (2AA) inserted through Finance Act, 2020 dated 30th June, 2020 \r\nChapter X – Procedure__________________________________ \r\n \r\n371 \r\n \r\n1[  ] \r\n \r\n2[  ] \r\n \r\n3[  ] \r\n  \r\n4[(6) After compilation of the audit, the Commissioner shall, after obtaining \r\ntaxpayer’s explanation on all the issues raised in the audit, issue an audit report \r\ncontaining audit observations and finding.] \r\n \r\n5[(6A) After issuing the audit report, the Commissioner may, if considered \r\nnecessary, amend the assessment un der sub -section (1) or  sub-section (4) of \r\nsection 122, as the case may be, after providing an opportunity of being heard to \r\nthe taxpayer under sub-section (9) of section 122.]  \r\n \r\n(7)  The fact that a person has been audited in a year shall not preclude \r\nthe person from being audited again in the next and following years where there \r\nare reasonable grounds for such audits 6[ ]. \r\n \r\n (8)  The 7[Board] may appoint a firm of Chartered Accountants as defined \r\nunder the Chartered Accountants Ordinance, 1961 (X of 1961)  8[or a firm of Cost \r\nand Management Accountants as defined under the Cost and Management \r\nAccountants Act, 1966 (XIV of 1966)] , or a firm of Cost and Management \r\nAccountants as defined under the Cost and Management Accountants Act, 1966 \r\n                                            \r\n1 Sub-section (3) omitted by the Finance Act, 2010. The omitted sub-section (3) read as follows: \r\n “(3)  The Board shall keep the criteria confidential.” \r\n2 Sub-section (4) omitted by the Finance Act, 2010. The omitted sub-section (4)  read as follows: \r\n “(4)  In addition to the selection referred to in sub-section (2), the Commissioner may also select \r\na person or classes of persons for an audit of the person’s income tax affairs having regard to - \r\n(a)  the person’s history of compliance or non-compliance with this Ordinance; \r\n  (b)  the amount of tax payable by the person; \r\n  (c)  the class of business conducted by the person; and \r\n(d)  any other matter which in the opinion of Commissioner is material for \r\ndetermination of correct income.” \r\n3Sub-section (5) omitted by the Finance Act, 2010. The omitted sub-section  (5)  read as follows: \r\n  “(5)  After selection of a person or classes of persons for audit under sub-section (2) or (4), \r\nthe Commissioner shall conduct an audit of the income tax affairs (including examination of accounts \r\nand records, enquiry into expenditure, assets and liabilities) of such person or classes of persons.” \r\n4Sub-section (6) substituted through Finance Act, 2019 substituted sub-section (6) read as follows:  \r\n(6) After completion of the audit 4[ ], the Commissioner may, if considered necessary, after obtaining \r\ntaxpayer’s explanation on all the issues raised in the audit, amend the assessment under sub-section \r\n(1) or sub-section (4) of section 122, as the case may be.   \r\n5 New sub-section (6A) inserted through Finance Act, 2019. \r\n6The words, comma, brackets and figure “particularly having regard to the factors in sub -section (4)“ \r\nomitted by the Finance Act, 2010. \r\n7The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n8 Inserted by the Finance Act, 2010. \r\nChapter X – Procedure__________________________________ \r\n \r\n372 \r\n \r\n(XIV of 1966)  to condu ct an audit of the income tax affairs of any person 1[or \r\nclasses of persons 2[  ] ] and the scope of such audit shall be as determined by the \r\n3[Board] 4[or the Commissioner] on a case to case basis. \r\n \r\n (9) Any person employed by a firm referred to in sub -section (8) may be \r\nauthorized by the Commissioner, in writing, to exercise the powers in sections 175 \r\nand 176 for the purposes of conducting an audit under that sub-section.] \r\n \r\n5[(10) Notwithstanding anything contained in sub-sections (2) and (6) where \r\na pers on fails to produce before the Commissioner or a firm of Chartered \r\nAccountants or a firm of Cost and Management Accountants appointed by the \r\nBoard or the Commissioner under sub -section (8) to conduct an audit, any \r\naccounts, documents and records, required to be maintained  under section 174 \r\nor any other relevant document, electronically kept record, electronic machine or \r\nany other evidence that may be required by the Commissioner or the firm of \r\nChartered Accountants or the firm of Cost and Management Accoun tants for the \r\npurpose of audit or determination of income and tax due thereon, the \r\nCommissioner may proceed to make best judgment assessment  under section \r\n121  of this Ordinance and the assessment treated to have been made on the \r\nbasis of return or revised return filed by the taxpayer shall be of no legal effect.] \r\n \r\n6[Explanation.