{"schema_version":"qanun-law-text/1","id":"pk-code-f40603913b933194","title":"Income Tax Ordinance, 2001 (Same as on the official website of FBR dated 31-07-2025)","source_collection":"Federal","content_kind":"stored_law_text","content_extent":null,"source_url":"https://pakistancode.gov.pk/pdffiles/administratorc09ecd376211abe32a7e44510f3fd719.pdf","version":"Full identified original source: 822 PDF pages; original SHA-256 96cef5e5fb0d461b06b587a6fc880b400cd17dfe2e86816cddd9f30bc69bf590","source_snapshot":"2026-07-23T21:23:34Z","legal_status":"not independently verified","text_quality":"Complete source-derived reading transcription. The earlier extraction is preserved separately; current force and later amendment history are not certified.","text_sha256":"2b2ba40482fdceaafe1169e233500b67c9cf19fdbf558cf058405eef2cc51791","source_sha256":"96cef5e5fb0d461b06b587a6fc880b400cd17dfe2e86816cddd9f30bc69bf590","text_version_id":"law:pk-code-f40603913b933194:sha256:2b2ba40482fdceaafe1169e233500b67c9cf19fdbf558cf058405eef2cc51791","quality_flags":[],"encoding":"UTF-8","text":" \n \n45 \n \n \n \n \n \nGOVERNMENT OF PAKISTAN \nFEDERAL BOARD OF REVENUE \n(REVENUE DIVISION) \n…. \n \n \n \n  \nINCOME TAX MANUAL \n \nPART I \n \n \n \n \n \nINCOME TAX ORDINANCE, 2001 \n \n \nAMENDED UPTO 31st JULY, 2025 \n \n \n \n \n \n \n \n \n \n \n\n\f\nTABLE OF CONTENTS \n \nSECTIONS \nCHAPTER 1 \nPRELIMINARY \nPAGE NO. \n1. \nShort title, extent and commencement \n1 \n2. \nDefinitions \n1 \n3. \nOrdinance to override other laws \n31 \n \nCHAPTER II \nCHARGE OF TAX \n \n4. \nTax on taxable income \n32 \n4A. \nOmitted by Finance Act 2014 \n33 \n4AB. \nSubject to this Ordinance, a surcharge payable \n33 \n4B. \nSuper tax for rehabilitation of temporary displaced persons. \n33 \n4C. \nSuper tax on high earning persons. \n34 \n5. \nTax on dividends \n35 \n5A. \nTax on undistributed Profits. \n36 \n5AA. \nTan on return on investments in Sukuks. \n36 \n6. \nTax on certain payments to non-residents \n37 \n6A. \nTax on payments for digital transactions in e-commerce platforms \n38 \n7. \nTax on shipping and air transport income of a non-resident \nperson \n38 \n7A. \nTax on shipping of a resident person. \n39 \n7B. \nTax on profit on debt \n39 \n7C. \nTax on builders \n40 \n7D. \nTax on developers \n41 \n7E. \nTax on deemed income. \n41 \n7F. \nTax on Builders and Developers \n43 \n8. \nGeneral provisions relating to taxes imposed under sections 5, 6 \nand 7 \n44 \n \nCHAPTER III \nTAX ON TAXABLE INCOME \n \n \nPART I \nCOMPUTATION OF TAXABLE INCOME \n \n9. \nTaxable income \n45 \n10. \nTotal income \n45 \n11. \nHeads of income \n45 \n \nPART II \nHEAD OF INCOME \nSALARY \n \n12. \nSalary \n48 \n13. \nValue of perquisites \n50 \n14. \nEmployee share schemes \n54 \n \nPART III \nHEAD OF INCOME \nINCOME FROM PROPERTY \n \n15. \nIncome from property \n56 \n15A. \nDeductions in computing income chargeable under the head \n“Income from Property” \n57 \n16. \nNon-adjustable amounts received in relation to buildings. \n60 \n17. \nOmitted by the Finance Act, 2006. \n \n60 \n\n\f\n \nPART IV \nHEAD OF INCOME \nINCOME FROM BUSINESS \n \n \nDivision I \nIncome from Business \n \n18. \nIncome from business \n61 \n19. \nSpeculation business \n63 \n \nDivision II \n Deductions \nGeneral Principles \n \n20. \nDeductions in computing income chargeable under the head \n“Income from Business” \n64 \n21. \nDeductions not allowed \n64 \n \nDivision III \nDeductions \nSpecial Provisions \n \n22. \nDepreciation \n68 \n23. \nInitial allowance \n73 \n23A. \nOmitted by the Finance Act, 2021. \n74 \n23B. \nAccelerated depreciation to alternate energy projects. \n75 \n24. \nIntangibles \n75 \n25. \nPre-commencement expenditure \n77 \n26. \nScientific research expenditure \n78 \n27. \nEmployee training and facilities \n78 \n28. \nProfit on debt, financial costs and lease payments \n79 \n29. \nBad debts \n81 \n29A \nProvision regarding consumer loans \n82 \n30. \nProfit on non-performing debts of a banking company or \ndevelopment finance institution \n82 \n31. \nTransfer to participatory reserve  \n83 \n \nDivision IV \nTax Accounting \n \n32. \nMethod of accounting \n84 \n33. \nCash-basis accounting \n84 \n34. \nAccrual-basis accounting \n84 \n35. \nStock-in-trade \n85 \n36. \nLong-term contracts \n87 \n \nPART V \nHEAD OF INCOME \nCAPITAL GAINS \n \n37. \nCapital gains \n88 \n37A. \nCapital gain on disposal of securities \n92 \n38. \nDeduction of losses in computing the amount chargeable under \nthe head “Capital Gains” \n94 \n \n \nPART VI \nHEAD OF INCOME \nINCOME FROM OTHER SOURCES \n \n39. \nIncome from other sources \n95 \n40. \nDeductions in computing income chargeable under the head \n“Income from Other Sources” \n97 \n \nPART VII \nEXEMPTIONS AND TAX CONCESSIONS \n \n41. \nAgricultural income \n99 \n\n\f\n42. \nDiplomatic and United Nations exemptions \n100 \n43. \nForeign government officials \n100 \n44. \nExemptions under international agreements \n100 \n44A. \nExemption under Foreign Investment (Promotion and Protection) \nAct, 2022 (XXXV of 2022).  \n101 \n45. \nPresident’s honours \n102 \n46. \nProfit on debt \n102 \n47. \nScholarships \n103 \n48. \nSupport payments under an agreement to live apart \n103 \n49. \nFederal Governments, Provincial Government and Local \nGovernment \n103 \n50. \nForeign-source income of short-term resident individuals \n104 \n51. \nForeign-source income of returning expatriates \n104 \n52. \nOmitted by Finance Ordinance, 2002 \n104 \n53. \nExemptions and tax concessions in the Second Schedule \n105 \n54. \nExemptions and tax provisions in other laws \n106 \n55. \nLimitation of exemption \n107 \n \nPART VIII \nLOSSES \n \n56. \nSet off of losses \n108 \n56A. \nSet off of losses of companies operating hotels. \n108 \n57. \nCarry forward of business losses \n108 \n57A. \nSet off of business loss consequent to amalgamation \n110 \n58. \nCarry forward of speculation business losses \n111 \n59. \nCarry forward of capital losses \n111 \n59A. \nLimitations on set off and carry forward of losses \n112 \n59AA. \nGroup Taxation. \n113 \n59B. \nGroup relief \n114 \n59C. \nOmitted by Finance Act, 2022 \n116 \n \nPART IX \nDEDUCTIBLE ALLOWANCES \n \n60. \nZakat \n117 \n60A. \nWorkers’ Welfare Fund \n117 \n60B. \nWorkers’ Participation Fund \n118 \n60C. \nOmitted by the Finance Act, 2022. \n118 \n60D. \nDeductible allowance for education expenses \n118 \n \nPART X \nTAX CREDITS \n \n61. \nCharitable donations \n119 \n62. \nOmitted by the Finance Act, 2022. \n121 \n62A. \nOmitted by the Finance Act, 2022. \n122 \n63. \nContribution to an Approved Pension Fund. \n122 \n63A. \nTax credit for interest paid on low-cost housing loan. \n124 \n64. \nOmitted by Finance Act, 2015. \n125 \n64A \nSection re-numbered as 60C \n126 \n64AB \nSection re-numbered as 60D \n126 \n64B. \nTax credit for employment generation by manufacturers \n126 \n64C. \nOmitted by Finance Act, 2021 \n127 \n64D. \nTax credit for point of sale machine \n127 \n65. \nMiscellaneous provisions relating to tax credits \n128 \n65A. \nOmitted by the Finance Act, 2017 \n129 \n65B. \nTax credit for investment \n129 \n65C. \nOmitted by the Finance Act, 2021 \n131 \n65D. \nOmitted by the Finance Act, 2021 \n131 \n65E. \nTax credit for industrial undertakings established before the first \nday of July, 2011 \n132 \n\n\f\n65F. \nTax credit for certain persons \n134 \n65G. \nTax credit for specified industrial undertakings \n135 \n65H. \nOmitted by the Finance Act, 2022. \n136 \n \nCHAPTER-IV \nCOMMON RULES \n \n \n \nPART I \nGENERAL \n \n66. \nIncome of joint owners \n137 \n67. \nApportionment of deductions \n137 \n68. \nFair market value \n138 \n69. \nReceipt of income \n139 \n70. \nRecouped expenditure \n139 \n71. \nCurrency conversion \n139 \n72. \nCessation of source of income \n139 \n73. \nRules to prevent double derivation and double deductions  \n140 \n \nPART II \nTAX YEAR \n \n74. \nTax year  \n141 \n \nPART III \nASSETS \n \n75. \nDisposal and acquisition of assets \n143 \n75A. \nPurchase of assets through banking channel \n143 \n76. \nCost \n144 \n77. \nConsideration received \n146 \n78. \nNon-arm's length transactions \n146 \n79. \nNon-recognition rules \n147 \n \n \nCHAPTER V \nPROVISIONS GOVERNING PERSONS \nPART I \nCENTRAL CONCEPTS \nDivision I \nPersons \n \n80. \nPerson \n146 \n \nDivision II \nResident and Non-resident Persons \n \n81. \nResident and non-resident persons \n150 \n82. \nResident individual \n150 \n83. \nResident company \n151 \n84. \nResident association of persons \n151 \n \nDivision III \nAssociates \n \n85. \nAssociates \n151 \n \n \n \n \nPART II \nINDIVIDUALS \nDivision I \nTaxation of Individuals \n \n86. \nPrinciple of taxation of individuals \n154 \n87. \nDeceased individuals \n154 \n\n\f\n \nDivision II \nProvisions Relating to Averaging \n \n88. \nAn individual as a member of an association of persons \n155 \n88A. \nOmitted by Finance Act, 2014 \n155 \n89. \nAuthors \n155 \n \nDivision III \nIncome Splitting \n \n90. \nTransfers of assets \n156 \n91. \nIncome of a minor child \n157 \n \nPART III \nASSOCIATIONS OF PERSONS \n \n92. \nPrinciples of taxation of associations of persons \n158 \n93. \nOmitted by the Finance Act, 2007. \n159 \n \nPART IV \nCOMPANIES \n \n94. \nPrinciples of taxation of companies \n159 \n95. \nDisposal of business by individual to wholly-owned company \n160 \n96. \nDisposal of business by association of persons to wholly-owned \ncompany \n161 \n97. \nDisposal of asset between wholly-owned companies \n163 \n97A. \nDisposal of asset under a scheme of arrangement and \nreconstruction. \n164 \n \nPART V \nCOMMON PROVISIONS APPLICABLE TO ASSOCIATIONS \nOF PERSONS AND COMPANIES \n \n98. \nChange in control of an entity \n166 \n \nPART VA \nTAX LIABILITY IN CERTAIN CASES \n \n98A. \nChange in the constitution of an association of persons \n167 \n98B. \nDiscontinuance of business or dissolution of an association of \npersons \n167 \n98C. \nSuccession to business, otherwise than on death \n167 \n \nCHAPTER-VI \nSPECIAL INDUSTRIES \nPART I \nINSURANCE BUSINESS \n \n99. \nSpecial provisions relating to insurance business  \n169 \n99A. \nSpecial provisions relating to payment of tax through electricity \nconnections \n169 \n99B. \nSpecial procedure for small traders and shopkeepers \n171 \n99C. \nSpecial procedure for certain persons \n171 \n99D. \nAdditional tax on certain income, profits and gains.  \n171 \n \nPART II \nOIL, NATURAL GAS AND OTHER MINERAL DEPOSITS \n \n100. \nSpecial provisions relating to the production of oil and natural \ngas, and exploration and extraction of other mineral deposits \n173 \n100A. \nSpecial provisions relating to banking business. \n173 \n100B. \nSpecial provision relating to capital gain tax. \n174 \n100BA. \nSpecial provisions relating to persons not appearing in active \ntaxpayers’ list. \n174 \n100C. \nTax credit for certain persons \n175 \n100D. \nSpecial provisions relating to builders and developers \n179 \n\n\f\n100E. \nSpecial provisions relating to small and medium enterprises \n186 \n100F \nOmitted by the Finance Act, 2022 \n186 \n \nCHAPTER VII \nINTERNATIONAL \nPART I \nGEOGRAPHICAL SOURCE OF INCOME \n \n101. \nGeographical source of income \n187 \n101A \nGain on disposal of assets outside Pakistan \n194 \n \n \nPART II \nTAXATION OF FOREIGN-SOURCE INCOME OF RESIDENTS \n \n102. \nForeign source salary of resident individuals \n197 \n103. \nForeign tax credit \n197 \n104. \nForeign losses \n198 \n \nPART III \nTAXATION OF NON-RESIDENTS \n \n105. \nTaxation of a permanent establishment in Pakistan of a non-\nresident person \n199 \n106. \nThin capitalization \n200 \n106A. \nRestriction on deduction of profit on debt payable to associated \nenterprise \n202 \n \nPART IV \nAGREEMENTS FOR THE AVOIDANCE OF \nDOUBLE TAXATION AND \n PREVENTION OF FISCAL EVASION \n \n107. \nAgreements for the avoidance of double taxation and prevention \nof fiscal evasion \n205 \n \nCHAPTER VIII \nANTI-AVOIDANCE \n \n108. \nTransactions between associates \n207 \n108A. \nReport from independent chartered accountant or cost and \nmanagement accountant \n208 \n108B. \nTransactions under dealership arrangements \n208 \n109. \nRecharacterisation of income and deductions \n209 \n109A \nControlled foreign company. \n210 \n110. \nSalary paid by private companies \n212 \n111. \nUnexplained income or assets \n212 \n112. \nLiability in respect of certain security transactions \n215 \n \nCHAPTER IX \nMINIMUM TAX \n \n113. \nMinimum tax on the income of certain persons. \n214 \n113A. \nOmitted by the Finance Act, 2016 \n219 \n113B. \nOmitted by the Finance Act, 2016 \n220 \n113C. \nAlternative Corporate Tax \n220 \n \nCHAPTER X \nPROCEDURE \nPART I \nRETURNS \n \n114. \nReturn of income \n221 \n114A. \nBusiness bank account \n230 \n114B. \nPowers to enforce filing of returns. \n231 \n114C. \nRestriction on economic transactions by certain persons. \n231 \n115. \nPersons not required to furnish a return of income \n233 \n116. \nWealth statement \n235 \n116A \nForeign   income   and   assets   statement \n237 \n\n\f\n117. \nNotice of discontinued business \n237 \n118. \nMethod of furnishing returns and other documents \n236 \n119. \nExtension of time for furnishing returns and other documents \n240 \n \nPART II \nASSESSMENTS \n \n120. \nAssessments \n       242 \n120A. \n \nOmitted by Finance Act, 2013 \n245 \n120B. \n \nRestriction of proceedings \n245 \n121. \nBest judgment assessment \n245 \n122. \nAmendment of assessments \n247 \n122A. \nRevision by the Commissioner \n251 \n122B. \nRevision by the Chief Commissioner \n252 \n122C. \nOmitted by the Finance Act, 2017 \n252 \n122D. \nAgreed assessment in certain cases \n253 \n123. \nProvisional assessment in certain cases \n254 \n124. \nAssessment giving effect to an order \n254 \n124A. \nPowers of tax authorities to modify orders, etc. \n257 \n125. \nAssessment in relation to disputed property \n257 \n126. \nEvidence of assessment \n257 \n \nPART III \nAPPEALS \n \n126A. \nOmitted by the Finance Act, 2025 \n258 \n127. \nAppeal to the Commissioner (Appeals) \n258 \n128. \nProcedure in appeal \n261 \n129. \nDecision in appeal \n261 \n130. \nAppellate Tribunal \n263 \n131. \nAppeal to the Appellate Tribunal  \n267 \n132. \nDisposal of appeals by the Appellate Tribunal \n268 \n133. \nReference to High Court \n272 \n134. \nOmitted by Finance Act, 2005 \n275 \n134A. \nAlternative Dispute Resolution \n277 \n135. \nOmitted by the Finance Ordinance, 2002 \n281 \n136. \nBurden of proof \n282 \n \nPART IV \nCOLLECTION AND RECOVERY OF TAX \n \n137. \nDue date for payment of tax \n283 \n138. \nRecovery of tax out of property and through arrest of taxpayer \n284 \n138A. \nRecovery of tax by District Officer (Revenue) \n286 \n138B. \nEstate in bankruptcy \n286 \n139. \nCollection of tax in the case of private companies and \nassociations  of persons \n286 \n140. \nRecovery of tax from persons holding money on behalf of a \ntaxpayer \n287 \n141. \nLiquidators \n289 \n142. \nRecovery of tax due by non-resident member of an association \nof persons \n290 \n143. \nNon-resident ship owner or charterer \n290 \n144. \nNon-resident aircraft owner or charterer \n291 \n145. \nAssessment of persons about to leave Pakistan  \n292 \n146. \nRecovery of tax from persons assessed in Azad Jammu and \nKashmir \n293 \n146A. \nInitiation, validity, etc., of recovery proceedings. \n293 \n146B. \nTax arrears settlement incentives scheme \n294 \n146C. \nAssistance in the recovery and collection of taxes \n294 \n146D. \nRecovery of liability outstanding under other laws.  \n294 \n \nPART V \n \n\n\f\nADVANCE TAX AND DEDUCTION OF TAX AT SOURCE \nDivision I \nAdvance Tax Paid by the Taxpayer \n147. \nAdvance tax paid by the taxpayer \n296 \n147A. \nAdvance tax from provincial sales tax registered person \n303 \n \nDivision II \nAdvance Tax Paid to a Collection Agent \n \n \n148. \nImports \n304 \n148A. \nomitted through Finance Act, 2020 dated 30th June, 2020 \n308 \n \nDivision III \nDeduction of Tax at Source \n \n149. \nSalary \n308 \n150. \nDividends \n310 \n150A \nomitted by the Finance Act, 2021 \n310 \n151. \nProfit on debt \n310 \n151A. \nGain arising on disposal of certain debt securities. \n311 \n152. \nPayments to non-residents \n312 \n152A. \nOmitted by the Finance Act, 2021 \n320 \n153. \nPayments for goods, services and contracts \n320 \n153A. \nOmitted by Finance Act, 2013 \n328 \n153B. \nOmitted by Finance Act, 2021 \n328 \n154. \nExports \n328 \n154A. \nExport of Services \n330 \n155. \nRent of immoveable property \n331 \n156. \nPrizes and winnings \n332 \n156A. \nPetroleum products \n333 \n156B. \nOmitted by Finance Act, 2020 \n333 \n157. \nOmitted by the Finance Ordinance, 2002 \n334 \n158. \nTime of deduction of tax \n334 \n \nDivision IV \nGeneral Provisions Relating to the Advance Payment of Tax \nor the Deduction of Tax at Source \n \n159. \nExemption or lower rate certificate \n335 \n160. \nPayment of tax collected or deducted \n337 \n161. \nFailure to pay tax collected or deducted \n337 \n162. \nRecovery of tax from the person from whom tax was not \ncollected or deducted \n338 \n \n163. \nRecovery of amounts payable under this Division \n339 \n164. \nCertificate of collection or deduction of tax \n339 \n164A. \nSettlement of transactions liable to Withholding Tax by SWAPS \nagents \n339 \n165. \nStatements \n340 \n165A. \nFurnishing of information by banks \n344 \n165B. \nFurnishing of information by financial institutions \nincluding banks \n345 \n165C. \nFurnishing of information by online marketplace, payment \nintermediary and courier service. \n346 \n166. \nPriority of tax collected or deducted \n346 \n167. \nIndemnity \n347 \n168. \nCredit for tax collected or deducted \n347 \n169. \nTax collected or deducted as a final tax \n350 \n \nPART VI \nREFUNDS \n \n\n\f\n170. \nRefunds \n354 \n170A. \nElectronic processing and electronic issuance of Refunds by the \nBoard \n355 \n171. \nAdditional payment for delayed refunds  \n355 \n171A. \nPayment of refund through income tax refund bonds.- \n356 \n \nPART VII \nREPRESENTATIVES \n \n172. \nRepresentatives \n358 \n173. \nLiability and obligations of representatives \n360 \n \nPART VIII \nRECORDS, INFORMATION COLLECTION AND AUDIT \n \n174. \nRecords \n361 \n175. \nPower to enter and search premises \n362 \n175A. \nReal-time access to information and databases \n363 \n175AA. \nExchange of banking and tax information related to high-risk \npersons. \n364 \n175B. \nNational Database and Registration Authority (NADRA) \n365 \n175C. \nPosting of officer of Inland Revenue. \n366 \n176. \nNotice to obtain information or evidence \n366 \n177. \nAudit \n369 \n178. \nAssistance to Commissioner \n374 \n179. \nAccounts, documents, records and computer-stored information \nnot in Urdu  or English language \n374 \n180. \nPower to collect information regarding exempt income \n374 \n \nPART IX \nTAXPAYER’S REGISTRATION  \n \n181. \nTaxpayer’s Registration \n375 \n181A. \nActive taxpayers’ list \n376 \n181AA. \nCompulsory registration in certain cases \n376 \n181B. \nTaxpayer card \n376 \n181C. \nDisplaying of National Tax Number \n376 \n181D. \nBusiness licence scheme \n376 \n181E. \nRecord of beneficial owners. \n377 \n \n \nPART X \nPENALTY \n \n182. \nOffences and penalties \n378 \n182A \nReturn not filed within due date. \n395 \n183. \nExemption from penalty and default surcharge \n396 \n184. \nOmitted by the Finance Act, 2010. \n397 \n185. \nOmitted by the Finance Act, 2010. \n397 \n186. \nOmitted by the Finance Act, 2010. \n397 \n187. \nOmitted by the Finance Act, 2010. \n397 \n188. \nOmitted by the Finance Act, 2010. \n398 \n189. \nOmitted by the Finance Act, 2010. \n398 \n190. \nOmitted by the Finance Act, 2010. \n398 \n \nPART XI \nOFFENCES AND PROSECUTIONS \n \n191. \nProsecution for non-compliance with certain statutory obligations \n398 \n191A. \nProsecution for failure to furnish information in return of income. \n400 \n191B. \nProsecution for non-registration \n400 \n192. \nProsecution for false statement in verification \n400 \n\n\f\n192A. \nProsecution for concealment of income. \n400 \n192B \nProsecution for concealment of and offshore assets \n401 \n193. \nProsecution for failure to maintain records \n401 \n194. \nProsecution for improper use of National Tax Number Certificate \n401 \n195. \nProsecution for making false or misleading statements \n401 \n195A. \nProsecution for non-compliance with notice under section \n116A.— \n402 \n195B. \nProsecution for enabling offshore tax evasion \n402 \n196. \nProsecution for obstructing an income tax authority \n402 \n197. \nProsecution for disposal of property to prevent attachment \n402 \n198. \nProsecution for unauthorised disclosure of information by a \npublic servant \n403 \n199. \nProsecution for abetment \n403 \n200. \nOffences by companies and associations of persons \n403 \n201. \nInstitution of prosecution proceedings without prejudice to other \naction \n403 \n202. \nPower to compound offences \n404 \n203. \nTrial by Special Judge \n404 \n203A. \nAppeal against the order of a Special Judge \n405 \n203B. \nPower to arrest and prosecute \n405 \n203C. \nProcedure to be followed on arrest of a person \n406 \n203D. \nSpecial Judges \n408 \n203E. \nCognizance of offences by Special Judges \n408 \n203F. \nSpecial Judge, etc. to have exclusive jurisdiction \n409 \n203G. \nProvisions of Code of Criminal Procedure, 1898, to apply \n410 \n203H. \nTransfer of cases \n410 \n203I. \nPlace of sittings \n410 \n204. \nPower to tender immunity from prosecution \n410 \n \nPART XII \nDEFAULT SURCHARGE \n \n205. \nDefault surcharge \n411 \n205A. \nReduction in default surcharge, consequential to reduction in tax \nor penalty \n415 \n \nPART XIII \nCIRCULARS \n \n206. \nCirculars \n415 \n206A. \nAdvance ruling \n416 \n \nCHAPTER XI \nADMINISTRATION \nPART I \nGENERAL \n \n207. \nIncome tax authorities \n404 \n208. \nAppointment of income tax authorities \n419 \n209. \nJurisdiction of income tax authorities \n420 \n209A. \nUniform \n422 \n210. \nDelegation \n423 \n211. \nPower or function exercised \n424 \n212. \nAuthority of approval \n424 \n213. \nGuidance to income tax authorities \n425 \n214. \nIncome tax authorities to follow orders of the Board  \n425 \n214A. \nCondonation of time limit \n425 \n214B. \nPower of the Board to call for records \n426 \n214C. \nSelection for audit by the Board \n426 \n214D. \nOmitted by the Finance Act, 2018 \n427 \n214E. \nInserted by the Finance Supplementary (Amendment) Act, 2018 \n427 \n215. \nFurnishing of returns, documents etc. \n428 \n\n\f\n216. \nDisclosure of information by a public servant \n429 \n216A. \nOmitted by the Finance Act, 2022 \n434 \n217. \nForms and notices; authentication of documents \n435 \n218. \nService of notices and other documents \n435 \n219. \nTax or refund to be computed to the nearest Rupee \n436 \n220. \nReceipts for amounts paid \n436 \n221. \nRectification of mistakes \n437 \n222. \nAppointment of expert \n437 \n222A. \nFee and service charges \n438 \n223. \nAppearance by authorized representative \n438 \n224. \nProceedings under the Ordinance to be judicial proceedings \n440 \n225. \nProceedings against companies under liquidation \n441 \n226. \nComputation of limitation period \n441 \n227. \nBar of suits in Civil Courts \n441 \n227A. \nReward to officers and officials of Inland Revenue \n442 \n227B. \nReward of whistleblowers \n442 \n227BA. \nReward and benefits for certain persons \n443 \n227C \nomitted through Finance Act 2019 \n443 \n227D \nAutomated impersonal tax regime \n444 \n227E \nE-hearing \n444 \n \nPART II \nDIRECTORATES-GENERAL  \n \n228. \nThe Directorate-General of Internal Audit \n444 \n229. \nDirectorate General of Training and Research \n445 \n230. \nDirectorate General (Intelligence and Investigation), Inland \nRevenue \n445 \n \nPART III \nDIRECTORATES-GENERAL  \n \n230A. \nDirectorate-General of Withholding Taxes \n446 \n230B. \nDirectorate-General of Law \n446 \n230C. \nDirectorate-General of Research and Development \n446 \n230D. \nDirectorate-General of Broadening of Tax Base   \n446 \n230E. \nDirectorate-General of Transfer Pricing   \n447 \n230F. \nDirectorate-General of Immovable Property. \n448 \n230G. \nDirectorate General of Special Initiative \n451 \n230H. \nDirectorate General of Valuation \n452 \n230I. \nDirectorate General of Compliance Risk Management \n452 \n230J. \nInternational Centre of Tax Excellence \n452 \n230K. \nTax Fraud Investigation Wing Inland Revenue \n454 \n231. \nOmitted by Finance Act, 2005 \n455 \n \n \nCHAPTER XII \nTRANSITIONAL ADVANCE TAX PROVISIONS \n \n231A. \nOmitted by the Finance Act, 2021 \n456 \n231AA. \nOmitted by the Finance Act, 2021 \n456 \n231AB. \nAdvance tax on cash withdrawal \n456 \n231B. \nAdvance tax on private motor vehicles \n457 \n231C. \nAdvance tax on foreign domestic workers \n459 \n232. \nOmitted by the Finance Ordinance, 2002 \n459 \n233. \nBrokerage and Commission \n460 \n233A. \nOmitted by the Finance Act, 2021 \n461 \n233AA. \nOmitted by the Finance Act, 2021 \n461 \n234. \nTax on motor vehicles \n462 \n234A. \nomitted by the Finance Act, 2021 \n462 \n235. \nElectricity Consumption \n463 \n\n\f\n235A. \nomitted by the Finance Act, 2021 \n464 \n235B. \nomitted through Finance Act, 2020 dated 30th June, 2020 \n464 \n236. \nTelephone and internet users \n465 \n236A. \nAdvance tax at the time of sale by auction \n466 \n236B. \nOmitted by the Finance Act, 2021 \n467 \n236C. \nAdvance Tax on sale or transfer of immovable Property \n467 \n236CA. \nAdvance Tax on TV plays and advertisements \n469 \n236CB. \nAdvance tax on functions and gatherings \n470 \n236D. \nOmitted by the Finance Act, 2020  \n470 \n236E \nOmitted by the Finance Act, 2016 \n470 \n236F. \nOmitted through Finance Act, 2020  \n470 \n236G. \nAdvance tax on sales to distributors, dealers and wholesalers \n471 \n236H. \nAdvance tax on sales to retailers \n471 \n236HA \nOmitted by the Finance Act, 2021 \n471 \n236I. \nOmitted by the Finance Act, 2022 \n472 \n236J. \nOmitted through Finance Act, 2020  \n472 \n236K. \nAdvance tax on purchase or transfer of immovable property \n472 \n236L. \nOmitted by the Finance Act, 2021 \n474 \n236M. \nOmitted by the Finance Act, 2018 \n474 \n236N. \nOmitted by the Finance Act, 2018 \n474 \n236O. \nAdvance tax under this chapter \n475 \n236P. \nomitted by the Finance Act, 2021 \n475 \n236Q. \nOmitted by the Finance Act, 2022 \n475 \n236R. \nOmitted through Finance Act, 2020  \n476 \n236S. \nomitted by the Finance Act, 2021 \n476 \n236T. \nOmitted by the Finance Act, 2016 \n476 \n236U. \nomitted through Finance Act, 2020 dated 30th June, 2020 \n477 \n236V. \nOmitted by the Finance Act, 2021 \n477 \n236W. \nOmitted through Finance Act, 2019 \n477 \n236X. \nomitted through Finance Act, 2020 dated 30th June, 2020 \n477 \n236Y \nOmitted by the Finance Act, 2021 \n477 \n236Y. \nAdvance tax on persons remitting amounts abroad through \ncredit or debit or prepaid cards \n478 \n236Z. \nBonus shares issued by companies. \n478 \n \nCHAPTER XIII \n    MISCELLANEOUS \n \n237. \nPower to make rules \n480 \n237A. \nElectronic record \n481 \n237B. \nPrize schemes to promote tax culture \n481 \n238. \nRepeal \n481 \n239. \nSavings \n482 \n239A. \nTransition to Federal Board of Revenue. \n485 \n239B. \nReference to authorities \n485 \n240. \nRemoval of difficulties \n486 \n241. \nValidation \n486 \n242. \nBenefits of repealed provisions \n486 \n \nFIRST SCHEDULE \nPART I \nRATES OF TAX \n488 \n \nDivision I \n \n488 \n \nRates of Tax for Individuals \n488 \n \nRates of Tax for Association of Persons \n488 \n \nDivision IA \n493 \n\n\f\n(Omitted by the Finance Act, 2013) \n \nDivision IB \n(Omitted by the Finance Act, 2012) \n494 \n \nDivision II \nRates of Tax for Companies \n494 \n \nDivision IIA \nRates of Super Tax  \n495 \n \nDivision IIB \nSuper Tax on high earning persons \n496 \n \nDivision III \nRate of Dividend Tax \n498 \n \nDivision IIIA \nRate for Profit on Debt \n500 \n \nDivision IIIB \nRate of Tax on Return on investment in \nSukuks received from a special \npurpose vehicle \n501 \n \nDivision IV \nRate of Tax on Certain Payments to Non-residents \n501 \n \nDivision IVA \nRate of Tax on Payments for Digital Transactions in  \nE-commerce Platforms \n501 \n \nDivision V \nRate of Tax on Shipping or Air Transport Income of a Non-\nresident Person \n502 \n \nDivision VI \n(Omitted by the Finance Act, 2013) \n502 \n \nDivision VIA \nIncome from Property \n(Omitted by the Finance Act, 2021) \n503 \n \nDivision VII \nCapital Gains on disposal of Securities \n506 \n \nDivision VIII \nCapital Gains on Disposal of Immovable Property \n510 \n \nDivision VIIIA \n Tax on Builders \n511 \n \nDivision VIIIB \n Tax on Developers \n512 \n \nDivision VIIIC \nTax on deemed income \n512 \n \nDivision IX \n512 \n\n\f\n Minimum tax under section 113 \n \nPART II \nRates of Advance Tax \n514 \n \n \n \nPART IIA \nCollection of Tax from Distributors, Dealers, And \nWholesalers \nOmitted by the Finance Act, 2014 \n517 \n \nPart IIB  \nRates of Advance Tax \n518 \n \nPART III \nDEDUCTION OF TAX AT SOURCE \n \n519 \n \nDivision I \nAdvance Tax on Dividend \n519 \n \nDivision IA \nProfit on Debt \n521 \n \nDivision IB \nReturn on Investment in Sukuks \n522 \n \nDivision II \nPayments to non-residents \n522 \n \nDivision III \nPayments for Goods or Services \n524 \n \nDivision III A \n(Omitted by the Finance Act, 2012) \n528 \n \nDivision IIIAA \nGain arising on disposal of certain debt securities  \n528 \n \nDivision III B \n(Omitted by the Finance Act, 2012) \n529 \n \nDivision IV \nExports \n529 \n \nDivision IVA \nExports of Services \n529 \n \nDivision V \nIncome from Property \n530 \n \nDivision VI \nPrizes and Winnings \n531 \n \nDivision VIA \nPetroleum Products \n532 \n \nDivision VIB \nOmitted by the Finance Act, 2021 \n532 \n \nDivision VII \nOmitted by the Finance Act, 2002 \n532 \n\n\f\n \nPART IV \nDEDUCTION OR COLLECTION OF  \nADVANCE TAX \n533 \n \nDivision I \nOmitted by the Finance Act, 2002 \n533 \n \nDivision II \nBrokerage and Commission \n533 \n \nDivision IIA \nOmitted by the Finance Act, 2021 \n533 \n \nDivision IIB \nOmitted by the Finance Act, 2021 \n534 \n \nDivision III \nTax on motor vehicles \n534 \n \nDivision IV \nElectricity Consumption \n536 \n \nDivision V \nTelephone users \n538 \n \nDivision VI \nomitted by the Finance Act, 2021 \n540 \n \nDivision VIA \nomitted by the Finance Act, 2021 \n540 \n \nDivision VII \nAdvance tax on Purchase, Registration and Transfer Motor \nVehicles \n540 \n \nDivision VIII \nAdvance tax at the time of sale by auction \n543 \n \nDivision IX \nomitted by the Finance Act, 2021 \n543 \n \nDivision X \nAdvance tax on sale or transfer of \nImmovable property \n543 \n \nDivision XA  \nAdvance tax on TV plays and advertisements \n544 \n \nDivision XI \nOmitted through Finance Act, 2020 dated 30th June, 2020 \n545 \n \nDivision XII \nOmitted by the Finance Act, 2016 \n545 \n \nDivision XIII \nOmitted through Finance Act, 2020 dated 30th June, 2020 \n546 \n \nDivision XIV \nAdvance tax on sale to distributors, dealers or wholesalers \n546 \n \nDivision XV \nAdvance tax on sale to retailers \n548 \n \nDivision XVA \nOmitted by the Finance Act, 2021 \n548 \n\n\f\n \nDivision XVI \nOmitted by the Finance Act, 2022 \n548 \n \nDivision XVII \nOmitted through Finance Act, 2020 dated 30th June, 2020 \n548 \n \nDivision XVIII \nAdvance Tax on purchase of immoveable property \n549 \n \nDivision XIX \nOmitted by the Finance Act, 2021 \n553 \n \nDivision XX \nOmitted by the Finance Act, 2021 \n553 \n \nDivision XXI \nOmitted by the Finance Act, 2021 \n553 \n \nDivision XXII \nOmitted by the Finance Act, 2016 \n553 \n \nDivision XXIII \nOmitted by the Finance Act, 2022 \n554 \n \nDivision XXIV \nomitted through Finance Act, 2020 dated 30th June, 2020 \n554 \n \nDivision XXV \nOmitted through Finance Act, 2020 dated 30th June, 2020 \n554 \n \nDivision XXVI \nOmitted by the Finance Act, 2021 \n554 \n \nDivision XXVII \nAdvance tax on amount remitted abroad through credit, \ndebit or prepaid cards  \n554 \n \nDivision XXVII \nOmitted by the Finance Act, 2021 \n554 \n \nDivision XXVII \nAdvance tax on amount remitted abroad through credit, \ndebit or prepaid cards  \n554 \n \nTHE SECOND SCHEDULE \n \nEXEMPTIONS AND TAX CONCESSIONS \n555 \n \nPART I \nEXEMPTIONS FROM TOTAL INCOME \n555 \n \nPART II \nREDUCTION IN TAX RATES \n609 \n \nPART III \nREDUCTION IN TAX LIABILITY \n624 \n \nPART IV \nEXEMPTION FROM SPECIFIC PROVISIONS \n631 \n \nTHE THIRD SCHEDULE \n700 \n\n\f\n \nPART I \nDEPRECIATION \n700 \n \nPART II \nINITIAL ALLOWANCE AND FIRST YEAR ALLOWANCE \n702 \n \nPART III \nPRE-COMMENCEMENT EXPENDITURE \n702 \n \nTHE FOURTH SCHEDULE \nRULES FOR THE COMPUTATION OF THE PROFITS AND \nGAINS OF INSURANCE BUSINESS \n703 \n     THE FIFTH SCHEDULE                                                                      708 \n \nPART I \nRULES FOR THE COMPUTATION OF THE PROFITS AND \nGAINS FROM THE EXPLORATION AND PRODUCTION OF \nPETROLEUM \n708 \n \nPART II \nRULES FOR THE COMPUTATION OF THE PROFITS AND \nGAINS FROM THE EXPLORATION AND EXTRACTION OF \nMINERALS DEPOSITS (OTHER THAN PETROLEUM) \n714 \nTHE SIXTH SCHEDULE                                                                    717 \n \nPART I \nRECOGNIZED PROVIDENT FUNDS \n717 \n \nPART II \nAPPROVED SUPERANNUATION FUNDS \n726 \n \nPART III \nAPPROVED GRATUITY FUNDS \n730 \nTHE SEVENTH SCHEDULE                                                              733 \n \nRULES FOR THE  \nCOMPUTATION OF THE PROFITS AND GAINS OF A \nBANKING COMPANY AND TAX PAYABLE THEREON \n \n733 \nTHE EIGHTH SCHEDULE                                                                      753 \n \nRULES FOR THE COMPUTATION OF CAPITAL GAINS ON \nLISTED SECURITIES \n753 \n \n \nTHE NINTH SCHEDULE                                                                       757 \n \nPART I \nRULES FOR THE COMPUTATION OF THE PAYABLE ON \nPROFITS AND GAINS OF A TRADER FALLING UNDER SUB-\nSECTION (1) OF SECTION 99A \n757 \n \nPART II \nRULES FOR THE COMPUTATION OF THE PAYABLE ON \nPROFITS AND GAINS OF A TRADER FALLING UNDER SUB-\nSECTION (2) OF SECTION 99A \n758 \n\n\f\n \nPART III \nGENERAL PROVISIONS FOR THE TRADERS UNDER PART I \nAND PART II \n758 \n \n \nTHE TENTH SCHEDULE \nRULES FOR PERSONS NOT APPEARING IN THE ACTIVE \nTAXPAYERS’ LIST \n763 \n \nELEVENTH SCHEDULE \nRULES FOR COMPUTATION OF PROFITS AND GAINS OF \nBUILDERS AND DEVELOPERS AND TAX PAYABLE \nTHEREON \n771 \n \nTHE TWELFTH SCHEDULE \n777 \n \nTHE THIRTEENTH SCHEDULE \n797 \n \nFOURTEENTH SCHEDULE \nRULES FOR COMPUTATION OF PROFIT AND GAINS FOR \nSMALL AND MEDIUM ENTERPRISES \n800 \n \nFIFTEENTH SCHEDULE \n \n \nTHRESHOLD FOR ECONOMIC TRANSACTIONS \n802 \n  \n\n\f\nChapter I – Preliminary__________________________________ \n \n1 \n \nF.No.2(1)/2001—Pub.— The following Ordinance promulgated by the President is \nhereby  published for general information:— \n \nAN \n \nORDINANCE \n \nTo consolidate and amend the law relating to income tax \n \n \nWHEREAS it is expedient to consolidate and amend the law relating to \nincome tax and to provide for matters ancillary thereto or connected therewith; \n \n \nWHEREAS the President is satisfied that circumstances exist which render \nit necessary to take immediate action; \n \n \nNOW, THEREFORE, in pursuance of the Proclamation of Emergency of the \nfourteenth day of October, 1999, and the Provisional Constitution Order No. 1 of \n1999, read with Provisional Constitutional Amendment Order No. 9 of 1999, and \nin exercise of all powers enabling him in that behalf, the President of the Islamic \nRepublic of Pakistan is pleased to make and promulgate the following \nOrdinance:— \n \nCHAPTER I \nPRELIMINARY \n \n1. \nShort title, extent and commencement.—(1) This Ordinance may be \ncalled the Income Tax Ordinance, 2001. \n \n(2) \nIt extends to the whole of Pakistan. \n \n(3) \nIt shall come into force on such date as the Federal Government may, \nby notification in official Gazette, appoint. \n \n2. \nDefinitions. — In this Ordinance, unless there is anything repugnant in the \nsubject or context — \n \n(1) \n\"accumulated profits\" in relation to 1[distribution or payment of] a \ndividend, 2[include] — \n \n                                            \n*Vide notification S.R.O.381(I)/2002 dated 15.06.2002 the Federal Government appointed the first  day \nof July, 2002 on which the Ordinance shall come into force.  \n1 Inserted by the Finance Act, 2003. \n2 The word “includes” substituted by the Finance Act, 2005. \n\n\f\nChapter I – Preliminary__________________________________ \n \n2 \n \n(a) \nany reserve made up wholly or partly of any allowance, \ndeduction, or exemption admissible under this Ordinance;-\n.9230 \n \n(b) \nfor the purposes of 1[sub-clauses (a), (b) and (e) of clause (19)”] \nall profits of the company including income and gains of a trust \nup to the date of such distribution or such payment, as the case \nmay be; and \n \n(c) \nfor the purposes of 2[sub-clause (c) of clause (19)], includes all \nprofits of the company including income and gains of a trust up \nto the date of its liquidation; \n \n3[(1A) \n“active taxpayer’ list” means the list instituted by the Board under \nSection 181A and includes such list issued by the Azad Jammu and Kashmir \nCentral Board of Revenue or Gilgit-Baltistan Council Board of Revenue;] \n    \n4[5(1B) “amalgamation” means the merger of one or more banking companies \nor non-banking financial institutions, 6[or insurance companies,] 7[or \ncompanies owning and managing industrial undertakings] \n8[or \ncompanies engaged in providing services and not being a trading \ncompany or companies] in either case 9[at least one of them] being a \npublic company, or a company incorporated under any law, other than \n10[Companies Act, 2017 (XIX of 2017)], for the time being in force, (the \ncompany or companies which so merge being referred to as the \n“amalgamating company” or companies and the company with which \nthey merge or which is formed as a result of merger, as the \n“amalgamated company”) in such manner that – \n \n(a) \nthe assets of the amalgamating company or companies \nimmediately before the amalgamation become the assets of the \namalgamated company by virtue of the amalgamation, \notherwise than by purchase of such assets by the amalgamated \n                                            \n1 Clauses (a), (d) and (e) of sub-section (20) substituted by the Finance Act, 2002. \n2 Clause (c) of sub-section (20) substituted by the Finance Act, 2002. \n3 Clause 1A inserted through Finance Act, 2019. \n4 Inserted by the Finance Act, 2002. \n51A renumbered by 1B by the Finance Act, 2019. \n6 Inserted by the Finance Act, 2004. \n7 Inserted by the Finance Act, 2005. \n8Inserted by the Finance Act, 2007. \n9 Inserted by the Finance Act, 2005. \n10 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n\n\f\nChapter I – Preliminary__________________________________ \n \n3 \n \ncompany or as a result of distribution of such assets to the \namalgamated \ncompany \nafter \nthe \nwinding \nup \nof \nthe \namalgamating company or companies; 1[and] \n \n(b) \nthe liabilities of the amalgamating company or companies \nimmediately before the amalgamation become the liabilities of \nthe amalgamated company by virtue of the amalgamation 2[.]  \n \n \n \n3[  ] \n \n4[(2)  “Appellate Tribunal” means the Appellate Tribunal Inland Revenue \nestablished under section 130;] \n \n(3) \n“approved gratuity fund” means a gratuity fund approved by the \nCommissioner in accordance with Part III of the Sixth Schedule; \n \n5[(3A)  \n“Approved Annuity Plan” means an Annuity Plan approved by \nSecurities and Exchange Commission of Pakistan (SECP) under \nVoluntary Pension System Rules, 2005 and offered by a Life \nInsurance Company registered with the SECP under Insurance \nOrdinance, 2000 (XXXIX of 2000);] \n \n6[(3B)  \n“Approved Income Payment Plan” means an Income Payment Plan \napproved by Securities and Exchange Commission of Pakistan \n(SECP) under Voluntary Pension System Rules, 2005 and offered by \na Pension Fund Manager registered with the SECP under Voluntary \nPension System Rules, 2005;] \n \n7[(3C)  \n“Approved Pension Fund” means Pension Fund approved by \nSecurities and Exchange Commission of Pakistan (SECP) under \nVoluntary Pension System Rules, 2005, and managed by a Pension \n                                            \n1 Added by the Finance Act, 2005. \n2 The semi-colon and word “and” substituted by the Finance Act, 2005. \n3 Clause (c) omitted by the Finance Act, 2005. The omitted clause (c) read as follows: - \n“(c) the scheme of amalgamation is approved by the State Bank of Pakistan or by the Securities \nand Exchange Commission of Pakistan on or before thirtieth day of June, 2006;” \n4 Substituted by the Finance Act, 2010. The substituted provision has been made effective from \n05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \nmade through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. Clause (2) before substitution \nby the Finance (Amendment) Ordinance, 2009 read as follows: \n“(2) “Appellate Tribunal” means the Appellate Tribunal Inland Revenue established under section \n130;”.  \n5 Inserted by the Finance Act, 2005. \n6 Inserted by the Finance Act, 2005. \n7 Inserted by the Finance Act, 2005. \n\n\f\nChapter I – Preliminary__________________________________ \n \n4 \n \nFund Manager registered with the SECP under Voluntary Pension \nSystem Rules, 2005;] \n \n1[(3D)  \n“Approved Employment Pension or Annuity Scheme” means any \nemployment related retirement scheme approved under this \nOrdinance, which makes periodical payment to a beneficiary i.e. \npension or annuity such as approved superannuation fund, public \nsector pension scheme and Employees Old-Age Benefit Scheme;] \n \n2[(3E)  \n“Approved Occupational Savings Scheme” means any approved \ngratuity fund or recognized provident fund;]  \n \n(4) \n“approved superannuation fund” means a superannuation fund, or any \npart of a superannuation fund, approved by the Commissioner in \naccordance with Part II of the Sixth Schedule; \n \n3[(5)  \n“assessment” includes 4[provisional assessment,] re-assessment and \namended assessment and the cognate expressions shall be \nconstrued accordingly;] \n \n5[(5A)  \n“assessment year” means assessment year as defined in the repealed \nOrdinance;] \n \n6[(5B) \n“asset management company” means an asset management \ncompany as defined in the Non-Banking Finance Companies and \nNotified Entities Regulations, 2007;] \n \n7[(5C) \n“assets move” means the transfer of an offshore asset to an \nunspecified jurisdiction by or on behalf of a person who owns, \n                                            \n1Inserted by the Finance Act, 2006. \n2Inserted by the Finance Act, 2006 \n3 Clause (5) substituted by the Finance Act, 2002. The substituted clause read as follows: \n“(5) \n“assessment” means – \n(a) \nan assessment referred to in section 120; \n(b) \nan assessment raised under section 121; \n(c) \nan amended assessment under section 122; \n(d) \na demand for an amount due under sections 141, 142, 143 and 144; or  \n(e) \nan assessment of penalty under section 190;”.  \n4Inserted by the Finance Act, 2011. \n5Inserted by the Finance Act, 2002  \n6Clause (5B) substituted by the Finance Act, 2008. The substituted clause (5B) read as follows: \n“(5B) “assets management company” means a company registered under the Assets Management \ncompanies Rules, 1995;” \n7 Clause (5C) inserted by Finance Act, 2019 \n\n\f\nChapter I – Preliminary__________________________________ \n \n5 \n \npossesses, controls or is the beneficial owner of such offshore assets \nfor the purpose of tax evasion;] \n \n(6) \n“association of persons” means an association of persons as defined \nin section 80; \n \n(7) \n“banking company” means a banking company as defined in the \nBanking Companies Ordinance, 1962 (LVII of 1962) 1[  ]; \n \n2[(7A) “beneficial owner” means a natural person who – \n(a) ultimately owns or controls a Company or association of persons, \nwhether directly or indirectly, through at least twenty five percent \nshares or voting rights; or  \n \n(b) exercise ultimate effective control, through direct or indirect \nmeans, over the company or association of persons including \ncontrol over the finances or decisions or other affairs of the \ncompany or association of persons;] \n \n3[(8) \n“Board” means the Central Board of Revenue established under the \nCentral Board of Revenue Act, 1924 (IV of 1924), and on the \ncommencement of Federal Board of Revenue Act, 2007, the Federal \nBoard of Revenue established under section 3 thereof 4[and includes \na Member of the Federal Board of Revenue to whom powers of the \nBoard have been delegated under section 8 of the Federal Board of \nRevenue Act, 2007;]; \n \n(9) \n“bonus shares” includes bonus units in a unit trust; \n \n(10) “business” includes any trade, commerce, manufacture, profession, \nvocation or adventure or concern in the nature of trade, commerce, \nmanufacture, profession or vocation, but does not include employment; \n \n5[(10A) “business bank account” means a bank account utilized by the taxpayer  \nfor business transaction declared to the Commissioner through original \nor modified registration form prescribed under section 181;] \n \n(11)] \n“capital asset” means a capital asset as defined in section 37; \n \n                                            \n1 Expression “and includes anybody corporate which transacts the business of banking in Pakistan” \nomitted by the Finance Act, 2025. \n2 Clause (7A) Inserted by the Finance Act, 2022. \n3Clauses (8), (9), (10) and (11) re-numbered as clauses (9), (10), (11) and (8) respectively by the \nFinance Act, 2014. \n4 Expression inserted by the Finance Act, 2024. \n5 Clause (10A) inserted by the Finance Act, 2021. \n\n\f\nChapter I – Preliminary__________________________________ \n \n6 \n \n1[(11A) \n“charitable purpose” includes relief of the poor, education, medical relief \nand the advancement of any other object of general public utility;] \n \n \n2[(11B) “Chief Commissioner” means a person appointed as Chief                    \nCommissioner Inland Revenue under section 208 and includes a \n3[Chief Investigator,] Regional Commissioner of Income Tax and a \nDirector-General of Income Tax and Sales Tax;] \n \n4[(11C) “Collective Investment Scheme” shall have the same meanings as are \nassigned under the Non-Banking Finance Companies (Establishment \nand Regulation) Rules, 2003;] \n \n(12) \n“company” means a company as defined in section 80; \n \n5[(13) \n “Commissioner” means a person appointed as Commissioner Inland \nRevenue under section 208 and includes any other authority vested with \nall or any of the powers and functions of the Commissioner;] \n \n6[(13A)  \n“Commissioner (Appeals)” means a person appointed as Commissioner \nInland Revenue (Appeals) under section 208;] \n \n 7[(13AA) concealment of income includes –  \n \n                                            \n1Inserted by the Finance Act, 2002. \n2 Substituted by the Finance Act, 2010. The substituted provision has been made effective from \n05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \nmade through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. The substituted clause (11B) \nread as follows: \n“(11B) “Chief Commissioner” means a person appointed as Chief Commissioner Inland  \nRevenue under section 208 and includes a Regional Commissioner of Income Tax and \na Director-General of Income Tax and Sales Tax.” \n3 Expression inserted by the Finance Act, 2024. \n4Inserted by the Finance Act, 2011. \n5Substituted by the Finance Act, 2010. The substituted provision has been made effective from \n05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \nmade through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. The substituted Clause (13) \nread as   follows: \n“(13)  Commissioner” means a person appointed as Commissioner Inland Revenue under \nsection 208, and includes any other authority vested with all or any of the powers and \nfunctions of the Commissioner;”. \n6Substituted by the Finance Act, 2010. The substituted provision has been made effective from \n05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \nmade through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010.  The substituted Clause (13A) \nread as follows: \n“(13A)  “Commissioner (Appeals)” means a person appointed as Commissioner Inland \nRevenue (Appeals) under section 208; \n7 New clause (13AA) inserted by the Finance Act, 2021. \n\n\f\nChapter I – Preliminary__________________________________ \n \n7 \n \n(a) the suppression of any item of receipt liable to tax in whole or in  \npart, or failure to disclose income chargeable to tax; \n \n(b)  claiming any deduction or any expenditure not actually incurred;  \n \n(c)  any act referred to in sub-section (1) of section 111; and  \n \n(d) claiming of any income or receipt as exempt which is otherwise     \ntaxable.  \n \nExplanation.- For removal of doubt it is clarified that none of the \naforementioned acts would constitute concealment of income \nunless it is proved that taxpayer has knowingly and willfully \ncommitted these acts;] \n \n1[2[(13AB)] “consumer goods” means goods that are consumed by the end \nconsumer rather than used in the production of another good;”] \n \n3[(13B)  “Contribution to an Approved Pension Fund” means contribution as \ndefined in rule 2(j) of the Voluntary Pension System Rules, 20054[ ];] \n \n(14) “co-operative society” means a co-operative society registered under \nthe Co-operative Societies Act, 1925 (VII of 1925) or under any other \nlaw for the time being in force in Pakistan for the registration of co-\noperative societies; \n \n(15) “debt” means any amount owing, including accounts payable and the \namounts owing under promissory notes, bills of exchange, \ndebentures, securities, bonds or other financial instruments; \n \n(16) “deductible allowance” means an allowance that is deductible from \ntotal income under Part IX of Chapter III; \n \n(17) “depreciable asset” means a depreciable asset as defined in section 22; \n \n5[17A. ”Developmental REIT Scheme” means Developmental REIT \nScheme as defined under the Real Estate Investment Trust \nRegulations, 2015;] \n \n6[(17B) \"digital means\" means digital payments and financial services \nincluding but not limited to— online portals or platforms for digital \npayments/receipts; online interbank fund transfer services; online bill \n                                            \n1Inserted by the Finance Act, 2015 \n2 Clause (13AA) re-numbered as clause (13AB) by the Finance Act, 2021. \n3 Inserted by the Finance Act, 2005. \n4The comma and words “, but not exceeding five hundred thousand rupees in a tax year” omitted by \nthe Finance Act, 2006. \n5Inserted by the Finance Act, 2015 \n6 Clause (17B) Inserted through Finance (Supplementary) Act, 2022. \n\n\f\nChapter I – Preliminary__________________________________ \n \n8 \n \nor invoice presentment and payment services; over the Counter \ndigital payment services or facilities; card payments using Point of \nSale terminals, QR codes, mobile devices, ATMs, Kiosk or any other \ndigital; payments enabled devices; or any other digital or online \npayment modes.] \n \n1[(17C) “digitally delivered services” means any service delivered over the \ninternet or electronic networks, where the delivery is automated and \nrequires minimal or no human intervention including music, audio and \nvideo streaming services, cloud services, online software applications \nservices, services delivered through online inter-personal interaction \ni.e., tele medicines, e-learning etc., online banking services, \narchitectural design services, research and consultancy reports, \naccounting services in the form of digital files or any other online \nfacility;] \n \n(18) “disposal” in relation to an asset, means a disposal as defined in \nsection 75; \n \n2[(18A) “distributor” means a person appointed by a manufacturer, importer \nor any other person for a specified area to purchase goods from him \nfor further supply;] \n \n(19) “dividend” includes — \n \n(a) \nany distribution by a company of accumulated profits to its \nshareholders, whether capitalised or not, if such distribution \nentails the release by the company to its shareholders of all or \nany part of the assets including money of the company; \n(b) \nany distribution by a company, to its shareholders of \ndebentures, debenture-stock or deposit certificate in any form, \nwhether with or without profit, 3[ ] to the extent to which the \ncompany possesses accumulated profits whether capitalised or \nnot; \n \n(c) \nany distribution made to the shareholders of a company on its \nliquidation, to the extent to which the distribution is attributable \nto the accumulated profits of the company immediately before \nits liquidation, whether capitalised or not; \n(d) \nany distribution by a company to its shareholders on the \nreduction of its capital, to the extent to which the company \n                                            \n1 Clause (17C) inserted by the Finance Act, 2025. \n2 Clause (18A) Inserted by the Finance Act, 2022. \n3 The words  “and any distribution to its shareholders of shares by way of bonus or bonus shares”, \nomitted by the Finance Act, 2002 \n\n\f\nChapter I – Preliminary__________________________________ \n \n9 \n \npossesses accumulated profits, whether such accumulated \nprofits have been capitalised or not; 1[  ] \n \n(e) \nany payment by a private company 2[as defined in the \n3[Companies Act, 2017 (XIX of 2017)] ] or trust of any sum \n(whether as representing a part of the assets of the company or \ntrust, or otherwise) by way of advance or loan to a shareholder \nor any payment by any such company or trust on behalf, or for \nthe individual benefit, of any such shareholder, to the extent to \nwhich the company or trust, in either case, possesses \naccumulated profits;4[or] \n \n5[(f)  6[remittance of] after tax profit of a branch of a foreign company \noperating in Pakistan;] \n \nbut does not include — \n \n(i) \na distribution made in accordance with 7[sub-clause] (c) \nor (d) in respect of any share for full cash consideration, \nor redemption of debentures or debenture stock, where \nthe holder of the share or debenture is not entitled in the \nevent of liquidation to participate in the surplus assets; \n \n(ii) \nany advance or loan made to a shareholder by a company \nin the ordinary course of its business, where the lending \nof money is a substantial part of the business of the \ncompany; 8[ ]  \n \n(iii) \nany dividend paid by a company which is set off by the \ncompany against the whole or any part of any sum \npreviously paid by it and treated as a dividend within the \nmeaning of 9[sub-clause] (e) to the extent to which it is so \nset off;10[and] \n                                            \n1The word ‘or’ omitted by Finance Act, 2008. \n2 Inserted by the Finance Act, 2003. \n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n4The word ‘or’ added by the Finance Act, 2008. \n5Inserted by the Finance Act, 2008. \n6The word “any” substituted by the Finance Act, 2009. \n7 Substituted for “clause” by the Finance Act, 2002 \n8The word “and” omitted by the Finance Act, 2009. \n9 The word  “clause” substituted by the Finance Act, 2002 \n10The word “and” inserted by the Finance Act, 2009. \n\n\f\nChapter I – Preliminary__________________________________ \n \n10 \n \n \n1[(iv)  remittance of after tax profit by a branch of Petroleum  \nExploration and Production (E&P) foreign company, \noperating in Pakistan.] \n \n2[(19A) \n“Eligible Person”, for the purpose of Voluntary Pension System Rules, \n2005, means an individual Pakistani who 3[holds] a valid National Tax \nNumber4[or Computerized National Identity Card5[or National Identity \nCard for Overseas Pakistanis] issued by the National Database and \nRegistration Authority] 6[ ]7[:]] \n \n8[Provided that the total tax credit available for the contribution made to \napproved employment pension or annuity scheme and approved \npension fund under Voluntary Pension System Rules, 2005, should not \nexceed the limit prescribed or specified in section 63.] \n \n9[(19AA) “e-commerce” means sale or purchase of goods and services \nconducted over computer networks by methods specifically designed \nfor the purpose of receiving or placing of orders either through \nwebsites, mobile applications or online marketplace having digital \nordering features by using either mobile phone, iPad, Tablet or \nautomated computer-to-computer ordering system;] \n \n10[(19B)  The expressions “addressee”, “automated”, “electronic”, “electronic \nsignature”, “information”, “information system”, “originator” and \n“transaction”,  shall have the same meanings as are assigned to them \nin the Electronic Transactions Ordinance, 2002 (LI of 2002);] \n \n11[(19C)  “electronic record” includes the contents of communications, \ntransactions and procedures under this Ordinance, including \nattachments, annexes, enclosures, accounts, returns, statements, \ncertificates, applications, forms, receipts, acknowledgements, notices, \n                                            \n1Added by the Finance Act, 2009. \n2 Inserted by the Finance Act, 2005. \n3 The words “has obtained” substituted by the Finance Act, 2007. \n4 Inserted by the Finance Act, 2007. \n5Inserted by the Finance Act, 2008.  \n6The words “but does not include an individual who is entitled to benefit under any other approved \nemployment pension or annuity scheme” omitted by the Finance Act, 2006. \n7The semicolon substituted by the Finance Act, 2006. \n8Inserted by the Finance Act, 2006. \n9 Clause (19AA) inserted by the Finance Act, 2025. \n10 Inserted by the Finance Act, 2008. \n11New clause (19C) inserted by Finance Act, 2008. \n\n\f\nChapter I – Preliminary__________________________________ \n \n11 \n \norders, judgments, approvals, notifications, circulars, rulings, \ndocuments and any other information associated with such \ncommunications, transactions and procedures, created, sent, \nforwarded, replied to, transmitted, distributed, broadcast, stored, held, \ncopied, downloaded, displayed, viewed, read, or printed, by one or \nseveral electronic resources and any other information in electronic \nform;] \n \n1[(19D) “electronic resource” includes telecommunication systems, transmission \ndevices, electronic video or audio equipment, encoding or decoding \nequipment, input, output or connecting devices, data processing or \nstorage systems, computer systems, servers, networks and related \ncomputer programs, applications and software including databases, \ndata warehouses and web portals as may be prescribed by the Board \nfrom time to time, for the purpose of creating electronic record;] \n \n2[(19E)  \n“telecommunication system” includes a system for the conveyance, \nthrough the agency of electric, magnetic, electro-magnetic, electro-\nchemical or electro-mechanical energy, of speech, music and other \nsounds, visual images and signals serving for the impartation of any \nmatter otherwise than in the form of sounds or visual images and also \nincludes real time online sharing of any matter in manner and mode \nas may be prescribed by the Board from time to time.] \n \n(20) \n“employee” means any individual engaged in employment; \n \n(21) \n“employer” means any person who engages and remunerates an \nemployee; \n \n(22) \n“employment” includes – \n \n(a) \na directorship or any other office involved in the management of \na company; \n \n(b) \na position entitling the holder to a fixed or ascertainable \nremuneration; or \n \n(c) \nthe holding or acting in any public office; \n \n3[(22A) “fast moving consumer goods” means consumer goods which are \nsupplied \nin \nretail \nmarketing \nas \nper \ndaily \ndemand \nof \na \nconsumer4[excluding durable goods]. \n                                            \n1Inserted by the Finance Act, 2008. \n2Inserted by the Finance Act, 2008. \n3Inserted by the Finance Act 2015 \n4Inserted by the Finance Act 2017 \n\n\f\nChapter I – Preliminary__________________________________ \n \n12 \n \n \n1[(22AA) “fair market value” means value as provided in section 68;] \n \n2[(22B)  ”fee for offshore digital services” means any consideration for providing \nor rendering services by a non-resident person for online advertising \nincluding digital advertising space, designing, creating, hosting or \nmaintenance of websites, digital or cyber space for websites, \nadvertising, e-mails, online computing, blogs, online content and online \ndata, providing any facility or service for uploading, storing or \ndistribution of digital content including digital text, digital audio or digital \nvideo, online collection or processing of data related to users in \nPakistan, any facility for online sale of goods or services or any other \nonline facility.] \n \n \n3[(22C) “FBR Refund Settlement Company Limited” means the company with this \nname as incorporated under the Companies Act, 2017 (XIX of 2017), for \nthe purposes of settlement of income tax refund claims including payment \nby way of issuing refund bonds under section 171A;]  \n(23) \n“fee for technical services” means any consideration, whether \nperiodical or lump sum, for the rendering of any managerial, technical \nor consultancy services including the services of technical or other \npersonnel, but does not include — \n \n(a) \nconsideration for services rendered in relation to a construction, \nassembly or like project undertaken by the recipient; or \n \n(b) \nconsideration which would be income of the recipient \nchargeable under the head “Salary”; \n \n4[  ] \n \n(24) \n“financial institution” means an institution 5[as defined] under the \n6[Companies Act, 2017 (XIX of 2017)] ] 7[  ]; \n \n                                            \n1 Clause (22AA) Inserted by the Finance Act, 2022. \n2Inserted by the Finance Act 2018 \n3Clause (22C) Inserted by the Finance Act 2019  \n4Omitted by Finance Act 2019. The Omitted clause read as follow: \n(23A) “filer” means a taxpayer whose name appears in the active taxpayers’ list issued by the Board \n4[or Azad Jammu and Kashmir Council Board of Revenue or Gilgit-Baltistan Council Board of \nRevenue] from time to time or is holder of a taxpayer’s card; \n \n5 The word “notified” substituted by the Finance Act, 2005. \n6 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \n7 The words “by the Federal Government in the official Gazette as a financial institution” omitted by the \nFinance Act, 2003. \n\n\f\nChapter I – Preliminary__________________________________ \n \n13 \n \n(25) \n“finance society” includes a co-operative society which accepts money \non deposit or otherwise for the purposes of advancing loans or making \ninvestments in the ordinary course of business; \n \n(26) \n“firm” means a firm as defined in section 80; \n(27) \n“foreign-source income” means foreign-source income as defined in \nsub-section (16) of section 101. \n \n1[(27A) “greenfield industrial undertaking” means – \n \n(a) a new industrial undertaking which is – \n \n(i) \nsetup on land which has not previously been utilized for any \ncommercial, industrial or manufacturing activity and is free from \nconstraints imposed by any prior work; \n \n(ii) built without demolishing, revamping, renovating, upgrading, \nremodeling or modifying any existing structure, facility or plant; \n(iii) not formed by the splitting up or reconstitution of an undertaking \nalready in existence or by transfer of machinery, plant or building \nfrom an undertaking established in Pakistan prior to \ncommencement of the new business and is not part of an \nexpansion project; \n \n(iv) using any process or technology that has not earlier been used \nin Pakistan and is so approved by the Engineering Development \nBoard; and  \n \n(b) is approved by the Commissioner on an application made in the \nprescribed form and manner, accompanied by the prescribed \ndocuments and, such other documents as may be required by the \nCommissioner: \n \nProvided that this definition shall be applicable from the 1st July, 2019 \nand onwards.]  \n \n(28) \n“House Building Finance Corporation” means the Corporation \nconstituted under the House Building Finance Corporation Act, 1952 \n(XVIII of 1952); \n \n                                            \n1  New clause (27A) inserted through Tax Laws (Second Amendment) Ordinance 2019 dated 26th \nDecember, 2019 \n\n\f\nChapter I – Preliminary__________________________________ \n \n14 \n \n1[(28A)  “imputable income” in relation to an amount subject to final tax means \nthe income which would have resulted in the same tax, had this \namount not been subject to final tax;”] \n \n2[(29) \n“income” includes any amount chargeable to tax under this Ordinance, \nany amount subject to collection 3[or deduction] of tax under section \n148, 4[150, 152(1), 153, 154, 156, 156A, 233, 5[  ] ] 6[,] sub-section (5) \nof section 234 7[, section 236Z] 8[ ] 9[and] 10[any amount treated as \nincome under any provision of this Ordinance] and any loss of \nincome11[ ]; \n \n12[(29A) “income year” means income year as defined in the repealed \nOrdinance;] \n \n13[(29B)  “Individual Pension Account” means an account maintained by an \neligible person with a Pension Fund Manager approved under the \nVoluntary Pension System Rules, 2005;] \n \n \n14[(29C) “Industrial undertaking” means — \n                                            \n1Inserted by the Finance Act, 2015 \n2 Clause (29) substituted by the Finance Act, 2002. The substituted clause read as follows:  \n “(29) “income” includes any amount chargeable to tax under this Ordinance, any amount subject to \ncollection of tax under Division II of Part V of Chapter X, sub-section (5) of 234 Division III of \nChapter XII, and any loss of income;”  \n3 Inserted by the Finance Act, 2003. \n4 The figures, commas and word “153, 154 and 156,” substituted by the Finance Act, 2005. \n5 The expression “233A,” omitted by the Finance Act, 2021. \n6 The word “and” substituted by a comma by the Finance Act, 2014. \n7 The expression “, section 236Z” inserted by the Finance Act, 2023. \n8The word and figure “and 236M” substituted by a comma by the Finance Act, 2015 \n9The expression “, 236M and 236N,” substituted by the Finance Act, 2018 \n10 Inserted by the Finance Act, 2003. \n11Omitted by the Finance Act, 2014. The omitted text read as follows:  \n“but does not include, in case of a shareholder of a company, the amount representing the face \nvalue of any bonus share or the amount of any bonus declared, issued or paid by the company to \nthe shareholders with a view to increasing its paid up share capital.” \n12 Inserted by the Finance Act, 2002. \n13 Inserted by the Finance Act, 2005. \n14Clause (29C) substituted by the Finance Act, 2010. The substituted clause (29C) read as follows:- \n “(29C) \n“Industrial undertaking” means – \n(a) an undertaking which is set up in Pakistan and which employs, (i) ten or more persons in \nPakistan and involves the use of electrical energy or any other form of energy which is \nmechanically transmitted and is not generated by human or animal energy; or (ii) twenty or more \npersons in Pakistan and does not involve the use of electrical energy or any other form of energy \nwhich is mechanically transmitted and is not generated by human or animal energy and which is \nengaged in,- \n (i) \nthe manufacture of goods or materials or the subjection of goods or materials to any \nprocess which substantially changes their original condition; \n\n\f\nChapter I – Preliminary__________________________________ \n \n15 \n \n \n(a) \nan undertaking which is set up in Pakistan and which \nemploys,— \n \n(i) \nten or more persons in Pakistan and involves the use \nof electrical energy or any other form of energy which is \nmechanically transmitted and is not generated by \nhuman or animal energy; or \n \n(ii) \ntwenty or more persons in Pakistan and does not \ninvolve the use of electrical energy or any other form of \nenergy which is mechanically transmitted and is not \ngenerated by human or animal energy: \n \nand which is engaged in,— \n \n(i) \nthe manufacture of goods or materials or the subjection \nof goods or materials to any process which substantially \nchanges their original condition; or  \n \n(ii) \nship-building; or \n(iii) \ngeneration, conversion, transmission or distribution of \nelectrical energy, or the supply of hydraulic power; or \n \n(iv) \nthe working of any mine, oil-well or any other source of \nmineral deposits; 1[  ] \n \n2[(aa) from the 1st day of May, 2020, a person directly involved in the \nconstruction of buildings, roads, bridges and other such \nstructures or the development of land, to the extent and for the \npurpose of import of plant and machinery to be utilized in such \nactivity, subject to such conditions as may be notified by the \nBoard; \n \n(ab) from the first day of July, 2020 a resident company engaged in \nthe hotel business in Pakistan;] 3[and] \n \n 4[  ]    ] \n                                            \n(ii) \nship-building;  \n(iii)  \ngeneration, conversion, transmission or distribution of electrical energy, or the supply \nof hydraulic power; or \n(iv)  \nthe working of any mine, oil-well or any other source of mineral deposits; and \n(b) any other industrial undertaking which the Board may by notification in the official Gazette, \nspecify;”. \n1 The word “and” omitted through Finance Act, 2020 dated 30.06.2020. \n2 New sub-clauses inserted through Finance Act, 2020 dated 30th June, 2020. \n3 The word “and” added by the Finance Act, 2021. \n4 Sub-clause (b) omitted by the Finance Act, 2021. Earlier this sub-clause was omitted through Tax \nLaws (Second Amendment) Ordinance, 2021. The omitted sub-clause read as follows: \n\n\f\nChapter I – Preliminary__________________________________ \n \n16 \n \n \n 1[(c) telecommunication companies operating under the license of \nPakistan Telecommunication Authority (PTA).;] \n \n(30) “intangible” means an intangible as defined in section 24; \n \n2[(30A) \n“integrated enterprise” means a person integrated with the Board \nthrough approved fiscal electronic device and software, and who \nfulfills obligations and requirements for integration as may be \nprescribed;] \n \n3[4[(30AA)] “investment company” means an investment company as defined in \nthe \nNon-Banking \nFinance \nCompanies \n(Establishment \nand \nRegulation) Rules, 2003;] \n \n5[6[(30AB)] KIBOR means Karachi Inter Bank Offered Rate prevalent on the  \nfirst day of each quarter of the financial year;] \n \n7[(30AC) \n“Iris” means a web based computer programme for operation and \nmanagement of Inland Revenue taxes and laws administered by the \nBoard;] \n \n8[(30AD)   Information Technology (IT) services include 9[but not limited to] \nsoftware development, software maintenance, system integration, \nweb design, web development, web hosting and network design; \nand  \n \n(30AE)        IT enabled services include 10[but not limited to] inbound or outbound \ncall centres, medical transcription, remote monitoring, graphics \ndesign, accounting services, Human Resource (HR) services, \ntelemedicine centers, data entry operations, cloud computing \n                                            \n“(b)  any other industrial undertaking which the Board may by notification in the official gazette, \nspecify.” \n1 Clause (c) added by the Finance Act, 2021. \n2 New sub-clause (30A) inserted through Finance Act, 2020 dated 30th June, 2020 \n3 Clause (30A) substituted  by the Finance Act, 2008. The substituted clause (30A) read as follows: \n“ (30A) “investment company” means a company registered under the Investment Companies and \nInvestment Advisors Rules, 1971;” \n4 Clause (30A) renumbered as clause (30AA)  through Finance Act, 2020 dated 30th June, 2020 \n5Inserted by the Finance Act, 2009. \n6 Clause (30AA) renumbered as (30AB) through Finance Act, 2020 dated 30th June, 2020 \n7 New clause (30AC) inserted through Finance Act, 2020 dated 30th June,2020 \n8 Clauses (30AD) and (30AE) inserted by the Finance Act, 2021. \n9 Inserted by the Finance Act, 2022. \n10 Inserted by the Finance Act, 2022. \n\n\f\nChapter I – Preliminary__________________________________ \n \n17 \n \nservices, data storage services, locally produced television \nprograms and insurance claims processing;] \n \n1[(30B)  “leasing company” means a leasing company as defined in the Non-\nBanking Finance Companies and Notified Entities Regulation, 2007;] \n \n2[(30C)  “liaison office” means a place of business acting for the principal, head \noffice or any entity of which it is a part, and \n \n(a) \nits activities do not result in deriving income in Pakistan; and \n \n(b) \nmaintains itself out of any amount remitted from outside \nPakistan received through normal banking channels. \n \nExplanation,—  It is clarified that— \n \n(i) \na place of business shall not be treated as liaison office if \nit engages in -  \n \n(a) \ncommercial activities;  \n(b) \ntrading or industrial activities; or \n(c) \nthe negotiation and conclusion of contracts; \n \n(ii) \nthe activities shall be treated to be commercial activities, if \nthese include— \n \n(a) \nproviding after sales services for goods or services; \nor \n \n(b) \nmarketing or promoting pharmaceutical and medical \nproducts or services; \n \n(iii) subject to clause (i), a place of business shall be treated \nas a liaison office, if it undertakes activities of— \n \n(a) \nan exploratory or preparatory nature, to investigate \nthe possibilities of trading with, or in, Pakistan; \n \n(b) \nexploring the possibility of joint collaboration and \nexport promotion; \n \n                                            \n1Clause (30B) substituted by the Finance Act, 2008. The substituted clause (30B) read as follows: \n“ (30B) “leasing company” means a company licensed under the Leasing Companies (Establishment \nand Regulation) Rules, 2000; \n2Inserted by the Finance Act, 2017. \n\n\f\nChapter I – Preliminary__________________________________ \n \n18 \n \n(c) \npromoting  products where such products are yet to \nbe supplied to, or sold in, Pakistan; \n \n(d) \npromoting technical and financial collaborations \nbetween  its principal and taxpayers in Pakistan;  or \n \n(e) \nprovision of technical advice and assistance.] \n \n(31) “liquidation” in relation to a company, includes the termination of a \ntrust; \n \n1[(31A) “Local Government” shall have the same meaning for respective \nprovisions and Islamabad Capital Territory as contained in the \nBalochistan Local Government Act,2010 (V of 2010), the Khyber \nPakhtunkhwa Local Government Act, 2013 (XXVIII of 2013), the Sindh \nLocal Government Act, 2013 (XLII of 2013), the Islamabad Capital \nTerritory Local Government Act, 2015 (X of 2015) and the Punjab \nLocal Government Act, 2019(XIII of 2019)] \n(32) “member” in relation to an association of persons, includes a partner \nin a firm; \n \n(33) “minor child” means an individual who is under the age of eighteen \nyears at the end of a tax year; \n \n(34) “modaraba” means a modaraba as defined in the Modaraba Companies \nand Modarabas (Floatation and Control) Ordinance, 1980 (XXXI of \n1980); \n \n(35) “modaraba certificate” means a modaraba certificate as defined in the \nModaraba Companies and Modarabas (Floatation and Control) \nOrdinance, 1980 (XXXI of 1980); \n \n2[(35A) “Mutual Fund” means a mutual fund 3[registered or approved by the \nSecurities and Exchange Commission of Pakistan];] \n \n                                            \n1 Clause (31A) is substituted through Finance Act 2020 dated 30th June, 2020 the substituted  clause \nread as follows: “(31A) \n“Local Government” shall have the same meaning as defined in the \nPunjab Local Government Ordinance, 2001 (XIII of 2001), the Sindh Local Government Ordinance, \n2001 (XXVII of 2001), the NWFP Local Government Ordinance, 2001 (XIV of 2001) and the \nBalochistan Local Government Ordinance, 2001 (XVIII of 2001);” \n2 Inserted by the Finance Act, 2002 \n3 The  words “set up by the Investment Corporation of Pakistan or by an investment company” \nsubstituted by the Finance Act, 2003. \n\n\f\nChapter I – Preliminary__________________________________ \n \n19 \n \n1[(35AA)  “NCCPL” means National Clearing Company of Pakistan Limited, \nwhich is a company incorporated under the 2[Companies Act, 2017 \n(XIX of 2017)] and licensed as “Clearing House” by the Securities and \nExchange Commission of Pakistan,3[or any subsidiary of NCCPL \nnotified by the Board for the purpose of this clause] \n \n4[(35B) “non-banking finance company” means an NBFC as defined in the \nNon-Banking Finance Companies (Establishment and Regulation) \nRules, 2003;] \n \n5[  ] \n \n6[(36)  \n“non-profit organization” means any person other than an individual, \nwhich is — \n \n(a) \nestablished for religious, educational, charitable, welfare \n7[purposes for general public], or for the promotion of an \namateur sport 8[excluding recreational clubs where the joining \nfee for membership exceeds one million for any class of new \nmembers]; \n \n(b) \nformed and registered 9[by or] under any law as a non-profit \norganization; \n \n(c) \napproved by the Commissioner for specified period, on an \napplication made by such person in the prescribed form and \nmanner, accompanied by the prescribed documents and, on \n                                            \n1Inserted by the Finance Act, 2012. \n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \n3Inserted by the Finance Act, 2017 \n4Clause (35B) substituted by the Finance Act, 2008. The substituted clause (35B) read as follows: \n“ (35B) “non-banking finance company” means an institution notified under the Non-Banking Finance \nCompanies (Establishment and Regulation) Rules, 2003.” \n5Omitted by Finance Act, 2019. Omitted clause read as follow:  \n(35C)“non-filer” means a person who is not a filer;  \n6 Clause (36) substituted by the Finance Act, 2002. The substituted clause (36) read as follows: \n“(36) \n“non-profit organization” means any person – \n(a) \nestablished for religious, charitable or educational purposes, or for the \npromotion of amateur sport; \n(b) \nwhich is registered under any law as a non-profit organization and in respect of \nwhich the Commissioner has issued a ruling certifying that the person is a non-\nprofit organization for the purposes of this Ordinance; and \n(c) \nnone of the income or assets of the person confers, or may confer a private \nbenefit on any other person”;. \n7 The expressions “or development purposes” substituted through Finance Act,2020 dated 30th June, \n2020 \n8 Words inserted by Finance Act, 2025. \n9 Words “by or” inserted through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nChapter I – Preliminary__________________________________ \n \n20 \n \nrequisition, such other documents as may be required by the \nCommissioner; \nand none of the assets of such person confers, or may confer, \na private benefit to any other person;] \n \n(37) “non-resident person” means a non-resident person as defined in \nSection 81; \n \n(38) “non-resident taxpayer” means a taxpayer who is a non-resident \nperson; \n \n \n1[(38A) “Officer of Inland Revenue” means any Additional Commissioner \nInland Revenue, Deputy Commissioner Inland Revenue, Assistant \nCommissioner Inland Revenue, Inland Revenue Officer, Inland \nRevenue Audit Officer,2[District Taxation Officer Inland Revenue, \nAssistant Director Audit,]or any other officer however designated or \nappointed by the Board for the purposes of this Ordinance;] \n \n \n3[(38AA) “offshore asset” in relation to a person, includes any movable or \nimmovable asset held, any gain, profit, or income derived, or any \nexpenditure incurred outside Pakistan; \n \n \n(38AB) “offshore evader” means a person who owns, possesses, controls, or \nis the beneficial owner of an offshore asset and does not declare, or \nunder declares or provides inaccurate particulars of such asset to the \nCommissioners.; \n \n \n(38AC) “offshore enabler” includes any person who, enables, assists, or \nadvises any person to plan, design, arrange or manage a transaction \nor declaration relating to an offshore asset, which has resulted or may \nresult in tax evasion;] \n \n4[(38B) “online marketplace” means an information technology platform run \nby e-commerce entity over an electronic network that acts as a \n                                            \n1Substituted by the Finance Act, 2010. The substituted provision has been made effective from \n05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \nmade through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. The substituted clause (38A) \nread as follows: \n“(38A)  “Officer of Inland Revenue” means any Additional  Commissioner Inland Revenue,  \nDeputy Commissioner Inland Revenue, Assistant Commissioner Inland Revenue, \nInland Revenue Officer, Special Officer Inland Revenue or any other officer however \ndesignated or appointed by the Board for the purposes of this Ordinance.” \n2Inserted by the Finance Act, 2017 \n3New clauses (38AA), (38AB) & (38AC) inserted by Finance Act, 2019  \n4Inserted by the Finance Act, 2017 \n\n\f\nChapter I – Preliminary__________________________________ \n \n21 \n \nfacilitator in transactions that occur between a buyer and a seller 1[and \nincludes “online interfaces” that facilitate, for a fee, the direct \ninteraction between multiple buyers and multiple sellers via digital \norders for supply of goods and services, with or without the platform \ntaking economic ownership of the goods or providing or rendering the \nservices that are being sold.];] \n \n(39) “Originator” means Originator as defined in the Asset Backed \nSecuritization Rules, 1999; \n \n(40) “Pakistan-source income” means Pakistan-source income as defined \nin section 101; \n \n2[(40A)  “Pension Fund Manager” means an asset management company \nregistered \nunder \nthe \nNon-Banking \nFinance \nCompanies \n(Establishment and Regulations) Rules, 2003, or a life insurance \ncompany registered under Insurance Ordinance, 2000 (XXXIX of \n2000), duly authorized by the Securities and Exchange Commission \nof Pakistan and approved under the Voluntary Pension System Rules, \n2005, to manage the Approved Pension Fund;] \n \n(41) \n“permanent establishment” in relation to a person, means a 3[  ] 4[  ] \nplace of business through which the business of the person is wholly \nor partly carried on, and includes –  \n \n(a) \na place of management, branch, office, factory or workshop, \n5[premises for soliciting orders, warehouse, permanent sales \nexhibition or sales outlet,] other than a liaison office except \nwhere the office engages in the negotiation of contracts (other \nthan contracts of purchase); \n \n(b) \na mine, oil or gas well, quarry or any other place of extraction of \nnatural resources; \n \n6[(ba) an agricultural, pastoral or forestry property;] \n \n7[(bb) virtual business presence in Pakistan including any business \nwhere transactions are conducted through internet or any other \n                                            \n1 Expression inserted by the Finance Act, 2025. \n2 Inserted by the Finance Act, 2005. \n3 The word “fixed” inserted by the Finance Act, 2006. \n4 The word “fixed” omitted by the Finance Act, 2023. \n5 Inserted by the Finance Act, 2003. \n6 Inserted by the Finance Act, 2003. \n7 The sub-clause (bb) inserted by the Finance Act, 2023. \n\n\f\nChapter I – Preliminary__________________________________ \n \n22 \n \nelectronic medium, with or without having any physical \npresence;] \n \n(c) \na building site, a construction, assembly or installation project or \nsupervisory activities 1[connected] with such site or project 2[but \nonly where such site, project and its 3[connected] supervisory \nactivities continue for a period or periods aggregating more than \nninety days within any twelve-months period] ; \n \n(d) \nthe furnishing of services, including consultancy services, by \nany person through employees or other personnel 4[or entity] \nengaged by the person for such purpose 5[  ]; \n \n(e) \na person  acting  in  Pakistan  on   behalf   of   the   person \n(hereinafter referred to as the “agent 6[”),] other than an agent \nof independent status acting in the ordinary course of business \nas such, if the agent – \n \n7[(i)  has and habitually exercises an authority to conclude                      \ncontracts on behalf of the other person or habitually \nconcludes contracts or habitually plays the principal role \nleading to the conclusion of contracts that are routinely \nconcluded without material modification by the person \nand these contracts are─ \n \n (a) in the name of the person; or \n (b) for the transfer of the ownership of or for the     \ngranting of the right to use property owned by that \nenterprise or that the enterprise has the right to use; \nor \n \n(c) \nfor the provision of services by that person; or”] \n \n \n                                            \n1 The word “connect” substituted by the Finance Act, 2010. \n2 Inserted by the Finance Act, 2006. \n3 The word “connect” substituted by the Finance Act, 2010. \n4  Words inserted by the Finance Act, 2023. \n5 The words “, but only where activities of that nature continue for the same or a connected project \nwithin Pakistan for a period or periods aggregating more than ninety days within any twelve-month \nperiod” omitted by the Finance Act, 2003. \n6 Comma  substituted by the Finance Act, 2002 \n7Paragraph (i) substituted by Finance Act 2018, the substituted Paragraph (i) is read as under: \n“has and habitually exercises an authority to conclude contracts on behalf of the other person;” \n\n\f\nChapter I – Preliminary__________________________________ \n \n23 \n \n(ii)  \nhas no such authority, but habitually maintains a stock-in-\ntrade or other merchandise from which the agent regularly \ndelivers goods or merchandise on behalf of the other \nperson; or \n \n1[Explanation.—For removal of doubt, it is clarified that an \nagent of independent status acting in the ordinary course \nof business does not include a person acting exclusively \nor almost exclusively on behalf of the person to which it \nis an associate; or ”;] \n \n(f) \nany substantial equipment installed, or other asset or property \ncapable of activity giving rise to income; \n \n2[(g)  a 3[  ] place of business that is used or maintained by a person if \nthe person or an associate of a person carries on business at \nthat place or at another place in Pakistan and ─ \n \n(i) that place or other place constitutes a permanent \nestablishment of the person or an associate of the person \nunder this sub-clause; or \n(ii)  business carried on by the person or an associate of the \nperson at the same place or at more than one place \nconstitute complementary functions that are part of a \ncohesive business operation. \n \nExplanation.— For the removal of doubt, it is clarified that ─  \n \n(A) the term ”cohesive business operation” includes an overall \narrangement for the supply of goods, installation, \nconstruction, \nassembly, \ncommission, \nguarantees \nor \nsupervisory activities and all or principal activities are \nundertaken or performed either by the person or the \nassociates of the person; and \n \n(B)  supply of goods include the goods imported in the name of \nthe associate or any other person, whether or not the title to \nthe goods passes outside Pakistan.] \n \n(42) “person” means a person as defined in section 80; \n \n                                            \n1Added by the Finance Act, 2018 \n2Added by the Finance Act, 2018 \n3 The word “fixed” omitted by the Finance Act, 2023. \n\n\f\nChapter I – Preliminary__________________________________ \n \n24 \n \n1[(42A) “PMEX” means Pakistan Mercantile Exchange Limited a futures \ncommodity exchange company incorporated under the 2[Companies \nAct, 2017 (XIX of 2017)] and is licensed and regulated by the \nSecurities and Exchange Commission of Pakistan;”] \n \n(43) “pre-commencement expenditure” means a pre-commencement \nexpenditure as defined in section 25; \n \n(44) “prescribed” means prescribed by rules made under this Ordinance; \n \n3[(44A) “principal officer” used with reference to a company or association of \npersons includes –  \n \n(a) \na director, a manager, secretary, agent, accountant or any \nsimilar officer; and \n \n(b) \nany person connected with the management or administration \nof the company or association of persons upon whom the \nCommissioner has served a notice of treating him as the \nprincipal officer thereof;] \n \n(45) “private company” means a company that is not a public company; \n \n4[  ] \n \n \n5[  ] \n \n(46) “profit on a debt” 6[whether payable or receivable, means] — \n(a) \nany profit, yield, interest, discount, premium or other amount 7[,] \nowing under a debt, other than a return of capital; or \n \n                                            \n1Inserted by the Finance Act, 2015. \n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n3 Inserted by the Finance Act, 2003. \n4Clause (45A) omitted by the Finance Act, 2008. The omitted clause (45A) read as follows: \n“ (45A) \n“Private Equity and Venture Capital Fund” means a fund registered with the Securities \nand Exchange Commission of Pakistan under the Private Equity and Venture Capital Fund Rules, \n2007;” \n5Clause (45B) omitted by the Finance Act, 2008. The omitted clause (45B) read as follows: \n“(45B) “Private Equity and Venture Capital Fund Management Company” means a company \nlicensed by the Securities and Exchange Commission of Pakistan under the Private Equity and \nVenture Capital Fund Rules, 2007;” \n6 The word “means” substituted by the Finance Act, 2003. \n7 Comma inserted by the Finance Act, 2002. \n\n\f\nChapter I – Preliminary__________________________________ \n \n25 \n \n(b) \nany service fee or other charge in respect of a debt, including \nany fee or charge incurred in respect of a credit facility which \nhas not been utilized; \n \n(47) “public company” means — \n \n(a) \na company in which not less than fifty per cent of the shares are \nheld by the Federal Government 1[or Provincial Government];  \n \n2[(ab) \na company in which 3[not less than fifty per cent of the] shares \nare held by a foreign Government, or a foreign company owned \nby a foreign Government 4[;]] \n \n(b) \na company whose shares were traded on a registered stock \nexchange in Pakistan at any time in the tax year and which \nremained listed on that exchange 5[ ] at the end of that year; or \n \n6[(c)  a unit trust whose units are widely available to the public and \nany other trust as defined in the Trusts Act, 1882 (II of 1882);] \n7[(47A)  “REIT Scheme” means a REIT Scheme as defined in the Real Estate \nInvestment Trust Regulations, 2015;”] \n \n \n \n8[(47B) \n“Real Estate Investment Trust Management Company 9[RMC]means \n10[RMC] as defined under the Real Estate Investment Trust \nRegulations, 11[2015];] \n \n                                            \n1 Inserted by the Finance Act, 2003. \n2 Inserted by the Finance Act, 2003. \n3 Inserted by the Finance Act, 2005. \n4 The full stop substituted by the Finance Act, 2005. \n5 The words “and was on the Central Depository System,” omitted by the Finance Act, 2002. \n6 Clause (c) substituted by the Finance Act, 2003. The substituted clause (c) read as follows:  \n   “(c) a unit trust whose units are widely available to the public and any other public trust;” \n7Clause (47A) substituted by the Finance Act, 2015. The substituted clause read as follows: \n“(47A)  “Real Estate Investment Trust (REIT) Scheme” means a REIT Scheme as defined in the \nReal Estate Investment Trust Regulations, 2008; \n8Clause (47B) substituted by the Finance Act, 2008. The substituted clause (47B) read as follows: \n “(47B) “Real Estate Investment Trust Management Company” means a company licensed by the \nSecurity and Exchange Commission of Pakistan under the Real Estate Investment Trust Rules, \n2006.” \n9Inserted by the Finance Act, 2015. \n10Inserted by the Finance Act, 2015. \n11 The figure “2008” substituted by the Finance Act, 2015. \n\n\f\nChapter I – Preliminary__________________________________ \n \n26 \n \n1[(47C) “Rental REIT Scheme” means a Rental REIT Scheme as defined  \n \n \nunder the Real Estate Investment Trust Regulations, 2015;”] \n \n(48) “recognised provident fund” means a provident fund recognised by the \nCommissioner in accordance with Part I of the Sixth Schedule;  \n \n \n2[ ] \n \n(49) “rent” means rent as defined in sub-section (2) of section 15 and \nincludes an amount treated as rent under section 16; \n \n3[(49A)  “repealed Ordinance” means Income Tax Ordinance, 1979 (XXXI of \n1979);] \n \n(50) “resident company” means a resident company as defined in section \n83; \n \n(51) “resident individual” means a resident individual as defined in section \n82; \n \n(52) “resident person” means a resident person as defined in section 81;  \n \n(53) “resident taxpayer” means a taxpayer who is a resident person; \n(54) \n4[“royalty”]means any amount paid or payable, however described or \ncomputed, whether periodical or a lump sum, as consideration for — \n \n(a) \nthe use of, or right to use any patent, invention, design or model, \nsecret formula or process, trademark or other like property or \nright; \n \n(b) \nthe use of, or right to use any copyright of a literary, artistic or \nscientific work, including films or video tapes for use in \nconnection with television or tapes in connection with radio \nbroadcasting, but shall not include consideration for the sale, \ndistribution or exhibition of cinematograph films; \n \n(c)  \nthe receipt of, or right to receive, any visual images or sounds, \nor both, transmitted by satellite, cable, optic fibre or similar \n                                            \n1Inserted by the Finance Act, 2015. \n2Clause (48A) omitted  by the Finance Act, 2010. The omitted clause (48A) read as follows: \n“(48)  “Regional Commissioner” means a person appointed as a Regional Commissioner of Income \nTax under section 208 and includes a Director-General of Income Tax and Sales Tax.” \n3 Inserted by the Finance Act, 2002 \n4 The word “royalties” substituted by the Finance Act, 2002. \n\n\f\nChapter I – Preliminary__________________________________ \n \n27 \n \ntechnology in connection with television, radio or internet \nbroadcasting; \n \n(d)  \nthe supply of any technical, industrial, commercial or scientific \nknowledge, experience or skill; \n \n(e) \nthe use of or right to use any industrial, commercial or scientific \nequipment; \n \n(f) \nthe supply of any assistance that is ancillary and subsidiary to,  \nand is furnished as a means of enabling the application or \nenjoyment of, any such property or right as mentioned in 1[sub-\nclauses] (a) through (e); 2[and] \n \n(g) \nthe disposal of any property or right referred to in 3[sub-clauses] \n(a) through (e); \n \n(55) “salary” means salary as defined in section 12; \n \n(56) “Schedule” means a Schedule to this Ordinance; \n \n(57) “securitization” means securitization as defined in the Asset Backed \nSecuritization Rules, 1999; \n(58) “share” in relation to a company, includes a modaraba certificate and \nthe interest of a beneficiary in a trust (including units in a trust); \n \n(59) “shareholder” in relation to a company, includes a modaraba \ncertificate holder, 4[a unit holder of a unit trust] and a beneficiary of a \ntrust; \n \n5[(59A) “small and medium enterprise” means a person who is engaged in  \nmanufacturing as defined in clause (iv) of sub-section (7) of section \n153 of the Ordinance and his business turnover in a tax year does \nnot exceed two hundred and fifty million rupees:  \n \nProvided that if annual business turnover of a small and medium \nenterprise exceeds two hundred and fifty million rupees, it shall not \n                                            \n1 The word “clauses” substituted by the Finance Act, 2002. \n2 Added by the Finance Act,  2005. \n3 The word “clauses” substituted by the Finance Act, 2002 \n4 Inserted for “, a unit holder of a unit trust” by the Finance Act, 2002 \n5 New clause (59A) inserted by the Finance Act, 2021. \n\n\f\nChapter I – Preliminary__________________________________ \n \n28 \n \nqualify as small and medium enterprise in the tax year in which \nannual turnover exceeds that turnover or any subsequent tax year.] \n \n1[2[(59AB)] “Small Company” means a company registered on or after the first             \nday of July, 2005, under the 3[Companies Act, 2017 (XIX of 2017)], \nwhich,— \n \n(i)  \nhas paid up capital plus undistributed reserves not \nexceeding 4[fifty]million rupees; \n \n5[(ia) \nhas employees not exceeding two hundred and fifty any \ntime during the year;] \n \n \n(ii)  \nhas annual turnover not exceeding two hundred 6[and \nfifty] million rupees; 7[  ] \n \n(iii) \nis not formed by the splitting up or the reconstitution of \ncompany already in existence;] 8[and] \n \n9[(iv)    is not a small and medium enterprise as defined in clause \n(59A);] \n \n10[(59B) “Special Judge” means the Special Judge appointed under section  \n203;] \n \n(60) “Special Purpose Vehicle” means a Special Purpose Vehicle as \ndefined in the Asset Backed Securitization Rules, 1999; \n \n11[(60A)  “specified jurisdiction” means any jurisdiction which has committed to \nautomatically exchange information under the Common Reporting \nStandard with Pakistan;]  \n \n(61) “speculation business” means a speculation business as defined in \nsection 19; \n \n                                            \n1 Inserted by the Finance Act, 2005. \n2 Clause (59A) re-numbered as clause (59AB) by the Finance ACT, 2021. \n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n4The word “twenty-five” substituted by the Finance Act, 2015 \n5Inserted by the Finance Act, 2007. \n6Inserted by the Finance Act, 2007. \n7 The word “and “ omitted by the Finance Act, 2021. \n8 The word “and “ added by the Finance Act, 2021. \n9 New sub-clause (iv) added by the Finance Act, 2021. \n10Inserted by the Finance Act, 2014. \n11(60A)Inserted by the Finance Act, 2019 \n\n\f\nChapter I – Preliminary__________________________________ \n \n29 \n \n1[(61A)  “stock fund” means a collective investment scheme or a mutual fund \nwhere the investible funds are invested by way of equity shares in \ncompanies, to the extent of more than seventy per cent of the \ninvestment;] \n \n(62) “stock-in-trade” means stock-in-trade as defined in section 35; \n \n2[(62A) “startup” means,— \n \n(i) \na business of a resident individual, AOP or a company that \ncommenced on or after first day of July, 2012 and the person \nis engaged in or intends to offer technology driven products or \nservices to any sector of the economy provided that the person \nis registered with and duly certified by the Pakistan Software \nExport Board (PSEB) and has turnover of less than one \nhundred million in each of the last five tax years; or \n \n(ii) \nany business  of a person or class of persons, subject to the \nconditions as the 3[Board with the approval of Federal Minister-\nin-charge] may, by notification in the official Gazette, specify.;] \n \n4[(62B) “Synchronized Withholding Administration and Payment System \nagent” or “SWAPS agent” means any person or class of persons \nnotified by Board to collect or deduct withholding taxes through \nSynchronized Withholding Administration and Payment System;] \n(63) “tax” means any tax imposed under Chapter II, and includes any \npenalty, fee or other charge or any sum or amount leviable or payable \nunder this Ordinance; \n \n(64) “taxable income” means taxable income as defined in section 9; \n \n5[   ] \n \n(66) “taxpayer” means any person who derives an amount chargeable to \ntax under this Ordinance, and includes — \n \n                                            \n1Inserted by the Finance Act,  2014.. \n2Inserted by the Finance Act, 2017 \n3 The words “Federal Government” substituted by the Finance Act, 2021.  \n4 Inserted by the Finance Act, 2022. \n5Clause (65) omitted by the Finance Act, 2010. The omitted Clause (65) read as follows: \n“(65)  “taxation officer” means any Additional Commissioner of Income Tax, Deputy \nCommissioner of Income Tax, Assistant Commissioner of Income Tax, Income Tax \nOfficer, Special Officer or any other officer however designated appointed by the Board \nfor the purposes of this Ordinance;” \n\n\f\nChapter I – Preliminary__________________________________ \n \n30 \n \n(a) \nany representative of a person who derives an amount \nchargeable to tax under this Ordinance; \n \n(b) \nany person who is required to deduct or collect tax under Part V \nof Chapter X 1[and Chapter XII;] or \n \n(b) \nany person required to furnish a return of income or pay tax \nunder this Ordinance; \n2[(66A) “tax invoice” means an invoice as prescribed under the Income Tax \nRules, 2002;] \n \n(67) “tax treaty” means an agreement referred to in section 107; \n \n(68) “tax year” means the tax year as defined in sub-section (1) of section 74 \nand, in relation to a person, includes a special year or a transitional year \nthat the person is permitted to use under section 74; \n(69) “total income” means total income as defined in section 10; \n \n(70) “trust” means a “trust” as defined in section 80; \n \n3[(70A)  “turnover” means turnover as defined in sub-section (3) of section 113;] \n(71) “underlying ownership” means an underlying ownership as defined in \nsection 98;  \n(72) “units” means units in a unit trust;  \n(73) “unit trust” means a unit trust as defined in section 80; and \n4[(73A) “unspecified jurisdiction” means a jurisdiction which is not a specified \njurisdictions.] \n \n5[(74) \n“Venture Capital Company” and “Venture Capital Fund” shall have the \nsame meanings as are assigned to them under the 6[Non-Banking \nFinance 7[Companies] (Establishment and Regulation) Rules, 2003]; \n \n8[(75)  “whistleblower” means whistleblower as defined in section 227B;”] \n \n                                            \n1 Inserted by the Finance Act, 2002 \n2 Inserted by the Finance Act, 2022. \n3Inserted by the Finance Act, 2009. \n4(73A) inserted through Finance Act, 2019. \n5 Added by Finance Act, 2002 \n6 The words, brackets, comma and figure “Venture Capital Company and Venture Capital Fund \nRules, 2001” substituted by the Finance Act, 2004. \n7 The word “Company” substituted by the Finance Act, 2005. \n8 Inserted by the Finance Act, 2015. \n\n\f\nChapter I – Preliminary__________________________________ \n \n31 \n \n3. \nOrdinance to override other laws.—The provisions of this Ordinance shall \napply notwithstanding anything to the contrary contained in any other law for the \ntime being in force.\n\n\f\nChapter II – Charge of Tax_______________________________ \n \n32 \nCHAPTER II \nCHARGE OF TAX \n \n4. \nTax on taxable income.— (1)  Subject to this Ordinance, income tax shall \nbe imposed for each tax year, at the rate or rates specified in 1[Division I 2[ ] or II] \nof Part I of the First Schedule, as the case may be, on every person who has \ntaxable income for the year. \n \n (2) \nThe income tax payable by a taxpayer for a tax year shall be computed \nby applying the rate or rates of tax applicable to the taxpayer under this Ordinance \nto the taxable income of the taxpayer for the year, and from the resulting amount \nshall be subtracted any tax credits allowed to the taxpayer for the year. \n \n \n(3) \nWhere a taxpayer is allowed more than one tax credit for a tax year, \nthe credits shall be applied in the following order – \n \n(a) \nany foreign tax credit allowed under section 103; then \n(b) \nany tax credit allowed under Part X of Chapter III; and then \n(c) \nany tax credit allowed under sections 3[  ] 147 and 168. \n \n \n(4) \nCertain classes of income (including the income of certain classes of \npersons) may be subject to – \n \n(a) \nseparate taxation as provided 4[under this chapter]; or \n \n(b) \ncollection of tax under Division II of Part V of Chapter X or \ndeduction of tax under Division III of Part V of Chapter X as a \nfinal tax on the income 5[of] the person. \n \n \n(5) \nIncome referred to in sub-section (4) shall be subject to tax as \nprovided for 6[under this chapter], or Part V of Chapter X, as the case may be, and \nshall not be included in the computation of taxable income in accordance with \nsection 8 or 169, as the case may be. \n \n                                            \n1The words and letters “Division I or II” substituted by the Finance Act, 2010. \n2The expression “IB” omitted through Finance Act, 2020 dated 30th June, 2020 \n3 The figure and comma “140,” omitted by the Finance Act, 2003. \n4 The expression “in sections 5, 6 and 7” substituted by the Finance Act, 2022. \n5The word “or” substituted by the Finance Act, 2010. \n6 The expression “in sections 5, 6 and 7” substituted by the Finance Act, 2022. \n\n\f\nChapter II – Charge of Tax__________________________ \n \n33 \n \n1[(6)  \nWhere, by virtue of any provision of this Ordinance, income tax is to \nbe deducted at source or collected or paid in advance, it shall, as the case may \nbe, be so deducted, collected or paid, accordingly 2[.] ] \n3[  ]  \n \n4[(4AB) Subject to this Ordinance, a surcharge shall be payable by every individual \nand association of persons at the rate of ten percent of the income tax imposed \nunder Division I of Part I of the First Schedule where the taxable income exceeds \nrupees ten million 5[: \n \n \n \nProvided that in case of an individual deriving income chargeable under \nthe head “Salary”, a surcharge shall be payable at the rate of nine percent of the \nincome tax imposed under Division I of Part I of the First Schedule where the \ntaxable income exceeds rupees ten million in a tax year.] \n \n6[4B. Super tax for rehabilitation of temporarily displaced persons.― (1) A \nsuper tax shall be imposed for rehabilitation of temporarily displaced persons, for \ntax years 2015 7[and onwards], at the rates specified in Division IIA of Part I of the \nFirst Schedule, on income of every person specified in the said Division. \n \n(2)  \nFor the purposes of this section, “income” shall be the sum of the \nfollowing:— \n \n(i)  \nprofit on debt, dividend, capital gains, brokerage and \ncommission; \n \n                                            \n1 Added by the Finance Act,  2003. \n2 The semicolon substituted by the Finance Act, 2005. \n3Omitted by the Finance Act, 2014. Section 4A was added by Income Tax (Amendment) Ordinance, \ndated 30.05.2011. Earlier the identical section 4A was added by Income Tax (Amendment) \nOrdinance, dated 16.03.2011. The omitted section 4A read as follows: — \n“4A Surcharge. — (1) Subject to this Ordinance, a surcharge shall be payable by every taxpayer at \nthe rate of fifteen per cent of the income tax payable under this Ordinance including the tax payable \nunder Part V of Chapter X of Chapter XIII, as the case may be, for the period commencing from the \npromulgation of this Ordinance, till the 30th June, 2011. \n \n(2)  \nSurcharge shall be paid, collected, educated and deposited at the same time and in the \nsame manner as the tax is paid, collected, deducted and deposited under this Ordinance including \nChapter X or XII as the case may be: \nProvided that this surcharge shall not be payable for the tax year 2010 and prior tax years \nand shall be applicable, subject to the provisions of sub-section (1), for the tax year 2011 \nonly.” \n4 Section (4AB) inserted by the Finance Act, 2024. \n5 Full stop substituted by semi-colon and a new proviso added by the Finance Act, 2025.   \n6Inserted by the Finance Act, 2015. \n7The “expression” “to 2020” substituted by “and onwards” through Finance Supplementary (Second \nAmendment) Act, 2019. \n \n\n\f\nChapter II – Charge of Tax__________________________ \n \n34 \n \n(ii)  taxable income1[(other than brought forward depreciation and \nbrought forward business losses)] under section (9) of this \nOrdinance, if not included in clause (i); \n \n(iii)  imputable income as defined in clause (28A) of section 2 \nexcluding amounts specified in clause (i); and \n \n(iv) income computed, 2[other than brought forward depreciation, \nbrought forward amortization and brought forward business \nlossess] under Fourth, Fifth, Seventh and Eighth Schedules. \n \n(3)  \nThe super tax payable under sub-section (1) shall be paid, collected \nand deposited on the date and in the manner as specified in sub-section (1) of \nsection 137 and all provisions of Chapter X of the Ordinance shall apply. \n \n(4)  \nWhere the super tax is not paid by a person liable to pay it, the  \nCommissioner shall by an order in writing, determine the super tax payable, and \nshall serve upon the person, a notice of demand specifying the super tax payable \nand within the time specified under section 137 of the Ordinance. \n \n(5) \nWhere the super tax is not paid by a person liable to pay it, the \nCommissioner shall recover the super tax payable under subsection (1) and the \nprovisions of Part IV,X, XI and XII of Chapter X and Part I of Chapter XI of the \nOrdinance shall, so far as may be, apply to the collection of super tax as these \napply to the collection of tax under the Ordinance. \n \n(6) \nThe Board may, by notification in the official Gazette, make rules for \ncarrying out the purposes of this section.] \n \n3[4C. Super tax on high earning persons.― (1) A super tax shall be imposed for \ntax year 2022 and onwards at the rates specified in Division IIB of Part I of the First \nSchedule, on income of every person: \n \nProvided that this section shall not apply to a banking company for tax \nyear 2022. \n \n(2) For the purposes of this section, “income” shall be the sum of the \nfollowing:— \n  \n(i) profit on debt, dividend, capital gains, brokerage and commission; \n(ii) taxable income (other than brought forward depreciation and \nbrought forward business losses) under section 9 of the Ordinance, \nexcluding amounts specified in clause (i); \n                                            \n1Inserted by the Finance Act, 2016. \n2Inserted by the Finance Act, 2019.   \n3 Inserted by the Finance Act, 2022. \n\n\f\nChapter II – Charge of Tax__________________________ \n \n35 \n \n \n(iii) imputable income as defined in clause (28A) of section 2 excluding \namounts specified in clause (i); and  \n \n(iv) income computed, other than brought forward depreciation, \nbrought forward amortization and brought forward business losses \nunder Fourth, Fifth 1[, Seventh and Eighth] Schedules. \n \n(3) \nThe tax payable under sub-section (1) shall be paid, collected and \ndeposited on the date and in the manner as specified in sub-section (1) of section \n137 and all provisions of Chapter X of the Ordinance shall apply. \n \n(4) \nWhere the tax is not paid by a person liable to pay it, the \nCommissioner shall by an order in writing, determine the tax payable, and shall \nserve upon the person, a notice of demand specifying the tax payable and within \nthe time specified under section 137 of the Ordinance. \n \n(5) \nWhere the tax is not paid by a person liable to pay it, the \nCommissioner shall recover the tax payable under sub-section (1) and the \nprovisions of Part IV, X, XI and XII of Chapter X and Part I of Chapter XI of the \nOrdinance shall, so far as may be, apply to the collection of tax as these apply to \nthe collection of tax under the Ordinance. \n \n2[(5A) The provisions of section 147 shall apply on tax payable under this \nsection.] \n \n(6) \nThe Board may, by notification in the official Gazette, make rules for \ncarrying out the purposes of this section.] \n \n5. \nTax on dividends.— (1)  Subject to this Ordinance, a tax shall be imposed, \nat the rate specified in Division III of Part I of the First Schedule, on every person \nwho receives a dividend from a 3[  ] company 4[or treated as dividend under clause \n(19) of section 2]. \n \n(2) \nThe tax imposed under sub-section (1) on a person who receives a \ndividend shall be computed by applying the relevant rate of tax to the gross amount \nof the dividend. \n \n \n(3) \nThis section shall not apply to a dividend that is exempt from tax under \nthis Ordinance. \n \n                                            \n1  The words “and Seventh” substituted by the Finance Act, 2023. \n2  The sub-section (5A) inserted by the Finance Act, 2023. \n3The word “resident” omitted by the Finance Act, 2003. \n4Inserted by the Finance Act, 2009. \n\n\f\nChapter II – Charge of Tax__________________________ \n \n36 \n \n1[5A.  Tax on undistributed profits.—(1) For tax 2[years 2017 to 2019], a tax shall \nbe imposed at the rate of 3[five] percent of its accounting profit before tax on every \npublic company, other than a scheduled bank or a modaraba, that derives profit \nfor a tax year but does not distribute at least 4[twenty] percent of its after tax  \nprofits within six months of the end of the tax year through cash 5[ ]: \n \nProvided that for tax year 2017, bonus shares or cash dividends may \nbe distributed before the due date mentioned in sub-section (2) of section \n118, for filing of a return. \n \n(2) \nThe provisions of sub-section (1) shall not apply to— \n \n(a) \na company qualifying for exemption under clause (132) of Part \nI of the Second Schedule; and \n \n(b) \na company in which not less than fifty percent shares are held \nby the Government.] \n \n6[5AA. Tax on return on investments in sukuks.—(1) Subject to this Ordinance, \na tax shall be imposed, at the rate specified in Division IIIB of Part I of the First \n                                            \n1 section 5A substituted by the Finance Act, 2017. The substituted section read as follows:- \n“5A. Tax on undistributed reserves.—(1) Subject to this Ordinance, a tax shall be imposed at the \nrate of ten percent, on every public company other than a scheduled bank or a modaraba, that derives \nprofits for a tax year but does not distribute cash dividends within six months of the end of the said tax \nyear or distributes dividends to such an extent that its reserves, after such distribution, are in excess of \nhundred percent of its paid up capital, so much of its reserves as exceed hundred per cent of its paid \nup capital shall be treated as income of the said company: \nProvided that for tax year 2015, cash dividends may be distributed before the due date \nmentioned in sub-section (2) of section 118, for filing of return for tax year 2015. \n(2) The provisions of sub-section (1) shall not apply to— \n(a) a public company which distributes profit equal to either forty per cent of its after tax \nprofits or fifty per cent of its paid up capital, whichever is less, within six months of \nthe end of the tax year; \n(a) a company qualifying for exemption under clause (132) of Part I of the Second \nSchedule; and \n(b) a company in which not less than fifty percent shares are held by the Government. \n(3) For the purpose of this section, ‘reserve‘ includes amounts setaside out of revenue or other \nsurpluses excluding capital reserves, share premium reserves and reserves required to be \ncreated under any law, rules or regulations.”] \n2 The “expression” “year 2017 and onwards” substituted by “years 2017 to 2019” through Finance \nSupplementary (Second Amendment) Act, 2019 \n5The word “seven and half” substituted by the Finance Act, 2018 \n4The word “forty” substituted by the Finance Act, 2018 \n \n5The word “or bonus shares” omitted by the Finance Act, 2018 \n6Inserted by the Presidential Order No. F.2(1)/2016-Pub dated 31.08.2016.  \n\n\f\nChapter II – Charge of Tax__________________________ \n \n37 \n \nSchedule, on every person who receives a return on investment in sukuks from a \nspecial purpose vehicle1[, or a company]. \n \n(2) \nThe tax imposed under sub-section (1) on a person who receives a \nreturn on investment in sukuks shall be computed by applying the relevant rate of \ntax to the gross amount of the return on investment in sukuks. \n \n(3)     This section shall not apply to a return on investment in sukuks that is \nexempt from tax under this Ordinance.”] \n \n6. \nTax on certain payments to non-residents.— (1) Subject to this \nOrdinance, a tax shall be imposed, at the rate specified in Division IV of Part I of \nthe First Schedule, on every non-resident person who receives any Pakistan-\nsource royalty 2[, fee for offshore digital services 3[, fee for money transfer \noperations, card network services, payment gateway services, interbank financial \ntelecommunication services] ] or fee for technical services. \n \n \n(2) \nThe tax imposed under sub-section (1) on a non-resident person shall \nbe computed by applying the relevant rate of tax to the gross 4[amounts of receipts \nmentioned in sub-section (1)]. \n \n \n(3) \nThis section shall not apply to — \n \n(a) \nany royalty where the property or right giving rise to the royalty \nis effectively connected with a permanent establishment in \nPakistan of the non-resident person; \n \n(b) \nany fee 5[  ] where the services giving rise to the fee are \nrendered through a permanent establishment in Pakistan of the \nnon-resident person; or \n \n(c) \nany royalty or fee for technical services that is exempt from tax \nunder this Ordinance. \n \n                                            \n1Inserted by the Finance Act, 2017 \n2Inserted by the Finance Act, 2018 \n3 The expression inserted by the Finance Act, 2022. \n4 The expression “amount of the royalty 4[,free for offshore digital services]  or fee for technical \nservices” substituted by the Finance Act, 2022. \n5 The expression “for technical services 5[or fee for offshore digital services” omitted by the Finance \nAct, 2022. \n\n\f\nChapter II – Charge of Tax__________________________ \n \n38 \n \n \n(4) \nAny Pakistani-source royalty 1[ 2[or fee] received by a non-resident \nperson to which this section does not apply by virtue of clause (a) or (b) of sub-\nsection (3) shall be treated as income from business attributable to the permanent \nestablishment in Pakistan of the person.  \n \n3[6A. Tax on payments for digital transactions in e-commerce platforms.– (1) \nSubject to this Ordinance, a tax shall be imposed, at the rate specified in Division \nIVA of Part I of the First Schedule, on every person who receives payment for \nsupply of digitally ordered goods or services which are delivered from within \nPakistan using locally operated online platforms including online marketplace or \nwebsites:  \n \nProvided that the export proceeds subjected to withholding under section \n154 and 154A shall not fall within the ambit of this section.  \n \n(2) The tax imposed under sub-section (1) shall be computed by applying \nthe relevant rate of tax to the gross amounts of receipts mentioned in sub-section \n(1).] \n \n7. \nTax on shipping and air transport income of a non-resident person.— \n(1)  Subject to this Ordinance, a tax shall be imposed, at the rate specified in \nDivision V of Part I of the First Schedule, on every non-resident person carrying on \nthe business of operating ships or aircrafts as the owner or charterer thereof in \nrespect of – \n \n(a) \nthe gross amount received or receivable (whether in or out of \nPakistan) for the carriage of passengers, livestock, mail or \ngoods embarked in Pakistan; and \n \n(b) \nthe gross amount received or receivable in Pakistan for the \ncarriage of passengers, livestock, mail or goods embarked \noutside Pakistan. \n \n \n(2) \nThe tax imposed under sub-section (1) on a non-resident person shall \nbe computed by applying the relevant rate of tax to the gross amount referred to \nin sub-section (1). \n \n \n(3) \nThis section shall not apply to any amounts exempt from tax under \nthis Ordinance. \n \n                                            \n1Inserted by the Finance Act, 2018 \n2 The expression “, fee for offshore digital services] or fee for technical services” substituted by the \nFinance Act, 2022. \n3 Section 6A inserted by the Finance Act, 2025. \n\n\f\nChapter II – Charge of Tax__________________________ \n \n39 \n \n1[7A. Tax on shipping of a resident person.—(1) In the case of any resident \nperson engaged in the business of shipping, a presumptive income tax shall be \ncharged in the following manner, namely:— \n \n(a) \nships and all floating crafts including tugs, dredgers, survey \nvessels and other specialized craft purchased or bare-boat \nchartered and flying Pakistan flag shall pay tonnage tax of an \namount equivalent to one US $ per gross registered tonnage \nper annum; 2[  ]  \n \n(b)  \nships, vessels and all floating crafts including tugs, dredgers, \nsurvey vessels and other specialized craft not registered in \nPakistan and hired under any charter other than bare-boat \ncharter shall pay tonnage tax of an amount equivalent to fifteen \nUS cents per ton of gross registered tonnage per chartered \nvoyage provided that such tax shall not exceed one US $ per \nton of gross registered tonnage per annum: \n \nExplanation.—For the purpose of this section, the \nexpression “equivalent amount” means the rupee equivalent of a \nUS dollar according to the exchange rate prevalent on the first day \nof December in the case of a company and the first day of \nSeptember in other cases in the relevant assessment year 3[;and \n \n \n \n(c) \nA Pakistan resident ship owning company registered with the \nSecurities and Exchange Commission of Pakistan after the 15th \nday of November, 2019 and having its own sea worthy vessel \nregistered under Pakistan Flag shall pay tonnage tax of an \namount equivalent to seventy five US Cents per ton of gross \nregistered tonnage per annum.]  \n \n \n (2) \nThe provisions of this section shall not be applicable after the \n30thJune, 4[2030].”] \n \n5[7B.  Tax on profit on debt.—(1) Subject to this Ordinance, a tax shall be \nimposed, at the rate specified in Division IIIA of Part I of the First Schedule, on \nevery person, other than a company, who receives a profit on debt from any person \nmentioned in clauses (a) to (d) of sub-section (1)of section 151. \n \n                                            \n1Inserted by the Finance Act, 2015 \n2The word “and” omitted through Finance Act, 2020 dated 30th June, 2020 \n3 Full stop at the end substituted by semi-colon and  the word “and” thereafter new clause “(c)” shall \nbe added namely through Finance Act, 2020 dated 30th June, 2020   \n4 The word 2020 substituted by 2030 through Finance Act 2020 dated 30th June, 2020  \n5Inserted by the Finance Act, 2015 \n\n\f\nChapter II – Charge of Tax__________________________ \n \n40 \n \n(2)  \nThe tax imposed under sub-section (1) on a person, other than a \ncompany, who receives a profit on debt shall be computed by applying the relevant \nrate of tax to the gross amount of the profit on debt. \n \n1[(3) \nThis section shall not apply to a profit on debt that – \n \n \n(a) \nis exempt from tax under this Ordinance; or \n \n \n(b) \nexceeds 2[five] million Rupees.] \n \n3[7C. Tax on builders.