— For the removal of doubt, it is declared that the \r\npowers of the Commissioner under this section are independent of the \r\npowers of the Board under section 214C and nothing containe d in \r\nsection 214C restricts the powers of the Commissioner to call for the \r\nrecord or documents including books of accounts of a taxpayer for \r\naudit and to conduct audit under this section.] \r\n \r\n7[(11) The Board may appoint as many special audit panels as may b e \r\nnecessary, comprising two or more members from the following:— \r\n \r\n(a)  an officer or officers of Inland Revenue; \r\n \r\n(b)  a firm of chartered accountants as defined under the Chartered  \r\nAccountants Ordinance, 1961 (X of 1961); \r\n \r\n(c)  a firm of cost and management accountants as defined under the Cost \r\nand Management Accountants Act, 1966 (XIV of 1966); or \r\n \r\n                                            \r\n1Inserted by the Finance Act, 2009. \r\n2The  words “selected for audit by the Commissioner or by the Board” omitted by the Finance Act, 2010. \r\n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\n4Inserted by the Finance Act, 2010. \r\n5 Added by the Finance Act, 2010. \r\n6 Added by the Finance Act, 2013. \r\n7 Added by Finance Act, 2015. \r\nChapter X – Procedure__________________________________ \r\n \r\n373 \r\n \r\n(d)  any other person 1[including a foreign expert or specialist] as directed \r\nby the Board,  to conduct an audit, including a forensic audit, of the \r\nincome tax affairs of any person or classes of persons and the scope \r\nof such audit shall be as  determined by the Board or the \r\nCommissioner on case-to-case basis. \r\n \r\n2[(e) a tax audit expert deployed under an audit assistance programme of  \r\nan international tax organization or a tax authority outside Pakistan: \r\n \r\nProvided that in case the member is not an officer of Inland \r\nRevenue, the person shall only be included as a member in the special \r\naudit panel if an agreement of confidentiality has been  entered into \r\nbetween the Board and the person, international tax organization or a \r\ntax authority, as the case may be.] \r\n \r\n(12)  Special audit panel under sub -section (1) shall be headed by a  \r\nChairman who shall be an officer of Inland Revenue. \r\n \r\n(13)  Powers under sections 175 and 176 for the purposes of  conducting \r\nan audit under sub-section (11), shall only be exercised by an officer or officers of \r\nInland Revenue, who are member or members of the  special audit panel, and \r\nauthorized by the Commissioner. \r\n \r\n(14)  Notwithstanding anything contained in sub-sections (2) and(6), where \r\na person fails to produce before the Commissioner or a special  audit panel under \r\nsub-section (11) to conduct an audit, any accounts, documents  and records, \r\nrequired to be maintained under section 174 or any other rele vant document, \r\nelectronically kept record, electronic machine or any other evidence  that may be \r\nrequired by the Commissioner or the panel, the Commissioner may  proceed to \r\nmake best judgment assessment under section 121 and the  assessment treated \r\nto have been made on the basis of return or revised  return filed by the taxpayer \r\nshall be of no legal effect. \r\n \r\n(15) If any one member of the special audit panel, other than the Chairman, \r\nis absent from conducting an audit, the proceedings of the audit may continue, and \r\nthe audit conducted by the special audit panel  shall not be invalid or be called in \r\nquestion merely on the ground of such absence. \r\n \r\n(16)  Functions performed by an officer or officers of Inland  Revenue as \r\nmembers of the special audit panel, for conduct ing audit, shall be treated to have \r\nbeen performed by special audit panel. \r\n \r\n(17)  The Board may prescribe the mode and manner of  constitution, \r\nprocedure and working of the special audit panel.”] \r\n                                            \r\n1Inserted by Finance Act, 2018 \r\n2Added by Finance Act, 2018 \r\nChapter X – Procedure__________________________________ \r\n \r\n374 \r\n \r\n178. Assistance to Commissioner.