— (1)  Subject to this Ordinance, a tax shall be imposed \non the profits and gains of a person deriving income from the business of \nconstruction and sale of residential, commercial or other buildings at the rates \nspecified in Division VIIIA of Part I of the First Schedule. \n \n(2) \nThe tax imposed under sub-section (1) shall be computed by applying \nthe relevant rate of tax to the area of the residential, commercial or other building \nbeing constructed for sale. \n \n(3) \nThe Board may prescribe: \n \n(a) \nthe mode and manner for payment and collection of tax under this \nsection; \n \n(b) \nthe authorities granting approval for computation and payment plan \nof tax; and \n \n(c) \nresponsibilities and powers of the authorities approving, suspending \nand cancelling no objection certificate to sell and the matters \nconnected and ancillary thereto. \n \n4[(4) This section shall apply to projects undertaken for construction and \nsale of residential and commercial buildings initiated and approved.─ \n \n(a) \nduring tax year 2017 only; \n(b) \nfor which payment under rule 13S of the Income Tax Rules, 2002 has \nbeen made by the developer during tax year 2017; and \n                                            \n1Sub clause 3 of 7B substituted by Finance Act, 2019, substituted clause read as follow:                   \n“(3) This section shall not apply to a profit on debt that is exempt from tax under this Ordinance.” \n2 The words “thirty six” substituted by the Finance Act, 2021. \n3 Inserted by the Finance Act, 2016. \n4Section 4 substituted by the Finance Act, 2017. The substituted section read as follows: \n“This section shall apply to business or projects undertaken for construction and sale of residential, \ncommercial or other buildings initiated and approved after the 1st July, 2016.”] \n\n\f\nChapter II – Charge of Tax__________________________ \n \n41 \n \n(c)     the Chief Commissioner has issued online schedule of advance tax \ninstallments to be paid by the developer in accordance with rule 13U \nof the Income Tax Rules, 2002.] \n \n1[7D. Tax on developers.—(1)  Subject to this Ordinance, a tax shall be imposed \non the profits and gains of a person deriving income from the business of \ndevelopment and sale of residential, commercial or other plots at the rates \nspecified in Division VIIIB of Part I of the First Schedule. \n \n(2) \nThe tax imposed under sub-section (1) shall be computed by applying \nthe relevant rate of tax to the area of the residential, commercial or other plots for \nsale. \n \n(3) \nThe Board may prescribe: \n \n(a) the mode and manner for payment and collection of tax under \nthis section; \n(b) the authorities granting approval for computation and payment \nplan of tax; and \n(c) \nresponsibilities and powers of the authorities approving, \nsuspending and cancelling no objection certificate to sell and the \nmatters connected and ancillary thereto. \n2[(4) This section shall apply to projects undertaken for development and \nsale of residential and commercial plots initiated and approved.─ \n \n(a) \nduring tax year 2017 only; \n \n(b) \nfor which payment under rule 13S of the Income Tax Rules, 2002 has \nbeen made by the developer during tax year 2017; and \n \n(c) \nthe Chief Commissioner has issued online schedule of advance tax \ninstallments to be paid by the developer in accordance with rule 13ZB \nof the Income Tax Rules, 2002.”; \n \n3[7E. Tax on deemed income.- (1) For tax year 2022 and onwards, a tax shall \nbe imposed at the rates specified in Division VIIIC of Part-I of the First Schedule \non the income specified in this section. \n \n(2) \nA resident person shall be treated to have derived, as income \nchargeable to tax under this section, an amount equal to five percent of the fair \n                                            \n1 Inserted by the Finance Act, 2016. \n2Section 4 substituted by the Finance Act, 2017. The substituted section read as follows: \n“This section shall apply to projects undertaken for development and sale of residential, \ncommercial or other plots initiated and approved after the 1st July, 2016.” \n3 Section 7E inserted by the Finance Act, 2022. \n\n\f\nChapter II – Charge of Tax__________________________ \n \n42 \n \nmarket value of capital assets situated in Pakistan held on the last day of tax year \nexcluding the following, namely:– \n \n(a) \none capital asset owned by the resident person; \n \n(b) \nself-owned business premises from where the business is \ncarried out by the persons appearing on the active taxpayers’ \nlist at any time during the year; \n \n(c) \nself-owned agriculture land where agriculture activity is carried \nout by person excluding farmhouse and land annexed thereto; \n \n(d) \ncapital asset allotted to – \n \n(i) \na Shaheed or dependents of a shaheed belonging to \nPakistan Armed Forces; \n(ii) \na person or dependents of the person who dies while in the \nservice of Pakistan armed forces or Federal or provincial \ngovernment;  \n \n(iii) a war wounded person while in service of Pakistan armed \nforces or Federal or provincial government; and \n \n(iv) an ex-serviceman and serving personal of armed forces or \nex-employees or serving personnel of Federal and \nprovincial governments, being original allottees of the \ncapital asset duly certified by the allotment authority; \n \n(e) \nany property from which income is chargeable to tax under the \nOrdinance and tax leviable is paid thereon; \n \n(f) \ncapital asset in the first tax year of acquisition where tax under \nsection 236K has been paid; \n \n(g) \nwhere the fair market value of the capital assets in aggregate \nexcluding the capital assets mentioned in clauses (a), (b), (c), \n(d), (e) and (f) does not exceed Rupees twenty-five million; \n \n(h) \ncapital assets owned by a provincial government or a local \ngovernment; or \n \n(i) \ncapital assets owned by a local authority, a development \nauthority, builders and developers for land development and \nconstruction, subject to the condition that such persons are \n\n\f\nChapter II – Charge of Tax__________________________ \n \n43 \n \nregistered with Directorate General of Designated Non-\nFinancial Businesses and Professions 1[: \n \nProvided that the exclusions mentioned at clauses (a), (e), (f) \nand (g) of this sub-section shall not apply in case of a person not \nappearing in the active taxpayers’ list, other than persons covered in \nrule 2 of the Tenth Schedule.]  \n \n(3) \nThe Federal Government may include or exclude any person or \nproperty for the purpose of this section. \n  \n(4) \nIn this section– \n \n(a) \n“capital asset” means property of any kind held by a person, \nwhether or not connected with a business, but does not include \n– \n(i) \nany stock-in-trade, consumable stores or raw materials \nheld for the purpose of business; \n(ii) \nany shares, stocks or securities; \n(iii) \nany property with respect to which the person is entitled \nto a depreciation deduction under section 22 or \namortization deduction under section 24; or \n(iv) \nany movable asset not mentioned in clauses (i), (ii) or (iii); \n \n(b) \n“farmhouse” means a house constructed on a total minimum \narea of 2000 square yards with a minimum covered area of 5000 \nsquare feet used as a single dwelling unit with or without an \nannex: \n \n \n \nProvided that where there are more than one dwelling \nunits in a compound and the average area of the compound is \nmore than 2000 square yards for a dwelling unit, each one of \nsuch dwelling units shall be treated as a separate farmhouse. \n \n2[7F. Tax on builders and developers. – (1) A tax shall be imposed at the rate \nspecified in Division I or II of Part-I of the First Schedule on the taxable profit of \nevery person deriving income from the business of – \n \n(a)  \nconstruction and sale of residential, commercial or other buildings;  \n \n(b)  \ndevelopment and sale of residential commercial or other plots; or  \n \n(c)  \nactivities as mentioned in (a) and (b) above.  \n                                            \n1  The full stop substituted with colon and new proviso added by the Finance Act, 2023. \n2 Section 7F inserted by the Finance Act, 2024. \n\n\f\nChapter II – Charge of Tax__________________________ \n \n44 \n \n \n(2) For the purpose of this section, taxable profit shall be –  \n \n(a) \nten percent of gross receipts in respect of activities specified in clause \n(a) of sub-section (1);  \n \n(b)  \nfifteen percent of gross receipts in respect of activities specified in \nclause (b) of sub-section (1); and  \n \n(c)  \ntwelve percent of gross receipts in respect of activities specified in \nclause (c) of sub-section (1).  \n \nExplanation.- For the removal of doubt, it is clarified that the provisions of \nthis section shall only apply in respect of income accruing from gross receipts from \nactivities specified in sub-section (1) and shall not be applicable to income or \nincomes from any other source or under any head of income. \n \n(3) \nWhere a taxpayer, while explaining the nature and source of the \namount credited or the investment made, money or valuable article owned or the \nfunds from which the expenditure was made, takes into account any source of \nincome which is subject to tax under this section, the taxpayer shall not be allowed \nto take credit of any sum as is in excess of taxable profit: \n \nProvided that where taxable income under section 9 is more than the taxable \nprofit under this section, taxpayer shall be entitled to take credit of such taxable \nincome subject to the payment of tax at the rate specified in Division I or II of Part-\nI of First Schedule.  \n \n(4) \nThe provisions of this section shall not apply to a builder or developer \nestablished by an Act of the Parliament or a Provincial Assembly or by a \nPresidential Order and who is engaged in activities for the benefit of its employees \nor otherwise including activities for the planning and development of and for \nproviding and regulating housing and ancillary facilities in a specified or notified \narea.] \n \n8. \nGeneral provisions relating to taxes imposed under sections 1[ 2[ 3[5, \n5A, 5AA, 6, 6A,] 7, 7A, 7B and 7E]. – (1) Subject to this Ordinance, the tax \nimposed under Sections 4[ 5[5, 5A, 5AA, 6, 6A,] 7, 7A, 7B and 7E] shall be a final \ntax on the amount in respect of which the tax is imposed and— \n \n                                            \n1 The expression “5, 6 and 7” substituted by the Finance Act, 2021.  \n2 The expression “5, 5AA, 6, 7, 7A and 7B” substituted by the Finance Act, 2022. \n3 The expression “5, 5AA, 6,” substituted by the Finance Act, 2025. \n4 The expression  ”5, 4[ ] 4[ ] 4[“, 5AA”] 6, 7, 7A 4[and 7B]”” substituted by the Finance Act, 2022. \n5 The expression “5, 5AA, 6,” substituted by the Finance Act, 2025. \n\n\f\nChapter II – Charge of Tax__________________________ \n \n45 \n \n(a) \nsuch amount shall not be chargeable to tax under any head of \nincome in computing the taxable income of the person who \nderives it for any tax year; \n \n(b) \nno deduction shall be allowable under this Ordinance for any \nexpenditure incurred in deriving the amount;  \n \n(c) \nthe amount shall not be reduced by — \n \n(i) \nany deductible allowance; or \n \n(ii) \nthe set off of any loss; \n \n(d) \nthe tax payable by a person under 1[section] 2[5, 5A, 5AA, 6, \n6A,] 7, 3[7A, 7B and 7E] shall not be reduced by any tax credits \nallowed under this Ordinance; and \n(e) \nthe liability of a person under 4[section] 5, 6 5[, 6A]   or 7 shall \nbe discharged to the extent that — \n \n(i) \nin the case of shipping and air transport income, the tax \nhas been paid in accordance with section 143 or 144, as \nthe case may be; or \n \n(ii) \nin any other case, the tax payable has been deducted at \nsource under Division III of Part V of Chapter X 6[.] \n \n \n \n \n \n7[  ] \n                                            \n1The word “sections” substituted by the word “section”by the Finance Act, 2014. \n2 The expression “5, 2[5A,2[“, 5AA”] 6,” substituted by the Finance Act, 2025. \n3 The expression “7A and 7B” substituted by the Finance Act, 2022. \n4The word “sections” substituted by the word “section”by the Finance Act, 2014. \n5 The expression inserted by the Finance Act, 2025. \n6 Colon substituted by the Finance Act, 2013. \n7 Proviso omitted by the Finance Act, 2013. The omitted proviso read as follows:  \n  “Provided that the provision of this section shall not apply to dividend received by a company.” \n\n\f\nChapter III – Tax on Taxable Income_______________________ \n \n46 \nCHAPTER III \nTAX ON TAXABLE INCOME \n \nPART I \nCOMPUTATION OF TAXABLE INCOME \n \n9. \nTaxable income.—The taxable income of a person for a tax year shall be \nthe total income 1[under clause (a) of section 10] of the person for the year reduced \n(but not below zero) by the total of any deductible allowances under Part IX of this \nChapter of the person for the year. \n \n10. \nTotal Income.— The total income of a person for a tax year shall be the \nsum of the 2[—] \n \n \n \n3[(a)  person’s income under all heads of income for the year; and] \n \n4[(b)  person’s income exempt from tax under any of the provisions of \nthis Ordinance.] \n \n11. \nHeads of income.— (1)  For the purposes of the imposition of tax and the \ncomputation of total income, all income shall be classified under the following \nheads, namely: — \n \n(a) \nSalary; \n \n5[(b) \nIncome from Property;] \n \n6[(c)  \nIncome from Business;] \n \n7[(d)  \nCapital Gains; and] \n \n8[(e)  \nIncome from Other Sources.] \n                                            \n1Inserted by the Finance Act, 2012. \n2The words “person’s income under each of the heads of income for the year” substituted by the \nFinance Act, 2012. \n3Inserted by the Finance Act, 2012. \n4Inserted by the Finance Act, 2012. \n5 Clause (b) substituted by the Finance Act, 2002. The substituted clause (b) read as follows: \n “(b) \nincome from property;” \n6 Clause (c) substituted by the Finance Act, 2002. The substituted clause (c) read as follows: \n  “(c) \nincome from business;”  \n7 Clause (d) substituted by the Finance Act, 2002. The substituted clause (d) read as follows: \n  “(d) \ncapital gains; and” \n8 Clause (e) substituted by the Finance Act, 2002. The substituted clause (e) read as follows: \n  “(e) \nincome from other sources.” \n \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n47 \n \n \n(2) \nSubject to this Ordinance, the income of a person under a head of \nincome for a tax year shall be the total of the amounts derived by the person in \nthat year that are chargeable to tax under the head as reduced by the total \ndeductions, if any, allowed under this Ordinance to the person for the year under \nthat head.  \n \n \n(3) \nSubject to this Ordinance, where the total deductions allowed under \nthis Ordinance to a person for a tax year under a head of income exceed the total \nof the amounts derived by the person in that year that are chargeable to tax under \nthat head, the person shall be treated as sustaining a loss for that head for that \nyear of an amount equal to the excess.  \n \n \n(4) \nA loss for a head of income for a tax year shall be dealt with in \naccordance with Part VIII of this Chapter. \n \n \n(5) \nThe income of a resident person under a head of income shall be \ncomputed by taking into account amounts that are Pakistan-source income and \namounts that are foreign-source income. \n \n \n(6) \nThe income of a non-resident person under a head of income shall be \ncomputed by taking into account only amounts that are Pakistan-source income. \n \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n48 \n \nPART II \nHEAD OF INCOME: SALARY \n \n12. \nSalary.— (1)  Any salary received by an employee in a tax year, other than \nsalary that is exempt from tax under this Ordinance, shall be chargeable to tax in \nthat year under the head “Salary”. \n \n \n(2) \nSalary means any amount received by an employee from any \nemployment, whether of a revenue or capital nature, including — \n \n(a) \nany pay, wages or other remuneration provided to an employee, \nincluding leave pay, payment in lieu of leave, overtime payment, \nbonus, \ncommission, \nfees, \ngratuity \nor \nwork \ncondition \nsupplements (such as for unpleasant or dangerous working \nconditions)1[;] \n \n2[  ] \n \n(b) \nany perquisite, whether convertible to money or not; \n \n(c) \nthe amount of any allowance provided by an employer to an \nemployee including a cost of living, subsistence, rent, utilities, \neducation, entertainment or travel allowance, but shall not \ninclude any allowance solely expended in the performance of \nthe employee’s duties of employment. \n \n \n \n3[Explanation.– For removal of doubt, it is clarified that the \nallowance solely expended in the performance of employee’s \nduty does not include –  \n \n(i) allowance which is paid in monthly salary on fixed basis or \npercentage of salary; or  \n \n(ii) allowance which is not wholly, exclusively, necessarily or \nactually spent on behalf of the employer;] \n \n(d) \nthe amount of any expenditure incurred by an employee that is \npaid or reimbursed by the employer, other than expenditure \nincurred on behalf of the employer in the performance of the \nemployee’s duties of employment;  \n \n                                            \n1Semi-colon substituted by the Finance Act, 2015. \n2 Omitted by the Finance Act, 2015. The omitted proviso read as follows:-   \nProvided that any bonus paid or payable to corporate employees receiving salary income of \none million rupees or more (excluding bonus) in tax year 2010, shall be chargeable to tax at the rate \nprovided in paragraph (2) of Division I of Part I of the First Schedule; \n3 Explanation added by the Finance Act, 2021. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n49 \n \n(e) \nthe amount of any profits in lieu of, or in addition to, salary or \nwages, including any amount received — \n \n  (i) \nas consideration for a person’s agreement to enter into an \nemployment relationship; \n \n (ii) \nas consideration for an employee’s agreement to any \nconditions of employment or any changes to the \nemployee’s conditions of employment; \n \n(iii) \non termination of employment, whether paid voluntarily or \nunder an agreement, including any compensation for \nredundancy or loss of employment and golden handshake \npayments;  \n(iv) \nfrom a provident or other fund, to the extent to which the \namount is not a repayment of contributions made by the \nemployee to the fund in respect of which the employee \nwas not entitled to a deduction; and \n \n(v) \nas consideration for an employee’s agreement to a \nrestrictive covenant in respect of any past, present or \nprospective employment; \n \n(f) \nany pension or annuity, or any supplement to a pension or \nannuity; and \n \n(g) \nany amount chargeable to tax as “Salary” under section 14. \n \n \n1[(2A) In case of pension under clause (f) of sub-section (2),—  \n \n(i) \nthe pension shall be charged to tax as a final tax at the rates \nspecified in the proviso to clause (2) of Division I of Part I of the \nFirst Schedule where the amount received by an individual from \na former employer for a tax year exceeds ten million rupees and \nthe individual who has attained the age of seventy years shall \nnot be charged to tax on pension income; and  \n \n(ii) \nthe pension of an individual who continues to work for former \nemployer or its associate shall be charged to tax at the rates \nspecified under clause (1) or (2) of Division I of Part I to First \nSchedule as the case may be.] \n \n(3) \nWhere an employer agrees to pay the tax chargeable on an \nemployee’s salary, the amount of the employee’s income chargeable under the \nhead “Salary” shall be grossed up by the amount of tax payable by the employer. \n \n \n(4) \nNo deduction shall be allowed for any expenditure incurred by an \nemployee in deriving amounts chargeable to tax under the head “Salary”. \n                                            \n1 Sub-section (2A) inserted by the Finance Act, 2025. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n50 \n \n \n \n(5) \nFor the purposes of this Ordinance, an amount or perquisite shall be \ntreated as received by an employee from any employment regardless of whether \nthe amount or perquisite is paid or provided — \n \n(a) \nby the employee’s employer, an associate of the employer, or \nby a third party under an arrangement with the employer or an \nassociate of the employer; \n \n(b) \nby a past employer or a prospective employer; or \n \n(c) \nto the employee or to an associate of the employee 1[or to a third \nparty under an agreement with the employee or an associate of \nthe employee.] \n \n(6) \nAn employee who has received an amount referred to in sub-clause \n(iii) of clause (e) of sub-section (2) in a tax year may, by notice in writing to the \nCommissioner, elect for the amount to be taxed at the rate computed in \naccordance with the following formula, namely: — \n \nA/B% \nwhere — \n \nA \nis the total tax paid or payable by the employee on the employee’s total \ntaxable income for the three preceding tax years; and  \n \nB \nis the employee’s total taxable income for the three preceding tax years.  \n \n(7) \nWhere — \n \n(a) \nany amount chargeable under the head “Salary” is paid to an \nemployee in arrears; and \n \n(b) \nas a result the employee is chargeable at higher rates of tax than \nwould have been applicable if the amount had been paid to the \nemployee in the tax year in which the services were rendered, \n \nthe employee may, by notice in writing to the Commissioner, elect for the \namount to be taxed at the rates of tax that would have been applicable if the salary \nhad been paid to the employee in the tax year in which the services were rendered. \n \n(8) \nAn election under sub-section (6) or (7) shall be made by the due \ndate for furnishing the employee’s return of income or employer certificate, as the \ncase may be, for the tax year in which the amount was received or by such later \ndate as the Commissioner may allow.  \n \n13. \nValue of perquisites.— (1)  For the purposes of computing the income of \nan employee for a tax year chargeable to tax under the head “Salary”, the value of \n                                            \n1 Inserted by the Finance Act, 2002 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n51 \n \nany perquisite provided by an employer to the employee in that year that is \nincluded in the employee’s salary under section 12 shall be determined in \naccordance with this section. \n \n(2) \nThis section shall not apply to any amount referred to in clause (c) or \n(d) of sub-section (2) of section 12.  \n \n1(3)  Where, in a tax year, a motor vehicle is provided by an employer to \nan employee wholly or partly for the private use of the employee, the amount \nchargeable to tax to the employee under the head “Salary” for that year shall \ninclude an amount computed as may be prescribed.] \n \n2[   ] \n \n(5) \nWhere, in a tax year, the services of a housekeeper, driver, gardener or \nother domestic assistant is provided by an employer to an employee, the amount \nchargeable to tax to the employee under the head “Salary” for that year shall include \nthe total salary paid to the domestic assistant 3[such house keeper, driver, gardener \nor other domestic assistant] in that year for services rendered to the employee, as \nreduced by any payment made 4[to the employer]for such services. \n \n(6) \nWhere, in a tax year, utilities are provided by an employer to an \nemployee, the amount chargeable to tax to the employee under the head “Salary” \nfor that year shall include the fair market value of the utilities provided, as reduced \nby any payment made by the employee for the utilities. \n \n                                            \n1Substituted by the Finance Ordinance, 2002. The substituted sub-section (3) read as follows:- \n \n“ (3) Subject to sub-section (4), where, in a tax year, a motor vehicle is provided by an employer to \nan employee wholly or partly for the private use of the employee, the amount chargeable to tax to \nthe employee under the head “Salary” for that year shall include the amount computed in accordance \nwith the following formula, namely:-  \n(A*B)-C \nWhere,  \nA \nis the cost to the employer of acquiring the motor vehicle or, if the vehicle is leased by the \nemployer, the fair market value of the vehicle at the commencement of the lease; \nB \nis- \n \n(a) \nwhere the vehicle is wholly for private use, fifteen per cent; \n \n(b) \nwhere the vehicle is only partly for private use, seven and a half per cent; and \nC \nis any payment made by the employee for the use of the motor vehicle or for its running costs.” \n2 Sub-section (4) omitted by the Finance Act, 2002. The omitted sub-section (4) read as follows: \n“(4)  \nWhere a motor vehicle referred to in sub-section (3) is available to more than one \nemployee for a tax year, the amount chargeable to tax under the head “Salary” for each such \nemployee for that year shall be the amount determined under sub-section (3) divided by the number \nof employees permitted to use the vehicle.” \n3 The words “domestic assistant” substituted by the Finance Act, 2002 \n4 The words  “by the employee” substituted by the Finance Act, 2002 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n52 \n \n1[(7) \nWhere a loan is made, on or after the 1st day of July, 2002, by an \nemployer to an employee and either no profit on loan is payable by the employee \nor the rate of profit on loan is less than the benchmark rate, the amount chargeable \nto tax to the employee under the head “Salary” for a tax year shall include an \namount equal to— \n \n(a)  the profit on loan computed at the benchmark rate, where no profit \non loan is payable by the employee, or \n \n(d) the difference between the amount of profit on loan paid by the \nemployee in that tax year and the amount of profit on loan \ncomputed at the benchmark rate, as the case may be2[:] ] \n3[Provided that this sub-section shall not apply to such benefit \narising to an employee due to waiver of interest by such employee on \nhis account with the employer4[:] ] \n \n5[Provided further that this sub-section shall not apply to loans \nnot exceeding 6[one million]rupees.] \n \n \n(8) \nFor the purposes of this Ordinance not including sub-section (7), \nwhere the employee uses a loan referred to in sub-section (7) wholly or partly for \nthe acquisition of 7[any asset or property]producing income chargeable to tax \nunder any head of income, the employee shall be treated as having paid an amount \nas profit equal to the benchmark rate on the loan or that part of the loan used to \nacquire 8[ ][asset or property.] \n \n \n(9) \nWhere, in a tax year, an obligation of an employee to pay or repay an \namount owing by the employee to the employer is waived by the employer, the \namount chargeable to tax to the employee under the head “Salary” for that year \nshall include the amount so waived. \n \n                                            \n1 Sub-section (7) substituted by the Finance Act, 2002. The substituted sub-section (7) read as \nfollows: \n“(7) \nWhere, in a tax year, a loan is made by an employer to an employee, the amount \nchargeable to tax to the employee under the head “Salary” for that year shall include the difference \nbetween the profit paid by the employee on the loan in the tax year, if any, and the profit which would \nhave been paid by the employee on the loan for the year if the loan had been made at the benchmark \nrate for that year.” \n2Full stop substituted by the Finance Act, 2010. \n3Added by the Finance Act, 2010. \n4Full stop substituted by the Finance Act, 2012. \n5Added by the Finance Act, 2012. \n6The word “five hundred thousand” substituted by Finance Act, 2017 \n7 The word “property” substituted by the Finance Act, 2002 \n8The word “the” omitted by the Finance Act, 2014 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n53 \n \n(10) \nWhere, in a tax year, an obligation of an employee to pay or repay an \namount 1[owing]by the employee to another person is paid by the employer, the \namount chargeable to tax to the employee under the head “Salary” for that year \nshall include the amount so paid. \n \n(11) \nWhere, in a tax year, property is transferred or services are provided \nby an employer to an employee, the amount chargeable to tax to the employee \nunder the head “Salary” for that year shall include the fair market value of the \nproperty or services determined at the time the property is transferred or the \nservices are provided, as reduced by any payment made by the employee for the \nproperty or services. \n \n2[(12) Where, in the tax year, accommodation or housing is provided by an \nemployer to an employee, the amount chargeable to tax to the employee under \nthe head “Salary\" for that year shall include an amount computed as may be \nprescribed.] \n \n \n(13) Where, in a tax year, an employer has provided an employee with a \nperquisite which is not covered by sub-sections (3) through (12), the amount \nchargeable to tax to the employee under the head “Salary” for that year shall \ninclude the fair market value of the perquisite, 3[except where the rules, if any, \nprovide otherwise,] determined at the time it is provided, as reduced by any \npayment made by the employee for the perquisite. \n \n4[(14) In this section,— \n \n(a)  \n“benchmark rate” means —- \n \n                                            \n1 The word “owed” substituted by the Finance Act, 2002 \n2 Sub-section (12) substituted by the Finance Act, 2002. The substituted sub-section (12) read as \nfollows: \n“(12) \nWhere, in a tax year, accommodation or housing is provided by an employer to an \nemployee, the amount chargeable to tax to the employee under the head “Salary” for that year shall \ninclude – \n(a) \nwhere the employer or an associate owns the accommodation or housing, the \nfair market rent of the accommodation or housing; or  \n(b) \nin any other case, the rent paid by the employer for the accommodation or \nhousing, as reduced by any payment made by the employee for the \naccommodation or housing.” \n3Inserted by the Finance Act, 2002 \n4 Sub-section (14) substituted  by the Finance Act, 2002. The substituted sub-section (14) read as \nfollows: \n“(14) \nIn this section, - \n“benchmark rate” means the State Bank of Pakistan discount rate at the \ncommencement of the tax year;  \n“services” includes the making available of any facility; and   \n“utilities” includes electricity, gas, water and telephone.” \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n54 \n \n(i)  \nfor the tax year commencing on the first day of July, 2002, \na rate of five per cent per annum; and  \n \n(ii)  \nfor the tax years next following the tax year referred to in \nsub-clause (i), the rate for each successive year taken at \none per cent above the rate applicable for the immediately \npreceding tax year, but not exceeding 1[ten per cent per \nannum]  in respect of any tax year;  \n \n(b)  \n“services” includes the provision of any facility; and  \n \n(c)  \n“utilities” includes electricity, gas, water and telephone.] \n \n14. \nEmployee share schemes.— (1) The value of a right or option to acquire \nshares under an employee share scheme granted to an employee shall not be \nchargeable to tax. \n \n \n(2) \nSubject to sub-section (3), where, in a tax year, an employee is issued \nwith shares under an employee share scheme including as a result of the exercise \nof an option or right to acquire the shares, the amount chargeable to tax to the \nemployee under the head “Salary” for that year shall include the fair market value \nof the shares determined at the date of issue, as reduced by any consideration \ngiven by the employee for the shares including any amount given as consideration \nfor the grant of a right or option to acquire the shares. \n \n \n(3) \nWhere shares issued to an employee under an employee share \nscheme are subject to a restriction on the transfer of the shares — \n \n(a) \nno amount shall be chargeable to tax to the employee under the \nhead “Salary” until the earlier of — \n \n (i) \nthe time the employee has a free right to transfer the \nshares; or \n \n(ii)  \nthe time the employee disposes of the shares; and  \n \n(b) \nthe amount chargeable to tax to the employee shall be the fair \nmarket value of the shares at the time the employee has a free \nright to transfer the shares or disposes of the shares, as the \ncase may be, as reduced by any consideration given by the \nemployee for the shares including any amount given as \nconsideration for the grant of a right or option to acquire the \nshares. \n \n                                            \n1The words “such rate, if any, as the Federal. Government may, by notification, specify” substituted \nby the Finance Act, 2012 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n55 \n \n \n(4) \nFor purposes of this Ordinance, where sub-section (2) or (3) applies, \nthe cost of the shares to the employee shall be the sum of — \n \n(a) \nthe consideration, if any, given by the employee for the shares; \n \n(b) \nthe consideration, if any, given by the employee for the grant of \nany right or option to acquire the shares; and \n \n(c) \nthe amount chargeable to tax under the head “Salary” under \nthose sub-sections. \n \n \n(5) \nWhere, in a tax year, an employee disposes of a right or option to \nacquire shares under an employee share scheme, the amount chargeable to tax \nto the employee under the head “Salary” for that year shall include the amount of \nany gain made on the disposal computed in accordance with the following formula, \nnamely:— \n \nA—B \nwhere — \n \nA \nis the consideration received for the disposal of the right or option; and \n \nB \nis the employee’s cost in respect of the right or option. \n \n \n(6) \nIn this sub-section, “employee share scheme” means any agreement \nor arrangement under which a company may issue shares in the company to — \n \n(a) \nan employee of the company or an employee of an associated \ncompany; or \n \n(b) \nthe trustee of a trust and under the trust deed the trustee may \ntransfer the shares to an employee of the company or an \nemployee of an associated company. \n \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n56 \n \nPART III \nHEAD OF INCOME: INCOME FROM PROPERTY \n \n15. \nIncome from property.— (1)  The rent received or receivable by a person \n1[for] a tax year, other than rent exempt from tax under this Ordinance, shall be \nchargeable to tax in that year under the head “Income from Property”. \n \n \n(2) \nSubject to sub-section (3), “rent” means any amount received or \nreceivable by the owner of land or a building as consideration for the use or \noccupation of, or the right to use or occupy, the land or building, and includes any \nforfeited deposit paid under a contract for the sale of land or a building. \n \n \n(3) \nThis section shall not apply to any rent received or receivable by any \nperson in respect of the lease of a building together with plant and machinery and \nsuch rent shall be chargeable to tax under the head “Income from Other Sources”. \n \n2[(3A)  \nWhere any amount is included in rent received or receivable by any \nperson for the provision of amenities, utilities or any other service connected with \nthe renting of the building, such amount shall be chargeable to tax under the head \n“Income from Other Sources”.] \n \n(4) \nSubject to sub-section (5), where the rent received or receivable by a \nperson is less than the fair market rent for the property, the person shall be treated \nas having derived the fair market rent for the period the property is let on rent in \nthe tax year. \n \n(5) \nSub-section (4) shall not apply where the fair market rent is included \nin the income of the lessee chargeable to tax under the head “Salary”. \n \n \n3[  ]  \n \n \n4[  ]   \n \n5[  ] \n                                            \n1 Substituted for the word “in” by the Finance Act, 2003. \n2 Inserted by the Finance Act, 2003. \n3 Sub-section (6) omitted by the Finance Act, 2013. The omitted sub-section (6) read as follows: \n“(6)  \nIncome under this section shall be liable to tax at the rate specified in Division VI of Part \nI of the First Schedule.” \n4Sub-section (7) omitted by the Finance Act, 2013. The omitted sub-section (6) read as follows: \n“(7)  \nthe provisions of sub-section (1), shall not apply in respect of a taxpayer who—  \n \n   (i)  \nis an individual or association of persons;  \n \n  (ii)  \nderives income chargeable to tax under this section not exceeding  Rs. 150,000 in a \ntax year; and \n (iii)  \ndoes not derive taxable income under any other head.” \n5 Clause (6) inserted by the Finance Act, 2016. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n57 \n \n1[   ]  \n \n2[    ] \n \n 3[   ]   \n \n4[15A. \nDeductions in computing income chargeable under the head \n“Income from Property”.— (1) In computing the income of a 5[ ] 6[person] \nchargeable to tax under the head “Income from Property” for a tax year, a \ndeduction shall be allowed for the following expenditures or allowances, namely:- \n \n(a)   In respect of repairs to a building, an allowance equal to one-fifth of \nthe rent chargeable to tax in respect of the building for the year, \ncomputed before any deduction allowed under this section; \n \n(b) \nany premium paid or payable by the 7[  ] 8[person]  in the year to insure \nthe building against the risk of damage or destruction; \n \n(c) \nany local rate, tax, charge or cess in respect of the property or the rent \nfrom the property paid or payable by the 9[  ] 10[person]  to any local \nauthority or government in the year, not being any tax payable under \nthis Ordinance; \n \n(d) \nany ground rent paid or payable by the 11[  ] 12[person]  in the year in \nrespect  of the property; \n \n(e) \nany profit paid or payable by the 13[ ] 14[person]  in the year on any \nmoney borrowed including by way of mortgage, to acquire, construct, \nrenovate, extend or reconstruct the property; \n                                            \n1 Clause (6) omitted by the Finance Act, 2021. The omitted clause read as follows: \n    “(6) \nIncome under this section derived by an individual or an association of persons shall be liable \nto tax at the rate specified in Division VIA of Part I of the First Schedule.”   \n2 Clause (7) inserted by the Finance Act, 2016. \n3 Clause (7) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(7) \nThe provisions of sub-section (1), shall not apply in respect of an individual  or association of \npersons who derive income chargeable to tax under this section not exceeding two hundred \nthousand rupees in a tax year and does not derive taxable income under any other head.” \n4Inserted by the Finance Act, 2013. \n5 The word “person” substituted by the Finance Act, 2016. \n6 The word “company” substituted by the Finance Act, 2021.  \n7The word “person” substituted by the Finance Act, 2016. \n8 The word “company” substituted by the Finance Act, 2021.  \n9The word “person” substituted by the Finance Act, 2016. \n10 The word “company” substituted by the Finance Act, 2021.  \n11The word “person” substituted by the Finance Act, 2016. \n12 The word “company” substituted by the Finance Act, 2021.  \n13 The word “person” substituted by the Finance Act, 2016. \n14 The word “company” substituted by the Finance Act, 2021.  \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n58 \n \n(f)  \nwhere the property has been acquired, constructed, renovated, \nextended, or reconstructed by the 1[ ] 2[person] with capital contributed \nby the House Building Finance Corporation or a scheduled bank under \na scheme of investment in property on the basis of sharing the rent \nmade by the Corporation or bank, the share in rent and share towards \nappreciation in the value of property (excluding the return of capital, if \nany) from the property paid or payable by the 3[  ] 4[person] to the said \nCorporation or the bank in the year under that scheme; \n \n(g)  \nwhere the property is subject to mortgage or other capital charge, the \namount of profit or interest paid on such mortgage or charge; \n \n5[(h)  any expenditure, not exceeding 6[four] per cent of the rent chargeable \nto tax in respect of the property for the year computed before any \ndeduction allowed under this section, paid or payable by the 7[ ] \n8[person] in the year wholly and exclusively for the purpose of deriving \nrent chargeable to tax under the head, “Income from Property” \nincluding administration and collection charges;”] \n \n(i) \nany expenditure paid or payable by the 9[  ] 10[person] in the tax year \nfor legal services acquired to defend the 11[  ] 12[persons]’s title to the \nproperty or any suit connected with the property in a court; and \n \n(j) \nwhere there are reasonable grounds for believing that any unpaid rent \nin respect of the property is irrecoverable, an allowance equal to the \nunpaid rent where— \n \n(i) \nthe tenancy was bona fide, the defaulting tenant has vacated \nthe property or steps have been taken to compel the tenant to \nvacate the property and the defaulting tenant is not in \noccupation of any other property of the 13[  ] 14[person]; \n                                            \n1The word “person” substituted by the Finance Act, 2016. \n2 The word “company” substituted by the Finance Act, 2021.  \n3The word “person” substituted by the Finance Act, 2016. \n4 The word “company” substituted by the Finance Act, 2021.  \n5Clause (h) substituted by the Finance Act, 2015. The substituted (h) read as follows:- \n“(h)  any expenditure (not exceeding six per cent of the rent chargeable to tax in respect of the \nproperty for the year computed before any deduction allowed under this section) paid or \npayable by the person in the year for the purpose of collecting the rent due in respect of \nthe property;” \n6The word “six” substituted by “four” through Finance Act, 2020 dated 30th June, 2020 \n7The word “person” substituted by the Finance Act, 2016. \n8 The word “company” substituted by the Finance Act, 2021.  \n9The word “person” substituted by the Finance Act, 2016. \n10 The word “company” substituted by the Finance Act, 2021.  \n11The word “person” substituted by the Finance Act, 2016. \n12 The word “company” substituted by the Finance Act, 2021.  \n13The word “person” substituted by the Finance Act, 2016. \n14 The word “company” substituted by the Finance Act, 2021.  \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n59 \n \n(ii) \nthe 1[ ] 2[persons] has taken all reasonable steps to institute \nlegal proceedings for the recovery of the unpaid rent or has \nreasonable grounds to believe that legal proceedings would be \nuseless; and  \n \n(iii) \nthe unpaid rent has been included in the income of the 3[ ] \n4[persons] chargeable to tax under the head “Income from \nProperty” for the tax year in which the rent was due and tax has \nbeen duly paid on such income. \n \n \n(2)  Where any unpaid rent allowed as a deduction under clause (j) of \nsub-section (1) is wholly or partly recovered, the amount recovered shall be \nchargeable to tax in the tax year in which it is recovered. \n \n \n(3)  Where a person has been allowed a deduction for any expenditure \nincurred in deriving rent chargeable to tax under the head “Income from Property” \nand the person has not paid the liability or a part of the liability to which the \ndeduction relates within three years of the end of the tax year in which the \ndeduction was allowed, the unpaid amount of the liability shall be chargeable to \ntax under the head “Income from Property” in the first tax year following the end of \nthe three years. \n \n \n(4)  Where an unpaid liability is chargeable to tax as a result of the \napplication of sub-section (3) and the person subsequently pays the liability or a \npart of the liability, the person shall be allowed a deduction for the amount paid in \nthe tax year in which the payment is made. \n \n \n(5)  Any expenditure allowed to a person under this section as a \ndeduction shall not be allowed as a deduction in computing the income of the \nperson chargeable to tax under any other head of income.  \n \n \n(6)  The provisions of section 21 shall apply in determining the \ndeductions allowed to a person under this section in the same manner as they \napply in determining the deductions allowed in computing the income of a person \nchargeable to tax under the head “Income from Business”.] \n \n \n5[  ] \n  \n \n 6[   ] \n                                            \n1The word “person” substituted by the Finance Act, 2016. \n2 The word “company” substituted by the Finance Act, 2021.  \n3The word “person” substituted by the Finance Act, 2016. \n4 The word “company” substituted by the Finance Act, 2021.  \n5 New sub-section (7) added by Finance Act, 2019 \n6 Sub-section (7) omitted by the Finance Act, 2021. The omitted sub-section read as follows: \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n60 \n \n16. \nNon-adjustable amounts received in relation to buildings.— (1)  Where \nthe owner of a building receives from a tenant an amount which is not adjustable \nagainst the rent payable by the tenant, the amount shall be treated as rent \nchargeable to tax under the head “Income from Property” in the tax year in which \nit was received and the following nine tax years in equal proportion. \n \n \n(2) \nWhere an amount (hereinafter referred to as the “earlier amount”) \nreferred to in sub-section (1) is refunded by the owner to the tenant on termination \nof the tenancy before the expiry of ten years, no portion of the amount shall be \nallocated to the tax year in which it is refunded or to any subsequent tax year \nexcept as provided for in sub-section (3). \n \n \n(3) \nWhere the circumstances specified in sub-section (2) occur and the \nowner lets out the building or part thereof to another person (hereinafter referred \nto as the “succeeding tenant”) and receives from the succeeding tenant any \namount (hereinafter referred to as the “succeeding amount”) which is not \nadjustable against the rent payable by the succeeding tenant, the succeeding \namount as reduced by such portion of the earlier amount as was charged to tax \nshall be treated as rent chargeable to tax under the head “Income from Property” \nas specified in sub-section (1). \n1[  ] \n                                            \n“(7) \nNotwithstanding sub-section (6) of section 15, the provisions of this section shall apply to \nan individual or an association of persons,6[ ] who opts to pay tax at the rate specified in \nDivision I of Part I of the First Schedule.” \n1 Section 17 omitted  by the Finance Act, 2006. The omitted section 17 read as follows:  \n \n“17. \nDeductions in computing income chargeable under the head “Income from \nProperty”.- (1)  In computing the income of a person chargeable to tax under the head “Income from \nProperty” for a tax year, a deduction shall be allowed for the following expenditures or allowances, \nnamely:– \n(a) In respect of repairs to a building, an allowance equal to one-fifth of the rent chargeable to tax in respect \nof the building for the year, computed before any deduction allowed under this section; \n(b) any premium paid or payable by the person in the year to insure the building against the risk \nof damage or destruction; \n(c) any local rate, tax, charge, or cess in respect of the property or the rent from the property paid \nor payable by the person to any local authority or government in the year, not being any tax \npayable under this Ordinance; \n(d) any ground rent paid or payable by the person in the year in respect of the property; \n(e) any profit paid or payable by the person in the year on any money borrowed including by way \nof mortgage, to acquire, construct, renovate, extend, or reconstruct the property; \n(f) \nwhere the property has been acquired, constructed, renovated, extended, or reconstructed by \nthe person with capital contributed by the House Building Finance Corporation or a scheduled \nbank under a scheme of investment in property on the basis of sharing the rent made by the \nCorporation or bank, the share in rent and share towards appreciation in the value of property \n(excluding the return of capital, if any) from the property paid or payable by the person to the \nsaid Corporation or the bank in the year under that scheme; \n (fa)  where the property is subject to mortgage or other capital charge, the amount of profit or interest \npaid on such mortgage or charge; \n(g) any expenditure (not exceeding six per cent of the rent chargeable to tax in respect of the \nproperty for the year computed before any deduction allowed under this section) paid or \npayable by the person in the year for the purpose of collecting the rent due in respect of the \nproperty; \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n61 \n \nPART IV \nHEAD OF INCOME: INCOME FROM BUSINESS \n \nDivision I \nIncome from Business \n \n18. \nIncome from business.— (1)  The following incomes of a person for a tax \nyear, other than income exempt from tax under this Ordinance, shall be chargeable \nto tax under the head “Income from Business” — \n \n(a) the profits and gains of any business carried on by a person at any time \nin the year; \n \n(b) any income derived by any trade, professional or similar association from \nthe sale of goods or provision of services to its members 1[. \n  \nExplanation.– For the removal of doubt, it is clarified that income \nderived by co-operative societies 2[including recreational club] from the \nsale of goods, immoveable property or provision of services to its \n                                            \n(h) any expenditure paid or payable by the person in the tax year for legal services acquired to defend the \nperson’s title to the property or any suit connected with the property in a Court; and \n(i) \nwhere there are reasonable grounds for believing that any unpaid rent in respect of the \nproperty is irrecoverable, an allowance equal to the unpaid rent where – \n  (i) \nthe tenancy was bona fide, the defaulting tenant has vacated the property or steps have \nbeen taken to compel the tenant to vacate the property, and the defaulting tenant is not \nin occupation of any other property of the person; \n (ii) \nthe person has taken all reasonable steps to institute legal proceedings for the recovery \nof the unpaid rent or has reasonable grounds to believe that legal proceedings would \nbe useless; and \n(iii) \nthe unpaid rent has been included in the income of the person chargeable to tax under \nthe head “Income from Property” for the tax year in which the rent was due and tax has \nbeen duly paid on such income. \n \n(2) \nWhere any unpaid rent allowed as a deduction under clause (i) of sub-section (1) is \nwholly or partly recovered, the amount recovered shall be chargeable to tax in the tax year in which it \nis recovered. \n \n(3) \nWhere a person has been allowed a deduction for any expenditure incurred in deriving \nrent chargeable to tax under the head “Income from Property” and the person has not paid the liability \nor a part of the liability to which the deduction relates within three years of the end of the tax year in \nwhich the deduction was allowed, the unpaid amount of the liability shall be chargeable to tax under \nthe head “Income from Property” in the first tax year following the end of the three years. \n \n(4) \nWhere an unpaid liability is chargeable to tax as a result of the application of sub-section \n(3) and the person subsequently pays the liability or a part of the liability, the person shall be allowed a \ndeduction for the amount paid in the tax year in which the payment is made.  \n \n(5) \nAny expenditure allowed to a person under this section as a deduction shall not be \nallowed as a deduction in computing the income of the person chargeable to tax under any other head \nof income. \n \n(6) \nThe provisions of section 21 shall apply in determining the deductions allowed to a \nperson under this section in the same manner as they apply in determining the deductions allowed in \ncomputing the income of a person chargeable to tax under the head “Income from Business”.” \n1 Semi colon substituted and Explanation added by the Finance Act, 2021. \n2 Words inserted by the Finance Act, 2025. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n62 \n \nmembers is and has always been chargeable to tax under the \nprovisions of this Ordinance;] \n \n(c) \nany income from the hire or lease of tangible movable property;  \n \n(d) \nthe fair market value of any benefit or perquisite, whether \nconvertible into money or not, derived by a person in the course \nof, or by virtue of, a past, present, or prospective business \nrelationship1[.]  \n \n2[Explanation. — For the purposes of this clause, it is declared that \nthe word ‘benefit’ includes any benefit derived by way of waiver of \nprofit on debt or the debt itself under the State Bank of Pakistan \nBanking Policy Department’s Circular No.29 of 2002 or in any other \nscheme issued by the State Bank of Pakistan;] \n \n(e) \nany management fee derived by a management company \n(including a modaraba 3[management company] ).]   \n \n4[Explanation.—For the removal of doubt it is clarified that \nincome subject to taxation under sections 5A, 5AA, 6, 7 and 7A \nshall not be chargeable to tax under this section.”] \n \n \n(2) \nAny profit on debt derived by a person where the person’s business is \nto derive such income shall be chargeable to tax under the head “Income from \nBusiness” and not under the head “Income from Other Sources”. \n \n5[(3) Where a 6[lessor], being a scheduled bank or an investment bank or \na development finance institution or a modaraba or a leasing company has leased \nout any asset, whether owned by it or not, to another person, any amount paid or \npayable by the said person in connection with the lease of said asset shall be \ntreated as the income of the said 7[lessor] and shall be chargeable to tax under the \nhead “Income from Business”.] \n \n8[(4) Any amount received by a banking company or a non-banking finance \ncompany, where such amount represents distribution by a mutual fund 9[or a \n                                            \n1The semi-colon and the word “and” substituted by the Finance Act, 2011. \n2Inserted by the Finance Act, 2011. \n3 Inserted by the Finance Act, 2002 \n4 Added by the Finance Act, 2018 \n \n5 Added by the Finance Act, 2003. \n6The word “lesser”  substituted by the word “lessor”  by the Finance Act, 2014. \n7The word “lesser”  substituted by the word “lessor”  by the Finance Act, 2014. \n8Added by the Finance Act, 2003. \n9Inserted by the Finance Act, 2007. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n63 \n \nPrivate Equity and Venture Capital Fund] out of its income from profit on debt, shall \nbe chargeable to tax under the head “Income from Business” and not under the \nhead “Income from Other Sources”.] \n \n19. \nSpeculation business.— (1)  Where a person carries on a speculation \nbusiness – \n \n(a) \nthat business shall be treated as distinct and separate from any \nother business carried on 1[by]the person; \n \n(b) \nthis Part shall apply separately to the speculation business and \nthe other business of the person; b head “Income from \nBusiness” for that year; and \n \n(e) \nany loss of the person arising from the speculation business \nsustained for a tax year computed in accordance with this Part \nshall be dealt with under section 58. \n \n \n(2) \nIn this section, “speculation business” means any business in which a \ncontract for the purchase and sale of any commodity (including 2[stocks] and \nshares) is periodically or ultimately settled otherwise than by the actual delivery or \ntransfer of the commodity, but does not include a business in which — \n \n(a) \na contract in respect of raw materials or merchandise is entered \ninto by a person in the course of a manufacturing or mercantile \nbusiness to guard against loss through future price fluctuations \nfor the purpose of fulfilling the person’s other contracts for the \nactual delivery of the goods to be manufactured or merchandise \nto be sold; \n(b) \na contract in respect of stocks and shares is entered into by a \ndealer or investor therein to guard against loss in the person’s \nholding of stocks and shares through price fluctuations; or \n \n(c) \na contract is entered into by a member of a forward market or \nstock exchange in the course of any transaction in the nature of \njobbing 3[arbitrage] to guard against any loss which may arise in \nthe ordinary course of the person’s business as such member. \n \n \n \n                                            \n1Inserted by the Finance Act, 2002 \n2 The word “stock” substituted by the Finance Act, 2005. \n3 The word “arbitrate” substituted by the Finance Act, 2005. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n64 \n \nDivision II \nDeductions: General Principles \n \n20. \nDeductions in computing income chargeable under the head “Income \nfrom Business”.— (1)  Subject to this Ordinance, in computing the income of a \nperson chargeable to tax under the head “Income from Business” for a tax year, a \ndeduction shall be allowed for any expenditure incurred by the person in the year \n1[wholly and exclusively for the purposes of business]. \n \n \n2[(1A) Subject to this Ordinance, where animals which have been used for \nthe purposes of the business or profession otherwise than as stock-in-trade and \nhave died or become permanently useless for such purposes, 3[a deduction shall \nbe allowed equal to] the difference between the actual cost to the taxpayer of the \nanimals and the amount, if any, realized in respect of the carcasses or animals.] \n \n \n(2) \nSubject to this Ordinance, where the expenditure referred to in sub-\nsection (1) is incurred in acquiring a depreciable asset or an intangible with a useful \nlife of more than one year or is pre-commencement expenditure, the person must \ndepreciate or amortise the expenditure in accordance with sections 22, 23, 24 and \n25. \n \n4[(3) Subject to this Ordinance, where any expenditure is incurred by an \namalgamated company on legal and financial advisory services and other \nadministrative cost relating to planning and implementation of amalgamation, a \ndeduction shall be allowed for such expenditure.] \n \n21. \nDeductions not allowed.— Except as otherwise provided in this \nOrdinance, no deduction shall be allowed in computing the income of a person \nunder the head “Income from Business” for — \n \n(a) \nany cess, rate or tax paid or payable by the person in Pakistan or a \nforeign country that is levied on the profits or gains of the business or \nassessed as a percentage or otherwise on the basis of such profits or \ngains; \n(b) \nany amount of tax deducted under Division III of Part V of Chapter X \nfrom an amount derived by the person;  \n                                            \n1 The words “to the extent the expenditure is incurred in deriving income from business chargeable to \ntax” substituted by the Finance Act, 2004. \n2Inserted by the Finance Act, 2009. \n3 Inserted by the Finance Act, 2021. \n4 Added  by the Finance Act, 2002 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n65 \n \n1[(c) any expenditure from which the person is required to deduct or collect \ntax under Part V of Chapter X or Chapter XII, unless the person has \npaid or deducted and paid the tax as required by Division IV of Part V \nof Chapter X: \nProvided that disallowance in respect of purchases of raw \nmaterials and finished goods under this clause shall not exceed twenty \nper cent of purchases of raw materials and finished goods: \nProvided further that recovery of any amount of tax under \nsections 161 or 162 shall be considered as tax paid.] \n2[(ca) any amount of commission paid or payable in respect of supply of \nproducts listed in the Third Schedule of the Sales Tax Act, 1990, \nwhere the amount of commission paid or payable exceeds 0.2 percent \nof gross amount of supplies thereof unless the person to whom \ncommission is paid or payable, as the case may be, is appearing in \nthe active taxpayer list under this Ordinance;]  \n(d) \nany entertainment expenditure in excess of such limits 3[or in violation \nof such conditions] as may be prescribed; \n(e) \nany contribution made by the person to a fund that is not a recognized \nprovident fund4[,]5[approved pension fund], approved superannuation \nfund or approved gratuity fund; \n6[(ea) an amount in excess of fifty percent of contribution made by a person \nto an approved gratuity fund, an approved pension fund or an \napproved superannuation fund.]  \n \n(f) \nany contribution made by the person to any provident or other fund \nestablished for the benefit of employees of the person, unless the \nperson has made effective arrangements to secure that tax is \ndeducted under section 149 from any payments made by the fund in \nrespect of which the recipient is chargeable to tax under the head \n\"Salary\";  \n                                            \n1Clause (c) substituted by the Finance Act, 2016. The substituted clause (c) read as follows: \n“(c) any salary, rent, brokerage or commission, profit on debt, payment to non-resident, payment \nfor services or fee paid by the person from which the person is required to deduct tax under \nDivision III of Part V of Chapter X or section 233 of chapter XII, 1[unless] the person has 1[paid \nor] deducted and paid the tax as required by Division IV of Part V of Chapter X” \n2New clause (ca) inserted by Finance Act, 2019. \n3 Inserted by the Finance Act, 2003. \n4Inserted by Finance Act, 2014. \n5 Inserted by the Finance Act, 2005. \n6 Clause (ea) inserted by the Finance Act, 2022. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n66 \n \n(g) \nany fine or penalty paid or payable by the person for the violation of \nany law, rule or regulation; \n(h) \nany personal expenditures incurred by the person;  \n(i) \nany amount carried to a reserve fund or capitalised in any way;  \n(j) \nany profit on debt, brokerage, commission, salary or other \nremuneration paid by an association of persons to a member of the \nassociation;  \n \n1[  ] \n  2[(l)  \nany expenditure for a transaction, paid or payable under a  single account \nhead which, in aggregate, exceeds 3[two hundred and fifty]  thousand \nrupees, made other than by a crossed cheque drawn on a bank or by \ncrossed bank draft or crossed pay order or any other crossed banking \ninstrument showing transfer of amount from the business bank account \nof the taxpayer: \nProvided that online transfer of payment from the business \naccount of the payer to the business account of payee as well as \npayments through credit card shall be treated as transactions through \nthe banking channel, subject to the condition that such transactions \nare verifiable from the bank statements of the respective payer and \nthe payee: \nProvided further that this clause shall not apply in the case of — \n(a)  \nexpenditures not exceeding \n4[twenty-five] thousand \nrupees;  \n \n \n(b)  \nexpenditures on account of — \n \n \n \n(i)  \nutility bills; \n \n \n \n(ii)  \nfreight charges; \n                                            \n1 Clause (k) omitted by the Finance Act, 2006. The omitted clause (k) read as follows: \n “(k) any expenditure paid or payable by an employer on the provision of perquisites and allowances \nto an employee where the sum of the value of the perquisites computed under section 13 and \nthe amount of the allowances exceeds fifty per cent of the employee’s salary for a tax year \n(excluding the value of the perquisites or amount of the allowances);” \n2 Clause (l) substituted by the Finance Act, 2006. The substituted clause (l) read as follows: \n“(l) any expenditure paid or payable under a single account head which, in aggregate, exceeds fifty \nthousand rupees made other than by a crossed bank cheque or crossed bank draft, except \nexpenditures not exceeding ten thousand rupees or on account of freight charges, travel fare, \npostage, utilities or payment of taxes, duties, fee, fines or any other statutory obligation;” \n3 Expression substituted through Finance Act, 2020 dated 30th June, 2020 \n4 Expression substituted through Finance Act, 2020 dated 30th June, 2020 \n \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n67 \n \n \n \n \n \n(iii)  \ntravel fare;  \n \n \n \n \n(iv)  postage; and \n(v)  \npayment of taxes, duties, fee, fines or any other  \nstatutory obligation 1[:]] \n2[Provided further also that this clause shall not \napply to a company from the date clause (la) has been \nmade effective through the notification issued by the \nBoard. \n \n \n \n(la) \nany expenditure by a taxpayer being a company for a transaction, paid \nor payable under a single account head which, in aggregate, exceeds \nrupees two hundred and fifty thousand, made other than by digital \nmeans from business bank account of the taxpayer notified to the \nCommissioner under section 114A: \n \nProvided that this clause shall not apply in the case of- \n \n(a) \nexpenditures not exceeding Rupees twenty-five thousand; and \n(b) \nexpenditures on account of — \n(i) \nutility bills;  \n(ii) \nfreight charges; \n(iii) \ntravel fare; \n(iv) \npostage; and \n(v) \npayment of taxes, duties, fee, fines or any other statutory \nobligation: \n \nProvided further that this clause shall be effective from such date \nas the Board may notify.] \n  \n \n(m) \nany salary paid or payable exceeding 3[  ] 4[thirty-two thousand rupees \nper month to an individual] other than by a crossed cheque or direct \ntransfer of funds to the employee’s bank account 5[or through digital \nmeans]; 6[   ] \n                                            \n1 Semi colon substituted by the Finance Act, 2022. \n2 Inserted by the Finance Act, 2022. \n3 The word “fifteen” substituted by the Finance Act, 2020 dated 30th June, 2020. \n4 The expression “twenty-five thousand rupees per month” substituted by the Finance Act, \n2023. \n5 Inserted by the Finance Act, 2022. \n6 The word “and” omitted by the Finance Act, 2016. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n68 \n \n(n) \nexcept as provided in Division III of this Part, any expenditure paid or \npayable of a capital nature; 1[   ]  \n2[(o) \nany expenditure in respect of sales promotion, advertisement and \npublicity in excess of 3[ten] per cent of turnover incurred by \npharmaceutical manufacturers 4[;] ] \n5[(p) \nany expenditure on account of utility bill in excess of such limits and in \nviolation of such conditions as may be prescribed; 6[  ]  \n7[(q)  \nten percent of the claimed expenditure made attributable to purchases \nmade from persons who are not National Tax Number holders:  \nProvided that in case of purchase of agricultural produce this \nclause shall only apply to the purchase made from middle man:  \nProvided further that the Board may, by notification in the official \nGazette, exempt persons or classes of persons from this clause \nsubject to such conditions and limitations as may be specified therein;] \n8[(r)  any expenditure attributable to sales claimed by any person who is \nrequired to integrate but fails to integrate his business with the Board \nthrough approved fiscal electronic device and software: \n \n                                            \n1 The word “and” omitted by the Finance Act, 2020 dated 30th June, 2020. \n2 Inserted by the Finance Act, 2016 \n3 The word “five” substituted by the Finance Act, 2017 \n4 Full stop substituted by semi colon through Finance Act, 2020 dated 30th June, 2020 \n5 New clauses (p) and (q)  added through Finance Act, 2020 dated 30th June, 2020 \n6 The word “and” omitted by the Finance Act, 2025. \n7 Clause (q) substituted by the Finance Act, 2025. The substituted clause read as follows: \n   “(q) \nany expenditure attributable to sales made to persons required to be registered but not \nregistered under the Sales Tax Act, 1990 by an industrial undertaking computed according to \nthe following formula, namely:- \n (A/B) x C \n \nWhere— \n \nA \nis the total amount of deductions claimed under this Part; \n \nB \nis the turnover for the tax year; and  \nC \nis the total amount of sales exclusive of sales tax and federal excise duty to persons \nrequired to be registered but not registered under the Sales Tax, 1990 where sales \nequal or exceed rupees one hundred million per person: \n \n \n \nProvided that disallowance of expenditure under this clause shall not exceed \nten percent of total deductions claimed under this Part: \n \n \n \nProvided further that the Board may, by notification in the official Gazette, \nexempt persons or classes of persons from this clause subject to such conditions and \nlimitations as may be specified therein: \n \n \n \nProvided also that this clause shall come into force with effect from the first day \nof October, 2020.]” \n8 Inserted by the Finance Act, 2022. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n69 \n \nProvided that disallowance of expenditure under this clause \nshall not exceed eight percent of the allowable deduction 1[; and] ]  \n \n2[(s) fifty percent of the expenditure claimed in respect of sale where the \ntaxpayer received payment exceeding two hundred thousand rupees \notherwise than through a banking channel or digital means against a \nsingle invoice containing one or more than one transactions of supply \nof goods or provisions of services.] \n \nDivision III \nDeductions: Special Provisions \n \n22. \nDepreciation.— (1)  Subject to this section, a person shall be allowed a \ndeduction for the depreciation of the person’s depreciable assets used in the \nperson’s business in the tax year 3[: \n \nProvided that the depreciation expense shall not be allowed for the \namount paid for addition of capital assets to a seller in all relevant tax years \nif the tax deductible under sections 152 or 153 of the Ordinance in respect \nof those payments has not been deducted and deposited in the treasury, by \nnot adding such amount paid for addition in capital assets in the assets for \ncomputation of tax depreciation.] \n \n \n(2) \nSubject to 4[sub-section] (3) 5[  ], the depreciation deduction for a tax year \nshall be computed by applying the rate specified in Part I of the Third Schedule against \nthe written down value of the asset at the beginning of the year 6[ ] 7[.] \n \n \n8[  ]  \n \n \n(3) \nWhere a depreciable asset is used in a tax year partly in deriving \nincome from business chargeable to tax and partly for another use, the deduction \nallowed under this section for that year shall be restricted to the fair proportional \n                                            \n1 Full stop substituted by the Finance Act, 2025. \n2 Clause (s) inserted by the Finance Act, 2025.  \n3 Full stop substituted by colon and thereafter the new proviso added by the Finance Act, 2025. \n4 The word “sub-sections” substituted by the Finance Act, 2005. \n5 The word, brackets and figure “and (4)” omitted by Finance Act, 2004. \n6 Full stop substituted by colon and thereafter the new proviso added through Finance Act, 2020 \ndated 30th June, 2020 \n7 Colon substituted by the Finance Act, 2025. \n8 Proviso omitted by the Finance Act, 2022. The omitted proviso read as follows: \n“Provided that where a depreciable asset is used in the person’s business for the first \ntime in a tax year commencing on or after the 1st day of July, 2020, the depreciation deduction \nshall be reduced by fifty percent.” \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n70 \n \npart of the amount that would be allowed if the asset 1[was] wholly used to 2[derive] \nincome from business chargeable to tax. \n \n 3[  ] \n \n \n(5) \nThe written down value of a depreciable asset of a person at the \nbeginning of the tax year shall be — \n \n(a) \nwhere the asset was acquired in the tax year, the cost of the \nasset to the person as reduced by any initial allowance in \nrespect of the asset under section 23; or \n(b) \nin any other case, the cost of the asset to the person as reduced \nby the total depreciation deductions (including any initial \nallowance under section 23) allowed to the person in respect of \nthe asset in previous tax years. \n \n4[“Explanation,- For the removal of doubt, it is clarified that where any \nbuilding, furniture, plant or machinery is used for the purposes of \nbusiness during any tax year for which the income from such business \nis exempt, depreciation admissible under sub-section (1) shall be \ntreated to have been allowed in respect of the said tax year and after \nexpiration of the exemption period, written down value of such assets \nshall be determined after reducing total depreciation deductions \n(including any initial allowance under section 23) in accordance with \nclauses (a) and (b) of this sub-section.”] \n \n(6) \nWhere sub-section (3) applies to a depreciable asset for a tax year, \nthe written down value of the asset shall be computed on the basis that the asset \nhas been solely used to derive income from business chargeable to tax.  \n \n(7) \nThe total deductions allowed to a person during the period of \nownership of a depreciable asset under this section and section 23 shall not \nexceed the cost of the asset. \n                                            \n1The word “were” substituted by the Finance Act, 2010. \n2 The word “derived” substituted by the Finance Act, 2003. \n3 Sub-section (4) omitted by the Finance Act, 2004. The omitted sub-section (4) reads as follows: \n“(4) \nWhere a depreciable asset is not used for the whole of the tax year in deriving income \nfrom business chargeable to tax, the deduction allowed under this section shall be computed \naccording to the following formula, namely:– \nA x B/C \nwhere – \nA \nis the amount of depreciation computed under sub-section (2) or (3), as the case may be;  \nB \nis the number of months in the tax year the asset is used in deriving income from business \nchargeable to tax; and \nC \nis the number of months in the tax year.” \n4 Inserted by the Finance Act, 2016. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n71 \n \n \n(8) \nWhere, in any tax year, a person disposes of a depreciable asset, no \ndepreciation deduction shall be allowed under this section for that year and — \n(a) \nif the consideration received exceeds the written down value of \nthe asset at the time of disposal, the excess shall be chargeable \nto tax in that year under the head “Income from Business”; or  \n(b) \nif the consideration received is less than the written down value of \nthe asset at the time of disposal, the difference shall be allowed as \na deduction in computing the person’s income chargeable under \nthe head “Income from Business” for that year 1[:] \n2[  ]  \n \n(9) \nWhere sub-section (3) applies, the written down value of the asset for \nthe purposes of sub-section (8) shall be increased by the amount that is not \nallowed as a deduction as a result of the application of sub-section (3). \n \n(10) Where clause (a) of sub-section (13) applies, the 3[consideration \nreceived on disposal] of the passenger transport vehicle for the purposes of sub-\nsection (8) shall be computed according to the following formula — \nA x B/C \nwhere – \nA \nis the 4[amount] received on disposal of the vehicle; \nB \nis the amount referred to in clause (a) of sub-section (13); and \nC \nis the actual cost of acquiring the vehicle. \n \n(11) Subject to sub-sections (13) and (14), the rules in Part III of Chapter IV \nshall apply in determining the cost and consideration received in respect of a \ndepreciable asset for the purposes of this section. \n \n5[(12) The depreciation deductions allowed to a leasing company or an \ninvestment bank or a modaraba or a scheduled bank or a development finance \n                                            \n1 Full stop substituted by colon and thereafter the new proviso added through Finance Act, 2020 \ndated 30th June, 2020 \n \n2 Proviso omitted by the Finance Act, 2022. The omitted proviso read as follows: \n“Provided that where a depreciable asset is used in the person’s business for the first time in \na tax year commencing on or after the 1st day of July, 2020, depreciation deduction equal to fifty \npercent of the rate specified in Part I of the Third Schedule shall be allowed in the year of disposal.”. \n3 The words “written down value” substituted by the Finance Act, 2004. \n4 The word “consideration” substituted by the Finance Act, 2004. \n5 Sub-section (12) substituted by the Finance Act, 2002. The substituted sub-section (12)  read as \nfollows: \n“(12) \nThe depreciation deductions allowed to a leasing company in respect of assets owned \nby the company and leased to another person shall be deductible only against the lease rental \nincome derived in respect of such assets.”  \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n72 \n \ninstitution in respect of assets owned by the leasing company or an investment \nbank or a modaraba or a scheduled bank or a development finance institution and \nleased to another person shall be deductible only against the lease rental income \nderived in respect of such assets.] \n \n \n(13) For the purposes of this section, — \n \n(a) \nthe cost of a depreciable asset being a passenger transport \nvehicle not plying for hire shall not exceed 1[seven and a half]  \nmillion rupees; \n \n \n \n2[  ] \n \n(b) \nthe cost of immovable property or a structural improvement to \nimmovable property shall not include the cost of the land; \n \n3[(c)  any asset owned by a leasing company or an investment bank \nor a modaraba or a scheduled bank or a development finance \ninstitution and leased to another person is treated as used in the \nleasing company or the investment bank or the modaraba or the \nscheduled bank or the development finance institution’s \nbusiness; and] \n \n(d) \nwhere the consideration received on the disposal of immovable \nproperty exceeds the cost of the property, the consideration \nreceived shall be treated as the cost of the property. \n \n \n(14) Where a depreciable asset that has been used by a person in Pakistan \nis exported or transferred out of Pakistan, the person shall be treated as having \ndisposed of the asset at the time of the export or transfer for a consideration \nreceived equal to the cost of the asset. \n \n \n(15) In this section, — \n \n“depreciable asset” means any tangible movable property, immovable \nproperty (other than unimproved land), or structural improvement to \nimmovable property, owned by a person that — \n \n(a) \nhas a normal useful life exceeding one year; \n \n                                            \n1 The expression “1[two]1[and half]” substituted by the Finance Act, 2022. \n2Proviso omitted by the Finance Act, 2009. The omitted proviso read as follows: \n   “Provided that the prescribed limit of one million rupees shall not apply to passenger transport \nvehicles, not plying for hire, acquired on or after the first day of July, 2005.” \n3Clause (c) substituted by the Finance Act, 2002. The substituted clause read as follows: \n“(c)  \nan asset owned by a financial institution or leasing company and leased to another person \nis treated as used in the financial institution or leasing company’s business; and”. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n73 \n \n(b) \nis likely to lose value as a result of normal wear and tear, or \nobsolescence; and \n \n(c) \nis used wholly or partly by the person in deriving income from \nbusiness chargeable to tax, \n \nbut shall not include any tangible movable property, immovable \nproperty, or structural improvement to immovable property in relation \nto which a deduction has been allowed under another section of this \nOrdinance for the entire cost of the property or improvement in the tax \nyear in which the property is acquired or improvement made by the \nperson; and \n \n“structural improvement” in relation to immovable property, includes \nany building, road, driveway, car park, railway line, pipeline, bridge, \ntunnel, airport runway, canal, dock, wharf, retaining wall, fence, power \nlines, water or sewerage pipes, drainage, landscaping or dam1[:] \n \n2[Provided that where a depreciable asset is jointly owned by a \ntaxpayer and an Islamic financial institution licensed by the State Bank \nof Pakistan or Securities and Exchange Commission of Pakistan, as \nthe case may be, pursuant to an arrangement of Musharika financing \nor diminishing Musharika financing, the depreciable asset shall be \ntreated to be wholly owned by the taxpayer.] \n \n23. \nInitial allowance.—(1)  A person who places an eligible depreciable asset \ninto service in Pakistan for the first time in a tax year shall be allowed a deduction \n(hereinafter referred to as an “initial allowance”) computed in accordance with sub-\nsection (2), provided the asset is 3[used by the person for the purposes of his \nbusiness for the first time or the tax year in which commercial production is \ncommenced, whichever is later]. \n(2) \nThe amount of the initial allowance of a person shall be computed by \napplying the rate specified in Part II of the Third Schedule against the cost of the \nasset. \n \n(3) \nThe rules in section 76 shall apply in determining the cost of an eligible \ndepreciable asset for the purposes of this section. \n                                            \n1Full stop substituted by Finance Act, 2017. \n2Added by the Finance Act, 2017. \n3Substituted for “wholly and exclusively used by the person in deriving income from business \nchargeable to tax” by Finance Act,2004 dated June 24,2004 w.e.f July 1,2004 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n74 \n \n1[(4) \nA deduction allowed under this section to a leasing company or an \ninvestment bank or a modaraba or a scheduled bank or a development finance \ninstitution in respect of assets owned by the leasing company or the investment \nbank or the modaraba or the scheduled bank or the development finance institution \nand leased to another person shall be deducted only against the leased rental \nincome derived in respect of such assets.] \n \n(5) \nIn this section, “eligible depreciable asset” means a depreciable asset \n2[  ] other than — \n(a) \nany road transport vehicle unless the vehicle is plying for hire; \n(b) \nany furniture, including fittings; \n(c) \nany plant or machinery3[that has been used previously in \nPakistan]; 4[ ]  \n(d) \nany plant or machinery in relation to which a deduction has been \nallowed under another section of this Ordinance for the entire \ncost of the asset in the tax year in which the asset is acquired   \n5[; or \n (e) \nimmovable property or structural improvement to the immovable \nproperty.] \n \n6[  ] \n 7[  ] \n                                            \n1 Sub-section (4) substituted by the Finance Act, 2002. The substituted sub-section (4) read as follows: \n \n \n“(4) \nA deduction allowed under this section to a leasing company in respect of assets owned \nby the company and leased to another person shall be deductible only against the lease rental \nincome derived in respect of such assets.”  \n2 The words and comma “that is plant and machinery,” omitted by the Finance Act, 2003. \n3The words “that is acquired second hand” substituted by the Finance Act.2003 \n4 The word “or” omitted by the Finance Act, 2022. \n5 The full stop substituted with semi colon and the word “or” and thereafter clause (e) added by the \nFinance Act, 2022. \n6Inserted by the Finance Act, 2008. \n7 Section 23A omitted by the Finance Act, 2021. Earlier this omission was made through Tax Laws \n(Second Amendment) Ordinance, 2021. The omitted section read as follows: \n“23A. First Year Allowance.— (1)  Plant, machinery and equipment installed by any industrial \nundertaking set up in specified rural and under developed areas 7[or engaged in the manufacturing of \ncellular mobile phones and qualifying for exemption under clause (126N) of Part I of the Second \nSchedule] and owned and managed by a company shall be allowed first year allowance in lieu of initial \nallowance under section 23 at the rate specified in Part II of the Third Schedule against the cost of the \n“eligible depreciable assets” put to use after July 1, 2008. \n(2) The provisions of section 23 except sub-sections (1) and (2) thereof, shall mutatis mutandis \napply. \n(3) The Federal Government may notify “specified areas” for the purposes of sub-section (1).] \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n75 \n \n1[23B. Accelerated depreciation to alternate energy projects.— (1) Any plant, \nmachinery and equipments installed for generation of alternate energy by an \nindustrial undertaking set up anywhere in Pakistan and owned and managed by a \ncompany shall be allowed first year allowance in lieu of initial allowance under \nsection 23, at the rate specified in Part II of the Third Schedule against the cost of \nthe eligible depreciation assets put to use after first day of July, 2009. \n \n(2)  \nThe provisions of section 23 except sub-sections (1) and (2) thereof, \nshall mutatis mutandis apply.] \n24. \nIntangibles.—(1) A person shall be allowed an amortisation deduction in \naccordance with this section in a tax year for the cost of the person’s intangibles– \n(a) \nthat are wholly or partly used by the person in the tax year in \nderiving income from business chargeable to tax; and \n(b) \nthat have a normal useful life exceeding one year. \n \n(2) \nNo deduction shall be allowed under this section where a deduction \nhas been allowed under another section of this Ordinance for the entire cost of the \nintangible in the tax year in which the intangible is acquired. \n \n(3) \nSubject to sub-section (7), the amortization deduction of a person for \na tax year shall be computed according to the following formula, namely:— \n \nA \nB \nwhere — \n \nA \nis the cost of the intangible; and  \n \nB \nis the normal useful life of the intangible in whole years. \n \n \n2[(4) An intangible that does not have an ascertainable useful life shall be \ntreated as if it had a normal useful life of 3[fifteen years].]  \n \n \n(5) \nWhere an intangible is used in a tax year partly in deriving income \nfrom business chargeable to tax and partly for another use, the deduction allowed \nunder this section for that year shall be restricted to the fair proportional part of the \namount that would be allowed if the intangible were wholly used to derive income \nfrom business chargeable to tax. \n                                            \n1Inserted by the Finance Act, 2009. \n2 In sub-section 4 of section 24 is substituted by the Finance Act, 2019, the substituted sub-section \nread as follow:  \n(4) \nAn intangible — \n(a) \nwith a normal useful life of more than ten years; or \n(b) \nthat does not have an ascertainable useful life, \nshall be treated as if it had a normal useful life of ten years. \n \n3 The expression “twenty-five years” substituted by the Finance Act, 2025. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n76 \n \n \n \n(6) \nWhere an intangible is not used for the whole of the tax year in deriving \nincome from business chargeable to tax, the deduction allowed under this section \nshall be computed according to the following formula, namely: — \n \nA x B/C \nwhere — \n \nA \nis the amount of 1[amortization] computed under sub-section (3) or (5), as \nthe case may be; \n \nB \nis the number of days in the tax year the intangible is used in deriving income \nfrom business chargeable to tax; and \n \nC \nis the number of days in the tax year. \n \n \n(7) \nThe total deductions allowed to a person under this section in the \ncurrent tax year and all previous tax years in respect of an intangible shall not \nexceed the cost of the intangible. \n \n \n(8) \nWhere, in any tax year, a person disposes of an intangible, no \namortisation deduction shall be allowed under this section for that year and — \n \n(a) \nif the consideration received by the person exceeds the written \ndown value of the intangible at the time of disposal, the excess \nshall be income of the person chargeable to tax in that year \nunder the head “Income from Business”; or  \n \n(b) \nif the consideration received is less than the written down value \nof the intangible at the time of disposal, the difference shall be \nallowed as a deduction in computing the person’s income \nchargeable under the head “Income from Business” in that year. \n \n \n(9) \nFor the purposes of sub-section (8) — \n \n(a) \nthe written down value of an intangible at the time of disposal \nshall be the cost of the intangible reduced by the total \ndeductions allowed to the person under this section in respect \nof the intangible or, where the intangible is not wholly used to \nderive income chargeable to tax, the amount that would be \nallowed under this section if the intangible were wholly so used; \nand \n \n                                            \n1 The word “depreciation” substituted by the Finance Act, 2002 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n77 \n \n(b) \nthe consideration received on disposal of an intangible shall be \ndetermined in accordance with section 77. \n \n \n(10) For the purposes of this section, an intangible that is available for use \non a day (including a non-working day) is treated as used on that day. \n \n(11) In this section, — \n \n“cost” in relation to an intangible, means any expenditure incurred in \nacquiring or creating the intangible, including any expenditure incurred \nin improving or renewing the intangible; and  \n \n“intangible” means any patent, invention, design or model, secret \nformula or process, copyright 1[, trade mark, scientific or technical \nknowledge, computer software, motion picture film, export quotas, \nfranchise, licence, intellectual property], or other like property or right, \ncontractual rights and any expenditure that provides an advantage or \nbenefit for a period of more than one year (other than expenditure \nincurred to acquire a depreciable asset or unimproved land, 2[but shall \nnot include self-generated goodwill or any adjustment arising on \naccount of accounting treatment in the manner as may be prescribed]  \n \n25. \nPre-commencement expenditure.—(1)  A person shall be allowed a \ndeduction for any pre-commencement expenditure in accordance with this section.  \n \n \n(2) \nPre-commencement expenditure shall be amortized on a straight-line \nbasis at the rate specified in Part III of the Third Schedule. \n \n \n(3) \nThe total deductions allowed under this section in the current tax year \nand all previous tax years in respect of an amount of pre-commencement \nexpenditure shall not exceed the amount of the expenditure. \n \n \n(4) \nNo deduction shall be allowed under this section where a deduction \nhas been allowed under another section of this Ordinance for the entire amount of \nthe pre-commencement expenditure in the tax year in which it is incurred. \n \n \n(5) \nIn this section, “pre-commencement expenditure” means any \nexpenditure incurred before the commencement of a business wholly and \nexclusively to derive income chargeable to tax, including the cost of feasibility \nstudies, construction of prototypes, and trial production activities, but shall not \ninclude any expenditure which is incurred in acquiring land, or which is depreciated \nor amortised under section 22 or 24.  \n \n                                            \n1 Inserted by the Finance Act, 2003. \n2The words Inserted by the Finance Act, 2019. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n78 \n \n26. \nScientific research expenditure.— (1)  A person shall be allowed a \ndeduction for scientific research expenditure incurred in Pakistan in a tax year \nwholly and exclusively for the purpose of deriving income from business \nchargeable to tax.  \n \n \n(2) \nIn this section — \n“scientific research” means any 1[activity] 2[undertaken in Pakistan] in \nthe fields of natural or applied science for the development of human \nknowledge; \n \n“scientific research expenditure” means any expenditure incurred by \na person on scientific research 3[undertaken in Pakistan] for the \npurposes of developing the person’s business, including any \ncontribution to a scientific research institution to undertake scientific \nresearch for the purposes of the person’s business, other than \nexpenditure incurred – \n \n \n(a) \nin the acquisition of any depreciable asset or intangible; \n \n(b) \nin the acquisition of immovable property; or \n \n(c) \nfor the purpose of ascertaining the existence, location, extent or \nquality of a natural deposit; and \n \n“scientific research institution” means any institution certified by the \n4[Board] as conducting scientific research in Pakistan.  \n \n27. \nEmployee training and facilities.— A person shall be allowed a deduction \nfor any expenditure (other than capital expenditure) incurred in a tax year in \nrespect of— \n \n(a) \nany educational institution or hospital in Pakistan established for \nthe benefit of the person’s employees and their dependents; \n \n(b) \nany institute in Pakistan established for the training of industrial \nworkers recognized, aided, or run by the Federal Government \n5[or a Provincial Government] or a 6[Local Government]; or \n                                            \n1 The word  “activities” substituted by the Finance Act, 2002 \n2 Inserted by the Finance Act, 2003. \n3 Inserted by the Finance Act, 2003. \n4The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n5Inserted by the Finance Act, 2003. \n6The words “local authority” substituted by the Finance Act, 2008. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n79 \n \n(c) \nthe training of any person, being a citizen of Pakistan, in \nconnection with a scheme approved by the 1[Board] for the \npurposes of this section.  \n \n28. \nProfit on debt, financial costs and lease payments.— (1) Subject to this \nOrdinance, a deduction shall be allowed for a tax year for — \n(a) \nany profit on debt incurred by a person in the tax year to the \nextent that the proceeds or benefit of the debt have been used \nby the person 2[for the purposes of business]; \n \n(b) \nany lease rental incurred by a person in the tax year to a \nscheduled bank, financial institution, an approved modaraba, an \napproved leasing company or a Special Purpose Vehicle on \nbehalf of the Originator for an asset used by the person 3[for the \npurposes of business] 4[:] \n \n \n  \n5[Provided that for the purpose of determining the \ndeduction on account of lease rentals the cost of a passenger \ntransport vehicle not paying for hire to the extent of principal \namount shall not exceed two and a half million rupees;] \n  \n(c) \nany amount incurred by a person in the tax year to a modaraba \nor a participation term certificate holder for any funds borrowed \nand used by the person 6[for the purposes of business]; \n \n(d) \nany amount incurred by a scheduled bank in the tax year to a \nperson maintaining a profit or loss sharing account or a deposit \nwith the bank as a distribution of profits by the bank in respect \nof the account or deposit; \n \n(e) \nany amount incurred by the House Building Finance \nCorporation (hereinafter referred to as “the Corporation”) \nconstituted under the House Building Finance Corporation Act, \n1952 (XVIII of 1952), in the tax year to the State Bank of \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2 The words “in deriving income chargeable to tax under the head “Income from Business” \nsubstituted by the Finance Act, 2004. \n3 The words “in deriving income chargeable to tax under the head “Income from Business” \nsubstituted by the Finance Act, 2004. \n4 Sami colon substituted by colon and thereafter the new proviso added through Finance Act, 2020 \ndated 30th June, 2020 \n \n5 Proviso added through Finance Act, 2020 dated 30th June, 2020  \n6 The words “in deriving income chargeable to tax under the head “Income from Business” \nsubstituted by the Finance Act, 2004. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n80 \n \nPakistan (hereinafter referred to as “the Bank”) as the share of \nthe Bank in the profits derived by the Corporation on its \ninvestment in property made under a scheme of partnership in \nprofit and loss, where the investment is provided by the Bank \nunder the House Building Finance Corporation (Issue and \nRedemption of Certificates) Regulations, 1982; \n \n(f) \nany amount incurred by the National Development Leasing \nCorporation \nLimited \n(hereinafter \nreferred \nto \nas \n“the \nCorporation”) in the tax year to the State Bank of Pakistan \n(hereinafter referred to as “the Bank”) as the share of the Bank \nin the profits derived by the Corporation on its leasing operations \nfinanced out of a credit line provided by the Bank on a profit and \nloss sharing basis; \n \n(g) \nany amount incurred by the 1[Small and Medium Enterprises \nBank (hereinafter referred to as “the SME Bank”)]in the tax year to \nthe State Bank of Pakistan (hereinafter referred to as the “Bank”) \nas the share of the Bank in the profits derived by the 2[SME Bank] \non investments made in small business out of a credit line provided \nby the Bank on a profit and loss sharing basis; \n \n(h) \nany amount incurred by a person in the tax year to a banking \ncompany under a scheme of musharika representing the bank’s \nshare in the profits of the musharika; \n \n(i) \nany amount incurred by a person in the tax year to a certificate \nholder under a musharika scheme approved by the Securities \nand Exchange Commission and Religious Board formed under \nthe Modaraba Companies and Modaraba (Floatation and \nControl) Ordinance, 1980 (XXXI of 1980) representing the \ncertificate holder’s share in the profits of the musharika; or \n \n(j) \nthe financial cost of the securitization of receivables incurred by \nan Originator in the tax year from a Special Purpose Vehicle \nbeing the difference between the amount received by the \nOriginator and the amount of receivables securitized from a \nSpecial Purpose Vehicle. \n \n \n(2) \nNotwithstanding any other provision in this Ordinance, where any assets \nare transferred by an Originator, as a consequence of securitisation3[“or issuance of \n                                            \n1The words “Small Business Finance Corporation (hereinafter referred to as “the Corporation”)” \nsubstituted by the Finance Act, 2009. \n2The word “Corporation” substituted by the Finance Act, 2011. \n3 Inserted by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016.  \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n81 \n \nsukuks”], to a Special Purpose Vehicle, it shall be treated as a financing transaction \nirrespective of the method of accounting adopted by the Originator. \n \n \n(3) \nIn this section, — \n \n“approved leasing company” means a leasing company approved by \nthe 1[Board] for the purposes of clause (b) of sub-section (1); and  \n“approved modaraba” means a modaraba approved by the 2[Board] \nfor the purposes of clause (b) of sub-section (1). \n \n29. \nBad debts.— (1)  A person shall be allowed a deduction for a bad debt in \na tax year if the following conditions are satisfied, namely:— \n \n(a)  \nthe amount of the debt was – \n \n(i) \npreviously included in the person’s income from business \nchargeable to tax; or \n \n(ii) \nin respect of money lent by a financial institution in \nderiving income from business chargeable to tax;  \n \n(b) \nthe debt or part of the debt is written off in the accounts of the \nperson in the tax year; and \n \n(c) \nthere are reasonable grounds for believing that the debt is \nirrecoverable. \n \n \n(2) \nThe amount of the deduction allowed to a person under this section \nfor a tax year shall not exceed the amount of the debt written off in the accounts \nof the person in the tax year. \n \n \n(3) \nWhere a person has been allowed a deduction in a tax year for a bad \ndebt and in a subsequent tax year the person receives in cash or kind any amount \nin respect of that debt, the following rules shall apply, namely:– \n \n(a) \nwhere the amount received exceeds the difference between the \nwhole of such bad debt and the amount previously allowed as a \ndeduction under this section, the excess shall be included in the \nperson’s income under the head “Income from Business” for the \ntax year in which it was received; or \n \n(b) \nwhere the amount received is less than the difference between \nthe whole of such bad debt and the amount allowed as a \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n82 \n \ndeduction under this section, the shortfall shall be allowed as a \nbad debt deduction in computing the person’s income under the \nhead “Income from Business” for the tax year in which it was \nreceived. \n \n1[29A. \nProvision regarding consumer loans.— (1) A 2[ ] 3[non-banking \nfinance company or the House Building Finance Corporation] shall be allowed a \ndeduction, not exceeding three per cent of the income for the tax year, arising out \nof consumer loans for creation of a reserve to off-set bad debts arising out of such \nloans. \n \n \n(2) \nWhere bad debt cannot be wholly set off against reserve, any amount \nof bad debt, exceeding the reserves shall be carried forward for adjustment against \nthe reserve for the following years.] \n \n4[Explanation.— In this section, “consumer loan” means a loan of \nmoney or its equivalent made by 5[ ] a non-banking finance company \nor the House Building Finance Corporation to a debtor (consumer) \nand the loan is entered primarily for personal, family or household \npurposes and includes debts created by the use of a lender credit card \nor similar arrangement as well as insurance premium financing.] \n \n30. \nProfit on non-performing debts of a banking company or development \nfinance institution.—(1) A banking company or development finance institution 6[or \nNon-Banking Finance Company (NBFC) or modaraba] shall be allowed a deduction for \nany profit accruing on a non-performing debt of the banking company or institution 7[or \nNon-Banking Finance Company (NBFC) or modaraba] where the profit is credited to a \nsuspense account in accordance with the Prudential Regulations for Banks or 8[Non-\nBanking Finance Company or modaraba] Non-bank Financial Institutions, as the case \nmay be, issued by the State Bank of Pakistan 9[or the Securities and Exchange \nCommission of Pakistan]. \n \n \n(2) \nAny profit deducted under sub-section (1) that is subsequently \nrecovered by the banking company or development finance institution 10[or Non-\nBanking Finance Company (NBFC) or modaraba] shall be included in the income \n                                            \n1 Inserted by the Finance Act, 2003. \n2The words “banking company or” omitted by the Finance Act, 2009. \n3 Inserted by the Finance Act, 2004. \n4 Added by the Finance Act, 2004. \n5The words “a banking company or” omitted by the Finance Act, 2009. \n6 Inserted by the Finance Act, 2003. \n7 Inserted by the Finance Act, 2003. \n8 The words “Non-bank Financial Institutions” substituted by the Finance Act, 2003. \n9 Inserted by the Finance Act, 2003. \n10 Inserted by the Finance Act, 2003. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n83 \n \nof the company or institution 1[or Non-Banking Finance Company (NBFC) or \nmodaraba] chargeable under the head “Income from Business” for the tax year in \nwhich it is recovered. \n \n31. \nTransfer to participatory reserve.—(1) \nSubject \nto \nthis \nsection, \na \ncompany shall be allowed a deduction for a tax year for any amount transferred by \nthe company in the year to a participatory reserve created under 2[section 66 of \nthe Companies Act, 2017 (XIX of 2017)] in accordance with an agreement relating \nto participatory redeemable capital entered into between the company and a \nbanking company as defined in the3[Financial Institutions(Recovery of Finances) \nOrdinance,2001 (XLVI of 2001).] \n \n \n(2) \nThe deduction allowed under subsection (1) for a tax year shall be limited \nto five per cent of the value of the company’s participatory redeemable capital. \n \n \n(3) \nNo deduction shall be allowed under subsection (1) if the amount of \nthe tax exempted accumulation in the participatory reserve exceeds ten per cent \nof the amount of the participatory redeemable capital. \n \n \n(4) \nWhere any amount accumulated in the participatory reserve of a company \nhas been allowed as a deduction under this section is applied by the company towards \nany purpose other than payment of share of profit on the participatory redeemable capital \nor towards any purpose not allowable for deduction or exemption under this Ordinance \nthe amount so applied shall be included in the income from business of the company in \nthe tax year in which it is so applied. \n \n                                            \n1 Inserted by the Finance Act, 2003. \n2 The expression “section 120 of the Companies Ordinance, 1984 (XLVII of 1984)” substituted by the \nFinance Act, 2021. \n3The words “Banking Tribunals Ordinance, 1984” substituted by the words “Financial Institutions \n(Recovery Of Finances)    Ordinance, 2001 (XLVI of 2001) by the Finance Act 2014”. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n84 \n \nDivision IV \nTax Accounting \n \n32. \nMethod of accounting.—1[(1) Subject to this Ordinance, a person’s income \nchargeable to tax shall be computed in accordance with the method of accounting \nregularly employed by such person.]  \n \n \n(2) \nSubject to sub-section (3), a company shall account for income \nchargeable to tax under the head “Income from Business” on an accrual basis, \nwhile other persons may account for such income on a cash or accrual basis. \n \n \n(3) \nThe 2[Board] may prescribe that any class of persons shall account \nfor income chargeable to tax under the head “Income from Business” on a cash or \naccrual basis. \n \n \n(4) \nA person may apply, in writing, for a change in the person’s  method \nof accounting and the Commissioner may, by 3[order] in writing, approve such an \napplication but only if satisfied that the change is necessary to clearly reflect the \nperson’s income chargeable to tax under the head “Income from Business”. \n \n \n(5) \nIf a person’s method of accounting has changed, the person shall \nmake adjustments to items of income, deduction, or credit, or to any other items \naffected by the change so that no item is omitted and no item is taken into account \nmore than once. \n \n33. \nCash-basis accounting.—A person accounting for income chargeable to \ntax under the head “Income from Business” on a cash basis shall derive income \nwhen it is received and shall incur expenditure when it is paid.  \n \n34. \nAccrual-basis accounting.—(1)  A person accounting for income \nchargeable to tax under the head “Income from Business” on an accrual basis shall \nderive income when it is due to the person and shall incur expenditure when it is \npayable by the person.  \n \n \n(2) \nSubject to this Ordinance, an amount shall be due to a person when \nthe person becomes entitled to receive it even if the time for discharge of the \nentitlement is postponed or the amount is payable by instalments. \n \n                                            \n1 Sub-section (1) substituted by the Finance Act, 2003. The substituted sub-section (1) read as follows: \n“(1) \nA person’s income chargeable to tax under the head “Income from Business” shall be \ncomputed in accordance with the method of accounting regularly employed by the person.” \n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n3 Substituted for the word “notice” by the Finance Act, 2003. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n85 \n \n \n(3) \nSubject to this Ordinance, an amount shall be payable by a person \nwhen all the events that determine liability have occurred and the amount of the \nliability can be determined with reasonable accuracy 1[  ]. \n \n2[   ] \n \n \n(5) \nWhere a person has been allowed a deduction for any expenditure \nincurred in deriving income chargeable to tax under the head “Income from \nBusiness” and the person has not paid the liability or a part of the liability to which \nthe deduction relates within three years of the end of the tax year in which the \ndeduction was allowed, the unpaid amount of the liability shall be chargeable to \ntax under the head “Income from Business” in the first tax year following the end \nof the three years. \n \n3[(5A)  Where a person has been allowed a deduction in respect of a trading \nliability and such person has derived any benefit in respect of such trading liability, \nthe value of such benefit shall be chargeable to tax under 4[the] head “Income from \nBusiness” for the tax year in which such benefit is received.] \n \n \n(6) \nWhere an unpaid liability is chargeable to tax as a result of the \napplication of sub-section (5) and the person subsequently pays the liability or a \npart of the liability, the person shall be allowed a deduction for the amount paid in \nthe tax year in which the payment is made.  \n \n35. \nStock-in-trade.— (1)  For the purposes of determining a person’s income \nchargeable to tax under the head “Income from Business” for a tax year, the cost \nof stock-in-trade disposed of by the person in the year shall be computed in \naccordance with the following formula, namely:— \n \n(A + B) – C \nwhere — \n \nA \nis the opening value of the person’s stock-in-trade for the year; \n \nB \nis cost of stock-in-trade acquired by the person in the year; and \n \n                                            \n1The comma and words “, but not before economic performance occurs” omitted by the Finance Act, 2004. \n2 Sub-section (4) omitted by the Finance Act, 2004. The omitted sub-section (4) read as follows:  \n“(4) \nFor the purposes of sub-section (3), economic performance shall occur - \n(a) \nin the case of the acquisition of services or assets, at the time the services or \nassets are provided; \n(b) \nin the case of the use of assets, at the time the assets are used; and \n(c) \nin any other case, at the time payment is made in full satisfaction of the \nliability.” \n3 Inserted by the Finance Act, 2003. \n4 Inserted by the Finance Act, 2005. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n86 \n \nC \nis the closing value of stock-in-trade for the year. \n  \n \n(2) \nThe opening value of stock-in-trade of a person for a tax year shall be — \n \n(a) \nthe closing value of the person’s stock-in-trade at the end of the \nprevious year; or \n \n(b) \nwhere the person commenced to carry on business in the year, \nthe fair market value of any stock-in-trade acquired by the \nperson prior to the commencement of the business. \n \n \n(3) \nThe fair market value of stock-in-trade referred to in clause (b) of sub-\nsection (2) shall be determined at the time the stock-in-trade is ventured in the \nbusiness. \n \n \n(4) \nThe closing value of a person’s stock-in-trade for a tax year shall be \nthe lower of cost or 1[net realisable]value of the person’s stock-in-trade on hand at \nthe end of the year.  \n \n \n(5) \nA person accounting for income chargeable to tax under the head \n“Income from Business” on a cash basis may compute the person’s cost of stock-\nin-trade on the prime-cost method or absorption-cost method, and a person \naccounting for such income on an accrual basis shall compute the person’s cost \nof stock-in-trade on the absorption-cost method. \n \n \n(6) \nWhere particular items of stock-in-trade are not readily identifiable, a \nperson may account for that stock on the first-in-first-out method or the average-\ncost method but, once chosen, a stock valuation method may be changed only \nwith the written permission of the Commissioner and in accordance with any \nconditions that the Commissioner may impose. \n \n \n(7) \nIn this section, — \n \n“absorption-cost method” means the generally accepted accounting \nprinciple under which the cost of an item of stock-in-trade is the sum \nof direct material costs, direct labour costs, and factory overhead \ncosts; \n \n“average-cost method” means the generally accepted accounting \nprinciple under which the valuation of stock-in-trade is based on a \nweighted average cost of units on hand; \n \n“direct labour costs” means labour costs directly related to the \nmanufacture or production of stock-in-trade; \n \n                                            \n1 Substituted for the words “fair market” by the Finance Act, 2002 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n87 \n \n“direct material costs” means the cost of materials that become an \nintegral part of the stock-in-trade manufactured or produced, or which \nare consumed in the manufacturing or production process; \n“factory overhead costs” means the total costs of manufacturing or \nproducing stock-in-trade, other than direct labour and direct material \ncosts;  \n \n“first-in-first-out method” means the generally accepted accounting \nprinciple under which the valuation of stock-in-trade is based on the \nassumption that stock is sold in the order of its acquisition; \n \n“prime-cost method” means the generally accepted accounting \nprinciple under which the cost of stock-in-trade is the sum of direct \nmaterial costs, direct labour costs, and variable factory overhead \ncosts; \n \n“stock-in-trade” means anything produced, manufactured, purchased, \nor otherwise acquired for manufacture, sale or exchange, and any \nmaterials or supplies to be consumed in the production or \nmanufacturing process, but does not include stocks or shares; and \n \n“variable factory overhead costs” means those factory overhead costs \nwhich vary directly with changes in volume of stock-in-trade \nmanufactured or produced. \n \n36. \nLong-term contracts.— (1)  A person accounting for income chargeable to \ntax under the head “Income from Business” on an accrual basis shall compute \nsuch income arising for a tax year under a long-term contract on the basis of the \npercentage of completion method.  \n \n \n(2) \nThe percentage of completion of a long-term contract in a tax year \nshall be determined by comparing the total costs allocated to the contract and \nincurred before the end of the year with the estimated total contract costs as \ndetermined at the commencement of the contract. \n \n \n(3) \nIn this section, — \n \n“long-term contract” means a contract for manufacture, installation, or \nconstruction, or, in relation to each, the performance of related \nservices, which is not completed within the tax year in which work \nunder the contract commenced, other than a contract estimated to be \ncompleted within six months of the date on which work under the \ncontract commenced; and  \n \n“percentage of completion method” means the generally accepted \naccounting principle under which revenue and expenses arising under \na long-term contract are recognised by reference to the stage of \ncompletion of the contract, as modified by sub-section (2). \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n88 \n \nPART V \nHEAD OF INCOME: CAPITAL GAINS \n \n37. \nCapital gains.— (1)  Subject to this Ordinance, a gain arising on the \ndisposal of a capital asset by a person in a tax year, other than a gain that is \nexempt from tax under this Ordinance, shall be chargeable to tax in that year under \nthe head “Capital Gains”. \n \n \n1[     ] \n \n 2[(1A) Notwithstanding anything contained in sub-section (1), gain arising on \ndisposal of immovable property situated in Pakistan, to a person in a tax year shall \nbe chargeable to tax under the head capital gains at the rates specified in Division \nVIII of Part I of the First Schedule.] \n \n \n(2) \nSubject to 3[sub-section (4)], the gain arising on the disposal of a \ncapital asset by a person shall be computed in accordance with the following \nformula, namely:– \n \nA – B \nwhere — \n \nA \nis the consideration received by the person on disposal of the asset; and  \n \nB \nis the cost of the asset. \n \n \n4[   ]  \n \n \n                                            \n1Inserted by the Finance Act, 2012. \n2 Sub-section (1A) substituted by the Finance Act, 2022. Substituted sub-section (1A) reads as \nfollows: \n“(1A) Notwithstanding anything contained in sub-sections (1) and (3) gain 2[under sub-section \n(3A) 2[  ] ] 2[ ]  by a person in a tax year, shall be chargeable to tax in that year under the head Capital \nGains at the rates specified in Division VIII of Part I of the First Schedule.” \n3 The expression “sub-sections (3) and” omitted by the Finance Act, 2022. \n4 Sub-section (3) omitted by the Finance Act, 2022. Omitted sub-section (3) reads as follows: \n    “(3) Where a capital asset has been held by a person for more than one year,4[other than shares of \npublic companies including the vouchers of Pakistan Telecommunication Corporation, \nmodaraba certificates or any instrument of redeemable capital as defined in the 4[Companies \nAct, 2017 (XIX of 2017)], ] the amount of any gain arising on disposal of the asset shall be \ncomputed in accordance with the following formula, namely: — \nA x ¾ \nwhere A is the amount of the gain determined under sub-section (2).” \n \n \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n89 \n \n   1[    ]  \n     \n    2[     ] \n \n3[  ]  \n                                            \n1 The sub-section (3A) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted  \nsub-section read as follows: \n(3A) \nNotwithstanding anything contained in sub-section (3), the amount of any gain arising on \ndisposal of immovable property being an open plot shall be computed in accordance with the formula \nspecified in the Table below, namely:- \nTABLE \nS.No. \nHolding Period  \nGain \n(1) \n(2) \n(3) \n1. \nWhere the holding period of open plot does not exceed one year \nA \n2. \nWhere the holding period of open plot exceeds one year but does not \nexceed eight years  \nA x 3/4 \n3. \nWhere the holding period of open plot exceeds eight years \n0 \n \n \nwhere A is the amount of the gain determined under sub-section (2). \n \n2 Sub-sections (3A) omitted by the Finance Act, 2022. Omitted sub-section reads as follows: \n(3A) \nNotwithstanding anything contained in sub-section (3), the amount of any gain arising \non disposal of an immovable property shall be computed in accordance with the formula specified \nin the Table below, namely:- \nTABLE \nS.No. \nHolding period \nGain \n(1) \n(2) \n(3) \n1. \nWhere the holding period of an immovable property \ndoes not exceed one year  \nA \n2. \nWhere the holding period of an immovable property \nexceeds one year but does not exceed two years  \nA x 3/4 \n3. \nWhere the holding period of an immovable property \nexceeds two years but does not exceed three \nyears  \nA x 1/2 \n4. \nWhere the holding period of an immovable property \nexceeds three years but does not exceed four \nyears  \nA x 1/4 \n5. \nWhere the holding period of an immovable property \nexceeds four years  \n0 \nwhere A is the amount of gain determined under sub-section (2).] \n3 Sub-section (3B) omitted through Finance Act, 2020 dated 30th June, 2020. The omitted clause read \nas follows: (3B) Notwithstanding anything contained in sub-section (3), the amount of any gain arising \non disposal of immovable property being a constructed property shall be computed in accordance with \nthe formula specified in the Table below, namely:- \nTABLE \nS.No. \nHolding Period  \nGain \n(1) \n(2) \n(3) \n1. \nWhere the holding period of constructed property does not exceed one year \nA \n2. \nWhere the holding period of constructed property exceeds one year but \ndoes not exceed four years  \nA x 3/4 \n3. \nWhere the holding period of constructed property exceeds four years \n0 \nwhere A is the amount of the gain determined under sub-section (2).]  \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n90 \n \n(4) \nFor the purposes of determining component B of the formula in sub-\nsection (2), no amount shall be included in the cost of a capital asset for any \nexpenditure incurred by a person – \n \n(a) \nthat is or may be deducted under another provision of this \nChapter; or \n(b) \nthat is referred to in section 21. \n \n1[     ] \n \n 2[     ]  \n \n \n(5) \nIn this section, “capital asset” means property of any kind held by a \nperson, whether or not connected with a business, but does not include — \n \n3[(a)  any stock-in-trade 4[ ], consumable stores or raw materials held \nfor the purpose of business;] \n \n(b) \nany property with respect to which the person is entitled to a \ndepreciation deduction under section 22 or amortisation \ndeduction under section 24; 5[or] \n \n \n6[  ] \n \n(d) \nany movable property 7[excluding capital assets specified in \nsub-section (5) of section 38] held for personal use by the \n                                            \n1 Inserted by the Finance Act, 2003. \n2 Sub-section (4A) omitted through Finance Act, 2022. Omitted sub-section read as follows: \n“(4A) Where the capital asset becomes the property of the person — \n(a)  under a gift 2[from a relative as defined in sub section (5) of section 85], bequest or will;  \n(b)  by succession, inheritance or devolution; \n(c)  a distribution of assets on dissolution of an association of persons; or  \n(d)  on distribution of assets on liquidation of a company,  \n \nthe fair market value of the asset, on the date of its transfer or acquisition by the person shall be \ntreated to be the cost of the asset 2[: \nProvided that, if the capital asset acquired through gift is disposed of within two years of \nacquisition and the Commissioner is satisfied that such gift arrangement is a part of tax avoidance \nscheme, then the provisions of sub-section (3) of section 79 shall apply for the purpose of \ndetermining the cost of asset in the hands of recipient of the gift.] \n3 The brackets and words “(a) any stock-in-trade;” substituted by the Finance Act, 2002 \n4The brackets and words “(not being stocks and shares)” omitted by the Finance Act, 2010. \n5Inserted by the Finance Act, 2012. \n6Clause (c) omitted by the Finance Act, 2012. Omitted clause (c) read as follows:- \n   “(c)  \nany immovable property; or” \n7 The brackets, commas and words “(including wearing apparel, jewellery, or furniture)” substituted \nby the Finance Act, 2003. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n91 \n \nperson or any member of the person’s family dependent on the \nperson1[.] \n \n2[  ] \n \n3[(6) The person acquiring a capital asset, being shares of a company, shall \ndeduct advance adjustable tax from the gross amount paid 4[or payable] as \nconsideration for the shares 5[at the time of payment or at the time of registration \nof shares by the Securities and Exchange Commission of Pakistan or by the State \nBank of Pakistan, whichever is earlier] at the rate of ten percent of the fair market \nvalue of the shares which shall be paid to the Commissioner by way of credit to \nthe Federal Government, within fifteen days of the payment. \n \n \n(7) Notwithstanding the provisions of section 68, the value of shares, for the \npurpose of sub-section (6), shall be the fair market value, as prescribed for sub-\nsection (4) of section 101A, without reduction of liabilities. \n \n \n(8) The Commissioner may, on application made by the person acquiring of \nthe shares, and after making such inquiry as the Commissioner thinks fit, allow to \nmake the payment, without deduction of tax or deduction of tax at a reduced rate. \n \n(9) The provisions of sections 161, 162, entry No. 15 of the Table in section \n182, clause (c) of sub-section (1) of section 191 and section 205 shall mutatis \nmutandis apply to the tax deductible and payable under this section. \n \n(10) The person disposing of the capital asset, being shares of a company, \nshall furnish to the Commissioner within thirty days of the transaction of disposal, \nthe prescribed information or documents, in a statement as may be prescribed: \n \n \nProvided that the Commissioner may, by notice in writing, require the \nsaid person, to furnish information, documents and statement within a period of \nless than thirty days as specified in the notice.] \n \n                                            \n1 The comma and word “; or” substituted by the Finance Act, 2002 \n2 Clause (e) omitted by the Finance Act, 2001. The omitted clause (e)  read as follows: \n“(e) \nany modaraba certificate or any instrument of redeemable capital listed on any stock exchange \nor shares of a public company.” \n3 Sub-sections (6) to (10) added by the Finance (Supplementary) Act, 2023 (X of 2023) dated \n23.02.2023. \n4 Words inserted by the Finance Act, 2024. \n5 Expression inserted by the Finance Act, 2024. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n92 \n \n1[37A.  \nCapital gain on disposal of securities. — (1) The capital gain arising \non or after the first day of July 2010, from disposal of securities2[  ]3[, other than a \ngain that is exempt from tax under this Ordinance], shall be chargeable to tax at \nthe rates specified in Division VII of Part I of the First Schedule: \n4[ ] \n \n \n \n \nProvided 5[ ] that this section shall not apply to a banking  \n \n \ncompany and an insurance company 6[: \n \n7[Provided further that this section shall not apply to the disposal \nof shares –  \n \n(i)    of a listed company made otherwise than through registered \nstock exchange and which are not settled through NCCPL;  \n \n(ii)  through initial public offer during listing process except \nwhere the detail of such disposal is furnished to NCCPL for \ncomputation of capital gains and tax thereon under this \nsection, \n \nand the provisions of section 37 shall apply on such disposal of \nshares of a listed company or disposal of shares through initial public \noffer, accordingly.]] \n \n \n \n8[(1A) The gain arising on the disposal of a security by a person shall be \ncomputed in accordance with the following formula, namely: — \n \nA – B \n \n \nWhere — \n \n(i)  \n‘A’ is the consideration received by the person on disposal of \nthe security; and \n                                            \n1Added by the Finance Act, 2010. \n2 Omitted by Finance Act, 2015. The omitted words read as follows:- \n“ held for a period of less than a year,” \n3Inserted by the Finance Act, 2012. \n5 The First proviso omitted by Finance Act, 2014. The omitted proviso read as follows: \n“Provided that this section shall not apply if the securities are held for a period of more than a \nyear.” \n5The word “further” omitted by Finance Act, 2014 \n6 Full stop substituted with colon and new proviso added by the by the Finance (Supplementary) Act, \n2023 (X of 2023) dated 23.02.2023. \n7 Second proviso substituted by the by the Finance Act, 2023. The substituted second proviso read as \nfollows: \n“Provided further that this section shall not apply to the disposal of shares of a listed company made \notherwise than through registered stock exchange and which are not settled through NCCPL and \nthe provisions of section 37 shall apply on such disposal of shares of a listed company, accordingly.” \n8Inserted by the Finance Act,2012. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n93 \n \n \n \n(ii)  \n‘B’ is the cost of acquisition of the security.] \n \n \n(2) \nThe holding period of a security, for the purposes of this section, shall \nbe reckoned from the date of acquisition (whether before, on or after the thirtieth \nday of June, 2010) to the date of disposal of such security falling after the thirtieth \nday of June, 2010. \n \n(3) \nFor the purposes of this section “security” means share of a public \ncompany, voucher of Pakistan Telecommunication Corporation, Modaraba \nCertificate, an instrument of redeemable capital1[,debt Securities] 2[, unit of \nexchange traded fund] and derivative products. \n \n3[(3A)  \nFor the purpose of this section, “debt securities” means - \n \n(a) \nCorporate Debt Securities such as Term Finance Certificates \n(TFCs), \nSukuk \nCertificates \n(Sharia \nCompliant \nBonds), \nRegistered Bonds, Commercial Papers, Participation Term \nCertificates (PTCs) and all kinds of debt instruments issued by \nany Pakistani or foreign company or corporation registered in \nPakistan; and  \n \n(b) \nGovernment Debt Securities such as Treasury Bills (T-bills), \nFederal Investment Bonds (FIBs), Pakistan Investment Bonds \n(PIBs), Foreign Currency Bonds, Government Papers, \nMunicipal Bonds, Infrastructure Bonds and all kinds of debt \ninstruments issued by Federal Government, Provincial \nGovernments, Local Authorities and other statutory bodies.] \n \n4[“Explanation: For removal of doubt it is clarified that derivative \nproducts include future commodity contracts entered into by the \nmembers of Pakistan Mercantile Exchange whether or not \nsettled by physical delivery.”] \n \n5[(3B)  \nFor the purpose of this section, “shares of a public company” \nshall be considered as security if such company is a public company at the time of \ndisposal of such shares.] \n \n \n(4) \nGain under this section shall be treated as a separate block of income. \n \n \n \n(5) \nNotwithstanding anything contained in this Ordinance, where a person \nsustains a loss on disposal of securities in a tax year, the loss shall be set off only \n                                            \n1Inserted by the Finance Act, 2014. \n2 Inserted by the Finance Act, 2021. \n3The sub-section (3A) inserted by the Finance Act, 2014. \n4Inserted by the Finance Act, 2016. \n5 New sub-section (3B) inserted through Finance Act, 2020 dated 30th June, 2020  \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n94 \n \nagainst the gain of the person from any other securities chargeable to tax under \nthis section and no loss shall be carried forward to the subsequent tax year 1[:] \n \n2[Provided that so much of the loss sustained on disposal of securities in tax \nyear 20l9 and onwards that has not been set off against the gain of the person \nfrom disposal of securities chargeable to tax under this section shall be carried \nforward to the following tax year and set off only against the gain of the person \nfrom disposal of securities chargeable to tax under this section, but no such loss \nshall be carried forward to more than three tax years immediately succeeding the \ntax year for which the loss was first computed.] \n \n3[(6) To carry out purpose of this section, the Board may prescribe rules.] \n \n38. \nDeduction of losses in computing the amount chargeable under the \nhead “Capital Gains”.— (1)  Subject to this Ordinance, in computing the amount \nof a person chargeable to tax under the head “Capital Gains” for a tax year, a \ndeduction shall be allowed for any loss on the disposal of a capital asset by the \nperson in the year.  \n \n \n(2) \nNo loss shall be deducted under this section on the disposal of a \ncapital asset where a gain on the disposal of such asset would not be chargeable \nto tax.  \n \n \n(3) \nThe loss arising on the disposal of a capital asset by a person shall \nbe computed in accordance with the following formula, namely: — \n \nA – B \nwhere — \n \nA \nis the cost of the asset; and  \n \nB \nis the consideration received by the person on disposal of the asset. \n \n \n(4) \nThe provisions of sub-section (4) of section 37 shall apply in \ndetermining component A of the formula in sub-section (3). \n \n \n(5) \nNo loss shall be recognized under this Ordinance on the disposal of \nthe following capital assets, namely:— \n \n(a) \nA painting, sculpture, drawing or other work of art; \n \n(b) \njewellery; \n \n(c) \na rare manuscript, folio or book; \n \n(d) \na postage stamp or first day cover; \n \n(e) \na coin or medallion; or \n \n(f) \nan antique. \n                                            \n1 Full stop substituted by colon through Finance Supplementary (Second Amendment) Act, 2019 \n2 New Proviso added through Finance Supplementary (Second Amendment) Act, 2019 \n3 Added by the Finance Act, 2021. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n95 \n \nPART VI \nHEAD OF INCOME: INCOME FROM OTHER SOURCES \n \n39. \nIncome from other sources. — (1) Income of every kind received by a \nperson in a tax year, 1[if it is not included in any other head,] other than income \nexempt from tax under this Ordinance, shall be chargeable to tax in that year under \nthe head “Income from Other Sources”, including the following namely: — \n \n(a) \n2[Dividend;] \n \n(b) \n3[royalty;] \n \n(c) \nprofit on debt; \n \n4[(cc)  additional payment on delayed refund under any tax law;] \n \n(d) \nground rent; \n \n(e) \nrent from the sub-lease of land or a building; \n \n(f) \nincome from the lease of any building together with plant or machinery; \n \n5[(fa) \nincome from provision of amenities, utilities or any other service \nconnected with renting of building;] \n \n(g) \nany annuity or pension; \n \n(h) \nany prize bond, or winnings from a raffle, lottery6[, prize on winning a \nquiz, prize offered by companies for promotion of sale] or cross-word \npuzzle; \n \n(i) \nany other amount received as consideration for the provision, use or \nexploitation of property, including from the grant of a right to explore \nfor, or exploit, natural resources;  \n \n                                            \n1 Inserted by the Finance Act, 2002 \n2 The word “Dividends” substituted by the Finance Act, 2002 \n3 The word “royalties” substituted by the Finance Act, 2002 \n4Inserted by the Finance Act, 2012. \n5 Inserted by the Finance Act, 2003. \n6 Inserted by the Finance Act, 2003. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n96 \n \n(j) \nthe fair market value of any benefit, whether convertible to money or \nnot, received in connection with the provision, use or exploitation of \nproperty; 1[ ] \n \n(k) \nany amount received by a person as consideration for vacating the \npossession of a building or part thereof, reduced  by any amount paid \nby the person to acquire possession of such building or part thereof; \n2[ ] \n \n3[(l)  any amount received by a person from Approved Income Payment \nPlan or Approved Annuity Plan under Voluntary Pension System \nRules, 20054[; 5[ ] ]  \n \n6[(Ia) subject to sub-section (3), any amount or fair market value of any \nproperty received without consideration or received as gift, other than \ngift received from 7[relative as defined in sub-section (5) of section 85] \n] 8[; and] \n \n9[(lb)    income arising to the shareholder of a company, from the issuance of \nbonus shares;] \n \n \n \n10[ 11[ ] ] \n \n \n(2) \nWhere a person receives an amount referred to in clause (k) of sub-\nsection (1), the amount shall be chargeable to tax under the head “Income from \nOther Sources” in the tax year in which it was received and the following nine tax \nyears in equal proportion.  \n \n \n(3) \nSubject to sub-section (4), any amount received as a loan, advance, \ndeposit 12[for issuance of shares] or gift by a person in 13[a tax year] from another \nperson (not being a banking company or financial institution) otherwise than by a \n                                            \n1 The word “and” omitted by the Finance Act, 2014. \n2 The word “and” omitted by the Finance Act, 2019.  \n3 Added by the Finance Act,  2005. \n4 The “full stop” substituted by word “;and” by the Finance Act, 2019. \n5 The word “and” omitted by the Finance Act, 2023. \n6 New clause (Ia) inserted by the Finance Act, 2019. \n7 The expression “grandparents, parents, spouse, brother, sister, son or a daughter” substituted by \nthe Finance Act, 2021. \n8 Full stop substituted with a semi-colon and the word “and” added by the Finance Act, 2023. \n9 Clause added by the Finance Act, 2023. \n10 Clause (m) added by the Finance Act, 2014. \n11 Clause (m) omitted by the Finance Act, 2018,the omitted clause(m) reads as follows:- \n   “(m) income arising to the shareholder of a company, from the issuance of bonus shares” \n12 Inserted by the Finance Act, 2003. \n13 The words “an income year” substituted by the Finance Act, 2002 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n97 \n \ncrossed cheque drawn on a bank or through a banking channel 1[or through digital \nmeans as defined in section 2] from a person holding a National Tax Number 2[ ] \nshall be treated as income chargeable to tax under the head “Income from Other \nSources” for the tax year in which it was received. \n \n \n(4) \nSub-section (3) shall not apply to an advance payment for the sale of \ngoods or supply of services. \n \n3[(4A) Where — \n \n(a)  \nany profit on debt derived from investment in National Savings \nDeposit Certificates including Defence Savings Certificate paid \nto a person in arrears or the amount received includes profit \nchargeable to tax in the tax year or years preceding the tax year \nin which it is received; and \n \n(b)  \nas a result the person is chargeable at higher rate of tax than \nwould have been applicable if the profit had been paid to the \nperson in the tax year to which it relates,  \n \nthe person may, by notice in writing to the Commissioner, elect for the profit to be \ntaxed at the rate of tax that would have been applicable if the profit had been paid \nto the person in the tax year to which it relates.]  \n \n4[(4B)  An election under sub-section (4A) shall be made by the due date for \nfurnishing the person’s return of income for the tax year in which the amount was \nreceived or by such later date as the Commissioner may allow by an order in \nwriting.]  \n \n \n(5) \nThis section shall not apply to any income received by a person in a \ntax year that is chargeable to tax under any other head of income or subject to tax \nunder section 5[5, 5AA, 6, 7 or 7B].  \n \n6[  ] \n \n40. \nDeductions in computing income chargeable under the head “Income \nfrom Other Sources”.— (1)  Subject to this Ordinance, in computing the income \nof a person chargeable to tax under the head “Income from Other Sources” for a \ntax year, a deduction shall be allowed for any expenditure paid by the person in \n                                            \n1 The expression inserted by the Finance Act, 2025. \n2 The word “Card” omitted by the Finance Act, 2006. \n3 Inserted by the Finance Act, 2003. \n4 Inserted by the Finance Act, 2003. \n5 The expression “5, 6 or 7” substituted by the Finance Act, 2021. \n6 Sub-section (6) omitted by the Finance Act, 2002. The omitted sub-section (6) read as follows: \n“(6)  \nExpenditure is of a capital nature if it has a normal useful life of more than one year.” \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n98 \n \nthe year to the extent to which the expenditure is paid in deriving income \nchargeable to tax under that head, other than expenditure of a capital nature. \n \n(2) \nA person receiving any profit on debt chargeable to tax under the head \n“Income from Other Sources” shall be allowed a deduction for any Zakat paid by \nthe person 1[  ] under the Zakat and Ushr Ordinance, 1980 (XVIII of 1980), at the \ntime the profit is paid to the person. \n \n \n(3) \nA person receiving income referred to in clause 2[  ] (f) of sub-section \n(1) of section 39 chargeable to tax under the head “Income from Other Sources” \nshall be allowed — \n \n(a) \na deduction for the depreciation of any plant, machinery or \nbuilding used to derive that income in accordance with section \n22; and \n \n(b) \nan initial allowance for any plant or machinery used to derive \nthat income in accordance with section 23. \n \n \n(4) \nNo deduction shall be allowed to a person under this section to the \nextent that the expenditure is deductible in computing the income of the person \nunder another head of income.  \n \n \n(5) \nThe provisions of section 21 shall apply in determining the deductions \nallowed to a person under this section in the same manner as they apply in \ndetermining the deductions allowed in computing the income of the person \nchargeable to tax under the head \"Income from Business\". \n \n3[(6)  Expenditure is of a capital nature if it has a normal useful life of more \nthan one year.] \n                                            \n1 The words “on the profit” omitted by the Finance Act, 2003. \n2 The brackets, letter and word “(e) or” omitted by the Finance Act, 2003. \n3 Added by the Finance Act,  2002. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n99 \n \nPART VII \nEXEMPTIONS AND TAX CONCESSIONS \n \n41. \nAgricultural income. — (1) Agricultural income derived by a person shall \nbe exempt from tax under this Ordinance. \n \n(2) \nIn this section, “agricultural income” means, — \n \n(a) \nany rent or revenue derived by a person from land which is \nsituated in Pakistan and is used for agricultural purposes; \n \n(b) \nany income derived by a person from land situated in Pakistan \nfrom — \n \n(i) \nagriculture; \n \n(ii) \nthe performance by a cultivator or receiver of rent-in-kind \nof any process ordinarily employed by such person to \nrender the produce raised or received by the person fit to \nbe taken to market; or \n \n(iii) \nthe sale by a cultivator or receiver of rent-in-kind of the \nproduce raised or received by such person, in respect of \nwhich no process has been performed other than a \nprocess of the nature described in sub-clause (ii); or \n \n(c) \nany income derived by a person from — \n \n(i) \nany building owned and occupied by the receiver of the \nrent or revenue of any land described in clause (a) or (b); \n \n(ii) \nany building occupied by the cultivator, or the receiver of \nrent-in-kind, of any land in respect of which, or the \nproduce of which, any operation specified in sub-clauses \n(ii) or (iii) of clause (b) is carried on,  \n \nbut only where the building is on, or in the immediate vicinity of \nthe land and is a building which the receiver of the rent or \nrevenue, or the cultivator, or the receiver of the rent-in-kind by \nreason of the person’s connection with the land, requires as a \ndwelling-house, a store-house, or other out-building. \n \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n100 \n \n42. \nDiplomatic and United Nations exemptions. — (1) The income of an \nindividual entitled to privileges under the Diplomatic and Consular Privileges Act, \n1972 (IX of 1972) shall be exempt from tax under this Ordinance to the extent \nprovided for in that Act. \n \n \n(2) \nThe income of an individual entitled to privileges under the United \nNations (Privileges and Immunities) Act, 1948 (XX of 1948), shall be exempt from \ntax under this Ordinance to the extent provided for in that Act. \n \n \n(3) \nAny pension received by a person, being a citizen of Pakistan, by \nvirtue of the person’s former employment in the United Nations or its specialised \nagencies (including the International Court of Justice) provided the person’s salary \nfrom such employment was exempt under this Ordinance. \n \n43. \nForeign government officials.— Any salary received by an employee of a \nforeign government as remuneration for services rendered to such government \nshall be exempt from tax under this Ordinance provided — \n \n(a) \nthe employee is a citizen of the foreign country and not a citizen \nof Pakistan; \n \n(b) \nthe services performed by the employee are of a character \nsimilar to those performed by employees of the Federal \nGovernment in foreign countries; 1[and]  \n \n(c) \nthe foreign government grants a similar exemption to \nemployees of the Federal Government performing similar \nservices in such foreign country2[.] \n \n3[  ] \n \n44. \nExemptions under international agreements.— (1)  Any Pakistan-source \nincome which Pakistan is not permitted to tax under a tax treaty shall be exempt \nfrom tax under this Ordinance. \n \n \n(2) \nAny salary received by an individual (not being a citizen of Pakistan) \nshall be exempt from tax under this Ordinance to the extent provided for in an Aid \nAgreement between the Federal Government and a foreign government or public \ninternational organization, where – \n \n \n                                            \n1 Added by the Finance Act, 2002 \n2 The comma and word  “,and” substituted by the Finance Act, 2002 \n3 Clause (d) omitted by the Finance Act, 2002. The omitted clause (d) read as under: \n“(d) \nthe income is subject to tax in that foreign country.” \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n101 \n \n(a) \nthe individual is either 1[not a resident] individual or a resident \nindividual solely by reason of the performance of services under \nthe Aid Agreement; \n \n(b) \nif the Aid Agreement is with a foreign country, the individual is a \ncitizen of that country; and \n \n(c) \nthe salary is paid by the foreign government or public \ninternational organisation out of funds or grants released as aid \nto Pakistan in pursuance of such Agreement. \n \n \n(3) \nAny income received by 2[any person] engaged as a contractor, \nconsultant, or expert on a project in Pakistan shall be exempt from tax under this \nOrdinance to the extent provided for in a bilateral or multilateral 3[   ] agreement \nbetween the Federal Government and a foreign government or public international \norganisation, where — \n \n(a) \nthe project is financed out of grant funds in accordance with the \nagreement; \n \n(b) \nthe person is either a non-resident person or a resident person \nsolely by reason of the performance of services under the \nagreement; and \n \n(c) \nthe income is paid out of the funds of the grant in pursuance of \nthe agreement. \n \n4[(4) Federal Government may, in respect of an official development \nassistance financed loans and grants-in-aid, subject to such conditions and \nlimitations as it may specify, exempt income of any person on a case to case basis \nthrough a notification in the official Gazette.] \n \n5[44A. Exemption under Foreign Investment (Promotion and Protection) Act, \n2022 (XXXV of 2022). – (1) Taxes on income (including capital gains), advance \ntax, withholding taxes, minimum and final taxes under this Ordinance shall, for the \nperiod and to the extent provided in the Second and Third Schedules to the Foreign \nInvestment (Promotion and Protection) Act, 2022 (XXXV of 2022) in respect of \nqualified investment as specified at Sr. No.1 of the First Schedule to the said Act \n                                            \n1 The words “a non-resident” substituted by the Finance Act, 2003. \n2 The expression “a person (not being a citizen of Pakistan)” substituted by the Finance Act, 2022. \n3 The expression “technical assistance” omitted by the Finance Act, 2022. \n4 Sub-section (4) inserted by the Finance Act, 2022. \n5 Section 44A inserted by the Finance Act, 2023. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n102 \n \nor investors, be exempt or subject to tax at the rate and in the manner specified \nunder the said Act.  \n \n(2) All investors and shareholders of the qualified investment, their \nassociates and companies specified in the Second and Third Schedules to the said \nAct including third party lenders on account of any loan shall also be exempt from \ntaxes and other provisions of this Ordinance or subject to tax at the rate and in the \nmanner specified under the said Act for the period and to the extent provided in \nthe Second and Third Schedules to the said Act.  \n \n(3) Provisions of this Ordinance relating to Anti-Avoidance, for the period \nand to the extent specified in the said Act including sections 106, 106A, 108, 109 \nand 109A, shall not apply to the persons and amounts mentioned in sub-sections \n(1) and (2).  \n \n(4) Rates of depreciation, initial allowance and pre-commencement \nexpenditure under sections 22, 23 and 25 as on the 20th day of March, 2022 shall \ncontinue to be applicable for thirty years as provided in the Third Schedule to the \nsaid Act in respect of persons mentioned in sub-sections (1) and (2).  \n \n(5) For the purpose of this section, the terms defined under the Second and \nThird Schedules to the said Act shall apply mutatis mutandis to this Ordinance.]  \n \n45. \nPresident’s honours.— (1)  Any allowance attached to any Honour, Award, \nor Medal awarded to a person by the President of Pakistan shall be exempt from \ntax under this Ordinance. \n \n \n(2) \nAny monetary award granted to a person by the President of Pakistan \nshall be exempt from tax under this Ordinance. \n \n46. \nProfit on debt.— Any profit received by a non-resident person on a security \nissued by a resident person shall be exempt from tax under this Ordinance \nwhere— \n \n(a) \nthe persons are not associates; \n \n(b) \nthe security was widely issued by the resident person outside \nPakistan for the purposes of raising a loan outside Pakistan for \nuse in a business carried on by the person in Pakistan; \n \n(c) \nthe profit was paid outside Pakistan; and \n \n(d) \nthe security is approved by the 1[Board] for the purposes of this \nsection.  \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n103 \n \n \n47. \nScholarships.— Any scholarship granted to a person to meet the cost of \nthe person’s education shall be exempt from tax under this Ordinance, other than \nwhere the scholarship is paid directly or indirectly by an associate. \n \n48. \nSupport payments under an agreement to live apart.—1[Any income \nreceived by a spouse as support payment under an agreement to live apart] shall \nbe exempt from tax under this Ordinance. \n \n49. \nFederal \n2[Government,] \nProvincial \nGovernment, \nand \n3[Local \nGovernment] income.— (1) The income of the Federal Government shall be \nexempt from tax under this Ordinance. \n \n \n(2) \nThe income of a Provincial Government or a 4[Local Government] in \nPakistan shall be exempt from tax under this Ordinance, other than income \nchargeable under the head “Income from Business” derived by a Provincial \nGovernment or 5[Local Government] from a business carried on outside its \njurisdictional area. \n \n \n6[(3)  Subject to sub-section (2), any payment received by the Federal \nGovernment, a Provincial Government or a 7[Local Government] shall not be liable \nto any collection or deduction of advance tax.] \n \n \n8[(4)  Exemption under this section shall not be available in the case of \ncorporation, company, a regulatory authority, a development authority, other body \nor institution established by or under a Federal law or a Provincial law or an existing \nlaw or a corporation, company, a regulatory authority, a development authority or \nother body or institution set up, owned and controlled, either directly or indirectly, \nby the Federal Government or a Provincial Government, regardless of the ultimate \ndestination of such income as laid down in Article 165A of the Constitution of the \nIslamic Republic of Pakistan9[:] \n                                            \n1 The words “Any support payment received by a spouse under an agreement to live apart” substituted \nby the Finance Act, 2002. \n2 The word “and” substituted by the Finance Act, 2009. \n3The words “local authority” substituted by the Finance Act, 2008. \n4The words “local authority” substituted by the Finance Act, 2008. \n5The words “local authority” substituted by the Finance Act, 2008. \n6Added by the Finance Act, 2006. \n7The words “local authority” substituted by the Finance Act, 2008. \n8Added by the Finance Act, 2007. \n9Full stop substituted by a colon by the Finance Act, 2014. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n104 \n \n1[Provided that the income from sale of spectrum licenses 2[and \nrenewal thereof] by Pakistan Telecommunication Authority on behalf \nof the Federal Government after the first day of March 2014 shall be \ntreated as income of the Federal Government and not of the Pakistan \nTelecommunication Authority.] \n \n50. \nForeign-source income of short-term resident individuals.— (1)  \nSubject to sub-section (2), the foreign-source income of an individual 3[  ] — \n \n(a) \nwho is a resident individual solely by reason of the individual’s \nemployment; and  \n \n(b) \nwho is present in Pakistan for a period or periods not exceeding \nthree years, \n \nshall be exempt from tax under this Ordinance. \n \n \n(2) \nThis section shall not apply to — \n \n(a) \nany income derived from a business of the person established \nin Pakistan; or \n \n(b) \nany foreign-source income brought into or received in Pakistan \nby the person. \n \n51. \nForeign-source income of returning expatriates.—4[(1)] Any foreign-\nsource income derived by a citizen of Pakistan in a tax year who was not a resident \nindividual in any of the four tax years preceding the tax year in which the individual \nbecame a resident shall be exempt from tax under this Ordinance in the tax year \nin which the individual became a resident individual and in the following tax year. \n \n \n5[(2)  Where a citizen of Pakistan leaves Pakistan during a tax year and \nremains abroad during that tax year, any income chargeable under the head \n“Salary” earned by him outside Pakistan during that year shall be exempt from tax \nunder this Ordinance.] \n6[  ] \n                                            \n1Added by the Finance Act, 2014. \n2 The words “and renewal thereof” inserted through Finance Supplementary (Second Amendment) \nAct, 2019 \n3 The brackets and words “(other than a citizen of Pakistan)” omitted by the Finance Act, 2003. \n4 Section 51 numbered as sub-section (1) of section 51 by the Finance Act, 2003. \n5 Added by the Finance Act, 2003. \n6 Section 52 omitted by the Finance Act, 2002. The omitted section 52 read as follows: \n“52. Non-resident shipping and airline enterprises.- (1)  Subject to sub-section (2), any income of a non-\nresident person, for the time being approved by the Federal Government for the purpose of this section, \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n105 \n \n53. \nExemptions and tax concessions in the Second Schedule.—(1) The \nincome or classes of income, or persons or classes of persons specified in the \nSecond Schedule shall be — \n \n(a) \nexempt from tax under this Ordinance, subject to any conditions \nand to the extent specified therein; \n \n(b) \nsubject to tax under this Ordinance at such rates, which are less \nthan the rates specified in the First Schedule, as are specified \ntherein; \n \n(c) \nallowed a reduction in tax liability under this Ordinance, subject \nto any conditions and to the extent specified therein; or \n \n(d) \nexempted from the operation of any provision of this Ordinance, \nsubject to any conditions and to the extent specified therein. \n \n \n1[  ] \n \n \n(2) \nThe 2[Federal Government or the] 3[ ] 4[ ] 5[ ] 6[Board with the approval \nof the Federal Minister-in-charge may, from time to time, pursuant to the approval \nof the Economic Coordination Committee of the Cabinet] whenever circumstances \nexist to take immediate action for the purposes of national security, natural \ndisaster, national food security in emergency situations, protection of national \neconomic interests in situations arising out of abnormal fluctuation in international \ncommodity prices, 7[ ] 8[,] implementation of bilateral and multilateral agreements \n                                            \nfrom the operation of ships and aircraft in international traffic shall be exempt from tax under this Ordinance, \nother than income from ships and aircraft operated principally to transport passengers, livestock, mail, or \ngoods exclusively between places in Pakistan.  \n(2) \nSub-section (1) shall not apply to a non-resident person where the person’s country of \nresidence does not allow a similar exemption to a resident of Pakistan.” \n1Sub-section (1A) omitted by the Finance Act, 2012. The omitted sub-section (1A) read as follows:- \n           “(1A)  \nWhere any income which is exempt from tax under any provision of the Second \nSchedule, such income, as may be specified in the said Schedule and subject to such conditions \nas may be specified therein, shall be included in the total income, however the tax shall not be \npayable in respect of such income.” \n2Inserted by the Finance Act, 2022. \n3 the expression “Federal Government” substituted by Finance Act, 2017. \n4Inserted by the Finance Act, 2015. \n5The expression “Board with the approval of Federal Minister-in-charge may, from time to time  \npursuant to the approval of the Economic Coordination Committee of Cabinet, ” substituted by the  \n    Finance Act, 2018. \n6 The words “Federal Government may” substituted by the Finance Act, 2021.  \n7 The words “removal of anomalies in taxes, development of backward areas” omitted by Finance \nAct, 2019. \n8 Inserted by the Finance Act, 2016. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n106 \n \n1[or granting  an exemption from any tax imposed under this Ordinance including \na reduction in the rate of tax imposed under this Ordinance or a reduction in tax \nliability under this Ordinance or an exemption from the operation of any provision \nof this Ordinance to any international financial institution or foreign Government \nowned financial institution operating under an agreement, memorandum of \nunderstanding or any other arrangement with the Government of Pakistan] ], by \nnotification in the official Gazette, make such amendment in the Second Schedule \nby — \n \n(a) \nadding any clause or condition therein; \n(b) \nomitting any clause or condition therein; or \n(c) \nmaking any change in any clause or condition therein, \nas the Government may think fit, and all such amendments shall have effect in \nrespect of any tax year beginning on any date before or after the commencement \nof the financial year in which the notification is issued. \n \n \n(3) \nThe Federal Government shall place before the National Assembly all \namendments made by it to the Second Schedule in a financial year. \n \n2[“(4) Any notification issued under sub-section (2) after the commencement \nof the Finance Act, 2015, shall, if not earlier rescinded, stand rescinded on the \nexpiry of the financial year in which it was issued3[:] \n \n4[Provided that all such notifications, except those earlier rescinded, \nshall be deemed to have been in force with effect from the first day of July, \n2016 and shall continue to be in force till the thirtieth day of June, 2018, if not \nearlier rescinded: \n \nProvided  further that all notifications issued on or after the first day \nof July, 2016 and placed before the National Assembly as required under sub-\nsection (3) shall continue to remain in force till the thirtieth day of June, 2018, \nif not earlier rescinded by the Federal Government or the National Assembly.] \n \n54. \nExemptions and tax provisions in other laws.—No provision in any other \nlaw providing for — \n \n(a) \nan exemption from any tax imposed under this Ordinance; \n \n                                            \n1Inserted by the Finance Act, 2016. \n2Inserted by the Finance Act, 2015. \n3Full stop substituted by the Finance Act, 2017. \n4Added by the Finance Act, 2017 \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n107 \n \n(b) \na reduction in the rate of tax imposed under this Ordinance; \n \n(c) \na reduction in tax liability of any person under this Ordinance; or \n \n(d) \nan exemption from the operation of any provision of this \nOrdinance, \n \nshall have legal effect unless also provided for in this Ordinance 1[.]  \n \n2[  ] \n \n \n55. \nLimitation of exemption.— (1)  Where any income is exempt from tax \nunder this Ordinance, the exemption shall be, in the absence of a specific provision \nto the contrary contained in this Ordinance, limited to the original recipient of that \nincome and shall not extend to any person receiving any payment wholly or in part \nout of that income. \n \n3[  ] \n \n \n                                            \n1The colon substituted by the Finance Act, 2008. \n2Proviso omitted by the Finance Act, 2008. The omitted proviso read as follows: \n“Provided that any exemption from income tax or a reduction in the rate of tax or a reduction in \ntax liability of any person or an exemption from the operation of any provision of this Ordinance \nprovided in any other law and in force on the commencement of this Ordinance shall continue to be \navailable unless withdrawn.” \n3 Sub-section (2) omitted by the Finance Act, 2003. Omitted sub-section (2) read as follows: - \n“(2) \nWhere a person’s income from business is exempt from tax under this Ordinance as a \nresult of a tax concession, any loss sustained in the period of the exemption shall not be set off \nagainst the person’s income chargeable to tax after the exemption expires.” \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n108 \n \nPART VIII \nLOSSES \n \n56. \nSet off of losses.— (1)  Subject to sections 58 and 59, where a person \nsustains a loss for any tax year under any head of income specified in section 11, \nthe person shall be entitled to have the amount of the loss set off against the \nperson’s income, if any, chargeable to tax under any other head of income 1[except \nincome under the head salary 2[ ] ] for the year 3[: \n \n \nProvided that the adjustment of business loss shall not be allowed against \nincome from property for the tax year.] \n \n \n(2) \nExcept as provided in this Part, where a person sustains a loss under a \nhead of income for a tax year that cannot be set off under sub-section (1), the person \nshall not be permitted to carry the loss forward to the next tax year. \n \n \n(3) \nWhere,4[in a tax year,]a person sustains a loss under the head \n“Income from Business” and a loss under another head of income, the loss under \nthe head “Income from Business shall be set off last. \n \n5[56A.  Set off of losses of companies operating hotels.— Subject to sections \n56 and 57, where a 6[public company as defined in the Companies Act, 2017 and] \nregistered in Pakistan 7[,Gilgit-Baltistan] or Azad Jammu and Kashmir (AJ&K), \noperating hotels in Pakistan 8[,Gilgit-Baltistan] or AJ&K, sustains a loss in Pakistan \n9[,Gilgit-Baltistan] or AJ&K for any tax year under the head “income from business” \nshall be entitled to have the amount of the loss set off against the company’s \nincome in Pakistan 10[,Gilgit-Baltistan] or AJ&K, as the case may be, from the tax \nyear 2007 11[onward]. \n \n57.  Carry forward of business losses.—(1) Where a person sustains a loss \nfor a tax year under the head “Income from Business” (other than a loss to which \n                                            \n1Inserted by the Finance Act, 2013. \n2 The words “or income from property” omitted by the Finance Act, 2021.  \n3 Full stop substituted with a colon and thereafter a new proviso added by the Finance Act, 2025. \n4 Inserted by the Finance Act, 2002 \n5 Inserted by the Finance Act, 2007. \n6 The word “company” substituted by the Finance Act, 2019. \n7After word “Pakistan” the expression “, Gilgit-Baltistan”  inserted by the Finance Act, 2019.  \n8After word “Pakistan” the expression “, Gilgit-Baltistan”  inserted by the Finance Act, 2019. \n9After word “Pakistan” the expression “, Gilgit-Baltistan”  inserted by the Finance Act, 2019. \n10After word “Pakistan” the expression “, Gilgit-Baltistan”  inserted by the Finance Act, 2019. \n11The word “onward” substituted by the word “onward” by the Finance Act, 2014. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n109 \n \n1[sub-section (4) or] section 58 applies) and the loss cannot be wholly set off under \nsection 56, so much of the loss that has not been set off shall be carried forward \nto the following tax year and set off against the person’s income chargeable under \nthe head “Income from Business” for that year. \n \n \n(2) \nIf a loss sustained by a person for a tax year under the head “Income \nfrom Business” is not wholly set off under sub-section (1), then the amount of the \nloss not set off shall be carried forward to the following tax year and applied as \nspecified in sub-section (1) in that year, and so on, but no loss can be carried \nforward to more than six tax years immediately succeeding the tax year for which \nthe loss was first computed. \n \n2[(2A) Where a loss, referred to in sub-section (2), relating to any \nassessment year commencing on or after 1st day of July, 1995, and ending on the \n30th day of June 2001, is sustained by a banking company wholly owned by the \nFederal Government as on first day of June, 2002, which is approved by the State \nBank of Pakistan for the purpose of this sub-section, the said loss shall be carried \nforward for a period of ten years.] \n \n3[(2B) Where a loss, referred to in sub-section (2), relating to a tax year \ncommencing on or after the first day of July, 2020 is sustained by a resident \ncompany engaged in the hotel business in Pakistan, the said loss shall be carried \nforward for a period of eight years.]  \n \n \n4[(2C) Where a loss, referred to in sub-section (2), relating to a tax year \ncommencing on or after the first day of January, 2017 is sustained by Pakistan \nInternational Airlines Corporation Limited, the said loss shall be carried forward for \na period of ten years.] \n  \n(3)   Where a person has a loss carried forward under this section for more \nthan one tax year, the loss of the earliest tax year shall be set off first. \n \n          5[(4) The loss attributable to deductions allowed under sections 22, 23, 6[ ] \n23B and 24 that has not been set off against income, the loss not set off shall be \n                                            \n1Inserted by the Finance Act, 2018. \n \n2 Inserted by the Finance Act, 2002. \n3 New sub-section (2B) inserted through Finance Act, 2020 dated 30th June, 2020 \n4 Sub-section (2C) inserted by the Finance Act, 2024. \n5Sub Section (4) substituted by the finance Act 2018,the substituted subsection (4) is read as follows \n“(4) \nWhere the loss referred to in sub-section (1) includes deductions allowed under sections 22, 23 \n5[23A, 23B] and 24 that have not been set off against income, the amount not set off shall be added to the deductions \nallowed under those sections in the following tax year, and so on until completely set off”. \n6 The expression “23A” omitted by the Finance Act, 2021. Earlier this omission was made through \nTax Laws (Second Amendment) Ordinance, 2021. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n110 \n \nset off against fifty percent of the person's balance income chargeable under the \nhead \"income from business\" after setting off loss under sub-section (1), in the \nfollowing tax year and so on until completely set off: \n \nProvided that such loss shall be set off against hundred percent of the \nsaid balance income if the taxable income for the year is less than ten million \nRupees.\"] \n \n \n \n(5) \nIn determining whether a person’s deductions under sections 22, 23, \n1[ 2[ ] 23B] and 24 have been set off against income, the deductions allowed under \nthose sections shall be taken into account last.  \n \n3[57A. Set off of business loss consequent to amalgamation.—4[(1) The \nassessed loss (excluding capital loss) for the tax year, other than brought forward \nand capital loss, of the amalgamating company or companies shall be set off \nagainst business profits and gains of the amalgamated company, and vice versa, \nin the year of amalgamation and where the loss is not adjusted against the profits \nand gains for the tax year the unadjusted loss shall be carried forward for \nadjustment upto a period of six tax years succeeding the year of amalgamation.] \n \n \n(2)  \nThe provisions of sub-section (4) and (5) of section 57 shall, mutatis \nmutandis, apply for the purposes of allowing unabsorbed depreciation of \namalgamating company or companies in the assessment of amalgamated \ncompany 5[and vice versa]6[:]  \n \n7[Provided that the losses referred to in sub-section (1) and \nunabsorbed depreciation referred to in sub-section (2) shall be allowed set \noff subject to the condition that the amalgamated company continues the \nbusiness of the amalgamating company for a minimum period of five years \nfrom the date of amalgamation.] \n \n                                            \n1Inserted by the Finance Act, 2009. \n2 The expression “23A” omitted by the Finance Act, 2021. Earlier this omission was made through Tax \nLaws (Second Amendment) Ordinance, 2021. \n3 Added by the Finance Act, 2002. \n4Sub-section (1) substituted by the Finance Act, 2007. The substituted sub-section (1) read as follows: \n“(1) The accumulated loss under the head “Income from Business” (not being a loss to which section \n58 applies) of an amalgamating company or companies shall be set off or carried forward against \nthe business profits and gains of the amalgamated company and vice versa, up to a period of six \ntax years immediately succeeding the tax year in which the loss was first computed in the case of \namalgamated company or amalgamating company or companies.” \n5 Inserted by the Finance Act, 2005. \n6 Full stop substituted by the Finance Act, 2005. \n7 Inserted by the Finance Act, 2005. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n111 \n \n \n1[(2A).In case of amalgamation of Banking Company or Non-banking \nFinance Company, modarabas or insurance company, the accumulated loss under \nthe head “Income from Business” (not being speculation business losses) of an \namalgamating company or companies shall be set off or carried forward against \nthe business profits and gains of the amalgamated company and vice versa, up to \na period of six tax years immediately succeeding the tax year in which the loss was \nfirst computed in the case of amalgamated company or amalgamating company or \ncompanies: \n \nProvided that the provisions of this sub-section shall in the case of \nBanking companies be applicable from July 1, 2007.] \n \n \n(3)  \nWhere any of the conditions as laid down by the State Bank of \nPakistan or the Securities and Exchange Commission of Pakistan 2[or any court], \nas the case may be, in the scheme of amalgamation, are not fulfilled, the set off of \nloss or allowance for depreciation made in any tax year of the amalgamated \ncompany 3[or the amalgamating company or companies] shall be deemed to be \nthe income of that amalgamated company 4[or the amalgamating company or \ncompanies, as the case may be,] for the year in which such default is discovered \nby the Commissioner or taxation officer, and all the provisions of this Ordinance \nshall apply accordingly.] \n \n58. Carry forward of speculation business losses.—(1) Where a person \nsustains a loss for a tax year in respect of a speculation business carried on by the \nperson (hereinafter referred to as a “speculation loss”), the loss shall be set off \nonly against the income of the person from any other speculation business of the \nperson chargeable to tax for that year. \n \n \n(2) \nIf a speculation loss sustained by a person for a tax year is not wholly \nset off under sub-section (1), then the amount of the loss not set off shall be carried \nforward to the following tax year and applied against the income of any speculation \nbusiness of the person in that year and applied as specified in     sub-section (1) \nin that year, and so on, but no speculation loss shall be carried forward to more \nthan six tax years immediately succeeding the tax year for which the loss was first \ncomputed. \n \n \n(3) \nWhere a person has a loss carried forward under this section for more \nthan one tax year, the loss of the earliest tax year shall be set off first. \n \n59. \nCarry forward of capital losses.— (1)  Where a person sustains a loss for \na tax year under the head “Capital Gains” (hereinafter referred to as a “capital \nloss”), the loss shall not be set off against the person’s income, if any, chargeable \n                                            \n1Inserted by the Finance Act, 2008. \n2 Inserted by the Finance Act, 2005. \n3 Inserted by the Finance Act, 2005. \n4 Inserted by the Finance Act, 2005. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n112 \n \nunder any other head of income for the year, but shall be carried forward to the \nnext tax year and set off against the capital gain, if any, chargeable under the head \n“Capital Gains” for that year. \n \n \n(2) \nIf a capital loss sustained by a person for a tax year under the head \n“Capital Gains” is not wholly set off under sub-section (1), then the amount of the \nloss not set off shall be carried forward to the following tax year, and so on, but no \nloss shall be carried forward to more than six tax years immediately succeeding \nthe tax year for which the loss was first computed. \n \n(3) \nWhere a person has a loss carried forward under this section for more \nthan one tax year, the loss of the earliest tax year shall be set off first. \n \n1[59A. Limitations on set off and carry forward of losses.— \n \n2[  ] \n \n3[  ] \n \n \n \n(3)  \nIn case of association of persons 4[any loss] shall be set off or carried \nforward and set off only against the income of the association. \n \n \n(4)  \nNothing contained in section 56, 57, 58 or 59 shall entitle — \n \n(a)  \nany member of an association of persons 5[  ] to set off any loss \nsustained by such association of persons, as the case may be, \nor have it carried forward and set off, against his income; or  \n(b)  \nany person who has succeeded, in such capacity, any other \nperson carrying on any business or profession, otherwise than \nby inheritance, to carry forward and set off against his income, \nany loss sustained by such other person. \n \n6[(5)  Subject to sub-section (4) of section 57, sub-section (12) of section 22 and \nsub-section (6), where in computing the taxable  income for any tax year, \n                                            \n1 Added by the Finance Act,  2003. \n2Sub-section (1) omitted by the Finance Act, 2012. The omitted sub-section (1) read as follows: \n   “(1) In case of an association of persons to which sub-section (3) of section 92 applies, any loss which \ncannot be set off against any other income of the association of persons in accordance with section \n56, shall be dealt with as provided under sub-section (2) of section 93. \n3Sub-section (2) omitted by the Finance Act, 2012. The omitted sub-section (2) read as follows: \n   “(2)  Nothing contained in section 57, section 58 or section 59 shall entitle an association of persons, \nto which sub-section (3) of section 92 applies to have its loss carried forward and set off thereunder. \n4The words, figures, commas and brackets “, to which sub-section (3) of section 92 does not apply, \nany loss for such association” substituted by the Finance Act, 2012. \n5 The words, figures, commas and brackets “to which sub-section (3) of section 92 does not apply,” \nomitted by the Finance Act, 2012. \n6  Sub section (5) substituted by the finance Act 2018,the substituted sub section (5) is read as follows \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n113 \n \nfull effect cannot be given to the loss relating to deductions under section \n22, 23, 24 or 25 owing to there being no profits or gains chargeable for \nthat \nyear \nor \nsuch \nprofits \nor \ngains \nas \nmentioned \nin \nsub-section (4) of section 57, being less than the said loss, the loss or \npart of the loss, as the case may be, shall be set off against fifty percent \nof the person’s income chargeable under the head “income from \nbusiness” for the following year or if there is no “income from business” \nfor that year, be set off against fifty percent of the person’s income \nchargeable under the head ”income from business” for the next following \nyear and soon for succeeding years.] \n \n \n(6)  \nWhere, under sub-section (5), deduction is also to be carried forward, \neffect shall first be given to the provisions of section 56 and sub-section (2) of section \n58. \n \n \n(7)  \nNotwithstanding anything contained in this Ordinance, no loss which \nhas not been assessed or determined in pursuance of an order made under \nsection 59, 59A, 62, 63 or 65 of the repealed Ordinance or an order made or \ntreated as made under section 120, 121 or 122 shall be carried forward and set off \nunder section 57, sub-section (2)of section 58 or section 59.] \n \n1[59AA. Group taxation.— (1) Holding companies and subsidiary companies of \n100% owned group may opt to be taxed as one fiscal unit. In such cases, besides \nconsolidated group accounts as required under the 2[Companies Act, 2017 (XIX of \n2017)], computation of income and tax payable shall be made for tax purposes. \n \n \n(2)  \nThe companies in the group shall give irrevocable option for taxation \nunder this section as one fiscal unit. \n \n \n(3)  \nThe group taxation shall be restricted to companies locally \nincorporated under the 3[Companies Act, 2017 (XIX of 2017)]. \n \n \n(4) \nThe relief under group taxation would not be available to losses prior \nto the formation of the group. \n \n                                            \n“(5)  \nWhere in computing the taxable income for any tax year, full effect cannot be given to \na deduction mentioned in section 22, 23, 24 or 25 owing to there being no profits or gains \nchargeable for that year or such profits or gains being less than the deduction, then, subject to \nsub-section (12) of section 22, and sub-section (6), the deduction or part of the deduction to which \neffect has not been given, as the case may be, shall be added to the amount of such deduction \nfor the following year and be treated to be part of that deduction, or if there is no such deduction \nfor that year, be treated to be the deduction for that year and so on for succeeding years.” \n1 Inserted by the Finance Act, 2007. \n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n114 \n \n \n(5) \nThe option of group taxation shall be available to those group \ncompanies which comply with such corporate governance requirements 1[and \ngroup designation rules or regulations] as may be specified by the Securities and \nExchange Commission of Pakistan from time to time and are designated as \ncompanies entitled to avail group taxation. \n \n \n(6) \nGroup taxation may be regulated through rules as may be made by \nthe2[Board]. \n \n3[59B. Group relief.— (1) Subject to sub-section (2), any company, being a \nsubsidiary 4[or] a holding company, may surrender its assessed loss 5[as computed \nin sub-section (1A)] (excluding capital loss) for the tax year (other than brought \nforward losses and capital losses), in favour of its holding company or its subsidiary \nor between another subsidiary of the holding company: \n \nProvided that where one of the company in the group is a public \ncompany listed on a registered stock exchange in Pakistan, the holding \ncompany shall directly hold fifty-five per cent or more of the share capital of \nthe subsidiary company. Where none of the companies in the group is a listed \ncompany, the holding company shall hold directly seventy-five per cent or \nmore of the share capital of the subsidiary company. \n                                            \n1Inserted by the Finance Act, 2013. \n2The words “Central Board of Revenue” substituted by the word “Board” by the Finance Act.  2014. \n3Section 59B substituted by the Finance Act, 2007. The substituted section 59B read as follows: \n“59B. Group Relief.- (1) Subject to sub-section (2), any company, being a subsidiary of a public \ncompany listed on a registered stock exchange in Pakistan, owning and managing an industrial \nundertaking or an undertaking engaged in providing services, may surrender its assessed loss for \nthe tax year other than brought forward losses, in favour of its holding company provided such \nholding company owns or acquires seventy-five per cent or more of the share capital of the subsidiary \ncompany. \n \n(2)  \nThe loss surrendered by the subsidiary company may be claimed by the holding \ncompany for set off against its income under the head “income from Business” in the tax year and the \nfollowing two tax years subject to the following conditions, namely:- \n(a) \nthere is continued ownership of share capital of the subsidiary company to the \nextent of seventy-five per cent or more for five years; and  \n(b) \nthe subsidiary company continues the same business during the said period of \nfive years. \n(3)  \nThe subsidiary company shall not be allowed to surrender its assessed losses for set \noff against income of the holding company for more than three tax years.  \n \n(4)  \nWhere the losses surrendered by a subsidiary company are not adjusted against \nincome of the holding company in the said three tax years, the subsidiary company shall carry forward \nthe unadjusted losses in accordance with the provision of section 57. \n(5)  \nIf there has been any disposal of shares by the holding company during the aforesaid \nperiod of five years to bring the ownership of the holding company to less than seventy-five per cent, \nthe holding company shall, in the year of disposal, offer the amount of profit on which taxes have not \nbeen paid due to set off of losses surrendered by the subsidiary company.” \n4 The word “of” substituted by the Finance Act, 2021.  \n5Inserted by the Finance Act, 2016. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n115 \n \n1[(1A)   The loss to be surrendered under sub-section (1) shall be \nallowed as per following formula, namely:- \n \n(A/100) x B \nwhere— \n \nA \nis the percentage share capital held by the holding \ncompany of its subsidiary company; and \n \nB \nis the assessed loss of the subsidiary company.] \n \n \n(2) \nThe loss surrendered by the subsidiary company may be claimed by \nthe holding company or a subsidiary company for set off against its income under \nthe head “Income from Business” in the tax year and the following two tax years \nsubject to the following conditions, namely:— \n \n(a) \nthere is continued ownership for five years, of share capital of \nthe subsidiary company to the extent of fifty-five per cent in the \ncase of a listed company, or seventy-five per cent or more, in \nthe case of other companies; \n \n(b) \na company within the group engaged in the business of trading \nshall not be entitled to avail group relief; \n \n2[(ba) a company or companies within the group whose income from \nbusiness is chargeable to tax under any provisions of this \nOrdinance other than Division II of Part I of the First Schedule \nto the Ordinance shall not be entitled to avail group relief;] \n \n(c) \nholding company, being a private limited company with seventy-\nfive per cent of ownership of share capital gets itself listed within \nthree years from the year in which loss is claimed; \n \n(d) \nthe group companies are locally incorporated companies under \nthe 3[Companies Act, 2017 (XIX of 2017)]; \n \n(e) \nthe loss surrendered and loss claimed under this section shall have \napproval of the Board of Directors of the respective companies; \n \n(f) \nthe subsidiary company continues the same business during \nthe said period of three years; \n \n                                            \n1  Inserted by the Finance Act, 2016. \n2 Clause (ba) inserted by the Finance Act, 2025. \n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n116 \n \n(g) \nall the companies in the group shall comply with such corporate \ngovernance requirements 1[and group designation rules or \nregulations] as may be specified by the Securities and \nExchange Commission of Pakistan from time to time, and are \ndesignated as companies entitled to avail group relief; and \n \n(h) \nany other condition as may be prescribed. \n \n \n(3) \nThe subsidiary company shall not be allowed to surrender its \nassessed losses for set off against income of the holding company for more than \nthree tax years. \n \n \n(4) \nWhere the losses surrendered by a subsidiary company are not \nadjusted against income of the holding company in the said three tax years, the \nsubsidiary company shall carry forward the unadjusted losses in accordance with \nsection 57. \n \n \n(5) \nIf there has been any disposal of shares by the holding company \nduring the aforesaid period of five years to bring the ownership of the holding \ncompany to less than fifty-five per cent or seventy-five per cent, as the case may \nbe, the holding company shall, in the year of disposal, offer the amount of profit on \nwhich taxes have not been paid due to set off of losses surrendered by the \nsubsidiary company. \n \n \n(6) \nLoss claiming company shall, with the approval of the Board of \nDirectors, transfer cash to the loss surrendering company equal to the amount of \ntax payable on the profits to be set off against the acquired loss at the applicable \ntax rate. The transfer of cash would not be taken as a taxable event in the case of \neither of the two companies. \n \n \n(7) \nThe transfer of shares between companies and the share holders, in \none direction, would not be taken as a taxable event provided the transfer is to \nacquire share capital for formation of the group and approval of the Security and \nExchange Commission of Pakistan or State Bank of Pakistan, as the case may be, \nhas been obtained in this effect. Sale and purchase from third party would be taken \nas taxable event.] \n \n2[     ]   \n                                            \n1Inserted by the Finance Act, 2013. \n2 Section 59C shall be omitted and shall be deemed to have been omitted with effect from 2nd March, \n2022 through Finance Act, 2022. The omitted section read as follows: \n59C. Carry forward of business losses of sick industrial units.- (I) Subject to sub-section (2), \nwhere a company hereinafter referred to as acquiring company, acquires under a scheme of \nacquisition majority share capital of another company being a sick industrial unit, hereinafter referred \nto as acquired company, the acquiring company shall be entitled to adjust loss for the latest tax year \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n117 \n \nPART IX \nDEDUCTIBLE ALLOWANCES \n \n60. Zakat.— (1)  A person shall be entitled to a deductible allowance for the \namount of any Zakat paid by the person in a tax year under the Zakat and Ushr \nOrdinance, 1980 (XVIII of 1980). \n \n \n(2) \nSub-section (1) does not apply to any Zakat taken into account under \nsub-section (2) of section 40. \n \n \n(3) \nAny allowance or part of an allowance under this section for a tax year \nthat is not able to be deducted under section 9 for the year shall not be refunded, \ncarried forward to a subsequent tax year, or carried back to a preceding tax year. \n \n1[60A. Workers’ Welfare Fund.— A person shall be entitled to a deductible \nallowance for the amount of any Workers’ Welfare Fund paid by the person in tax \n                                            \nand brought forward assessed business losses excluding capital loss of the acquired company subject \nto provisions of section 57 for a period of three years.  \n(2) Sub-section (I) shall apply subject to the following conditions, namely:– (a) there is continued \nownership for five years starting from the 30th June, 2023 and there is no change in share capital of \nthe acquiring company; \n(b) the assets of the acquired company shall not be sold upto the 30\" June, 2026; and \n(c) the acquired company continues the same business till the 30th June, 2026. \n(3) Where the losses surrendered by the acquired company are not adjusted against income of \nthe acquiring company in the said three tax years, the acquired company shall carry forward the \nunadjusted losses in accordance with section 57. \n(4) The loss of the acquired company referred to in sub-section (1) shall be adjusted against \nincome under the head \"income from business\" of the acquiring company as per following formula, \nnamely:-  \n(A/I00) x B  \nwhere—  \nA is the percentage share capital held by the acquiring company of the acquired company; and  \nB \nis the loss of the acquired company referred to in sub-section (I). \n(5) \nIf the acquiring company fails to revive the acquired company by tax year 2026, the \nacquiring company shall, in tax year 2027 offer the amount of profit on which taxes have not been paid \ndue to set off of losses surrendered by the acquired company. \n(6) \nFor the removal of doubt, this section shall not apply to any scheme of amalgamation \nor merger.  \n(7) For the purposes of this section, -  \n(a) a sick industrial unit referred to as acquired company in sub-section (I), shall be deemed to \nbe revived if the said company attains maximum production capacity that was obtained before the \nindustrial unit vent sick:  \nProvided that the acquired company produces a certificate to the effect that it stands revived, \nduly issued by Engineering Development Board, along with the return of income filed for tax year 2026.  \n(b) \"sick industrial unit\" means a company being an industrial undertaking, which – \n(i) has accumulated losses, for a continuous period of three years prior to the I\" July, 2022, \nequal to or exceeding its entire capital and reserves at the time of acquisition, as the ease may be; or  \n(ii) has defaulted towards repayment of outstanding debts owing to banking companies or non-\nbanking financial institutions for a consecutive period of three years immediately before acquisition, as \nthe case may be, or  \n(iii) has been declared as such by the Federal Government in a notification published in the \nofficial Gazette.\"; \n1Added by the Finance Act, 2003. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n118 \n \nyear under Workers’ Welfare Fund Ordinance, 1971 (XXXVI of 1971) 1[or under \nany law relating to the Workers’ Welfare Fund enacted by Provinces after the \neighteenth Constitutional amendment Act, 2010: \n \nProvided that this section shall not apply in respect of any amount of \nWorkers’ Welfare Fund paid to the Provinces by a trans-provincial establishment.] \n \n2[60B. Workers’ Participation Fund.— A person shall be entitled to a deductible \nallowance for the amount of any Workers’ Participation Fund paid by the person in \na tax year in accordance with the provisions of the Companies Profit (Workers’ \nParticipation) Act, 1968 (XII of 1968) 3[or under any law relating to the Workers’ \nProfit Participation Fund enacted by Provinces after the eighteenth Constitutional \namendment Act, 2010: \nProvided that this section shall not apply in respect of any amount of \nWorkers’ Profit Participation Fund paid to the province by a trans-provincial \nestablishment.] \n \n4[    ] \n5[     ] \n \n6[60D. Deductible allowance for education expenses.— (1) Every individual \nshall be entitled to a deductible allowance in respect of tuition fee paid by the \nindividual in a tax year provided that the taxable income of the individual is less \nthan one 7[and a half]million rupees. \n \n(2) \nThe amount of an individual‘s deductible allowance allowed under \nsub-section (1) for a tax year shall not exceed  the lesser of — \n \n(a) \nfive per cent of the total tuition fee paid by the individual referred to in \nsub-section (1) in the year; \n \n                                            \n1 Added by the Finance Act, 2021.  \n2 Added by the Finance Act, 2004. \n3 Added by the Finance Act, 2021. \n4 Section 64A is re-numbered by the Finance Act 2017. \n5 Section 60C omitted by Finance Act, 2022 . Omitted section read as follows: \n   \"60C. Deductible allowance for profit on debt.— (1) Every individual shall be entitled to a \ndeductible allowance for the amount of any profit or share in rent and share in appreciation for value \nof house paid by the individual in a tax year on a loan by a scheduled bank or non-banking finance \ninstitution regulated by the Securities and Exchange Commission of Pakistan or advanced by \nGovernment or the Local Government, Provincial Government or a statutory body or a public \ncompany listed on a registered stock exchange in Pakistan where the individual utilizes the loan for \nthe construction of a new house or the acquisition of a house. \n(2) The amount of an individual‘s deductible allowance allowed under sub-section (1) for a tax \nyear shall not exceed fifty percent of taxable income or 5[“two”] million rupees, whichever is lower. \n(3) Any allowance or part of an allowance under this section for a tax year that is not able to be \ndeducted for the year shall not be carried forward to a subsequent tax year.” \n6 Section 64AB is re-numbered by the Finance Act, 2017. \n7 Inserted by the Finance Act, 2017. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n119 \n \n(b) \ntwenty-five per cent of the person’s taxable income for the year; and \n \n(c) \nan amount computed by multiplying sixty thousand with number of \nchildren of the individual.  \n \n(3) \nAny allowance or part of an allowance under this section for a tax year \nthat is not able to be deducted for the year shall not be carried forward to a \nsubsequent tax year. \n \n(4) \nAllowance under this section shall be allowed against the tax liability \nof either of the parents making payment of the feeon furnishing national tax number \n(NTN) or name of the educational institution. \n \n(5) \nAllowance under this section shall not be taken into account for \ncomputation of tax deduction under section 149.] \nPART X \nTAX CREDITS \n \n61. Charitable donations.—1[(1) A person shall be entitled to a tax credit in \nrespect of any sum paid, or any property given by the person in the tax year as a \ndonation 2[, voluntary contribution or subscription] to — \n \n(a)  \nany board of education or any university in Pakistan established \nby, or under, a Federal or a Provincial law; \n \n(b)  \nany educational institution, hospital or relief fund established or \nrun in Pakistan by Federal Government or a Provincial \nGovernment or a3[Local Government]; or \n \n(c)  \nany non-profit organization 4[or any person eligible for tax credit \nunder section 100C of this Ordinance; or \n(d)   entities, organizations and funds mentioned in the Thirteenth \nSchedule to this Ordinance.] \n                                            \n1 Sub-section (1) substituted by the Finance Act, 2003. The substituted sub-section (1) read as \nfollows:  \n“(1)  \nA person shall be entitled to a tax credit for a tax year in respect of any amount paid, or \nproperty given by the person in the tax year as a donation to a non-profit organization.” \n2 Inserted by the Finance Act, 2021. Earlier this insertion was made through Tax Laws (Second  \nAmendment) Ordinance, 2021. \n3The words “local authority” substituted by the Finance Act, 2008. \n4 Inserted by the Finance Act, 2021. Earlier this insertion was made through Tax Laws (Second  \nAmendment) Ordinance, 2021. \n \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n120 \n \n \n \n(2) \nThe amount of a person’s tax credit allowed under sub-section (1) for \na tax year shall be computed according to the following formula, namely:— \n \n(A/B) x C \nwhere — \n \nA \nis the amount of tax assessed to the person for the tax year before allowance \nof any tax credit under this Part; \n \nB \nis the person’s taxable income for the tax year; and  \n \nC \nis the lesser of — \n \n(a) \nthe total amount of the person’s donations referred to in sub-\nsection (1) in the year, including the fair market value of any \nproperty given; or \n(b) \nwhere the person is — \n \n \n(i) \nan individual or association of persons, thirty per cent of \nthe taxable income of the person for the year; or  \n \n(ii) \na company, 1[twenty] per cent of the taxable income of \nthe person for the year 2[:  \n \n \n \nProvided that where any sum is paid or any property is given to \nan associate by a donor, clause (b) of component C shall be, in the \ncase of –  \n \n(i) \nan individual or association of persons, fifteen percent of \nthe taxable income of the person for the year; or \n \n(ii) \na company, ten percent of the taxable income of the \nperson for the year.] \n \n \n(3) \nFor the purposes of clause (a) of component C of the formula in sub-\nsection (2), the fair market value of any property given shall be determined at the \ntime it is given. \n \n \n(4) \nA cash amount paid by a person as a donation shall be taken into \naccount under clause (a) of component C3[of]sub-section (2) only if it was paid by \na crossed cheque drawn on a bank. \n \n                                            \n1The word “fifteen” substituted by the Finance Act, 2009. \n2 Full stop substituted by colon and thereafter new proviso added through Finance Act, 2020 dated \n30th June, 2020 \n3 Inserted by the Finance Act, 2002. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n121 \n \n1[(5) The 2[Board] may make rules regulating the procedure of the grant of \napproval under sub-clause (c) of clause (36) of section 2 and any other matter \nconnected with, or incidental to, the operation of this section.]  \n \n3[     ] \n4[    ] \n                                            \n1 Added by the Finance Act, 2003. \n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n3Section 62 substituted by the Finance Act, 2011. The substituted section 62 read as follows: \n“62. \nInvestment in shares.— (1)  A person 3[other than a company] shall be entitled to a tax credit for a tax year in respect \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 \nwhere the person 3[other than a company] is the original allottee of the shares or the shares are acquired from the Privatization \nCommission of Pakistan.  \n \n(2) \nThe amount of a person’s tax credit allowed under sub-section (1) for a tax year shall \nbe computed according to the following formula, namely: — \n \n(A/B) x C \n \nwhere – \nA \nis the amount of tax assessed to the person for the tax year before allowance of any tax credit \nunder this Part; \nB \nis the person’s taxable income for the tax year; and  \nC \nis the lesser of — \n(a) \nthe total cost of acquiring the shares referred to in sub-section (1) in the year; \n(b) \nten per cent of the person’s 3[taxable] income for the year; or \n(c) \n3[ 3[three] hundred] thousand rupees. \n \n(3) \nWhere – \n(a) \na person has 3[been allowed] a tax credit under sub-section (1) in a tax year in \nrespect of the purchase of a share; and \n(b) \nthe person has made a disposal of the share within twelve months of the date \nof acquisition, \nthe amount of tax payable by the person for the tax year in which the shares were disposed of shall \nbe increased by the amount of the credit allowed.” \n4 Section 62 omitted by the Finance Act, 2022. Omitted section read as follows: \n“62. Tax credit for investment in shares and insurance. — (1) A resident person other than a company \nshall be entitled to a tax credit for a tax year either— \n(i) \nin respect of the cost of acquiring in the year new shares offered to the public by a \npublic company listed on a stock exchange in Pakistan, provided the resident person \nis the original allottee of the shares or the shares are acquired from the Privatization \nCommission of Pakistan;4[ ] \n4[(ia) \nin respect of cost of acquiring in the tax year, sukuks offered to the public by a public \ncompany listed and traded on  stock exchange in Pakistan, provided the resident \nperson is the original allottee of the sukuks; 4[ ] ] \n4[(ib)  \nin respect of cost of acquiring in the tax year, unit of exchange traded fund offered \nto public and traded on stock exchange in Pakistan; or] \n(ii) \nin respect of any life insurance premium paid on a policy to a life insurance company \nregistered by the Securities and Exchange Commission of Pakistan under the \nInsurance Ordinance, 2000 (XXXIX of 2000), provided the resident person is \nderiving income chargeable to tax under the head “salary” or “income from \nbusiness4[:] \n4[Provided that where tax credit has been allowed under this clause and \nsubsequently the insurance policy is surrendered within two years of its acquisition, \nthe tax credit allowed shall be deemed to have been wrongly allowed and the \nCommissioner, notwithstanding anything contained in this Ordinance, shall re-\n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n122 \n \n1[      ]  \n \n 2[      ] \n \n3[63.  Contribution to an Approved Pension Fund.— (1) An eligible person as \ndefined in sub-section (19A) of section 2 deriving income chargeable to tax under the \n                                            \ncompute the tax payable by the taxpayer for the relevant tax years and the \nprovisions of this Ordinance, shall, so far as may, apply accordingly. ] \n(2)  \nThe amount of a person’s tax credit allowed under sub-section (1) for a tax year shall be \ncomputed according to the following formula, namely: — \n(A/B) x C \n \nwhere— \nA \nis the amount of tax assessed to the person for the tax year before allowance \nof any tax credit under this Part; \n \n \nB  \nis the person’s taxable income for the tax year; and \nC \nis the lesser of — \n(a)  \nthe total cost of acquiring the shares,4[or sukuks], or the total \ncontribution or premium paid by the person referred to in sub-section (1) \nin the year; \n(b)  \n4[twenty] per cent of the person’s taxable income for the year; or \n \n \n \n(c)  \n4[ ] 4[ ] 4[two] million rupees]. \n \n(3)  \nWhere — \n(a)  \na person has been allowed a tax credit under sub-section (1) in a tax year in \nrespect of the purchase of a share; and \n(b)  \nthe person has made a disposal of the share within 4[twenty-four] months of the \ndate of acquisition, the amount of tax payable by the person for the tax year in \nwhich the shares were disposed of shall be increased by the amount of the \ncredit allowed.”  \n1Inserted by the Finance Act, 2016. \n2 Section 62A omitted by the Finance Act, 2022. The omitted section read as follows: \n“62A. Tax credit for investment in health insurance.— (1) A resident person  2[ ] other than a \ncompany shall be entitled to a tax credit for a tax year in respect of any health insurance premium or \ncontribution paid to any insurance company registered by the Securities and Exchange Commission of \nPakistan under the Insurance Ordinance, 2000 (XXXIX of 2000), provided the resident person 2[ ] is \nderiving income chargeable to tax under the head “salary” or “income from business”. \n(2) \nThe amount of a person’s tax credit allowed under sub-section (1) for a tax year shall \nbe computed according to the following formula, namely: — \n                     (A/B) x C \nwhere— \nA \nis the amount of tax assessed to the person for the tax year before allowance of tax \ncredit under this section; \nB  \nis the person’s taxable income for the tax year; and \nC \nis the lesser of — \n(a) \nthe total contribution or premium paid by the person referred to in sub-section \n(1) in the year; \n(a) five per cent of the person’s taxable income for the year; and \n(b) one hundred2[and fifty] thousand rupees.” \n3 Section 63 substituted by the Finance Act, 2005. The original section 63 read as follows: \n“63. Retirement annuity scheme. – (1)  Subject to sub-section (3), a resident individual deriving \nincome chargeable to tax under the head “Salary” or the head “Income from Business” shall be \nentitled to a tax credit for a tax year in respect of any contribution or premium paid in the year by the \nperson under a contract of annuity scheme approved by, Securities  and Exchange Commission of \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n123 \n \nhead “Salary” or the head “Income from Business” shall be entitled to a tax credit for a \ntax year in respect of any contribution or premium paid in the year by the person in \napproved pension fund under the Voluntary Pension System Rules, 2005.  \n \n(2)  \nThe amount of a person’s tax credit allowed under sub-section (1) for \na tax year shall be computed according to the following formula, namely: — \n \n(A/B) x C \n \nWhere.- \n \nA \nis the amount of tax assessed to the person for the tax year, before \nallowance of any tax credit under this Part; \nB \nis the person’s taxable income for the tax year; and \nC \nis the lesser of — \n \n (i)  \nthe total contribution or premium referred to in sub-section (1) \npaid by the person in the year; or \n \n(ii)  \ntwenty per cent of the 1[eligible] person’s taxable income for the \nrelevant tax year; Provided that 2[an eligible person] joining the \npension fund at the age of forty-one years or above, during the \nfirst ten years 3[starting from July 1, 2006] shall be allowed \n                                            \nPakistan] of an insurance company duly registered under the Insurance Ordinance, 2000 (XXXIX of \n2000), having its main object the provision to the person of an annuity in old age. \n \n(2) \nThe amount of a resident individual’s tax credit allowed under sub-section (1) for a tax \nyear shall be computed according to the following formula, namely: – \n(A/B) x C \nwhere – \nA   is the amount of tax assessed to the person for the tax year before allowance of any tax credit  \nunder this Part; \nB   is the person’s taxable income for the tax year; and  \nC   is the lesser of – \n(a) \nthe total contribution or premium referred to in sub-section (1) paid by the \nindividual in the year; \n(b) \nten per cent of the person’s taxable income for the tax year; or \n(c) \ntwo hundred thousand rupees. \n(3) \nA person shall not be entitled to a tax credit under sub-section (1) in respect of a contract \nof annuity which provides – \n(a) \nfor the payment during the life of the person of any amount besides an annuity; \n(b) \nfor the annuity payable to the person to commence before the person attains \nthe age of sixty years;  \n(c) \nthat the annuity is capable, in whole or part, of surrender, commutation, \nor assignment; or for payment of the annuity outside Pakistan.” \n1 Inserted by the Finance Act, 2006. \n2 The words “a person” substituted by the Finance Act, 2006. \n3 The words, figure and commas “of the notification of the Voluntary Pension System Rules, 2005,” \nsubstituted by the Finance Act, 2006. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n124 \n \nadditional contribution of 2% per annum for each year of age \nexceeding forty years. Provided further that the total \ncontribution allowed to such person shall not exceed 50% of the \ntotal taxable income of the preceding year 1[2[:] ] ] \n \n \n3[Provided also that the additional contribution of two percent \nper annum for each year of age exceeding forty years shall be \nallowed up to the 30th June, 2019 subject to the condition that \nthe total contribution allowed to such person shall not exceed \nthirty percent of the total taxable income of the preceding year.”] \n \n \n4[  ] \n \n \n5[(3)  The transfer by the members of approved employment pension or \nannuity scheme or approved occupational saving scheme of their existing balance \nto their individual pension accounts maintained with one or more pension fund \nmanagers shall not qualify for tax credit under this section.] \n \n6[63A. Tax credit for interest paid on low-cost housing loan. — (1) An individual \nshall be entitled to a tax credit for a tax year in respect of any profit on debt or \nshare in rent or share in appreciation for value of house paid by the person in the \nyear on a loan by a scheduled bank or any other financial institution regulated by \nthe Securities and Exchange Commission of Pakistan or advanced by Government \nor the Local Government or a statutory body or a public company listed on a \nregistered stock exchange in Pakistan where the person utilizes the loan for the \nconstruction (including land) or acquisition of one personal house having land area \nup to two thousand five hundred square feet or flat having total area up to two \nthousand square feet.  \n \n(2) The amount of a person‘s tax credit allowed under sub-section (1) for a \ntax year shall be computed according to the following formula, namely: —  \n \n(A/B) x C \n \nwhere —  \nA \nis the amount of tax assessed to the person for the tax year before \nallowance of any tax credit under this Part;  \n \nB  \nis the person‘s taxable income for the tax year; and  \n                                            \n1 The semi-colon and the word “or” substituted by the Finance Act, 2011. \n2 Full stop substituted by the Finance Act, 2016. \n3 Inserted by the Finance Act, 2016. \n4 Clause (iii) omitted by the Finance Act, 2011. The omitted clause (iii) read as follows: \n \n“(iii) five hundred thousand rupees.” \n5 Added by the Finance Act, 2006. \n6 Section 63A inserted by the Finance Act, 2025. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n125 \n \n \nC  \nis the lesser of —  \n \n(a) \nthe total profit on debt referred to in sub-section (1) paid by the \nperson in the year; or  \n \n(b) \nthirty per cent of the person‘s taxable income for the year.  \n \n(3) \nThe person shall not be entitled to tax credit under this section for any \nprofit deductible under section 15A.  \n \n(4) \nWhere an individual has claimed tax credit under this section, he shall \nnot be entitled to claim tax credit for another house or flat under this section during \nthe subsequent fifteen tax years.] \n \n1[  ] \n2[  ]  \n3[  ] \n4[  ] \n \n5[64B. Tax credit for employment generation by manufacturers.—(1) Where a \ntaxpayer being a company formed for establishing and operating a new \nmanufacturing unit sets up a new manufacturing unit between the 1st day of July, \n                                            \n1 Section 64 omitted by the Finance Act, 2015. Omitted section read as follows:-  \n“64. \nProfit on debt.—1[(1) A person shall be entitled to a tax credit for a tax year in respect of any \nprofit or share in rent and share in appreciation for value of house paid by the person in the year on a \nloan by a scheduled bank or non-banking finance institution regulated by the Securities and Exchange \nCommission of Pakistan or advanced by Government or the1[Local Government] 1[or a statutory body \nor a public company listed on a registered stock exchange in Pakistan] where the person utilizes the \nloan for the construction of a new house or the acquisition of a house.] \n \n(2) \nThe amount of a person’s tax credit allowed under sub-section (1) for a tax year shall \nbe computed according to the following formula, namely:— \n(A/B) x C \nwhere — \nA \nis the amount of tax assessed to the person for the tax year before allowance of any tax credit \nunder this Part; \nB \nis the person’s taxable income for the tax year; and  \nC \nis the lesser of — \n(a) \nthe total profit referred to in sub-section (1) paid by the person in the year; \n(b) \n1[fifty] per cent of the person’s 1[taxable] income for the year; or \n(c) \n1[seven hundred and fifty] thousand rupees. \n \n(3) \nA person is not entitled to 1[tax credit]under this section for any profit deductible under \nsection 17.” \n2 Inserted by the Finance Act, 2016. \n3 Section 64A is re-numbered as section 60C by Finance Act, 2017 \n4 Section 64AB is re-numbered as section 60D by Finance Act, 2017 \n5 Inserted by the Finance Act, 2015. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n126 \n \n2015 and the 30th day of June, 1[2019], (both days inclusive) it shall be given a tax \ncredit for a period of ten years. \n \n(2)  \nThe tax credit under sub-section (1) for a tax year shall be equal to \n2[two] percent of the tax payable for every fifty employees registered with The \nEmployees Old Age Benefits Institution or the Employees Social Security \nInstitutions of Provincial Governments during the tax year, subject to a maximum \nof ten percent of the tax payable. \n \n(3)  \nTax credit under this section shall be admissible where— \n \n(a) \nthe company is incorporated and manufacturing unit is setup \nbetween the first day of July, 2015 and the 30th day of June, \n2018, both days inclusive; \n \n(b) \nemploys more than fifty employees in a tax year registered with \nThe Employees Old Age Benefits Institution and the Employees \nSocial Security Institutions of Provincial Governments; \n \n(c) \nmanufacturing unit is managed by a company formed for \noperating the said manufacturing unit and registered under the \n3[Companies Act, 2017 (XIX of 2017)] and having its registered \noffice in Pakistan; and \n \n(d) \nthe manufacturing unit is not established by the splitting up or \nreconstruction or reconstitution of an undertaking already in \nexistence or by transfer of machinery or plant from an \nundertaking established in Pakistan at any time before the1st \nJuly 2015. \n \n(4)  \nWhere any credit is allowed under this section and subsequently it is \ndiscovered, on the basis of documents or otherwise, by the Commissioner that any \nof the conditions specified in this section were not fulfilled, the credit originally \nallowed shall be deemed to have been wrongly allowed and the Commissioner \nmay, notwithstanding anything contained in this Ordinance, re-compute the tax \npayable by the taxpayer for the relevant year and the provisions of this Ordinance \nshall, so far as may be, apply accordingly. \n \n(5)  \nFor the purposes of this section, a manufacturing unit shall be treated \nto have been setup on the date on which the manufacturing unit is ready to go into \nproduction, whether trial production or commercial production.”] \n                                            \n1 The figure “2018” substituted by the Finance Act, 2016. \n2 The word “one” substituted by the Finance Act, 2016. \n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n127 \n \n \n1[  ]  \n2[   ] \n \n3[64D. Tax credit for point of sale machine.—(1) Any person who is required to \nintegrate with Board’s computerized system for real time reporting of sale or \nreceipt, shall be entitled to tax credit in respect of the amount invested in purchase \nof point of sale machine. \n \n(2) The amount of tax credit allowed under sub-section (1) for a tax year in \nwhich point of sale machine is installed, integrated and configured with the Board’s \ncomputerized system shall be lesser of— \n \n(a) amount actually invested in purchase of point of sale machine; or \n \n(b) rupees one hundred and fifty thousand per machine. \n \n(3) For the purpose of this section, the term point of sale machine means a \nmachine meant for processing and recording the sale transactions for goods or \nservices, either in cash or through credit and debit cards or online payments in an \ninternet enabled environment.] \n \n                                            \n1 New sub-section 64C inserted by the Finance Act, 2019. \n2 Section 64C omitted by the Finance Act, 2021. Earlier this omission was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted section read as follows: \n“64C. Tax credit for persons employing fresh graduates.– (1) A person employing freshly qualified \ngraduates from a university or institution recognized by Higher Education Commission shall be entitled \nto a tax credit in respect of the amount of annual salary paid to the freshly qualified graduates for a \ntax year in which such graduates are employed. \n(2) \nThe amount of tax credit allowed under sub-section (1) for a tax year shall be computed \naccording to the following formula, namely:- \n(A/B) x C  \nwhere- \nA \nis the amount of tax assessed to the person for the tax year before allowance \nof tax credit under this section; \nB \nis the person’s taxable income for the tax year; and \n \n \nC \nis the lessor of – \n(a) the annual salary paid to the freshly qualified graduates referred to in sub-\nsection (1) in the year; and  \n(b) five percent of the person’s taxable income for the year;  \n(3) \nThe tax credit shall be allowed for salary paid to the number of freshly qualified \ngraduates not exceeding fifteen percent of the total employees of the company in the tax year. \n(4) \nIn this section, “freshly qualified graduate” means a person who has graduated after the \nfirst day of July, 2017 from any institute or university recognized by the Higher Education Commission.” \n3 Inserted by the Finance Act, 2021. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n128 \n \n65. \n Miscellaneous provisions relating to tax credits.— (1)  Where the \nperson entitled to a tax credit under 1[this]Part is a member of an association of \npersons to which sub-section (1) of section 92 applies, the following shall apply— \n \n(a) \ncomponent A of the formula in sub-section (2) of section 61, sub-\nsection (2) of section 62, sub-section (2) of section 63 and sub-\nsection (2) of section 64 shall be the amount of tax that would be \nassessed to the individual if any amount derived in the year that is \nexempt from tax under sub-section (1) of section 92 were chargeable \nto tax; and \n \n(b) \ncomponent B of the formula in sub-section (2) of section 61, sub-\nsection (2) of section 62, sub-section (2) of section 63 and sub-\nsection (2) of section 64 shall be the taxable income of the individual \nfor the year if any amount derived in the year that is exempt from tax \nunder sub-section (1) of section 92 were chargeable to tax. \n \n \n(2) \nAny tax credit allowed under this Part shall be applied in accordance \nwith sub-section (3) of section 4. \n \n \n(3) \nSubject to sub-section (4), any tax credit or part of a tax credit allowed \nto a person under this Part for a tax year that is not able to be credited under sub-\nsection (3) of section 4 for the year shall not be refunded, carried forward to a \nsubsequent tax year, or carried back to a preceding tax year. \n \n \n(4) \nWhere the person to whom sub-section (3) applies is a member of an \nassociation of persons to which sub-section (1) of section 92 applies, the amount \nof any excess credit under sub-section (3) for a tax year may be claimed as a tax \ncredit by the association for that year.  \n \n \n(5) \nSub-section (4) applies only where the member and the association \nagree in writing for the sub-section to apply and such agreement in writing must \nbe furnished with the association’s return of income for that year. \n \n2[(6) Where the person is entitled to a tax credit under section 65B, 65D or \n65E, provisions of clause (d) of sub-section (2) of section 169 and clause (d) of \nsub-section (1) of section 113 shall not apply.] \n \n3[  ] \n                                            \n1 Inserted by the Finance Act, 2002 \n2Inserted by the Finance Act, 2015 \n3Section 65A omitted by the Finance Act, 2017, Omitted section reads as follows: \n3[65A. Tax credit to a person registered under the Sales Tax Act, 1990. — (1) Every manufacturer, \nregistered under the Sales Tax Act, 1990, shall be entitled to a tax credit of 3[“three”] per cent of tax \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n129 \n \n \n1[65B. Tax credit for investment.— (1) Where a taxpayer being a company \ninvests any amount in the purchase of plant and machinery, for the purposes of \n2[extension, expansion,] balancing, modernization and replacement of the plant \nand machinery, already installed therein, in an industrial undertaking set up in \nPakistan and owned by it, credit equal to ten per cent of the amount so invested \nshall be allowed against the tax payable 3[, including on account of minimum tax \nand final taxes payable under any of the provisions of this Ordinance,] by it in the \nmanner hereinafter provided 4[:] \n \n \n \n5[Provided that for the tax year 2019 the rate of credit shall be equal to five \npercent of the amount so invested: \n \n \nProvided further that the provisions of sub-section (5) relating to carry \nforward of the credit to be deducted from tax payable, to the following tax years, \nas specified in the said sub-section, shall continue to apply after tax year 2019; \nand] \n \n \n \n(2) \nThe provisions of sub-section (1) shall apply if the plant and machinery \nis purchased and installed at any time between the first day of July, 2010, and the \n30th day of June, 6[ ] 7[ ] 8[2019]. \n \n \n(3) \nThe amount of credit admissible under this section shall be deducted \nfrom the tax payable by the taxpayer in respect of the tax year in which the plant \nor machinery in the purchase of which the amount referred to in sub-section (1) is \ninvested and installed. \n \n                                            \npayable for a tax year, if ninety per cent of his sales are to the person who is registered under the \naforesaid Act during the said tax year. \n(2) For claiming of the credit, the person shall provide complete details of the persons to whom \nthe sales were made. \n \n(3) No credit will be allowed to a person whose income is covered under final tax or minimum \ntax. \n \n(4) Carry forward of any amount where full credit may not be allowed against the tax liability for \nthe tax year, shall not be allowed. \n1Added by the Finance Act, 2010. \n2Inserted by the Finance Act, 2012. \n3 The coma and words inserted by Finance Act, 2012  \n4Full stop” substituted by “colon” by the Finance Act, 2019  \n5New provisos added by the Finance Act, 2019 \n6The figure “2015” substituted by Finance Act, 2015. \n7 The figure “2016” substituted by the Finance Act, 2016. \n8The figure “2021” substituted by Finance Act, 2019. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n130 \n \n \n1[(4) The provisions of this section shall mutatis mutandis apply to a company \nsetup in Pakistan before the first day of July, 2011, which makes investment, through \nhundred per cent new equity, during first day of July, 2011 and 30th day of June, 2016, \nfor the purposes of balancing, modernization and replacement of the plant and \nmachinery already installed in an industrial undertaking owned by the company. \nHowever, credit equal to twenty per cent of the amount so invested shall be allowed \nagainst the tax payable, including on account of minimum tax and final taxes payable \nunder any of the provisions of this Ordinance. The credit shall be allowed in the year in \nwhich the plant and machinery in the purchase of which the investment as aforesaid is \nmade, is installed therein.  \n \n“Explanation.— For the purpose of this section the term “new equity” shall, \nhave the same meaning as defined in sub-section (7) of section 65E.] \n \n \n2[(5) Where no tax is payable by the taxpayer in respect of the tax year in \nwhich such plant or machinery is installed, or where the tax payable is less than \nthe amount of credit as aforesaid, the amount of the credit or so much of it as is in \nexcess thereof, as the case may be, shall be carried forward and deducted from \nthe tax payable by the taxpayer in respect of the following tax year and so on, but \nno such amount shall be carried forward for more than two tax years in the case \nof investment referred to in sub-section (1) and for more than five tax years in \nrespect of investment referred to in sub-section (4), however, the deduction made \nunder this section shall not exceed in aggregate the limit specified in sub-section \n(1) or sub-section (4), as the case may be.] \n \n \n3[(6) Where any credit is allowed under this section and subsequently it is \ndiscovered by the Commissioner Inland Revenue that any one or more of the \nconditions specified in this section was, or were, not fulfilled, as the case may be, \nthe credit originally allowed shall be deemed to have been wrongly allowed and \nthe Commissioner, notwithstanding anything contained in this Ordinance, shall re-\ncompute the tax payable by the taxpayer for the relevant year and the provisions \nof this Ordinance shall, so far as may be, apply accordingly.] \n                                            \n1Sub-section (4) substituted by the Finance Act, 2012. The substituted sub-section (4) read as follows: \n \n \n“(4) \nWhere no tax is payable by the taxpayer in respect of the tax year in which such plant \nor machinery is installed, or where the tax payable is less than the amount of credit, the amount of \nthe credit or so much of it as is in excess thereof, as the case may be, shall be carried forward and \ndeducted from the tax payable by the taxpayer in respect of the following tax year, and so on, but no \nsuch amount shall be carried forward for more than two tax years, however, the deduction made \nunder sub-section (2) and this sub-section shall not exceed in aggregate the limit specified in sub-\nsection (1).” \n2Sub-section (5) substituted by the Finance Act, 2012. The substituted sub-section (5) read as follows: \n \n \n“(5) \nWhere any credit is allowed under this section and subsequently it is discovered by the \nCommissioner Inland Revenue that any one or more of the conditions specified in this section was, \nor were, not fulfilled, as the case may be, the credit originally allowed shall be deemed to have been \nwrongly allowed and the Commissioner Inland Revenue may, notwithstanding anything contained in \nthis Ordinance, re-compute the tax payable by the taxpayer for the relevant year and the provisions \nof this Ordinance shall, so far as may be, apply accordingly.” \n3Added by the Finance Act, 2012.  \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n131 \n \n1[    ]  \n2[    ] \n3[    ]  \n4[    ] \n                                            \n1Added by the Finance Act, 2010. \n2 Section 65C omitted by the Finance Act, 2021. Earlier this omission was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted section read as follows: \n65C. Tax credit for enlistment. —(1) Where a taxpayer being a company opts for enlistment in any \nregistered stock exchange in Pakistan2[on or before the 30th day of June, 2022] a tax credit equal to \n2[twenty] percent of the tax payable shall be allowed for the tax year in which the said company is \nenlisted 2[“and for the following 2[three tax years:] \n[Provided that the tax credit for the last two years shall be ten per cent of the tax payable.] \n3Added by the Finance Act, 2011. \n4 Section 65D omitted by the Finance Act, 2021. The omitted section read as follows: \n   “65D. Tax credit for newly established industrial undertakings. — (1) Where a taxpayer being a \ncompany formed for establishing and operating a new industrial undertaking 4[including corporate \ndairy farming] sets up a new industrial undertaking4[including a corporate dairy farm], it shall be given \na tax credit equal to 4[“an amount as computed in sub-section (1A)”] of the tax payable               4[, \nincluding on account of minimum tax and final taxes payable under any of the provisions of this \nOrdinance,] on the taxable income arising from such industrial undertaking for a period of five years \nbeginning from the date of setting up or commencement of commercial production, whichever is \nlater. \n \n4[“(1A)   The amount of a person’s tax credit allowed under sub-section (1) for a tax year shall \nbe computed according to the following formula, namely: — \nA x (B/C) \nwhere— \nA \nis the amount of tax assessed to the person for the tax year before \nallowance of any tax credit for the tax year; \nB \nis the equity raised through issuance of new shares for cash consideration; \nand \nC \nis the total amount invested in setting up the new industrial undertaking.”] \n \n(2)  \nTax credit under this section shall be admissible where— \n(a)  \nthe company is incorporated and industrial undertaking is setup between the \nfirst day of July, 2011 and 30th day of June, 4[4[“2021”]]; \n(b)  \nindustrial undertaking is managed by a company formed for operating the \nsaid industrial undertaking and registered under the Companies \nOrdinance, 1984 (XLVII of 1984) and having its registered office in \nPakistan; \n(c)  \nthe industrial undertaking is not established by the splitting up or reconstruction \nor reconstitution of an undertaking already in existence or by transfer of \nmachinery or plant from an industrial undertaking established in Pakistan at any \ntime before 1st July 2011; and \n(d)  \nthe industrial undertaking is set up with 4[“at least seventy per cent”] \nequity4[raised through issuance of new shares for cash consideration:] \nProvided that short term loans and finances obtained from banking companies or non-banking \nfinancial institutions for the purposes of meeting working capital requirements shall not disqualify the \ntaxpayer from claiming tax credit under this section.] \n             [  ] \n \n(4)  \nWhere any credit is allowed under this section and subsequently it is discovered, on the \nbasis of documents or otherwise, by the Commissioner Inland Revenue that4[“the business has been \ndiscontinued in the subsequent five  years after the credit has been allowed or”] any of the 4[conditions] \nspecified in this section [were] not fulfilled, the credit originally allowed shall be deemed to have been \nwrongly allowed and the Commissioner Inland Revenue may, notwithstanding anything contained in \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n132 \n \n1[65E. Tax credit for industrial undertakings established before the first day \nof July, 2011.—2[(1) Where a taxpayer being a company, setup in Pakistan before \nthe first day of July, 2011, invests any amount, with 3[at least seventy per cent] \nnew equity raised through issuance of new shares, in the purchase and installation \nof plant and machinery for an industrial undertaking, including corporate dairy \nfarming, for the purposes of- \n \n(i)  \nexpansion of the plant and machinery already installed therein; or  \n \n(ii)   undertaking a new project, \n \na tax credit shall be allowed against the tax payable in the manner provided in sub-\nsection (2) and sub-section (3), as the case may be, for a period of five years \nbeginning from the date of setting up or commencement of commercial production \nfrom the new plant or expansion project, whichever is later.] \n \n \n4[(2) Where a taxpayer maintains separate accounts of an expansion \nproject or a new project, as the case may be, the taxpayer shall be allowed a tax \ncredit equal to one 5[an amount as computed in sub-section (3A)] of the tax \npayable, including minimum tax and final taxes payable under any of the provisions \nof this Ordinance, attributable to such expansion project or new project.] \n \n \n6[(3) In all other cases, the credit under 7[sub-section (3A)] shall be such \nproportion of the tax payable, including minimum tax and final taxes payable under \n                                            \nthis Ordinance, re-compute the tax payable by the taxpayer for the relevant year and the provisions of \nthis Ordinance shall, so far as may be, apply accordingly.] \n[(5) \nFor the purposes of this section and sections 65B and 65E, an industrial undertaking \nshall be treated to have been setup on the date on which the industrial undertaking is ready to go into \nproduction, whether trial production or commercial production.] \n \n1Added by the Finance Act, 2011. \n2Sub-section (1) substituted by the Finance Act, 2012. The substituted sub-section (1) read as \nfollows:  \n“(1) Where a taxpayer being a company invests any amount, with hundred per cent equity \ninvestment, in the purchase and installation of plant and machinery for the purposes of balancing, \nmodernization, replacement, or for expansion of the plant and machinery already installed in an \nindustrial undertaking setup in Pakistan before the first day of July 2011, a tax credit shall be allowed \nagainst the tax payable in the manner provided hereinafter, in the same proportion, which exists \nbetween the total investment and such equity investment made by the industrial undertaking.” \n3 The words “hundred per cent” substituted by the Finance Act, 2016. \n4Sub-section (2) substituted by the Finance Act, 2012. The substituted sub-section (1) read as \nfollows:  \n“(2) The provisions of sub-section (1) shall apply if the plant and machinery is purchased and \ninstalled at any time between the first day of July, 2011, and the 30th day of June, 2016.” \n5 The words “hundred per cent” substituted by the Finance Act, 2016. \n6Sub-section (3) substituted by the Finance Act, 2012. The substituted sub-section (1) read as \nfollows:  \n“(3) The amount of credit admissible under this section shall be deducted from the tax payable \nby the taxpayer in respect of the tax year in which the plant or machinery referred in sub-section (1) \nis purchased and installed and for the subsequent four years.” \n7 The words “this section” substituted by the Finance Act, 2016. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n133 \n \nany of the provisions of this Ordinance, as is the proportion between the new equity \nand the total equity including new equity.] \n \n1[(3A) The amount of a person’s tax credit allowed under sub-section (1) for \na tax year shall be computed according to the following formula, namely: — \n \nA x (B/C) \nwhere—  \n \nA \nis the amount of tax assessed to the person for the tax year before \nallowance of any tax credit for the tax year;   \n \nB \nis the equity raised through issuance of new shares for cash \nconsideration; and \n \nC \nis the total amount invested in the purchase and installation of plant \nand machinery for the industrial undertaking.] \n \n \n2[(4) The provisions of sub-section (1) shall apply if the plant and machinery \nis installed at any time between the first day of July, 2011 and the 30th day of June, \n3[ 4[2021] .] \n \n \n5[(5) The amount of credit admissible under this section shall be deducted \nfrom the tax payable, including minimum tax and final taxes payable under any of \nthe provisions of this Ordinance, by the taxpayer 6[, for a period of five years \nbeginning from the date of setting up or commencement of commercial production \nfrom the new plant or expansion project, whichever is later.] \n \n \n7[(6)] Where any credit is allowed under this section and subsequently it is \ndiscovered, on the basis of documents or otherwise, by the Commissioner Inland \nRevenue that 8[“the business has been discontinued in the subsequent five  years \nafter the credit has been allowed or”]any of the condition specified in this section \n                                            \n1Inserted by the Finance Act, 2016. \n2Sub-section (4) substituted by the Finance Act, 2012. The substituted sub-section (1) read as follows:  \n“(4) Where no tax is payable by the taxpayer in respect of the tax year in which such plant or \nmachinery is installed, or where the tax payable is less than the amount of tax credit, the amount of \nsuch credit or so much of it as is in excess thereof, shall be carried forward and deducted from the \ntax payable by the taxpayer in respect of the following tax year: \n \nProvided that no such amount shall be carried forward for  more than four tax years: \n \n \nProvided further that deduction made under sub-section (1) and under this sub-section \nshall not exceed in aggregate the limit of the tax credit specified in sub-section (1).” \n3 The figure “2016” substituted by the Finance Act, 2016. \n4The figure “2019” substituted by Finance Act, 2018. \n5Inserted by the Finance Act, 2012. \n6 The words “in respect of the tax year in which the plant or machinery referred to in sub-section (1) is \ninstalled and for the subsequent four years” substituted by Finance Act, 2015. \n7Sub-section (5) renumbered by the Finance Act, 2012. \n8 Inserted by the Finance Act, 2016. \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n134 \n \nwas not fulfilled, the credit originally allowed shall be deemed to have been wrongly \nallowed and the Commissioner Inland Revenue may, notwithstanding anything \ncontained in this Ordinance, re-compute the tax payable by the taxpayer for the \nrelevant year and the provisions of this Ordinance shall apply accordingly. \n  \n \n1[(7) For the purposes of this section, ‘new equity’ means equity raised \nthrough fresh issue of shares against cash by the company and shall not include \nloans obtained from shareholders or directors: \n \nProvided that short term loans and finances obtained from banking \ncompanies or non-banking financial institutions for the purposes of meeting \nworking capital requirements shall not disqualify the taxpayer from claiming \ntax credit under this section.] \n \n2[65F. Tax credit for certain persons.– (1) Following persons or incomes shall \nbe allowed a tax credit equal to one hundred per cent of the tax payable under any \nprovisions of this Ordinance including minimum, alternate corporate tax and final \ntaxes for the period, to the extent, upon fulfillment of conditions and subject to \nlimitations detailed as under:-  \n \n3[(a)  persons engaged in coal mining projects in Sindh, to the extent, the \nincome is derived from supplying coal to power generation projects.]  \n \n(b)  a startup as defined in clause (62A) of section 2 for the tax year in which \nthe startup is certified by the Pakistan Software Export Board and the \nnext following two tax years 4[.] \n \n5[Explanation. – For the removal of doubt it is clarified that tax credit under \nclause (a) shall only be available to the income derived from the operations \nof coal mining projects in Sindh supplying coal to power generation \nprojects.] \n \n6[     ] \n \n(2) The tax credit under sub-section (1) shall be available subject to \nfulfillment of the following conditions, where applicable, namely:- \n                                            \n1Added by the Finance Act, 2012. \n2 Sections 65F and 65G inserted by the Finance Act, 2021. Earlier this insertion was made through \nTax Laws (Second  Amendment) Ordinance, 2021.   \n3 Clause (a) substituted by the Finance Act, 2025. The substituted clause (a) read as follows: \n   “(a)  persons engaged in coal mining projects in Sindh supplying coal exclusively to power generation \nprojects;” \n4 Expression “; and” substituted by the Finance Act, 2024. \n5 Explanation inserted by the Finance Act, 2024. \n6 Clause (c) omitted by the Finance Act, 2022. The omitted clause read as follows: \n  “(c)  Income from exports of computer software or IT services or IT enabled services as defined in \nclause (30AD) and (30AE) of section 2 upto the period ending on the 30th day of June, 2025:  \nProvided that eighty percent of the export proceeds is brought into Pakistan in foreign \nexchange remitted from outside Pakistan through normal banking channels.”  \n   \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n135 \n \n \n(a) return has been filed; \n \n(b) withholding tax statements for the relevant tax year have been filed in  \nrespect of those provisions of the Ordinance, where the person is a \nwithholding agent; and  \n \n(c) sales tax returns for the tax periods corresponding to relevant tax year \nhave been filed if the person is required to file Sales Tax Return under \nany of the Federal or Provincial sales tax laws.  \n \n65G. Tax credit for specified industrial undertakings.- (1) When making certain \neligible capital investments as specified in sub-section (2), the eligible taxpayers \ndefined in sub-section (3) shall be allowed to take an investment tax credit of \ntwenty five percent of the eligible investment amount, against tax payable under \nthe provisions of this Ordinance including minimum and final taxes. The tax credit \nnot fully adjusted during the year of investment shall be carried forward to the \nsubsequent tax year subject to the condition that it may be carried forward for a \nperiod not exceeding two years.  \n \n(2) For the purposes of this section, the eligible investment means \ninvestment made in purchase and installation of new machinery, buildings, \nequipment, hardware and software, except self-created software and used capital \ngoods.  \n     \n(3) For the purpose of this section, eligible person means —  \n \n(a) green field industrial undertaking as defined in clause (27A) of  \nsection 2 engaged in — \n \n(i)    the manufacture of goods or materials or the subjection of goods  \nor materials to any process which substantially changes their \noriginal condition; or \n \n(ii)  ship building:  \n \nProvided that the person incorporated between the 30th \nday of June, 2019 and the 30th day of June, 2024 and the \nperson is not formed by the splitting up or reconstitution of an \nundertaking already in existence or by transfer of machinery, \nplant or building from an undertaking established in Pakistan \nprior to commencement of the new business and is not part of \nan expansion project; and  \n \n(b)  industrial undertaking set up by the 30th day of June 2023 and  \nengaged in the manufacture of plant, machinery, equipment and \nitems with dedicated use (no multiple uses) for generation of \nrenewable energy from sources like solar and wind, for a period of \nfive years beginning from the date such industrial undertaking is set \nup.] \n\n\f\nChapter III – Tax on Taxable Income ______________________ \n \n136 \n \n \n1[     ] \n                                            \n1 Section 65H shall be omitted and shall be deemed to have been omitted with effect from 2nd March, \n2022 through Finance Act, 2022. The omitted section read as follows: \n\"65H. Tax credit for foreign investment for industrial promotion.- (I) Where a taxpayer being —  \n(a) a non-resident Pakistani citizen having continued non-residential status for more than five \nyears; or \n(b)  a resident individual having foreign assets declared in terms of section 116 or 116A by the \n31\" December, 2021, \ninvests in a company incorporated on or after the 1st March, 2022, to set up an industrial undertaking \nin Pakistan with equity, not less than fifty million rupees, with funds remitted into Pakistan through \nproper banking channel as per the procedure to be prescribed by the State Bank of Pakistan, at any \ntime up to the 31st December, 2022, that company shall be entitled to a one-time tax credit equal to one \nhundred percent of the amount remitted and credited in rupees in the bank account of such company \nagainst tax liability for the tax year in which commercial production commences.  \n(2) Where no tax is payable by the taxpayer in respect of the tax year in which the commercial \nproduction has commenced or where the tax payable is less than the amount of credit as aforesaid, \nthe amount of the credit or so much of it as is in excess thereof, as the case may be, shall be carried \nforward and deducted from the tax payable by the taxpayer in respect of the following tax year and so \non, but no such amount shall be carried forward for more than five tax years in the case of investment \nreferred to in sub-section (1), however, the deduction made under this section shall not exceed in \naggregate the limit specified in sub-section (1).  \n(3) This section shall not apply to a company or an industrial undertaking established by splitting \nup or reconstitution of a company or an industrial undertaking already in existence or by transfer of \nmachinery or plant from an industrial undertaking established at any time before the 1st March, 2022.  \n(4) The provisions of sub-section ( I) shall apply if commercial production commences by the \n30th June, 2024.  \n(5) Where any credit is allowed under this section and subsequently it is discovered by the \nCommissioner Inland Revenue that any one or more of the conditions specified in this section was or \nwere not fulfilled, as the case may be, the credit originally allowed shall be deemed to have been \nwrongly allowed and the Commissioner, notwithstanding anything contained in this Ordinance, shall re-\ncompute the tax payable by the taxpayer for the relevant year and the provisions of this Ordinance \nshall, so far as may be, apply accordingly.” \n\n\f\nChapter IV – Common Rules_____________________________ \n \n137 \n \nCHAPTER IV \nCOMMON RULES \n \nPART I \nGENERAL \n \n66. Income of joint owners.—(1)  For the purposes of this Ordinance and subject \nto sub-section (2), where any property is owned by two or more persons and their \nrespective shares are definite and ascertainable – \n \n(a) \nthe persons shall not be assessed as an association of persons \nin respect of the property; and \n(b) \nthe share of each person in the income from the property for a \ntax year shall be taken into account in the computation of the \nperson’s taxable income for that year. \n \n \n(2) \nThis section shall not apply in computing income chargeable under \nthe head “Income from Business”. \n \n67. Apportionment of deductions.