— Every Officer of Customs, 1[  ] Provincial \r\nExcise and Taxation, District Coordination Officer, District Officers including \r\nDistrict Officer – Revenue, the Police and the Civil Armed Forces is empowered \r\nand required to assist the Commissioner in the discharge of the Commissioner’s \r\nfunctions under this Ordinance. \r\n \r\n179.  Accounts, documents, records and computer -stored information not \r\nin Urdu or English language. — Where any account, document, record or \r\ncomputer-stored information referred to in section 174, 175 or 176 is not in the \r\nUrdu or English language, the Commissioner may, by notice in writing, require the \r\nperson keeping the account, document, record or computer -stored information to \r\nprovide, at the person's expense, a translation into the Urdu or English language \r\nby a translator approved by the Commissioner for this purpose. \r\n \r\n180.  Power to collect information regarding exempt income.— The 2[Board] \r\nmay, by notification in the official Gazette, authorise any department or agency of \r\nthe Government to collect and compile any data in r espect of incomes from \r\nindustrial and commercial undertakings exempt from tax under this Ordinance.  \r\n \r\n                                            \r\n1The words and commas “Federal Excise, Sales Tax,” omitted by the Finance Act, 2013.  \r\n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \r\nChapter X – Procedure__________________________________ \r\n \r\n375 \r\n \r\n1[PART IX \r\nTAXPAYER’S REGISTRATION \r\n \r\n181. Taxpayer’s registration.— (1)  Every taxpayer 2[including a person selling \r\ndigitally ordered goods or services fro m within Pakistan using online marketplace \r\nor a courier service, as the case may be,] shall apply in the prescribed form and in \r\nthe prescribed manner for registration. \r\n \r\n3[(1A) Every online marketplace or courier service, involved in e -commerce \r\nby supplying or delivering digitally ordered goods or services from within Pakistan, \r\nshall not allow any vendor to use its platform services to carry out e -commerce \r\ntransactions unless such vendors have been registered under this Ordinance.] \r\n \r\n(2) The Commissioner havi ng jurisdiction over a case, where \r\nnecessitated by the facts of the case, may also register a taxpayer in the prescribed \r\nmanner. \r\n \r\n(3) Taxpayers’ registration scheme shall be regulated through the rules \r\nto be notified by the Board 4[ 5[“.”] ] ] \r\n \r\n6[ 7[ ] ] \r\n \r\n 8[(4) From tax year 2015 and onwards, in case of individuals having \r\nComputerized National Identity Card (CNIC) issued by the National Database and \r\nRegistration Authority, CNIC shall be used as National Tax Number.]  \r\n                                            \r\n1 Part IX ssubstituted by the Finance Act,  2008. The substituted “Part IX” read as follows: \r\n“PART IX \r\nNATIONAL TAX NUMBER CERTIFICATE \r\n181.  National Tax Number Certificate.- (1)  Every taxpayer shall apply in the prescribed form and \r\nin the prescribed manner for a National Tax Number Certificate.  \r\n (2) An application under sub-section (1) shall be accompanied by the prescribed fee. \r\n(3) The Commissioner having jurisdiction over an applicant under sub-section (1) may after \r\nexamination of all relevant documents and evidence, and after satisfying himself of the genuineness \r\nof the application, may direct issuance of the National Tax Number Certificate for a period prescribed \r\nby Commissioner: \r\nProvided that the Board may in the case of individuals allow use of National Identity Card, \r\nissued by the National Database and Registration Authority, in place of National Tax Number.” \r\n2 Expression inserted by the Finance Act, 2025. \r\n3 Section (1A) inserted by the Finance Act, 2025. \r\n4 Full stop substituted by the Finance Act, 2013.  \r\n5 Substituted “:” by the Finance Act, 2015. \r\n6 Added by the Finance Act, 2013.  \r\n7 Omitted by the Finance Act, 2015. The omitted proviso read as follows:- \r\n“Provided that the Board may in case of individuals allow, in place of National Tax \r\nNumber, use of Computerized National Identity Card issued by the National Database and \r\nRegistration Authority.” \r\n8 Added by the Finance Act, 2015. \r\nChapter X – Procedure__________________________________ \r\n \r\n376 \r\n \r\n1[181A. Active taxpayers’ list.— (1) The Board shall have the power to institute \r\nactive taxpayers’ list. \r\n \r\n (2) Active taxpayers’ list shall be regulated as may be prescribed.] \r\n \r\n2[181AA. Compulsory registration in certain cases. -(1) Notwithstanding \r\nanything contained in any law, for the time bein g in forc e, any application for \r\ncommercial or industrial connection of electricity or natural gas, shall not be \r\nprocessed and such connection shall not be provided unless the  person applying \r\nfor electricity or gas connection is registered under section 181.] \r\n \r\n3[181B. Taxpayer card. — Subject to this Ordinance, the Board may make a \r\nscheme for introduction of a tax -payer honour card for individual taxpayers, who \r\nfulfill a minimum criteria to be eligible for the benefits as contained in the scheme.] \r\n \r\n4[181C. Displaying of National Tax Number .— Every person deriving income \r\nfrom business chargeable to tax, who has been issued a National Tax Number, \r\nshall display his National Tax Number at a conspicuous place at every place of his \r\nbusiness.] \r\n \r\n5[181D. Business licence scheme.- 6[(1)] Every person engaged in any business, \r\nprofession or vocation shall be required to obtain and display a business licence \r\nas prescribed by the Board.] \r\n \r\n 7[(2) Where a person fails to obtain business licence under sub-section (1), \r\nthe Commissioner may, in addition to and not in derogation of any punishment to \r\nwhich the person may be liable under this Ordinance or any other law, impose a \r\nfine of – \r\n \r\n(a) twenty thousand Rupees, in case of a taxpayer deriving income \r\nchargeable to tax under this Ordinance; or  \r\n \r\n(b) five thousand Rupees, in all other cases. \r\n \r\n                                            \r\n1 Inserted by the Finance Act, 2010.  \r\n2Inserted by the Finance Act, 2014. \r\n3 Added by the Finance Act, 2012. \r\n4 Added by the Finance Act, 2013. \r\n5 New Section (181D) inserted through Finance Act, 2019. \r\n6 Provision re-numbered as sub-section (1) through Tax Law (Second Amendment) 2019 dated 26th  \r\nDecember, 2019  \r\n7 New sub-sections (2) & (3) inserted through Tax Law (Second Amendment) 2019, dated 26th \r\nDecember, 2019 \r\nChapter X – Procedure__________________________________ \r\n \r\n377 \r\n \r\n (3) The Commissioner may, by an order in writing, cancel a business \r\nlicence issued under sub -section (1) after providing an opportunity of being \r\nheard to the person, if –  \r\n  \r\n(a) such person fails to notify any change in particulars within thirty days of \r\nsuch charge; or  \r\n \r\n(b) such person is convicted of any offence under any federal tax law.] \r\n \r\n1[181E. Record of beneficial owners. - (1) Every company and association of \r\npersons shall electronically furnish particu lars of its beneficial owners in such \r\nform and manner as may be prescribed. \r\n \r\n(2) Every company and association of persons shall update the particulars of its \r\nbeneficial owners as and when there is a change in the particulars of the \r\nbeneficial owners.]    \r\n  \r\n  \r\n                                            \r\n1 New Section 181E inserted by the Finance Act, 2022. \r\nChapter X – Procedure__________________________________ \r\n \r\n378 \r\n \r\nPART X \r\nPENALTY \r\n \r\n1[182. Offences and penalties. — (1) Any person who commits any offence \r\nspecified in column (2) of the Table below shall, in addition to and not in derogation \r\nof any punishment to which he may be liable under this Ordinance or any other \r\nlaw, be liable to the penalty mentioned against that offence in column (3) thereof:— \r\n  \r\n \r\nTABLE \r\n \r\n                                            \r\n1Section 182 substituted by the Finance Act, 2010. The substituted section 182 read as follows: \r\n “182.  Penalty for failure to furnish a return or statement.