— (1)  Subject to this Ordinance, where an \nexpenditure1[“expenditures, deductions and allowances”] relates to – \n(a) \nthe derivation of more than one head of income; or \n \n2[(ab) \nderivation of income comprising of taxable income and any \nclass of income to which sub-sections (4) and (5) of section 4 \napply, or;] \n \n(b) \nthe derivation of income chargeable to tax under a head of \nincome and to some other purpose, \nthe expenditure 3[“expenditures, deductions and allowances”] shall be apportioned \non any reasonable basis taking account of the relative nature and size of the \nactivities to which the amount relates. \n \n \n(2) \nThe 4[Board] may make rules under section 5[237] for the purposes of \napportioning deductions 6[expenditures and allowances].  \n \n                                            \n1 Substituted by the Finance Act, 2016. \n2Inserted by the Finance Act, 2002. \n3Substituted by the Finance Act, 2016. \n4The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n5The figure “232” substituted by the Finance Act, 2002. \n6 Inserted by the Finance Act, 2016. \n\n\f\nChapter IV – Common Rules _____________________________ \n \n138 \n \n68. Fair market value.— (1)  For the purposes of this Ordinance, the fair market \nvalue of any property 1[or rent], asset, service, benefit or perquisite at a particular \ntime shall be the price which the property 2[or rent], asset, service, benefit or \nperquisite would ordinarily fetch on sale or supply in the open market at that time.  \n \n \n(2) \nThe fair market value of any property 3[or rent], asset, service, benefit \nor perquisite shall be determined without regard to any restriction on transfer or to \nthe fact that it is not otherwise convertible to cash. \n \n4[(3)  Where the price 5[other than the price of immoveable property] \nreferred to in sub-section (1) is not ordinarily ascertainable, such price may be \ndetermined by the Commissioner.] \n \n6[(4)  \nNotwithstanding anything contained in sub-sections (1) and (3), 7[the \nBoard may, from time to time, by notification in the official Gazette, determine the \nfair market value of immovable property of the area or areas as may be specified \nin the notification] .] \n \n8[(5)  \nWhere the fair market value of any immovable property of an area or \nareas has not been determined by the Board in the notification referred to in    sub-\nsection (4), the fair market value of such immovable property shall be deemed to \nbe the value fixed by the District Officer (Revenue) or provincial or any other \nauthority authorized in this behalf for the purposes of stamp duty.] \n \n9[(6)  \nIn respect of immovable property— \n \n(i) \ncomponent A of the formula in sub-section (2) of section 37; \n \n(ii) \n“consideration received\" as mentioned in Division X of Part IV of First \nSchedule; \n \n \n(iii) \n“value of immovable property\" as mentioned in Divisions XVIII of Part \nIV of the First Schedule; and \n(iv) \nvaluation for the purposes of section 111,shall not be less than the fair \nmarket value as determined under sub-section (4) or (5). \n  \n \n                                            \n1 Inserted by the Finance Act, 2003. \n2Inserted by the Finance Act, 2003. \n3 Inserted by the Finance Act, 2003. \n4 Added by the Finance Act, 2003. \n5 Inserted by the Finance Act, 2016.  \n6Inserted by the Finance Act, 2016. \n7Substituted by the Income Tax (Fourth Amendment) Act, 2016 dated 02.12.2016. The substituted \nexpression read as follows: \n “the fair market value of immovable property shall be determined on the basis of valuation made by a \npanel of approved values of the State Bank of Pakistan”. \n8Added by the Income Tax (Fourth Amendment) Act, 2016 dated 02.12.2016.  \n9Added by the Income Tax (Fourth Amendment) Act, 2016 dated 02.12.2016. \n\n\f\nChapter IV – Common Rules _____________________________ \n \n139 \n \nExplanation.—(1) For the removal of doubt, it is clarified that the fair \nmarket value as determined under sub-section (4) or(5) shall be for carrying \nout the purposes of this Ordinance only. \n \n(2)  \nIt is further clarified that for the purposes of clauses (i) to (iv) of \nthis sub-section if the fair market value determined under sub-section (4) or \n(5) is different than the auction price the applicable price shall be the higher \nof the two.] \n \n69. Receipt of income.— For the purposes of this Ordinance, a person shall be \ntreated as having received an amount, benefit, or perquisite if it is — \n \n(a) \nactually received by the person; \n \n(b) \napplied on behalf of the person, at the instruction of the person \nor under any law; or \n \n(c) \nmade available to the person.  \n \n70. Recouped expenditure.— Where a person has been allowed a deduction \nfor any expenditure or loss incurred in a tax year in the computation of the person’s \nincome chargeable to tax under a head of income and, subsequently, the person \nhas received, in cash or in kind, any amount in respect of such expenditure or loss, \nthe amount so received shall be included in the income chargeable under that head \nfor the tax year in which it is received. \n \n71. Currency conversion.— (1)  Every amount taken into account under this \nOrdinance shall be in Rupees. \n \n \n(2) \nWhere an amount is in a currency other than rupees, the amount shall \nbe converted to the Rupee at the State Bank of Pakistan 1[  ] rate applying between \nthe foreign currency and the Rupee on the date the amount is taken into account \nfor the purposes of this Ordinance. \n \n72. Cessation of source of income.— Where — \n \n(a) \nany income is derived by a person in a tax year from any business, \nactivity, investment or other source that has ceased either before the \ncommencement of the year or during the year; and \n \n(b) \nif the income had been derived before the business, activity, \ninvestment or other source ceased it would have been chargeable to \ntax under this Ordinance, \n \nthis Ordinance shall apply to the income on the basis that the business, activity, \ninvestment or other source had not ceased at the time the income was derived. \n \n                                            \n1 The word “mid-exchange” omitted by the Finance Act, 2003. \n\n\f\nChapter IV – Common Rules _____________________________ \n \n140 \n \n73. Rules to prevent double derivation and double deductions.— (1)  For the \npurposes of this Ordinance, where – \n \n(a) \nany amount is chargeable to tax under this Ordinance on the basis that \nit is receivable, the amount shall not be chargeable again on the basis \nthat it is received; or \n(b) \nany amount is chargeable to tax under this Ordinance on the basis that \nit is received, the amount shall not be chargeable again on the basis \nthat it is receivable. \n \n \n(2) \nFor the purposes of this Ordinance, where — \n \n(a) \nany expenditure is deductible under this Ordinance on the basis \nthat it is payable, the expenditure shall not be deductible again \non the basis that it is paid; or \n \n(b) \nany expenditure is deductible under this Ordinance on the basis \nthat it is paid, the expenditure shall not be deductible again on \nthe basis that it is payable. \n \n\n\f\nChapter IV – Common Rules _____________________________ \n \n141 \n \nPART II \nTAX YEAR \n \n1[74.  Tax year.— (1) For the purpose of this Ordinance and subject to this section, \nthe tax year shall be a period of twelve months ending on the 30th day of June \n(hereinafter referred to as ‘normal tax year’) and shall, subject to sub-section (3), \nbe denoted by the calendar year in which the said date falls.  \n \n \n(2)  \nWhere a person’s income year, under the repealed Ordinance, is \ndifferent from the normal tax year, or where a person is allowed, by an order under \nsub-section (3), to use a twelve months’ period different from normal tax year, such \nincome year or such period shall be that person’s tax year (hereinafter referred to \nas ‘special tax year’) and shall, subject to sub-section (3), be denoted by the \ncalendar year relevant to normal tax year in which the closing date of the special \ntax year falls. \n \n2[(2A) The 3[Board],— \n \n(i)  \nin the case of a class of persons having a special tax year \ndifferent from a normal tax year may permit, by a notification in \nthe official Gazette, to use a normal tax year; and \n \n                                            \n1Section 74 substituted by the Finance Act, 2002. The substituted section 74  read as follows: \n “74. Tax year.- (1)  For the purposes of this Ordinance and subject to this section, the tax year shall \nbe the period of twelve months ending on the 30th day of June (referred to in this section as the \nfinancial year).  \n(2) \nA person may apply, in writing, to use as the person’s tax year a twelve-month period \n(hereinafter referred to as a “special year”) other than the financial year and the Commissioner may, \nsubject to sub-section (4), by notice in writing, approve the application. \n(3) \nA person granted permission under sub-section (2) to use a special year may apply, in \nwriting, to change the person’s tax year to the financial year or to another special year and the \nCommissioner may, subject to sub-section (4), by notice in writing, approve such application. \n(4) \nThe Commissioner may approve an application under sub-section (2) or (3) only if the \nperson has shown a compelling need to use a special year or to change the person’s tax year and \nany approval shall be subject to such conditions as the Commissioner may prescribe. \n(5) \nThe Commissioner may, by notice in writing to a person, withdraw the permission to \nuse a special year granted under sub-section (2) or (3). \n(6) \nA notice served by the Commissioner under sub-section (2) shall take effect on the date \nspecified in the notice and a notice under sub-section (3) or (5) shall take effect at the end of the \nspecial year of the person in which the notice was served. \n(7) \nWhere the tax year of a person changes as a result of sub-section (2), (3) or (5), the \nperiod between the last full tax year prior to the change and the date on which the changed tax year \ncommences shall be treated as a separate tax year, to be known as the “transitional year”. \n(8) \nIn this Ordinance, a reference to a particular financial year shall include a special year \nor a transitional year of a person commencing during the financial year.  \n(9) \nA person dissatisfied with a decision of the Commissioner under sub-section (2), (3) or \n(5) may challenge the decision only under the appeal procedure in Part III of Chapter X.” \n2 Added by the Finance Act, 2004. \n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nChapter IV – Common Rules _____________________________ \n \n142 \n \n(ii)  in the case of a class of persons having a normal tax year may \npermit, by a notification in the official Gazette, to use a special \ntax year.]  \n \n \n(3)  \nA person may apply, in writing, to the Commissioner to allow him to \nuse a twelve months’ period, other than normal tax year, as special tax year and \nthe Commissioner may, subject to sub-section (5), by an order, allow him to use \nsuch special tax year. \n \n \n(4)  \nA person using a special tax year, under sub-section (2), may apply \nin writing, to the Commissioner to allow him to use normal tax year and the \nCommissioner may, subject to sub-section (5), by an order, allow him to use \nnormal tax year. \n \n \n(5)  \nThe Commissioner shall grant permission under sub-section (3) or (4) \nonly if the person has shown a compelling need to use special tax year or normal \ntax year, as the case may be, and the permission shall be subject to such \nconditions, if any, as the Commissioner may impose. \n \n \n(6)  \nAn order under sub-section (3) or (4) shall be made after providing to \nthe applicant an opportunity of being heard and where his application is rejected \nthe Commissioner shall record in the order the reasons for rejection. \n \n \n(7)  \nThe Commissioner may, after providing to the person concerned an \nopportunity of being heard, by an order, withdraw the permission granted under \nsub-section (3) or (4). \n \n \n(8)  \nAn order under sub-section (3) or (4) shall take effect from such date, \nbeing the first day of the special tax year or the normal tax year, as the case may \nbe, as may be specified in the order. \n \n \n(9)  \nWhere the tax year of a person changes as a result of an order under \nsub-section (3) or sub-section (4), the period between the end of the last tax year \nprior to change and the date on which the changed tax year commences shall be \ntreated as a separate tax year, to be known as the “transitional tax year”. \n \n \n(10)  In this Ordinance, a reference to a particular financial year shall, \nunless the context otherwise requires, include a special tax year or a transitional \ntax year commencing during the financial year. \n \n \n(11)  A person dissatisfied with an order under sub-section (3), (4) or (7) \nmay file a review application to the 1[Board], and the decision by the 2[Board] on \nsuch application shall be final.] \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nChapter IV – Common Rules _____________________________ \n \n143 \n \nPART III \nASSETS \n \n75.  Disposal and acquisition of assets.—(1) A person who holds an asset shall \nbe treated as having made a disposal of the asset at the time the person parts with \nthe ownership of the asset, including when the asset is — \n \n(a) \nsold, exchanged, transferred or distributed; or \n \n(b) \ncancelled, redeemed, relinquished, destroyed, lost, expired or \nsurrendered. \n \n \n(2) \nThe transmission of an asset by succession or under a will shall be \ntreated as a disposal of the asset by the deceased at the time asset is transmitted. \n \n \n(3) \nThe application of a business asset to personal use shall be treated as a \ndisposal of the asset by the owner of the asset at the time the asset is so applied. \n \n1[(3A) Where a business asset is discarded or ceases to be used in \nbusiness, it shall be treated to have been disposed of.] \n \n \n(4) \nA disposal shall include the disposal of a part of an asset.  \n \n \n(5) \nA person shall be treated as having acquired an asset at the time the \nperson begins to own the asset, including at the time the person is granted any right.  \n \n \n(6) \nThe application of a personal asset to business use shall be treated \nas an acquisition of the asset by the owner at the time the asset is so applied. \n \n \n(7) \nIn this section, -  \n \n“business asset” means an asset held wholly or partly for use in a \nbusiness, including stock-in-trade and a depreciable asset; and \n \n“personal asset” means an asset held wholly for personal use. \n \n2[75A. Purchase of assets through banking channel 3[or digital means].- (1) \nNotwithstanding anything contained in any other law, for the time being in force, \nno person shall purchase-  \n \n                                            \n1 Inserted by the Finance Act, 2003.  \n2 New section 75A inserted by the Finance Act, 2019. \n3 Words inserted by the Finance Act, 2025.  \n\n\f\nChapter IV – Common Rules _____________________________ \n \n144 \n \n(a) immovable property having fair market value greater than five million \nRupees; or \n \n(b) any other asset having fair market value more than one million Rupees,  \notherwise than by a crossed cheque drawn on a bank or through crossed \ndemand draft or crossed pay order or any other crossed banking \ninstrument 1[or through digital means] showing transfer of amount from \none bank account to another bank account.  \n \n(2) \nFor the purposes of this section in case of immovable property, fair \nmarket value means value notified by the Board under sub-section (4) of section \n68 or value fixed by the provincial authority for the purposes of stamp duty, \nwhichever is higher. \n \n(3) \nIn case the transaction is not undertaken in the manner specified in \nsub-section (1), -  \n \n \n(a) such asset shall not be eligible for any allowance under sections 22, 23, \n24 and 25 of this Ordinance; and  \n \n(b) such amount shall not be treated as cost in terms of section 76 of this \nOrdinance for computation of any gain on sale of such asset.]  \n \n76. Cost.—(1) Except as otherwise provided in this Ordinance, this section shall \nestablish the cost of an asset for the purposes of this Ordinance. \n \n \n(2) \nSubject to sub-section (3), the cost of an asset purchased by a person \nshall be the sum of the following amounts, namely:— \n \n(a) \nThe total consideration given by the person for the asset, \nincluding the fair market value of any consideration in kind \ndetermined at the time the asset is acquired; \n \n(b) \nany incidental expenditure incurred by the person in acquiring \nand disposing of the asset; and  \n(c) \nany expenditure incurred by the person to alter or improve the \nasset, \n \nbut shall not include any expenditure under clauses (b) and (c) that has been fully \nallowed as a deduction under this Ordinance. \n \n \n(3) \nThe cost of an asset treated as acquired under sub-section (6) of \nsection 75 shall be the fair market value of the asset determined at the date it is \napplied to business use. \n \n                                            \n1 Words inserted by the Finance Act, 2025.  \n\n\f\nChapter IV – Common Rules _____________________________ \n \n145 \n \n \n(4) \nThe cost of an asset produced or constructed by a person shall be the \ntotal costs incurred by the person in producing or constructing the asset plus any \nexpenditure referred to 1[in] clauses (b) and (c) of sub-section (2) incurred by the \nperson. \n \n(5) \nWhere an asset has been acquired by a person with a loan denominated \nin a foreign currency and, before full and final repayment of the loan, there is an \nincrease or decrease in the liability of the person under the loan as expressed in \nRupees, the amount by which the liability is increased or reduced shall be added to or \ndeducted from the cost of the asset, as the case may be. \n \n \n2[Explanation.-Difference, if any, on account of foreign currency fluctuation, \nshall be taken into account in the year of occurrence for the purposes of \ndepreciation.] \n \n(6) \nIn determining whether the liability of a person has increased or \ndecreased for the purposes of sub-section (5), account shall be taken of the \nperson’s position under any hedging agreement relating to the loan. \n \n \n(7) \nWhere a part of an asset is disposed of by a person, the cost of the \nasset shall be apportioned between the part of the asset retained and the part \ndisposed of in accordance with their respective fair market values determined at \nthe time the person acquired the asset. \n \n \n(8) \nWhere the acquisition of an asset by a person is the derivation of an \namount chargeable to tax, the cost of the asset shall be the amount so charged \nplus any amount paid by the person for the asset. \n \n \n(9) \nWhere the acquisition of an asset by a person is the derivation of an \namount exempt from tax, the cost of the asset shall be the exempt amount plus \nany amount paid by the person for the asset. \n \n \n(10) The cost of an asset does not include the amount of any grant, \nsubsidy, rebate, commission or any other assistance (other than a loan repayable \nwith or without profit) received or receivable by a person in respect of the \nacquisition of the asset, except to the extent to which the amount is chargeable to \ntax under this Ordinance. \n \n \n3[(11) Notwithstanding anything contained in this section, the Board may \nprescribe rules for determination of cost for any asset.] \n \n                                            \n1Inserted by the Finance Act, 2003. \n2Added by the Finance Act, 2009. \n3Added by the Finance Act, 2012. \n\n\f\nChapter IV – Common Rules _____________________________ \n \n146 \n \n77. Consideration received.—(1)  The consideration received by a person on \ndisposal of an asset shall be the total amount received by the person for the asset \n1[or the fair market value thereof, whichever is the higher], including the fair market \nvalue of any consideration received in kind determined at the time of disposal. \n \n \n(2) \nWhere an asset has been lost or destroyed by a person, the \nconsideration received for the asset shall include any compensation, indemnity or \ndamages received by the person under — \n \n(a) \nan insurance policy, indemnity or other agreement; \n(b) \na settlement; or \n(c) \na judicial decision. \n \n(3) \nThe consideration received for an asset treated as disposed of under \nsub-section (3) 2[or (3A)] of section 75 shall be the fair market value of the asset \ndetermined at the time it is applied to personal use 3[or discarded or ceased to be \nused in business, as the case may be]. \n \n \n(4) \nThe consideration received by a scheduled bank, financial institution, \nmodaraba, or leasing company approved by the Commissioner (hereinafter \nreferred to as a “leasing company”) in respect of an asset leased by the company \nto another person shall be the residual value received by the leasing company on \nmaturity of the lease agreement subject to the condition that the residual value \nplus the amount realized during the term of the lease towards the cost of the asset \nis not less than the original cost of the asset. \n \n \n(5) \nWhere two or more assets are disposed of by a person in a single \ntransaction and the consideration received for each asset is not specified, the total \nconsideration received by the person shall be apportioned among the assets \ndisposed of in proportion to their respective fair market values determined at the \ntime of the transaction. \n \n \n4[(6) Notwithstanding anything contained in this section, the Board may \nprescribe rules for determination of consideration received for any asset.] \n \n78. Non-arm’s length transactions.— Where an asset is disposed of in a non-\narm’s length transaction — \n \n(a) \nthe person disposing of the asset shall be treated as having received \nconsideration equal to the fair market value of the asset determined at \nthe time the asset is disposed; and \n(b) \nthe person acquiring the asset shall be treated as having a cost equal \nto the amount determined under clause (a).  \n                                            \n1 Inserted by the Finance Act, 2003. \n2 Inserted by the Finance Act, 2003. \n3Inserted by the Finance Act, 2003. \n4Added by the Finance Act, 2012. \n\n\f\nChapter IV – Common Rules _____________________________ \n \n147 \n \n79. Non-recognition rules.— (1)  For the purposes of this Ordinance and \nsubject to sub-section (2), no gain or loss shall be taken to arise on the disposal of \nan asset – \n \n(a) \nbetween spouses under an agreement to live apart; \n(b) \nby reason of the transmission of the asset to an executor or beneficiary \non the death of a person;  \n(c) \nby reason of a gift of the asset 1[to a relative, as defined in sub-section \n(5) of section 85]; \n(d) \nby reason of the compulsory acquisition of the asset under any law \nwhere the consideration received for the disposal is reinvested by the \nrecipient in an asset of a like kind within one year of the disposal;  \n(e) \nby a company to its shareholders on liquidation of the company; or \n(f) \nby an association of persons to its members on dissolution of the \nassociation where the assets are distributed to members in accordance \nwith their interests in the capital of the association. \n \n(2) \nSub-section (1) shall not apply where the person acquiring the asset \nis a non-resident person at the time of the acquisition 2[in respect of disposal of an \nasset as mentioned in clauses (d), (e) and (f) of sub-section (1)]. \n \n \n(3) \nWhere clause (a), (b), (c), (e) or (f) of sub-section (1) applies, the \nperson acquiring the asset shall be treated as — \n \n(a) \nacquiring an asset of the same character as the person \ndisposing of the asset; and \n \n(b) \nacquiring the asset for a cost equal to the cost of the asset for \nthe person disposing of the asset at the time of the disposal.  \n \n \n(4) \nThe person’s cost of a replacement asset referred to in clause (d) of \nsub-section (1) shall be the cost of the asset disposed of plus the amount by which \nany consideration given by the person for the replacement asset exceeds the \nconsideration received by the person for the asset disposed of.\n                                            \n1Inserted by the Finance Act, 2018. \n2 Inserted by the Finance Act, 2021. \n\n\f\nChapter V – Provisions Governing Persons_________________ \n \n148 \nCHAPTER V \nPROVISIONS GOVERNING PERSONS \n \nPART I \nCENTRAL CONCEPTS \n \nDivision I \nPersons \n \n80. Person. — (1)  The following shall be treated as persons for the purposes of \nthis Ordinance, namely: — \n \n(a) \nAn individual; \n \n(b) \na company or association of persons incorporated, formed, organised \nor established in Pakistan or elsewhere;  \n \n(c) \nthe Federal Government, a foreign government, a political sub-Division \nof a foreign government, or public international organisation.  \n \n(2) \nFor the purposes of this Ordinance — \n \n(a) \n“association of persons” includes a firm, a Hindu undivided \nfamily, any artificial juridical person and anybody of persons \nformed under a foreign law, but does not include a company;  \n \n(b) \n“company” means — \n \n  (i) \na company as defined in the 1[Companies Act, 2017 (XIX \nof 2017)];  \n \n (ii) \na body corporate formed by or under any law in force in \nPakistan;  \n \n(iii) \na modaraba;  \n \n(iv) \na body incorporated by or under the law of a country \noutside Pakistan relating to incorporation of companies;  \n \n2[(v)  a co-operative society, a finance society or any other \nsociety;] \n                                            \n1 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \n2Clause (v) substituted by the Finance Act, 2013. The substituted Clause (v) read as follows:- \n“(v) \na trust,  a co-operative  society or a finance society or any other society \nestablished or constituted by or under any law for the time being in force;” \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n149 \n \n1[(va)  a non-profit organization;] \n \n2[(vb)  a trust, an entity or a body of persons established or \nconstituted by or under any law for the time being in force;] \n \n(vi) \na foreign association, whether incorporated or not, which \nthe 3[Board] has, by general or special order, declared to \nbe a company for the purposes of this Ordinance; \n \n(vii) \na Provincial Government; 4[  ]  \n \n(viii) a 5[Local Government] in Pakistan; 6[or] \n \n7[(ix)  a Small Company as defined in section 2;] \n \n(c) \n“firm” means the relation between persons who have agreed to \nshare the profits of a business carried on by all or any of them \nacting for all; \n \n(d) \n“trust” means an obligation annexed to the ownership of \nproperty and arising out of the confidence reposed in and \naccepted by the owner, or declared and accepted by the owner \nfor the benefit of another, or of another and the owner, and \nincludes a unit trust; and \n \n(e) \n“unit trust” means any trust under which beneficial interests are \ndivided into units such that the entitlements of the beneficiaries \nto income or capital are determined by the number of units held. \n \n \n \n \n                                            \n \n1Inserted by the Finance Act, 2013. \n2Inserted by the Finance Act, 2013. \n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n4The word “or” omitted by the Finance Act, 2005. \n5The words “local authority” substituted by the Finance Act, 2008. \n6Inserted by the Finance Act, 2005. \n7 Added by the Finance Act, 2005. \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n150 \n \nDivision II \nResident and Non-Resident Persons \n \n81.  Resident and non-resident persons.— (1)  A person shall be a resident \nperson for a tax year if the person is — \n \n(a) \na resident individual, resident company or resident association of \npersons for the year; or \n \n(b) \nthe Federal Government. \n \n(2) \nA person shall be a non-resident person for a tax year if the person is \nnot a resident person for that year. \n \n82. Resident individual. — An individual shall be a resident individual for a tax \nyear if the individual — \n \n(a) is present in Pakistan for a period of, or periods amounting in aggregate \nto, one hundred and 1[eighty-three] days or more in the tax year; 2[ ] 3[or] \n \n4[   ]  \n5[   ] \n6[   ] \n \n(c) is an employee or official of the Federal Government or a Provincial \nGovernment posted abroad in the tax year 7[; \n  \n(d)  being a citizen of Pakistan is not present in any other country for more \nthan one hundred and eighty-two days during the tax year or who is not \na resident taxpayer of any other country.] \n \n                                            \n1The words “eighty-two” substituted by the Finance Act, 2006. \n2The word “or” omitted by the Finance Act, 2019. \n3The word “or” added by the Finance Act, 2022. \n4New clause (ab) inserted by Finance Act, 2019 \n5 Clause (ab) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(ab) is present in Pakistan for a period of, or periods amounting in aggregate to, one hundred and \ntwenty days or more in the tax year and, in the four years preceding the tax year, has been in \nPakistan for a period of, or periods amounting in aggregate to, three hundred and sixty-five \ndays or more; or” \n6 Clause (b) omitted by the Finance Act, 2003. The omitted clause (b) read as follows:  \n“(b) \nis present in Pakistan for a period of, or periods amounting in aggregate to, \nninety days or more in the tax year and who, in the four years preceding the tax \nyear, has been in Pakistan for a period of, or periods amounting in aggregate \nto, three hundred and sixty-five days or more; or” \n7The full stop substituted with a semicolon and clause (d) inserted by the Finance Act, 2022. \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n151 \n \n83. Resident company.— A company shall be a resident company for a tax year \nif — \n \n(a) \nit is incorporated or formed by or under any law in force in \nPakistan;  \n \n(b) \nthe control and management of the affairs of the company is \nsituated wholly 1[  ] in Pakistan at any time in the year; or  \n \n(c) it is a Provincial Government or 2[Local Government] in Pakistan. \n \n84. Resident association of persons. — An association of persons shall be a \nresident association of persons for a tax year if the control and management of the \naffairs of the association is situated wholly or partly in Pakistan at any time in the \nyear. \n \nDivision III \nAssociates \n \n85. Associates. — 3[(1) Subject to sub-section (2), two persons shall be \nassociates where – \n  \n(i) \nthe relationship between the two is such that one may reasonably be \nexpected to act in accordance with the intentions of the other, or both \npersons may reasonably be expected to act in accordance with the \nintentions of a third person;  \n \n(ii) \none person sufficiently influences, either alone or together with an \nassociate or associates, the other person;  \n \nExplanation. – For the purpose of this section, two persons shall be \ntreated as sufficiently influencing each other, where one or both persons, \ndirectly or indirectly, are economically and financially dependent on each \nother and, decisions are made in accordance with the directions, \ninstructions or wishes of each other for common economic goal; or  \n(iii) \none person enters into a transaction, directly or indirectly, with the other \nwho is a resident of jurisdiction with zero taxation regime.]  \n \n                                            \n1The words “or almost wholly” omitted by the Finance Act, 2003. \n2The words “local authority” substituted by the Finance Act, 2008. \n3 Sub-section (1) substituted by the Finance Act, 2023. The substituted sub-section read as follows: \n“(1)  Subject to sub-section (2), two persons shall be associates where the relationship between the \ntwo is such that one may reasonably be expected to act in accordance with the intentions of the other, \nor both persons may reasonably be expected to act in accordance with the intentions of a third \nperson.” \n \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n152 \n \n \n(2) \nTwo persons shall not be associates solely by reason of the fact that \none person is an employee of the other or both persons are employees of a third \nperson.  \n \n \n(3) \nWithout limiting the generality of sub-section (1) and subject to sub-\nsection (4), the following shall be treated as associates — \n \n(a) \nan individual and a relative of the individual; \n \n(b) \nmembers of an association of persons; \n \n(c) \na member of an association of persons and the association, \nwhere the member, either alone or together with an associate \nor associates under another application of this section, controls \nfifty per cent or more of the rights to income or capital of the \nassociation; \n \n(d) \na trust and any person who benefits or may benefit under the \ntrust; \n \n(e) \na shareholder in a company and the company, where the \nshareholder, either alone or together with an associate or \nassociates under another application of this section, controls \neither directly or through one or more interposed persons — \n \n  (i) \nfifty per cent or more of the voting power in the company; \n \n (ii) \nfifty per cent or more of the rights to dividends; or \n \n(iii) \nfifty per cent or more of the rights to capital; and \n \n(f) \ntwo companies, where a person, either alone or together with \nan associate or associates under another application of this \nsection, controls either directly or through one or more \ninterposed persons — \n \n  (i) \nfifty per cent or more of the voting power in both \ncompanies; \n \n (ii) \nfifty per cent or more of the rights to dividends in both \ncompanies; or \n \n(iii) \nfifty per cent or more of the rights to capital in both \ncompanies. \n \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n153 \n \n \n(4) \nTwo persons shall not be associates under clause (a) or (b) of sub-\nsection (3) where the Commissioner is satisfied that neither person may \nreasonably be expected to act in accordance with the intentions of the other. \n \n \n1[(5) In this section, –  \n \n(i) \n“relative” in relation to an individual, means —  \n \n(a) \nan ancestor, a descendant of any of the grandparents, or \nan adopted child, of the individual, or of a spouse of the \nindividual; or  \n \n(b)  \na spouse of the individual or of any person specified in \nclause (a); \n \n(ii) \njurisdiction with zero taxation regime means jurisdiction as may \nbe prescribed.] \n \n \n \n \n \n \n                                            \n1 Sub-section (5) substituted by the Finance Act. 2023. The substituted sub-section (5) read as \nfollows:  \n“(5) In this section, “relative” in relation to an individual, means — \n(a) \nan ancestor, a descendant of any of the grandparents, or an adopted child, of the \nindividual, or of a spouse of the individual; or \n(b) \na spouse of the individual or of any person specified in clause (a).” \n \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n154 \n \nPART II \nINDIVIDUALS \n \nDivision I \nTaxation of Individuals \n \n86. Principle of taxation of individuals.— Subject to this Ordinance, the \ntaxable income of each individual shall be determined separately. \n \n87. Deceased individuals.— (1)  The legal representative of a deceased \nindividual shall be liable for — \n \n(a) \nany tax that the individual would have become liable for if the \nindividual had not died; and \n \n(b) \nany tax payable in respect of the income of the deceased’s \nestate. \n \n \n(2) \nThe liability of a legal representative under this section shall be limited \nto the extent to which the deceased’s estate is capable of meeting the liability. \n \n \n1[(2A) The liability under this Ordinance shall be the first charge on the \ndeceased’s estate.] \n \n \n(3) \nFor the purpose of this Ordinance, — \n \n(a) \nany proceeding taken under this Ordinance against the \ndeceased before his or her death shall be treated as taken \nagainst the legal representative and may be continued against \nthe legal representative from the stage at which the proceeding \nstood on the date of the deceased’s death; and \n \n(b) \nany proceeding which could have been taken under this \nOrdinance against the deceased if the deceased had survived \nmay be taken against the legal representative of the deceased. \n \n \n(4) \nIn this section, “legal representative” means a person who in law \nrepresents the estate of a deceased person, and includes any person who \nintermeddles with the estate of the deceased and where a party sues or is sued in \nrepresentative character the person on whom the estate devolves on the death of \nthe party so suing or sued. \n \n                                            \n1Added by the Finance Act, 2010. \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n155 \n \nDivision II \nProvisions Relating to Averaging \n \n88. An individual as a member of an association of persons.— If, for a tax \nyear, an individual has taxable income and derives an amount or amounts exempt \nfrom tax under sub-section (1) of section 92, the amount of tax payable on the \ntaxable income of the individual shall be computed in accordance with the following \nformula, namely: — \n \n(A/B) x C \nwhere — \n \nA \nis the amount of tax that would be assessed to the individual for the year if \nthe amount or amounts exempt from tax under sub-section (1) of section 92 \nwere chargeable to tax; \n \nB \nis the taxable income of the individual for the year if the amount or amounts \nexempt from tax under sub-section (1) of section 92 were chargeable to tax; \nand  \n \nC \nis the individual’s actual taxable income for the year. \n \n1[  ] \n \n89. \nAuthors. — Where the time taken by an author of a literary or artistic work \nto complete the work exceeds twenty-four months, the author may elect to treat \nany lump sum amount received by the author in a tax year on account of royalties \nin respect of the work as having been received in that tax year and the preceding \ntwo tax years in equal proportions. \n \n                                            \n1Section 88A omitted by Finance Act, 2014. The omitted section read as follows: \n“88A. Share profits of company to be added to taxable income.—(1) Notwithstanding the \nprovisions of sub-section (1) of section 92, the share of profits derived by a company from an \nassociation of persons shall be added to the taxable income of the company. \n(2) \nThe company shall be allowed a tax credit in accordance with the following formula, \nnamely: — \n(A/B) x C \nWhere — \n \nA \nis the amount of share of profits received by the company from the association; \nB \nis the taxable income of the association; and \nC \nis the amount of tax assessed on the association. \n(3) \nThe tax credit allowed under this section shall be applied in accordance with sub-section \n(3) of section 4.”  \n \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n156 \n \nDivision III \nIncome Splitting \n \n90. \nTransfers of assets. — (1) For the purposes of this Ordinance and subject \nto sub-section (2), where there has been a revocable transfer of an asset, any \nincome arising from the asset shall be treated as the income of the transferor and \nnot of the transferee.  \n \n \n(2) \nSub-section (1) shall not apply to any income derived by a person by \nvirtue of a transfer that is not revocable during the lifetime of the person and the \ntransferor derives no direct or indirect benefit from such income. \n \n(3) \nFor the purposes of this Ordinance, where there has been a transfer \nof an asset but the asset remains the property of the transferor, any income arising \nfrom the asset shall be treated as the income of the transferor.  \n \n \n(4) \nFor the purposes of this Ordinance and subject to sub-section (5), any \nincome arising from any asset transferred by a person directly or indirectly to— \n \n(a) \nthe person’s spouse or minor child; or  \n \n(b) \nany other person for the benefit of a person or persons referred \nto in clause (a), \n \nshall be treated as the income of the transferor. \n \n \n(5) \nSub-section (4) shall not apply to any transfer made — \n \n(a) \nfor adequate consideration; or  \n \n(b) \nin connection with an agreement to live apart. \n \n \n(6) \nFor the purposes of clause (a) of sub-section (5), a transfer shall not \nbe treated as made for adequate consideration if the transferor has provided, by \nway of loan or otherwise, to the transferee, directly or indirectly, with the funds for \nthe acquisition of the asset. \n \n \n(7) \nSub-section (5) does not apply where the transferor fails to produce \nevidence of the transfer of the asset by way of its registration or mutation in the \nrelevant record and the income arising from the asset shall be treated as the \nincome of the transferor for the purposes of this Ordinance. \n \n \n(8) \nFor the purposes of this section, — \n \n(a) \na transfer of an asset shall be treated as revocable if — \n(i) \nthere is any provision for the re-transfer, directly or \nindirectly, of the whole or any part of the asset to the \ntransferor; or \n \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n157 \n \n(ii) \nthe transferor has, in any way, the right to resume power, \ndirectly or indirectly, over the whole or any part of the \nasset;  \n \n(b) \n“minor child” shall not include a married daughter; and \n \n(c) \n“transfer” includes any disposition, settlement, trust, covenant, \nagreement or arrangement. \n \n91. \nIncome of a minor child.— (1)  Any income of a minor child for a tax year \nchargeable under the head \"Income from Business\" shall be chargeable to tax as the \nincome of the parent of the child with the highest taxable income for that year.  \n \n \n(2) \n Sub-section (1) shall not apply to the income of a minor child from a \nbusiness acquired by the child through an inheritance. \n \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n158 \n \nPART III \nASSOCIATIONS OF PERSONS \n \n92. Principles of taxation of associations of persons.—(1) 1[ ] An association \nof persons shall be liable to tax separately from the members of the association and \n2[where the association of persons has paid tax the] amount received by a member \nof the association in the capacity as member out of the income of the association \nshall be exempt from tax3[:] \n \n \n4[Provided that if at least one member of the association of persons is \na company, the share of such company or companies shall be excluded  for \nthe purpose of computing the total income of the association of persons and \nthe company or the companies shall be taxed separately, at the rate \napplicable to the companies, according to their share5[: ] \n \nProvided further that the share of a member of an association of \npersons having turnover of three hundred million rupees or above during the \ntax year or any of the preceding tax years shall not be exempt if financial \nstatements duly audited by a firm of Chartered Accountants as defined under \nthe Chartered Accountants Ordinance, 1961 (X of 1961), or a firm of Cost \nand Management Accountants as defined under the Cost and Management \nAccountants Act, 1966 (XIV of 1966) have not been filed along with return \nof income by the association of persons to whom he is a member:] \n \n6[Explanation.– For removal of doubt it is clarified that if the income of \nassociation of persons is exempt and no tax is payable under the Ordinance \ndue to this exemption, the share received in the capacity as member out of \nthe income of the association shall remain exempt.] \n \n7[  ] \n \n8[  ] \n \n9[  ] \n                                            \n1The words, brackets, figure and comma “Subject to sub-section (2)” omitted by the Finance Act, 2007. \n2 Inserted by the Finance Act, 2003. \n3Full stop substituted by a colon by the Finance Act, 2014. \n4Added by the Finance Act, 2014. \n5 Full stop substituted and new proviso inserted by the Finance Act, 2024. \n6 Explanation added by the Finance Act, 2022. \n7 Sub-section (2) omitted by the Finance Act, 2007. The omitted sub-section (2) read as follows:  \n“ (2) Sub-section (1) shall not apply to an association of persons that is a professional firm prohibited \nfrom incorporating by any law or the rules of the body regulating the profession.” \n8Sub-section (3) omitted by the Finance Act, 2007. The omitted sub-section (3) read as follows: \n“(3)  An association of persons to which subsection (2) applies shall not be liable to tax and the income \nof the association shall be taxed to the members in accordance with section 93”. \n9 Sub-section (4) omitted by the Finance Act, 2007. The omitted sub-section (4) read as follows:  \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n159 \n \n \n1[  ] \n \n2[  ] \nPART IV \nCOMPANIES \n \n94. Principles of taxation of companies.- (1)  A company shall be liable to tax \nseparately from its shareholders. \n \n \n(2) \nA dividend paid by a 3[  ] company shall be taxable in accordance with \nSection 5. \n \n \n4[ ] \n \n                                            \n“(4)An association of persons referred to in sub-section (3) shall furnish a return of total income for \neach tax year. \n1Sub-section (5) omitted by the Finance Act, 2007. The omitted sub-section (5) read as follows: \n“(5) \nSections 114, 118 and 119 shall apply to a return of total income required to be furnished under \nsub-section (4).” \n2 Section 93 omitted by the Finance Act, 2007. The omitted section read as follows:  \n“93. \nTaxation of members of an association of persons.- (1)  Where sub-section (3) of section \n92 applies, the income of a member of an association of persons chargeable under the head “Income \nfrom Business” for a tax year shall include – \n(a) \nin the case of a resident member, the member’s share in the total income of the \nassociation; or \n(b) \nin the case of a non-resident member, the member’s share in so much of the total income \nof the association as is attributable to Pakistani-source income. \n \n(2) \nWhere an association of persons to which sub-section (3) of section 92 applies sustains \na loss that cannot be set off against any other income of the association in accordance with section 56, \nthe amount of the loss shall be apportioned among the members of the association according to their \ninterest in the association and the members shall be entitled to have their share of the loss set off and \ncarried forward for set off under Part VIII of Chapter III in computing their taxable income under this \nOrdinance. \n \n(3) \nThe share of a loss referred to in sub-section (2) of a non-resident member shall be \nlimited to the extent that the loss relates to the derivation of Pakistan-source income. \n \n(4) \nThe total income of an association of persons for the purposes of sub-section (1) and \nthe loss of an association for the purposes of sub-section (2) shall be computed as if the association \nwere a resident person. \n \n(5) \nIncome, expenditures and losses of an association of persons to which this section \napplies shall retain their character as to geographic source and type of income, expenditure or loss in \nthe hands of the members of the association, and shall be treated as having passed through the \nassociation on a pro rata basis, unless the Commissioner permits otherwise by order in writing to the \nassociation. \n \n(6) \nThe share of a member in the total income of an association of persons shall be \ndetermined according to the  member’s interest in the association and shall include any profit on debt, \nbrokerage, commission, salary or other remuneration received or due from the association.” \n3The word “resident” omitted by the Finance Act, 2015 \n4Sub-section (3) omitted by the Finance Act 2017. Omitted sub-section reads as follows: \n    “A dividend paid by a non-resident company to a resident person shall be chargeable to tax under \nthe head “Income from Business” or “Income from Other Sources”, as the case may be, unless the \ndividend is exempt from tax.” \n \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n160 \n \n95. Disposal of business by individual to wholly-owned company.- (1)  \nWhere a resident individual (hereinafter referred to as the “transferor”) disposes of \nall the assets of a business of the transferor to a resident company, no gain or loss \nshall be taken to arise on the disposal if the following conditions are satisfied, \nnamely:— \n(a) \nThe consideration received by the transferor for the disposal is \na share or shares in the company (other than redeemable \nshares); \n \n(b) \nthe transferor must beneficially own all the issued shares in the \ncompany immediately after the disposal; \n(c) \nthe company must undertake to discharge any liability in respect \nof the assets disposed of to the company; \n \n(d) \nany liability in respect of the assets disposed of to the company \nmust not exceed the transferor’s cost of the assets at the time \nof the disposal; \n \n(e) \nthe fair market value of the share or shares received by the \ntransferor for the disposal must be substantially the same as the \nfair market value of the assets disposed of to the company, less \nany liability that the company has undertaken to discharge in \nrespect of the assets; and \n \n(f) \nthe company must not be exempt from tax for the tax year in \nwhich the disposal takes place. \n \n \n(2) \nWhere sub-section (1) applies — \n \n(a) \neach of the assets acquired by the company shall be treated as \nhaving the same character as it had in the hands of the \ntransferor; \n \n(b) \nthe company’s cost in respect of the acquisition of the assets \nshall be — \n \n  (i) \nin the case of a depreciable asset or amortised intangible, \nthe written down value of the asset or intangible \nimmediately before the disposal;  \n \n (ii) \nin the case of stock-in-trade valued for tax purposes under \nsub-section (4) of section 35 1[  ], that value; or  \n \n                                            \n1The words “at fair market value” omitted by the Finance Act, 2007. \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n161 \n \n(iii) \nin any other case, the transferor’s cost at the time of the \ndisposal; \n \n(c) \nif, immediately before the disposal, the transferor has \ndeductions allowed under sections 22, 23 and 24 in respect of \nthe assets transferred which have not been set off against the \ntransferor’s income, the amount not set off shall be added to the \ndeductions allowed under those sections to the company in the \ntax year in which the transfer is made; and \n(d) \nthe transferor’s cost in respect of the share or shares received \nas consideration for the disposal shall be — \n \n(i) \nin the case of a consideration of one share, the \ntransferor’s cost of the assets transferred as determined \nunder clause (b), less the amount of any liability that the \ncompany has undertaken to discharge in respect of the \nassets; or  \n \n(ii) \nin the case of a consideration of more than one share, the \namount determined under sub-clause (i) divided by the \nnumber of shares received. \n \n \n(3) \nIn determining whether the transferor’s deductions under sections 22, \n23 or 24 have been set off against income for the purposes of clause (c) of sub-\nsection (2), those deductions shall be taken into account last. \n  \n96. Disposal of business by association of persons to wholly-owned \ncompany.— (1)  Where a resident association of persons disposes of all the assets \nof a business of the association to a resident company, no gain or loss shall be taken \nto arise on the disposal if the following conditions are satisfied, namely: — \n \n(a) \nThe consideration received by the association for the disposal is a \nshare or shares in the company (other than redeemable shares); \n(b) \nthe association must own all the issued shares in the company \nimmediately after the disposal; \n(c) \neach member of the association must have an interest in the \nshares in the same proportion to the member’s interest in the \nbusiness assets immediately before the disposal; \n(d) \nthe company must undertake to discharge any liability in respect \nof the assets disposed of to the company; \n(e) \nany liability in respect of the assets disposed of to the company \nmust not exceed the association’s cost of the asset at the time \nof the disposal; \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n162 \n \n(f) \nthe fair market value of the share or shares received by the \nassociation for the disposal must be substantially the same as \nthe fair market value of the assets disposed of to the company, \nas reduced by any liability that the company has undertaken to \ndischarge in respect of the assets; and \n(g) \nthe company must not be exempt from tax for the tax year in \nwhich the disposal takes place. \n \n \n(2) \nWhere sub-section (1) applies — \n(a) \neach of the assets acquired by the company shall be treated as \nhaving the same character as it had in the hands of the \nassociation; \n(b) \nthe company’s cost in respect of the acquisition of the assets \nshall be — \n  (i) \nin the case of a depreciable asset or amortised intangible, \nthe written down value of the asset or intangible \nimmediately before the disposal;  \n (ii) \nin the case of stock-in-trade valued for tax purposes \nunder sub-section (4) of section 351[  ], that value; or  \n(iii) \nin any other case, the association’s cost at the time of the \ndisposal; \n(c) \nif, immediately before the disposal, the association is subject to tax \nin accordance with sub-section (1) of section 92 and the \nassociation has deductions allowed under sections 22, 23 and 24 \nin respect of the assets transferred which have not been set off \nagainst the association’s income, the amount not set off shall be \nadded to the deductions allowed under those sections to the \ncompany in the tax year in which the transfer is made; and \n(d) \nthe association’s cost in respect of the share or shares received \nas consideration for the disposal shall be — \n (i) \nin the case of a consideration of one share, the \nassociation’s cost of the assets transferred as determined \nunder clause (b), as reduced by the amount of any liability \nthat the company has undertaken to discharge in respect \nof the assets; or  \n                                            \n1 The words “at fair market value” omitted by the Finance Act, 2007. \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n163 \n \n(ii) \nin the case of a consideration of more than one share, the \namount determined under sub-clause (i) divided by the \nnumber of shares received. \n \n(3) \nIn determining whether the association’s deductions under Sections \n22, 23 or 24 have been set off against income for the purposes of clause (c) of \nsub-section (2), those deductions are taken into account last.  \n97. Disposal of asset between wholly-owned companies.— (1)  Where a resident \ncompany (hereinafter referred to as the “transferor”) disposes of an asset to another \nresident company (hereinafter referred to as the “transferee”), no gain or loss shall \nbe taken to arise on the disposal if the following conditions are satisfied, namely:- \n(a) \nBoth companies belong to a wholly-owned group of 1[resident] \ncompanies at the time of the disposal; \n(b) \nthe transferee must undertake to discharge any liability in \nrespect of the asset acquired; \n(c) \nany liability in respect of the asset must not exceed the \ntransferor’s cost of the asset at the time of the disposal; and \n(d) \nthe transferee must not be exempt from tax for the tax year in \nwhich the disposal takes place. \n \n(2) \nWhere sub-section (1) applies — \n(a) \nthe asset acquired by the transferee shall be treated as having \nthe same character as it had in the hands of the transferor; \n(b) \nthe transferee’s cost in respect of the acquisition of the asset \nshall be — \n  (i) \nin the case of a depreciable asset or amortized intangible, \nthe written down value of the asset or intangible \nimmediately before the disposal;  \n (ii) \nin the case of stock-in-trade valued for tax purposes under \nsub-section (4) of section 35 2[  ], that value; or  \n(iii) \nin any other case, the transferor’s cost at the time of the \ndisposal;  \n(c) \nif, immediately before the disposal, the transferor has \ndeductions allowed under sections 22, 23 and 24 in respect of \nthe asset transferred which have not been set off against the \ntransferor’s income, the amount not set off shall be added to the \n                                            \n1Inserted by the Finance Act, 2003. \n2The words “at fair market value” omitted by the Finance Act, 2007. \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n164 \n \ndeductions allowed under those sections to the transferee in the \ntax year in which the transfer is made; and \n(d) \nthe transferor’s cost in respect of any consideration in kind \nreceived for the asset shall be the transferor’s cost of the asset \ntransferred as determined under clause (b), as reduced by the \namount of any liability that the transferee has undertaken to \ndischarge in respect of the asset. \n \n(3) \nIn determining whether the transferor’s deductions under sections 22, \n23 or 24 in respect of the asset transferred have been set off against income for \nthe purposes of clause (c) of sub-section (2), those deductions shall be taken into \naccount last.  \n \n(4) \nThe transferor and transferee companies belong to a wholly-owned \ngroup if — \n(a) \none company beneficially holds all the issued shares of the \nother company; or \n(b) \na third company beneficially holds all the issued shares in both \ncompanies. \n1[97A. \nDisposal \nof \nasset \nunder \na \nscheme \nof \narrangement \nand \nreconstruction.—(1) No gain or loss shall be taken to arise on disposal of asset \nfrom one company (hereinafter referred to as the “transferor”) to another company \n(hereinafter referred to as the “transferee”) by virtue of operation of a Scheme of \nArrangement and Reconstruction under sections 282L and 284 to 287 of the \n2[Companies Act, 2017 (XIX of 2017)] or section 48 of the Banking Companies \nOrdinance, 1962 (LVII of 1962), if the following conditions are satisfied, namely:— \n(a) \nthe transferee must undertake to discharge any liability in \nrespect of the asset acquired; \n(b) \nany liability in respect of the asset must not exceed the \ntransferor’s cost of the asset at the time of the disposal; \n(c) \nthe transferee must not be exempt from tax for the tax year in \nwhich the disposal takes place; and \n(d) \nscheme is approved by the High Court, State Bank of Pakistan \nor Securities and Exchange Commission of Pakistan, as the \ncase may be, on or after first day of July, 2007. \n \n(2) \nNo gain or loss shall be taken to arise on issue, cancellation, \nexchange or receipt of shares as a result of Scheme of Arrangement and \nReconstruction under sections 282L and 284 to 287 of the Companies Act, 2017 \n                                            \n1 Inserted by the Finance Act, 2007. \n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” wherever occurring substituted by \n“Companies Act, 2017 (XIX of 2017)” through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n165 \n \n(XIX of 2017) or section 48 of the Banking Companies Ordinance, 1962 (LVII of \n1962) and approved by:— \n(a) \nthe High Court; \n(b) \nState Bank of Pakistan; or \n(c) \nSecurities and Exchange Commission of Pakistan, as the case \nmay be, on or after first day of July, 2007. \n \n(3) \nWhere sub-section (1) applies— \n(a) \nthe asset acquired by the transferee shall be treated as having \nthe same character as it had in the hands of the transferor; \n \n(b) \nthe transferee’s cost in respect of acquisition of the asset shall be— \n(i) \nin the case of a depreciable asset or amortised intangible, \nthe written down value of the asset or intangible \nimmediately before the disposal; \n(ii) \nin the case of stock-in-trade valued for tax purposes \nunder sub-section (4) of section 35, that value; or \n(iii) \nin any other case, the transferor’s cost at the time of the \ndisposal; \n(c) \nif, immediately before the disposal, the transferor has \ndeductions allowed under sections 22, 23 and 24 in respect of \nthe asset transferred which have not been set off against the \ntransferor’s income, the amount not set off shall be added to the \ndeduction allowed under those sections to the transferee in the \ntax year in which the transfer is made. \n \n(4) \nIn determining whether the transferor’s deductions under sections 22, \n23 or 24 in respect of the asset transferred have been set off against income for \nthe purposes of clause (c) of sub-section (2), those deductions shall be taken into \naccount last. \n \n \n(5) \nWhere sub-section (2) applies and the shares issued vested by virtue \nof the Scheme of Arrangement and Reconstruction under sections 282L and 284 \nto 287 of the Companies Act, 2017 (XIX of 2017) or section 48 of the Banking \nCompanies Ordinance, 1962 (LVII of 1962) and approved by the Court or State \nBank of Pakistan or Securities and Exchange Commission of Pakistan as the case \nmay be, are disposed of, the cost of shares shall be the cost prior to the operation \nof the said scheme.] \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n166 \n \nPART V \n \nCOMMON PROVISIONS APPLICABLE TO  \nASSOCIATIONS OF PERSONS AND COMPANIES \n \n98.  