- (1)  Any person who, without reasonable excuse, \r\nfails to furnish, within the time allowed under this Ordinance, return of income or a statement as required under \r\nsub-section (4) of section 115 or wealth statement for any tax year as required under this Ordinance shall be \r\nliable for a penalty equal to one-tenth of one per cent of the tax payable for each day of default subject to a \r\nminimum penalty of five hundred rupees and a maximum penalty of twenty-five per cent of the tax payable in \r\nrespect of that tax year. \r\n  (2) Any person who, without reasonable excuse, fails to furnish, within the time allowed under this \r\nOrdinance, any statement required under section 165 shall be liable for a penalty of two thousand rupees. \r\n  (3) Where a person liable to a penalty under sub-section (2) continues to fail to furnish the \r\nstatement, the person shall be liable for an additional penalty of two hundred rupees for each day of default \r\nafter the imposition of the penalty under sub-section (2).” \r\nChapter X – Procedure__________________________________ \r\n \r\n379 \r\n \r\nS. \r\nNo. \r\nOffences Penalties Section of \r\nthe \r\nOrdinance \r\nto which \r\noffence has \r\nreference \r\n(1) (2) (3) (4) \r\n1. 1[Where any person \r\nfails to furnish a return \r\nof income as required \r\nunder section 114 \r\nwithin the due date.] \r\n2[   ] \r\n \r\n3[Such person shall pay a penalty equal to higher \r\nof – \r\n \r\n(a) 0.1% of the tax payable in respect of that tax \r\nyear for each day of default; or \r\n(b) rupees one thousand for  each day of \r\ndefault: \r\n \r\nProvided that mini mum penalty shall be \r\n—  \r\n(i) rupees ten thousand in case of \r\nindividual having seventy-five percent or \r\nmore income from salary; or \r\n(ii)  rupees fifty thousand in all other cases: \r\n \r\n  Provided further that maximum penalty \r\nshall not exceed two hundred percent of tax \r\npayable by the person in a tax year:  \r\n \r\nProvided also that the amount of \r\npenalty shall be reduced by 75%, 50% and \r\n25% if the return is filed within one, two and \r\nthree months respectively after the due date \r\nor extended due date of filing of return as \r\nprescribed under the law; \r\n \r\nExplanation.— For the purposes of this \r\nentry, it is declared that the expression \"tax \r\npayable\" means tax chargeable on the \r\ntaxable income on the basis of assessment \r\nmade or treated to have been made under \r\nsection 120, 121, 122 or 122D;] \r\n \r\n114 *[and 118] \r\n4[1A. Where any person \r\nfails to furnish a \r\nstatement as required \r\nunder section 5[ ] \r\n6[165, 165A, 165B  or \r\n165C] within the due \r\ndate.] \r\n7[Such person shall pay a penalty of Rs. 8[50000] if the \r\nperson had already paid the tax collected or withheld \r\nby him within the due date for payment and the \r\nstatement is filed within ninety days from the due date \r\nfor filing the statement and, in all other cases, a penalty \r\nof Rs.2500 for each day of default from the due date \r\nsubject to a minimum penalty of Rs. 10,000] 9[: \r\n \r\nProvided that where it stands established that no \r\ntax was required to be deducted or collected during the \r\nrelevant period, minimum amount of penalty shall be \r\nten thousand Rupees.”; \r\n \r\n10[ ] 11[165, \r\n165A, 165B  and \r\n165C]   \r\nChapter X – Procedure__________________________________ \r\n \r\n380 \r\n \r\n                                            \r\n1The words and figures “Where any person fails to furnish a return of income or a statement as required under \r\nsection 115 or wealth statement or wealth reconciliation statement or statement under section 165 within the \r\ndue date” substituted by the Finance Act, 2013 \r\n2 The words and figures “Such person shall pay a penalty equal to 0.1% of the tax payable for each day of default \r\nsubject to a minimum penalty of five thousand rupees and a maximum penalty of 25% of the tax payable in \r\nrespect of that tax year” substituted by the Finance Act, 2013. \r\n3The expression “Such person shall pay a penalty equal to 0.1% of the tax payable in respect of that tax \r\nyear for each day of default subject to a maximum penalty of 50% of the tax payable provided that if \r\nthe penalty worked out as aforesaid is less than 3[forty] thousand rupees or no tax is payable for that \r\ntax year such person shall pay a penalty of 3[forty] thousand rupees] 3[:] \r\n3[Provided that If seventy-five percent of the income is from salary and the amount of income under \r\nsalary is less than five million Rupees, the minimum amount of penalty shall be five thousand Rupees] \r\n3[: \r\n“Provided further that if taxable income is up -to eight hundred thousand Rupees, the minimum \r\namount of penalty shall be five thousand Rupees:  \r\n  Provided also that the amount of penalty shall be reduced by 75%, 50% and 25% if the return is filed \r\nwithin one, two and three months respectively after the due date or extended due date of filing of return \r\nas prescribed under the law.] \r\n3[Explanation.— For the purposes of this entry, it is declared that the expression “tax payable” means \r\ntax chargeable on the taxable income on the basis of assessment made or treated to have been \r\nmade under section 120, 121, 122 or 122C.” substituted by the Finance Act, 2022. \r\n4 Inserted by the Finance Act, 2013. \r\n5 In column (2) the figure “115” omitted through Finance Act, 2020 dated 30th June, 2020 \r\n6 The expression “165, or 165A,165A or 165B” substituted by the Finance Act, 2025. \r\n7 The expression “Such person shall pay a penalty of Rs. 2500 for each day of default subject to a   \r\nminimum penalty of ten thousand rupees” substituted by the Finance Act, 2018. \r\n8 The figure “5000” substituted by the Finance Act, 2025. \r\n9 Full stop substituted and proviso added by the Finance Act, 2021. Earlier these amendments were \r\nmade through Tax Laws (Second  Amendment) Ordinance, 2021. \r\n10 In column (4) the figure “115” omitted through Finance Act, 2020 dated 30th June, 2020  \r\n11 The expression “165 and 165A,165A and 165B” substituted by the Finance Act, 2025. \r\nChapter X – Procedure__________________________________ \r\n \r\n381 \r\n \r\n1[1AA. Where any per son \r\nfails to furnish wealth \r\nstatement or wealth \r\nreconciliation \r\nstatement. \r\nSuch person shall pay a penalty of 2[“0.1% of the \r\ntaxable income per week or Rs. 3[100,000] \r\nwhichever is higher.”] \r\n114, 4[ ]  and \r\n116] \r\n \r\n  \r\n \r\n5[IAAA Where any person  \r\nfails to furnish a \r\nforeign assets   and \r\nincome statement \r\nwithin the due date. \r\nSuch persons shall pay a penalty   of 2 percent of \r\nthe foreign income   or value of the foreign assets \r\nfor each year of default. \r\n116A] \r\n6[1B Where any person \r\nfails to furnish a return \r\nof income as required \r\nunder sub-section (3) \r\nof section 117 within \r\nthe time specified in \r\nthe notice \r\nSuch person shall pay a penalty equal to higher of \r\n–  \r\n(a)  0.1% of the tax  payable in \r\n respect  of that  tax year for \r\n each day of  default;  or  \r\n(b) Rs. 1,000 per  day of  default:     \r\n  Provided that minimum \r\n penalty shall be Rs.10,000 in case of an \r\n individual and Rs.50,000 in all other cases. \r\n117(3)] \r\n2. Any person who fails \r\nto issue cash memo \r\nor invoice or receipt \r\nwhen required under \r\nthis Ordinance or the \r\nrules made \r\nthereunder. \r\nSuch person shall pay a penalty of five thousand \r\nrupees or three per cent of the amount of the tax \r\ninvolved, whichever is higher. \r\n \r\n174 and \r\nChapter VII of \r\nthe Income Tax \r\nRules. \r\n3. Any person who is \r\nrequired to apply for \r\nregistration under this \r\nOrdinance but fails to \r\nmake an application \r\nfor registration. \r\nSuch person shall pay a penalty of 7[ten] thousand \r\nrupees. \r\n \r\n181 \r\n8[3A. Where any person \r\nbeing a trader or a \r\nshopkeeper who is \r\nrequired to apply for \r\nregistration under this \r\nOrdinance but fails to \r\nregister or fails to pay \r\nadvance tax as \r\nspecified in a scheme \r\nof special procedure \r\nprescribed under \r\nsection 99B. \r\nThe shop of such person shall be sealed for seven \r\ndays for first default and for twenty one days for \r\neach subsequent default \r\n99B] \r\n4. Any person  who fails \r\nto notify the changes \r\nof material nature in \r\nthe particulars of \r\nregistration.  \r\nSuch person shall pay a penalty of five thousand \r\nrupees.  \r\n181 \r\n9[  ]  \r\n \r\n10[    ] \r\n \r\n   \r\n4B Any person who \r\ncontravenes the \r\nprovisions of section \r\n181AA. \r\nSuch a person shall pay a penalty at the rate of Rs. \r\n11[100,000] for each connection provided to an \r\nunregistered person. \r\n181AA]",
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