Change in control of an entity.- (1)  Where there is a change of fifty per \ncent or more in the underlying ownership of an entity, any loss incurred for a tax \nyear before the change shall not be allowed as a deduction in a tax year after the \nchange, unless the entity — \n \n(a) \ncontinues to conduct the same business after the change as it \nconducted before the change until the loss has been fully set \noff; and \n \n(b) \ndoes not, until the loss has been fully set off, engage in any new \nbusiness or investment after the change where the principal \npurpose of the entity or the beneficial owners of the entity is to \nutilise the loss so as to reduce the income tax payable on the \nincome arising from the new business or investment. \n \n \n(2) \nIn this section, — \n \n“entity” means a company or association of persons to which sub-\nsection (1) of section 92 applies; \n \n“ownership interest” means a share in a company or the interest of a \nmember in an association of persons; and \n \n“underlying ownership” in relation to an entity, means an ownership \ninterest in the entity held, directly or indirectly through an interposed \nentity or entities, by an individual or by a person not ultimately owned \nby individuals. \n \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n167 \n \n1[PART VA \nTAX LIABILITY IN CERTAIN CASES \n \n98A.  Change in the constitution of an association of persons.—Where, \nduring the course of a tax year, a change occurs in the constitution of an \nassociation of persons, liability of filing the return on behalf of the association of \npersons for the tax year shall be on the association of persons as constituted at \nthe time of filing of such return but the income of the association of persons shall \nbe apportioned among the members who were entitled to receive it and, where the \ntax assessed on a member cannot be recovered from him it shall be recovered \nfrom the association of persons as constituted at the time of filing the return.  \n \n98B.  Discontinuance of business or dissolution of an association of \npersons.— (1) Subject to the provisions of section 117, where any business or \nprofession carried on by an association of persons has been discontinued, or \nwhere an association of persons is dissolved, all the provisions of this Ordinance, \nshall, so far as may be, apply as if no such discontinuance or dissolution had taken \nplace. \n \n(2)  \nEvery person, who was, at the time of such discontinuance or \ndissolution, a member of such association of persons and the legal representative \nof any such person who is deceased, shall be jointly and severally liable for the \namount of tax payable by the association of persons. \n \n98C. Succession to business, otherwise than on death.— (1) Where a person \ncarrying on any business or profession has been succeeded in any tax year by any \nother person (hereafter in this section referred to as the “predecessor” and \n“successor” respectively), otherwise than on the death of the predecessor, and the \nsuccessor continues to carry on that business or profession,-  \n \n(a)  \nthe predecessor shall be liable to pay tax in respect of the income of \nthe tax year in which the succession took place upto the date of \nsuccession and of the tax year or years preceding that year; and  \n \n(b)  \nthe successor shall be liable to pay tax in respect of the income of \nsuch tax year after the date of succession.  \n \n \n(2)  \nNotwithstanding anything contained in sub-section (1), where the \npredecessor cannot be found, the tax liability in respect of the tax year in which the \nsuccession took place upto the date of succession and of the tax year or years \npreceding that year shall be that of the successor in like manner and to the same \nextent as it would have been that of the predecessor, and all the provisions of this \nOrdinance shall, so far as may be, apply accordingly. \n \n                                            \n1Inserted by the Finance Act, 2003. \n\n\f\nChapter V – Provisions Governing Persons ________________ \n \n168 \n \n \n(3)  \nWhere any tax payable under this section in respect of such business \nor profession cannot be recovered from the predecessor, it shall be recoverable \nfrom the successor, who shall be entitled to recover it from the predecessor.]\n\n\f\nChapter VI – Special Industries___________________________ \n \n169 \nCHAPTER VI \nSPECIAL INDUSTRIES \n \nPART I \nINSURANCE BUSINESS \n \n99. \nSpecial provisions relating to insurance business. — The profits and \ngains of any insurance business shall be computed in accordance with the rules in \nthe Fourth Schedule. \n \n1[   ] \n \n2[  ] \n \n3[99A. Special provisions relating to payment of tax through electricity \nconnections. (1) Notwithstanding anything contained in the Ordinance, a tax shall \n                                            \n1 Inserted by the National Assembly Secretariat’s O.M. No.F.22(2)/2016-Legis dated 29.01.2016.  \n2 Section 99A substituted by the Finance Act, 2022. The substituted section read as follows: \n“99A. Special provisions relating to traders.-(1) Subject to sub-section (3), tax payable on the profits \nand gains of a trader as defined in sub-section (4) who upto thirty first day of December, 2015 has not \nfiled a return for any of the preceding ten tax years shall be computed in accordance with the rules laid \ndown in Part I of the Ninth Schedule. \n(2)  \nSubject to sub-section (3), tax payable on the profits and gains of any trader as defined \nin sub-section (4), who-  \n(a)  \nis a filer; or \n(b) \nis NTN holder and a non-filer  but has filed return or returns in any of the last ten \npreceding tax years, shall be computed in accordance with the rules laid down in \nPart II of  the Ninth Schedule.  \n(3)  \nSub-sections (1) and (2) shall apply, if- \n(a)  \nthe return filed by the trader qualifies for acceptance in accordance with the rules \nlaid down in the Ninth Schedule; \n(b)   \nreturn relates to tax years 2015 to 2018; and  \n(c) \nincome from business consists of profits and  gains from trading activity only. \n(4) \nFor the purpose of this section and the Ninth Schedule, ‘trader’ means an individual or \nan association of persons (AOP) buying goods or merchandise and selling the same without further \nprocessing and providing, business-related after sales, services by doing repair jobs. \n Explanation 1.-  For the removal of doubt it is clarified that any person engaged in- \n(a) \nrendering of, or providing, services as defined in clause (ii) of sub-section (7) of section 153; or \n(b) \nbusiness of retailer falling under rule (5) of Chapter II of the Sales Tax Special Procedures Rules, \n2007, shall not be treated as a trader for the purposes of this section. \nExplanation 2.- It is also clarified that this section shall not apply to a person who is a Member of \nthe Senate of Pakistan, the National Assembly of Pakistan or a Provincial Assembly.”] \n3 Section 99A substituted and shall be deemed to have been so substituted from 1st day of July, 2022 \nby the Tax Laws (Amendment) Act, 2023 (XVI of 2023) dated 20.04.2023. Earlier this section was \nsubstituted through Tax Laws (Second Amendment) Ordinance, 2022 (VI of 2022) dated 22.08.2022. \nThe substituted section read as follows: \n“99A. Special provisions relating to payment of tax through electricity connections.– (1) \nNotwithstanding anything contained in the Ordinance, a tax shall be charged and collected from \nretailers other than Tier-I retailers as defined in Sales Tax Act, 1990 (VII of 1990) and specified service \n\n\f\nChapter VI – Special Industries ___________________________ \n \n170 \n \nbe charged and collected from retailers other than Tier-I retailers as defined in the \nSales Tax Act, 1990 (VII of 1990) and specified service providers on commercial \nelectricity connections at the rates specified in the income tax general order issued \nin terms of sub-section (2). \n \n(2) For the purposes of this section, the Federal Government or the Board \nwith the approval of the Minister in-charge pursuant to the approval of the \nEconomic Coordination Committee of the Cabinet may, issue an income tax \ngeneral order to — \n \n(a) provide the scope, time, payment, recovery, penalty, default \nsurcharge, adjustment or refund of tax payable under this section in \nsuch manner and with such conditions as may be specified; \n \n(b) provide the collection of tax on the amount of bill or on any basis of \nconsumption, in addition to or in lieu of advance tax collectible under \nsub-section (1) of section 235, at such rates or amounts, from such \ndate and with such conditions as may be specified; \n \n(c) \nprovide record keeping, filing of return, statement and assessment in \nsuch manner and with such conditions as may be specified; \n \n(d) provide mechanism of collection, deduction and payment of tax in \nrespect of any person; \n \n(e) include or exempt any person or classes of persons, any income or \nclasses of income from the application of this section, in such manner \nand with such conditions as may be specified; and \n \n(f) \nprovide that tax collected under this section shall in respect of such \npersons or classes of persons be adjustable, final or minimum, in \n                                            \nproviders on commercial electricity connections at the rates provided in clause (2A) of Division IV, Part \nIV of the First Schedule.  \n(2) \nA retailer who has paid sales tax under sub-section (9) of section 3 of Sales Tax Act, \n1990 (VII of 1990), shall not be required to pay tax under this section and the sales tax so paid shall \nconstitute discharge of tax liability under this section. \n(3) \nThe tax collected or paid under this section shall be final tax on the income of persons \ncovered under this section in respect of business being carried out from the premises where the \nelectricity connection is installed. \n(4) \nFor the purposes of this section, Board with the approval of the Minister in-charge may \nissue an income tax general order to- \n(a) \nprovide the scope, time, payment, recovery, penalty, default surcharge, adjustment or \nrefund of tax payable under this section in such manner and with such conditions as \nmay be specified. \n(b) \nprovide record keeping, filing of return, statement and assessment in such manner and \nwith such conditions as may be specified; \n(c) \nprovide mechanism of collection, deduction and payment of tax in respect of any person; \nor \n(d) \ninclude or exempt any person or classes of persons, any income or classes of income \nfrom the application of this section, in such manner and with such conditions as may be \nspecified.] \n  \n\n\f\nChapter VI – Special Industries ___________________________ \n \n171 \n \nrespect of any income to such extent and with such conditions as \nmay be specified. \n \n(3) The provisions of sub-section (1) of section 235 shall apply to the \npersons as specified therein unless specifically exempted under the income tax \ngeneral order issued under sub-section (2). \n \n(4) The provisions of section 100BA and rule 1 of the Tenth Schedule \nshall not apply to the tax collectible under this section unless specifically provided \nin respect of the person or class of persons mentioned in the income tax general \norder issued under sub-section (2).] \n \n1[99B. Special procedure for small traders and shopkeepers:-Notwithstanding \nanything contained in this Ordinance the 2[Board with the approval of the Minister-\nin-charge] may, by notification in the official Gazette, prescribe special procedure \nfor scope and payment of tax, filing of return and assessment in respect of such \nsmall traders and shopkeepers, in such cities or territories, as may be specified \ntherein.] \n \n3[99C. Special procedure for certain persons.- Notwithstanding anything \ncontained in this Ordinance, the 4[Board with the approval of the Minister-in-\ncharge] may, by notification in the official Gazette, prescribe special procedure for \nscope and payment of tax, record keeping, filing of return and assessment in \nrespect of small businesses, construction businesses, medical practitioners, \nhospitals, educational institutions and any other sector specified by 5[Board with \nthe approval of the Minister-in-charge], in such cities or territories, as may be \nspecified therein.] \n \n6[99D. Additional tax on certain income, profits and gains.– (1) \nNotwithstanding anything contained in this Ordinance or any other law for the time \nbeing in force, for any of the last three tax years preceding the tax year 2023 and \nonwards, in addition to any tax charged or chargeable, paid or payable under any \nof the provisions of this Ordinance, an additional tax shall be imposed on every \nperson being a company who has any income, profit or gains that have arisen due \nto any economic factor or factors that resulted in windfall income, profits or gains.  \n \n(2) \nThe Federal Government may, by notification in the official Gazette, –  \n \n(a) \nspecify sector or sectors, for which this section applies;  \n                                            \n1 New Section 99B inserted through Finance Supplementary (Second Amendment) Act, 2019. \n2 The words “Federal Government” substituted by the Finance Act, 2021. \n3 New section 99C inserted through Finance Act, 2019 \n \n4 The words “Federal Government” substituted by the Finance Act, 2021. \n5 The words “Federal Government” substituted by the Finance Act, 2021. \n6 New section 99D inserted by the Finance Act, 2023. \n \n\n\f\nChapter VI – Special Industries ___________________________ \n \n172 \n \n(b) \ndetermine windfall income, profits or gains and economic factor or \nfactors including but not limited to international price fluctuation having \nbearing on any commodity price in Pakistan or any sector of the \neconomy or difference in income, profit or gains on account of foreign \ncurrency fluctuation;  \n \n(c) \nprovide the rate not exceeding fifty percent of such income, profits or \ngains;  \n \n(d) \nprovide for the scope, time and payment of tax payable under this \nsection in such manner and with such conditions as may be specified \nin the notification; and  \n \n(e) \nexempt any person or classes of persons, any income or classes of \nincome from the application of this section, subject to any conditions \nas may be specified in the notification.  \n \n(3) \nThe Federal Government shall place before the National Assembly \nthe notification issued under this section within ninety days of the issuance of such \nnotification or by the 30th day of June of the financial year, whichever is earlier.] \n\n\f\nChapter VI – Special Industries ___________________________ \n \n173 \n \nPART II \n \nOIL, NATURAL GAS AND OTHER MINERAL DEPOSITS \n \n100. Special provisions relating to the production of oil and natural gas, and \nexploration and extraction of other mineral deposits.—(1) Subject to sub-\nsection (2), the profits and gains from — \n \n(a) \nthe exploration and production of petroleum including natural \ngas and from refineries set up at the Dhodak and Bobi fields; \n \n(b) \nthe pipeline operations of exploration and production \ncompanies; or \n \n(c) \nthe manufacture and sale of liquefied petroleum gas or \ncompressed natural gas, \n \nand the tax payable thereon shall be computed in accordance with the rules in Part \nI of the Fifth Schedule. \n \n \n(2) \nSub-section (1) shall not apply to the profits and gains attributable to \nthe production of petroleum including natural gas discovered before the 24th day \nof September, 19541[:] \n \n2[Provided that the for tax year 2017 and onward the provisions of this \nsub-section shall not apply on profit and gains derived from sui gas field.] \n \n         (3) \nThe profits and gains of any business which consists of, or includes, \nthe exploration and extraction of such mineral deposits of a wasting nature (not \nbeing petroleum or natural gas) as may be specified in this behalf by the 3[Board \nwith the approval of the Minister-in-charge] carried on by a person in Pakistan shall \nbe computed in accordance with the rules in Part II of the Fifth Schedule. \n \n \n4[100A. Special provisions relating to banking business.—(1) Subject to sub-\nsection (2), the income, profits and gains of any banking company as defined in \nclause (7) of section 2 and tax payable thereon shall be computed in accordance \nwith the rules in the Seventh Schedule. \n \n \n(2) \nSub-section (1) shall apply to the profits and gains of the banking \ncompanies relevant to tax year 2009 and onwards. \n                                            \n1Full stop substituted by the Finance Act 2017. \n2Inserted by the Finance Act, 2017. \n3 The words “Federal Government” substituted by the Finance Act, 2021. \n4Inserted by the Finance Act, 2007. \n\n\f\nChapter VI – Special Industries ___________________________ \n \n174 \n \n1[(3) Notwithstanding anything contained in sub-section (1), income,  profits  \nand  gains  and  tax  payable  thereon  shall  be computed subject to  the limitations \nand  provisions contained in Chapters VII and VIII.] \n \n2[100B. \nSpecial provision relating to capital gain tax.— (1) Capital gains on \ndisposal of listed securities and tax thereon 3[including super tax under section 4C  \n], subject to section 37A, shall be computed, determined, collected and deposited \nin accordance with the rules laid down in the Eighth Schedule. \n \n \n(2) \nThe provisions of sub–section (1) shall not apply to the following \npersons or class of persons, namely:- \n \n \n \n(a)  \na mutual fund; \n \n \n(b)  \nbanking company, a non-banking finance company and an  \ninsurance company subject to tax under the Fourth Schedule; \n \n \n \n(c)  \na modaraba;  \n \n4[(d)  a company, in respect of debt securities only; and] \n(e)  \nany other person or class of persons notified by the Board.] \n \n5[100BA. Special provisions relating to persons not appearing in active \ntaxpayers’ list.-(1) The collection or deduction of advance income tax, \ncomputation of income and tax payable thereon 6[in respect of a person not \nappearing on the active taxpayers’ list] 7[or persons appearing on the active \ntaxpayers’ list who have not filed return by the due date specified in section 118 \nor by the due date as extended under section 119 or 214A] shall be determined \nin accordance with the rules in the Tenth Schedule. \n \n \n \n(2) \nThe provisions of the Tenth Schedule shall have effect \nnotwithstanding anything to the contrary contained in this Ordinance.]  \n \n \n \n                                            \n1 Added by the Finance Act, 2018. \n2 Added by the Finance Act, 2012. \n3 Words inserted by the Finance Act, 2023.  \n4 Clause (d) substituted by new clause (d) by the Finance Act, 2014. The substituted clause read as  \nfollows: \n“(d) “a foreign institutional investor” being a person registered with NCCPL as a foreign \ninstitutional investor; and”  \n5 New section 100BA inserted through Finance Act, 2019.  \n6 Words inserted through Finance Act, 2020 dated 30th June, 2020.  \n7 Expression inserted by the Finance Act, 2024. \n\n\f\nChapter VI – Special Industries ___________________________ \n \n175 \n \n1[  ] \n \n2[100C. Tax credit for charitable organizations.— (1) The persons mentioned in \nsub-section (2) shall be allowed a tax credit equal to one hundred percent of tax \npayable under any of the provisions of this Ordinance including minimum and final \n                                            \n1 Inserted by the Finance Act, 2014. \n2 Section 100C substituted by the Finance Act, 2021. Earlier this substitution was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The substituted section read as follows: \n“100C. Tax credit for certain persons.- (1) 2[The income of]Non-profit organizations, trusts or welfare \ninstitutions, as mentioned in sub-section (2) shall be allowed a tax credit equal to one hundred per cent \nof the tax payable, including minimum tax and final taxes payable under any of the provisions of this \nOrdinance, subject to the following conditions, namely:- \n(a) \nreturn has been filed; \n(b) \ntax required to be deducted or collected has been deducted or collected and paid;2[ ] \n(c) \nwithholding tax statements for the immediately preceding tax year have been filed2[;] \n2[(d)  \nthe administrative and management expenditure does not exceed 15% of the total receipts: \n“Provided that clause (d) shall not apply to a non-profit organization, if— \n2[(i) \ncharitable and welfare activities of the non-profit organization have commenced for \nthe first time within last three years; and  \n(ii)] \ntotal receipts of the non-profit organization during the tax year are less than one \nhundred million Rupees” 2[;]  \n2[(e) \napproval of Commissioner has been obtained as per the requirement of clause (36) of \nsection 2: \n  \nProvided that this clause shall take effect from the first day of July, 2020; 2[  ] \n(f) \nnone of the assets of trusts or welfare institutions confers, or may confer, a private benefit \nto the donors or family, children or author of the trust or his descendents or the maker of \nthe institution or to any other person: \nProvided that where such private benefit is conferred, the amount of such benefit shall be \nadded to the income of the donor 2[; and] \n(g) \na statement of voluntary contributions and donations received in the immediately preceding \ntax year has been filed in the prescribed from and manner.] \n2[(1A) \nNotwithstanding anything contained in sub-section (1), surplus funds of non-profit \n2[organizations, trusts or welfare institutions] shall be taxed at a rate of ten percent. \n(1B)  \nFor the purpose of sub-section (1A), surplus funds mean funds or monies: \n(a) \nnot spent on charitable and welfare activities during the tax year; \n(b) \nreceived during the tax year as donations, voluntary contributions, subscriptions and \nother incomes; \n(c) \nwhich are more than twenty-five percent of the total receipts of the non-profit \norganization received during the tax year; and \n(d) \nare not part of restricted funds. \n \nExplanation.- For the purpose of this sub-section, “restricted funds” mean any \nfund received by the organization but could not be spent and treated as revenue during \nthe year due to any obligation placed by the donor.] \n(2) \nPersons 2[and incomes] eligible for tax credit under this section include- \n(a) \nany income of a trust or welfare institution or non-profit organization from donations, \nvoluntary contributions, subscriptions, house property, investments in the securities of \nthe Federal Government and so much of the income chargeable under the head \n\"income from business\" as is expended in Pakistan for the purposes of carrying out \nwelfare activities: \nProvided that in the case of income under the head \"income from business\", the \nexemption in respect of income under the said head shall not exceed an amount which \nbears to the income, under the said head, the same proportion as the said amount \nbears to the aggregate of the incomes from the aforesaid sources of income. \n \n\n\f\nChapter VI – Special Industries ___________________________ \n \n176 \n \ntaxes in respect of incomes mentioned in sub-section (3) subject to the conditions \nand limitations laid down in subsection (4). \n \n(2) The provisions of this section shall apply to the following persons, \nnamely:— \n \n(a)  persons specified in 1[  ] clause (66) of Part I of the Second Schedule to \nthis Ordinance; \n \n(b) a trust administered under a scheme approved by the Federal \nGovernment and established in Pakistan exclusively for the purposes of \n                                            \n(b) \na trust administered under a scheme approved by the Federal Government in this \nbehalf and established in Pakistan exclusively for the purposes of carrying out such \nactivities as are for the benefit and welfare of— \n \n(i) \nex-servicemen and serving personnel, including civilian employees of the \nArmed Forces, and their dependents; or \n(ii) \nex-employees and serving personnel of the Federal Government or a Provincial \nGovernment and their dependents, where the said trust is administered by a \ncommittee nominated by the Federal Government or, as the case may be, a \nProvincial Government; \n(c) \n2[  ]  \n(d) \nincome of a university or other educational institution being run by a non-profit \norganization existing solely for educational purposes and not for purposes of profit;  \n(e) \nany income which is derived from investments in securities of the Federal \nGovernment, profit on debt from scheduled banks 2[and microfinance banks], grant \nreceived from Federal Government or Provincial Government or District Governments, \nforeign grants and house property held under trust or other legal obligations wholly, \nor in part only, for religious or charitable purposes and is actually applied or finally set \napart for application thereto: \nProvided that nothing in this clause shall apply to so much of the income as is \nnot expended within Pakistan: \nProvided further that if any sum out of the amount so set apart is expended \noutside Pakistan, it shall be included in the total income of the tax year in which it is \nso expended or of the year in which it was set apart, whichever is the greater, and the \nprovisions of section 122 shall not apply to any assessment made or to be made in \npursuance of this proviso. \nExplanation.— Notwithstanding anything contained in the Mussalman Wakf \nValidating Act, 1913 (VI of 1913), or any other law for the time being in force or in the \ninstrument relating to the trust or the institution, if any amount is set apart, expended \nor disbursed for the maintenance and support wholly or partially of the family, children \nor descendants of the author of the trust or the donor or, the maker of the institution \nor for his own maintenance and support during his life time or payment to himself or \nhis family, children, relations or descendants or for the payment of his or their debts \nout of the income from house property dedicated, or if any expenditure is made other \nthan for charitable purposes, in each case such expenditure, provision, setting apart, \npayment or disbursement shall not be deemed, for the purposes of this clause, to be \nfor religious or charitable purposes; or \n(f) \nany income of a religious or charitable institution derived from voluntary contributions \napplicable solely to religious or charitable purposes of the institution: \nProvided that nothing contained in this clause shall apply to the income of a private \nreligious trust which does not ensure for the benefit of the public.”;] \n \n1 The expression “Table - II of” omitted by the Finance Act, 2025.  \n\n\f\nChapter VI – Special Industries ___________________________ \n \n177 \n \ncarrying out such activities as are for the welfare of ex-employees and \nserving personnel of the Federal Government or a Provincial \nGovernment or armed forces including civilian employees of armed \nforces and their dependents where the said trust is administered by a \ncommittee nominated by the Federal Government or a Provincial \nGovernment; \n \n(c)  a trust; \n \n(d) a welfare institution registered with Provincial or Islamabad Capital \nTerritory (ICT) social welfare department; \n \n(e)  a not for profit company registered with the Securities and Exchange \nCommission of Pakistan under section 42 of the Companies Act, 2017; \n \n(f)   a welfare society registered under the provincial or Islamabad Capital \nTerritory (ICT) laws related to registration of co-operative societies; \n \n(g)  a waqf registered under Mussalman Waqf Validating Act, 1913 (VI of \n1913) or any other law for the time being in force or in the instrument \nrelating to the trust or the institution; \n \n(h)  a university or education institutions being run by nonprofit organization \nexisting solely for educational purposes and not for the purposes of \nprofit; \n \n(i)  a religious or charitable institution for the benefit of public registered \nunder any law for the time being in force; and \n \n(j) international non-governmental organizations (INGOs) approved by the \nFederal Government. \n \n(3) The following income is eligible for tax credit, namely:— \n \n(a) income from donations, voluntary contributions and subscriptions; \n \n(b) income from house property; \n \n(c) income from investments in the securities of the Federal Government; \n \n(d) profit on debt from scheduled banks and microfinance banks; \n \n(e) grant received from Federal, Provincial, Local or foreign Government; \n \n\n\f\nChapter VI – Special Industries ___________________________ \n \n178 \n \n(f) so much of the income chargeable under the head “income from \nbusiness” as is expended in Pakistan for the purposes of carrying out \nwelfare activities: \n \nProvided that in the case of income under the head “income from \nbusiness”, only so much of such income shall be eligible for tax credit \nunder this section that bears the same proportion as the said amount of \nbusiness income bears to the aggregate of income from all sources; and \n \n(g) any income of the persons mentioned in clauses (a), (b) and (h) of sub- \nsection (2) of this section. \n \n(4) Eligibility for tax credit shall be subject to the following conditions, \nnamely:— \n \n(a) return has been filed; \n \n(b) tax required to be deducted or collected has been deducted or collected \nand paid; \n \n(c) withholding tax statements for the relevant tax year have been filed; \n \n(d) the administrative and management expenditure does not exceed 15% \nof the total receipts: \n \nProvided that clause (d) shall not apply to a nonprofit organization, if— \n \n(i) charitable and welfare activities of the non-profit organization have \ncommenced for the first time within last three years; or \n \n(ii) total receipts of the non-profit organization during the tax year are less \nthan one hundred million Rupees; \n \n(e) approval of Commissioner has been obtained as per requirement of \nclause (36) of section 2: \n \nProvided that the condition of approval in respect of persons \nmentioned in 1[  ] clause (66) of Part I of the Second Schedule to this \nOrdinance, shall take effect from the first day of July, 2[2023] and the \nrequirements of clause (36) of section 2, shall not be applicable for \nearlier years; \n \n                                            \n1 The expression “Table - II of” omitted by the Finance Act, 2025.  \n2 The figure 2022 substituted by the Finance Act, 2022. \n\n\f\nChapter VI – Special Industries ___________________________ \n \n179 \n \n(f)    none of the assets of trusts or welfare institutions confers, or may confer, \na private benefit to the donors or family, children or author of the trust or \nhis descendants or the maker of the institution or to any other person: \n \nProvided that where such private benefit is conferred, the amount \nof such benefit shall be added to the income of the donor; and \n \n(g) a statement of voluntary contributions and donations received in the \nimmediately preceding tax year has been filed in the prescribed form \nand manner. \n \n(5) Notwithstanding anything contained in sub-section (1), surplus funds of \norganizations to which this section applies shall be taxed at a rate of ten percent. \n \n(6) For the purpose of sub-section (5), surplus funds mean funds or \nmonies— \n \n(a)  not spent on charitable and welfare activities during the tax year; \n \n(b) received during the tax year as donations, voluntary contributions, \nsubscriptions and other incomes; \n \n(c)  which are more than twenty-five percent of the total receipts of the non-\nprofit organization received during the tax year; and \n \n(d)  are not part of restricted funds. \n \nExplanation.—For the purpose of this clause, “restricted funds” mean \nany fund received by the organization but could not be spent and treated \nas revenue during the year due to any obligation placed by the donor or \nfunds received in kind.] \n \n1[100D. Special provisions relating to builders and developers. – (1) For tax \nyear 2020 and onwards, the tax payable by a builder or a developer, as defined in \nsub-section (9), who opt to pay tax under this section shall be computed and paid \nin accordance with the rules in the Eleventh Schedule on a project by project basis \n                                            \n1 New section (100D) inserted through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nChapter VI – Special Industries ___________________________ \n \n180 \n \non the income, profits and gains derived from the sale of buildings or sale of plots, \nas the case may be, from – \n   \n(a) a new project to be completed by the 1[30th day of September, 2023]; or \n \n(b) an incomplete existing project to be completed by the 2[30th day of \nSeptember, 2023]: \n \n \nProvided that any income, profits and gains of a builder or developer \nof an incomplete existing project earned up to tax year 2019 3[or tax year \n2020, as the case may be] shall be subject to the provisions of this \nOrdinance as were in force prior to the commencement of the Tax Laws \n(Amendment) Ordinance, 2020 (Ordinance I of 2020): \n \n \n \nProvided further that any income of a builders or developer other than \nincome, profits and gains subject to this section shall be subject to tax as \nper the provisions of this Ordinance.  \n \n(2) \nWhere sub-section (1) applies,-  \n \n(a) the income shall not be chargeable to tax under any head of income in \ncomputing the taxable income of the person; \n \n(b) no deduction shall be allowed under this Ordinance for any expenditure \nincurred in deriving the income: \n \n(c) the amount of the income shall not be reduced by – \n \n(i) \nany deductible allowance under Part IX of Chapter III: or  \n \n(ii) \nthe set off of any loss;   \n \n(d) no tax credit shall be allowed against the tax payable under sub-section \n(1) except credit for tax under section 236A or 236K collected from the \nbuilder or developer after the commencement of the Tax Law \n(Amendment) Ordinance, 2020 (1 of 2020) on purchase of immoveable \nproperty utilized in a project; \n \n                                            \n1 The expression “30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n2 The expression “30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n3 This expression inserted by the Finance Act, 2021. Earlier this expression was made through Income \nTax (Amendment) Ordinance, 2021. \n\n\f\nChapter VI – Special Industries ___________________________ \n \n181 \n \n(e) there shall be no refund of any tax collected or deducted under this \nOrdinance; \n \n(f) if the tax payable has not been paid or short paid, the said amount of tax \nmay be recovered and all the provisions of this Ordinance shall apply \naccordingly; and  \n \n(g) section 113 and 113C shall not apply on the turnover, income, profits and \ngains of a builder or developer from a project. \n \n(3)  The provisions of section 111 shall not apply to capital investment made \nin a new project under clause (a) of sub-section (1) in the form of money or land, \nsubject to the following conditions, namely:- \n \n(a) if the investment is made by a builder or developer being an individual-  \n \n(i) in the form of money, such builder or developer shall open a new \nbank account and deposit such amount in it on or before the 1[30th \nday of June, 2021]; or \n \n(ii) in the form of land, such builder or developer shall have the \nownership title of the land at the time of commencement of the Tax \nLaws (Amendment) Ordinance, 2020 (I of 2020); \n \n(b) if the investment is made by a person in a project through a company \nor an association of persons,-  \n \n(i) such company or association of person shall be a single object \n(builder or developer) company or association of persons registered \nunder the Companies Act, 2017 (XIX of 2017), the Limited Liability \nPartnership Act, 2017 (XV of 2017) or the Partnership Act 1932 (IX \nof 1932), as the case may be, after the date of commencement of \nthe Tax Laws (Amendment) Ordinance, 2020 (I of 2020) and on or \nbefore the 2[30th day of June, 2021]; and \n    \n(ii) the person shall be a member or shareholder of such association of \npersons or company, as the case may be; \n \n \n \nand if the capital investment is made,- \n \n \n                                            \n1 The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n2 The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n\n\f\nChapter VI – Special Industries ___________________________ \n \n182 \n \n(i) \nin the form of money, such amount shall be invested through a \ncrossed banking instrument deposited in the bank account of \nsuch association of persons or company, as the case may be, \nno or before the 1[30th day of June, 2021]; or \n \n(ii) \nin the form of land, such land shall be transferred to such \nassociation of persons or company, as the case may be, on or \nbefore the 2[30th day of June, 2021]: \n \n \n \nProvided that the person shall have the ownership title of the \nland at the time of commencement of the Tax Laws \n(Amendment) Ordinance, 2020 (I of 2020) \n \n(c) a person making an investment under clause (a) or (b) shall submit a \nprescribed form on Iris web portal 3[by 30th day of June, 2021]; \n \n(d) the money or land invested under clause (a) or (b) shall be wholly utilized \nin a project; and  \n \n(e) completion of the project shall be certified in the following manner, \nnamely:- \n \n(i) \nin case of a builder, the map approving authority or NESPAK \nshall certify that grey structure as per the approved map has \nbeen completed by the builder on or before the 4[30th day of \nSeptember, 2023]; and \n \n(ii) \nin case of a develop,- \n \n \n(A) the map approving authority or NESPAK shall certify that \nlandscaping has been completed on or before the 5[30th day \nof September, 2023]; \n \n(B) a firm of chartered accountants having an ICAP QCR rating \nof ‘satisfactory’, notified by the Board for this purpose, shall \n                                            \n1 The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n2 The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n3 The expression inserted by the Finance Act, 2021. Earlier this insertion was made through Income \nTax (Amendment) Ordinance, 2021. \n4 The expression “30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n5 The expression “30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n\n\f\nChapter VI – Special Industries ___________________________ \n \n183 \n \ncertify that at least 50% of the plots have been booked for \nsale and at least 40% of the sale proceeds have been \nreceived by the 1[30th day of September, 2023]; and \n \n(C) at least 50% of the roads have been laid up to sub-grade \nlevel as certified by the approving authority of NESPAK. \n \n(4) \nThe provisions of section 111 shall also not apply to.- \n \n(a) the first purchaser of a building or a unit of the building purchased from \nthe builder in respect of purchase price of the building or unit of the \nbuilding subject to the following conditions, namely:- \n \n(i) \nfull payment is made through a crossed banking instrument to \nthe builder during a period starting from the date of registration \nof the project with the Board under this section and ending on \nthe 2[31st day of March, 2023], in case the purchase is from a \nnew project; and \n \n(ii) \nfull or balance amount of payment is made through a crossed \nbanking instrument to the builder during a period starting from \nthe date of registration of the project with the Board under this \nsection and ending on the 3[31st day of March, 2023], in case \nthe purchase is from an existing incomplete project; and \n \n(b) the purchaser of a plot who intends to construct a building thereon, if-  \n \n(i) \nthe purchase is made on a before the 4[30th day of June, 2021]; \n(ii) \nthe full payment is made on or before the 5[30th day of June, \n2021] through a crossed banking instrument; \n(iii) construction on such plot is commenced on or before the 6[31st \nday of December, 2021]; \n                                            \n1 The expression “30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n2 The expression “30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n3 The expression “30th day of September, 2022” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n4 The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021.. \n5 The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n6 The expression “31st day of December, 2020” ” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n\n\f\nChapter VI – Special Industries ___________________________ \n \n184 \n \n(iv) such construction is completed on or before the 1[30th day of \nSeptember, 2023]; and \n \n(v) \nthe person registers himself with the Board on the online Iris \nwerb portal. \n \n(5) \nWhere sub-section (3) or (4) apply, the value or price of land or \nbuilding, as the case may be, shall be the higher of clause (a) or (b) below:- \n \n(a) 130% of the fair market value as determined by the Board under sub-\nsection (4) of section 68; or \n \n(b) at the option of the person making investment, the lower of the values \nas determined by at least two independent valuers from the list of \nvaluers approved by the State Bank of Pakistan. \n \n(6) \nSub-sections (3) and (4) shall not apply to -  \n \n(a) holder of any public office as defined in the Voluntary Declaration of \nDomestic Assets Act, 2018 or his benamidar as defined in the Benami \nTransactions (Prohibition) Act, 2017 (V of 2017) or his spouse or \ndependents; \n \n(b) a public listed company, a real estate investment trust or a company \nwhose income is exempt under any provision of this Ordinance; or \n \n(c) any proceeds derived from the commission of a criminal offence \nincluding the crimes of money laundering extortion or terror financing \nbut excluding the offences under this Ordinance. \n \n(7) \nDivided income paid to a person by a builder or developer being a \ncompany out of the profits and gains derived from a project shall be exempt from \ntax. \n \n(8) \nNotwithstanding anything contained in this section or the Eleventh \nSchedule, where a return or declaration has been made through misrepresentation \nor suppression of facts, such return or declaration shall be void and all the \nprovisions of this Ordinance shall apply: \n \n \n \n \nProvided that no action under this sub-section shall be taken if such \nmisrepresentation has been made on account of a bona fide mistake: \n \n \n                                            \n1 The expression “30th day of September, 2022” ” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n\n\f\nChapter VI – Special Industries ___________________________ \n \n185 \n \n \n \nProvided further that no action under this sub-section shall be taken \nwithout providing an opportunity of being heard and without prior approval of \nthe Board. \n \n(9) \nIn this section.- \n \n(a) “builder” means a person who is registered as a builder with the Board \nand is engaged in the construction and disposal of residential or \ncommercial buildings; \n \n(b) “capital investment” means investment as equity resources and does not \ninclude borrowed funds; \n \n(c) “developer” means a person who is registered as a developer with the \nBoard and is engaged in the development of land in the form of plots of \nany kind either for itself or otherwise; \n \n(d) “existing project” means a construction or development project, which- \n \n(i) has commenced before the date of commencement of the Tax Laws \n(Amendment) Ordinance, 2020; \n \n(ii) is incomplete; \n \n(iii) is completed on or before the 1[30th day of September, 2023];and \n \n(iv) a declaration is provided in the registration from under Eleventh \nSchedule to the effect of percentage of the project completed up to \nthe last day of  the accounting period pertaining to tax year 2019 2[or \ntax year 2020 at the option of the taxpayer]; \n  \n(e) “first purchaser” means a person who purchases a building or a unit, as \nthe case may be, directly from the builder and does not include a \nsubsequent or a substituted purchaser; \n \n(f) “new project” means a construction or development project, which- \n \n(i) \n is commenced during the period starting from the date of \ncommencement of the Tax Laws (Amendment) Ordinance, \n2020 and ending on the 3[31st day of December, 2021]; and  \n                                            \n1 The expression “30th day of September, 2022” ” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n2 This expression inserted ” by the Finance Act, 2021. Earlier this insertion was made through Income \nTax (Amendment) Ordinance, 2021. \n3 The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n\n\f\nChapter VI – Special Industries ___________________________ \n \n186 \n \n(ii) \nis competed on or before the 1[30th day of September, 2023]; \n \n(g) “project” means a project for construction of a building with the object of \ndisposal, or a project for development of land into plots with the object \nof disposal or otherwise; \n \n(h) “registered with the Board” means registered after submission of form \non project-by-project basis on the online Iris web portal; \n \n(10) \nThe provisions of the Ordinance not specifically dealt with in this \nsection or the rules made thereunder shall apply mutatis mutandis to builders and \ndevelopers in so far as they are not inconsistent with this section or the rules made \nthereunder.]  \n \n2[100E. Special provisions relating to small and medium enterprises.— (1) \nFor tax year 2021 and onwards, the tax payable by a small and medium enterprise \nas defined in clause (59A) of section 2 shall be computed and paid in accordance \nwith rules made under the Fourteenth Schedule.  \n \n(2) The Board may prescribe a simplified return for a small and medium \nenterprise.]  \n \n \n3[   ] \n                                            \n1 The expression “30th day of September, 2022” ” substituted by the Finance Act, 2021. Earlier the \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n2 Section 100E inserted by the Finance Act, 2021. \n3 Section 100F shall be omitted and shall be deemed to have been omitted with effect from 02nd March, \n2022 by the Finance Act, 2022. The omitted section read as follows: \n\"100F. Special provisions relating to investment for industrial promotion. — (1) Any eligible \nperson may file a statement by the 30th September, 2022, declaring therein the amount of funds \n(which have not been declared in any of the returns of income upto tax year 2021 filed by the 31st \nDecember, 2021) for investment in a new company formed for establishing and operating an \nindustrial undertaking in accordance with this section:  \nProvided that the funds referred to in sub-section (I) shall be deposited in rupees in a \ndedicated bank account in Pakistan as equity of the newly formed company, incorporated under the \nCompanies Act, 2017 (XIX of 2017), before the filing of the statement and such funds shall only be \nused for purchase or import of plant and machinery through letter of credit or for construction of \nbuilding and structure for the industrial undertaking:  \nProvided further that the minimum amount which would qualify for the purposes of this \nsection shall be fifty million rupees.  \n(2) The provisions of section 111 shall not apply to the funds declared under sub-section (I) \nsubject to fulfilment of conditions as laid down in this section and payment of an amount equal to five \npercent thereof along with the statement filed under sub-section (1).  \n(3) The new industrial undertaking in which such investment is made shall commence \ncommercial production by the 30th June, 2024 and a certificate to that effect, duly issued by \nEngineering Development Board, is submitted to the Commissioner along with the return filed for tax \nyear 2024.  \n(4) Any amount of tax paid under this section shall not be refundable or adjustable against \nany other tax liability of the declarant.  \n\n\f\nChapter VI – Special Industries ___________________________ \n \n187 \n \n                                            \n(5) Where a declarant has paid tax under this section in respect of funds declared under sub-\nsection (I), the declarant shall be entitled to incorporate the same in his wealth statement, financial \nstatements or books of accounts, as the case may be.  \n(6) For the purposes of this section, eligible person means all persons, except–  \n(a) holders of' public office, their spouses and dependent children;  \n(b) \na public company as defined in clause (47) of section 2 of this Ordinance;  \n(c)  \na person who has filed a declaration under the Voluntary Declaration of   Domestic \nAssets Act, 2018, the Foreign Assets (Declaration and Repatriation) Act, 2018, or the Assets \nDeclaration Act, 2019;  \n(d) a person that has been declared a bank loan defaulter by a bank or a financial institution \nwithin the last three years; or  \n(e) a director of a company who has been declared a bank loan defaulter by a bank or a financial \ninstitution within the last three years.  \n(7) The provisions of this section shall not apply to —  \n(a) any proceeds of crime, corruption, money laundering and terror financing;  \n(b)  any amount which is subject of any departmental or court proceedings; \n(c)  the investments made in following sectors, namely:—  \n(i)   arms and ammunitions; \n(ii)  explosives; \n(i) \nsugar;  \n(ii) \ncigarettes;  \n(iii) \naerated beverages;  \n(iv) \nflour mills;  \n(v) \nvegetable ghee; and \n(vi) \ncooking oil manufacturing excluding extraction units.  \n(8) Notwithstanding the provisions of any other law for the time being in force including sub-\nsection (3) of section 216 of this Ordinance excluding clauses (a) and (g) of sub-section (3) thereof, \nthe National Accountability Ordinance, 1999 (XVIII of 1999), the Federal Investigation Agency Act, \n1974 (VIII of 1975) and the Right of Access to Information Act, 2017 (XXXI V of 2017), particulars of \nany person making a statement under this section or any information received in any statement made \nunder this section shall be confidential.  \n(9) The statement filed under sub-section (1) shall not be valid, if—  \n(a) the newly formed industrial undertaking company fails to prove commercial production in \nterms of sub-section (3);  \n(b) there is change in ownership of industrial undertaking company prior to the 30th June, 2026; \nor \n(c) the newly formed industrial undertaking company disposes of any of its assets prior to the \n30th June, 2026.  \n(10) Notwithstanding anything contained in this section, where the provisions of sub-section (7) \nor (9) apply, or where the statement under sub-section (I) has been made by misrepresentation or \nsuppression of facts, such statement shall be void as if it had never been made and all the provisions \nof this Ordinance shall apply accordingly:  \nProvided that the Commissioner shall not take any action under this section without providing \nthe declarant an opportunity of being heard.  \n(11) The statement filed under this section shall be made in the form and manner as specified \nby the Board through a notification in the official Gazette.  \n(12) The provisions of this section shall apply, mutatis mutandis, to an existing company being \nan industrial undertaking, for investment in expansion and modernization from amount of funds \n(which have not been declared in any of the returns of income upto tax year 2021 filed by the 31st \nDecember, 2021):  \nProvided that such company opens a dedicated bank account to deposit the said funds before \nthe filing of the statement and such funds shall only be used for expansion and modernization by \nway of purchase or import of plant and machinery including IT hardware through letter of credit, \nor software and IT services or for construction of building and structure for the manufacturing \npremises of the existing industrial undertaking:  \n\n\f\nChapter VI – Special Industries ___________________________ \n \n188 \n \n \n                                            \nProvided further that the expansion and modernization shall be completed by the 30th June, \n2024, and a certificate to that effect, duly issued by the Engineering Development Board, is \nsubmitted to the Commissioner along with the return filed for tax year 2024.  \n(13) In this section, unless there is anything repugnant in the subject or context,—  \n(a) \"declarant\" means a person filing a statement under sub-section (1);  \n(b)  \"holder of public office\" means a person as defined in the Voluntary Declaration of Domestic \nAssets Act, 2018;  \n(c)   \"industrial undertaking\" means a company being a new industrial undertaking setup for the \npurpose of this section and is not established by the splitting up or reconstruction or reconstitution \nof an undertaking already in existence or by transfer of machinery or plant from an existing \nindustrial undertaking established in Pakistan;  \n(d) \"investment\" means investment in equity and does not include borrowed funds and \ninvestment in land; and  \n(e) \"modernization\" includes acquisition or upgradation of IT hardware, software and IT \nservices.\";  \n \n\n\f\nChapter VII – International_______________________________ \n \n189 \nCHAPTER VII \nINTERNATIONAL \n \nPART I \nGEOGRAPHICAL SOURCE OF INCOME \n \n101. Geographical source of income. — (1) Salary shall be Pakistan-source \nincome to the extent to which the salary — \n \n(a) \nis received from any employment exercised in Pakistan, \nwherever paid; or \n \n(b) \nis paid by, or on behalf of, the Federal Government, a Provincial \nGovernment, or a 1[Local Government] in Pakistan, wherever \nthe employment is exercised. \n \n(2) \nBusiness income of a resident person shall be Pakistan-source \nincome to the extent to which the income is derived from any business carried on \nin Pakistan.  \n \n(3) \nBusiness income of a non-resident person shall be Pakistan-source \nincome to the extent to which it is directly or indirectly attributable to – \n \n(a) \na permanent establishment of the non-resident person in \nPakistan;  \n \n(b) \nsales in Pakistan of goods  merchandise of the same or similar \nkind as those sold by the person through a permanent \nestablishment in Pakistan; 2[  ] \n \n(c) \nother business activities carried on in Pakistan of the same or \nsimilar kind as those effected by the non-resident through a \npermanent establishment in Pakistan 3[; or] \n \n4[(d)  \nany business connection in Pakistan 5[; or] \n                                            \n1The words “local authority” substituted by the Finance Act, 2008. \n2 The word “or” omitted by the Finance Act, 2003. \n3 Full stop substituted by the Finance Act, 2003. \n4 Inserted by the Finance Act, 2003. \n5Full stop substituted by the Finance Act, 2018. \n \n\n\f\nChapter VII – International_______________________________ \n \n190 \n \n1[(e) import of goods, whether or not the title to the goods passes outside \n Pakistan, if the import is part of an overall arrangement for the supply of \ngoods, installation, construction, assembly, commission, guarantees\n or supervisory   activities   and   all   or   principal   activities are undertaken  \nor  performed  either  by  the  associates  of  the person supplying the goods \nor its permanent establishment, whether  or  not  the  goods  are  imported  \nin  the  name  of  the person, associate of the person or any other person. \n \nExplanation.—For  the  removal  of  doubt,  it  is  clarified  that where the \nincome is subject to taxation under sections 5A, 5AA, 6, 7 and 7A, the income \nshall not be chargeable to tax under the head income from business.”]  \n \n2[(3A) For the purposes of clause (d) of sub-section (3), business connection in \nPakistan shall include “significant economic presence in Pakistan” of a non-\nresident.  \n \n(3B) significant economic presence in Pakistan shall mean –  \n \n(a) \ntransaction in respect of any goods, services or property carried out \nby a non-resident with any person in Pakistan including provision of \ndownload of data or software in Pakistan, if the aggregate of payments \narising from such transaction or transactions during the tax year \nexceeds such amount as may be prescribed; and  \n \n(b) \nsystematic and continuous soliciting of business activities or engaging \nin interaction through digital means with such number of users in \nPakistan as may be prescribed, irrespective of whether or not —  \n \n(i) \nthe agreement for such transactions or activities is signed in \nPakistan;  \n(ii) \nthe non-resident has a residence or place of business in \nPakistan; or  \n(iii) \nthe non-resident renders services in Pakistan:  \n \nProvided that only so much of income as is attributable to the \ntransactions or activities referred to in clause (a) or clause (b) shall be \ndeemed to accrue or arise from a business connection in Pakistan.] \n \n                                            \n1Added by the Finance Act, 2018. \n2 Sub-sections (3A) and (3B) added by the Finance Act, 2024. \n\n\f\nChapter VII – International_______________________________ \n \n191 \n \n1[(4) Where the business of a non-resident person comprises the rendering of \nindependent services (including professional services and the services of \nentertainers and sports persons), the Pakistan-source business income of the \nperson shall include [in addition to any amounts treated as Pakistan-source income \nunder sub-section (3)] any remuneration derived by the person where the \nremuneration is paid by a resident person or borne by a permanent establishment \nin Pakistan of a non-resident person.] \n \n \n(5) \nAny gain from the disposal of any asset or property used in deriving \nany business income referred to in sub-section (2), (3) or (4) shall be Pakistan-\nsource income. \n \n \n(6) \nA dividend shall be Pakistan-source income if it is 2[—] \n \n \n \n3[( a)  paid by a resident company; or] \n \n4[(b)  dividend as per provisions of sub-clause (f) of clause (19) of \nsection 2.] \n \n(7) \nProfit on debt shall be Pakistan-source income if it is — \n \n(a) \npaid by a resident person, except where the profit is payable in \nrespect of any debt used for the purposes of a business carried \non by the resident outside Pakistan through a permanent \nestablishment; or \n \n(b) \nborne by a permanent establishment in Pakistan of a non-\nresident person. \n \n \n(8) \nA royalty shall be Pakistan-source income if it is — \n \n(a) \npaid by a resident person, except where the royalty is payable \nin respect of any right, property, or information used, or services \nutilised for the purposes of a business carried on by the resident \noutside Pakistan through a permanent establishment; or \n \n                                            \n1 Sub-section (4) substituted by the Finance Act, 2003. The substituted sub-section (4) read as \nfollows: - \n“(4) \nWhere the business of a non-resident person comprises the rendering of independent \nservices (including professional services and the services of entertainers and sports-persons), the \nPakistan-source business income of the person shall include (in addition to any amounts treated as \nPakistan-source income under sub-section (3)) any remuneration derived by the person where – \n(a) \nthe remuneration is paid by a resident person or borne by a permanent \nestablishment in Pakistan of a non-resident; person; and \n(b) \nthe aggregate gross amount (before deduction of expenses) of the \nremuneration is sixty thousand rupees or more.” \n2 The words and full stop “paid by a resident company.” substituted by the Finance Act, 2012. \n3Added by the Finance Act, 2012. \n4Added by the Finance Act, 2012. \n \n\n\f\nChapter VII – International_______________________________ \n \n192 \n \n(b) \nborne by a permanent establishment in Pakistan of a non-\nresident person. \n \n \n(9) \nRental income shall be Pakistan-source income if it is derived from \nthe lease of immovable property in Pakistan whether improved or not, or from any \nother interest in or over immovable property, including a right to explore for, or \nexploit, natural resources in Pakistan.  \n \n \n(10)  Any gain from the alienation of any property or right referred to in sub-\nsection (9) or from the alienation of any share in a company the assets of which \nconsist wholly or principally, directly or indirectly, of property or rights referred to in \nsub-section (9) shall be Pakistan-source income. \n \n \n(11)  A pension or annuity shall be Pakistan-source income if it is paid by \na resident or borne by a permanent establishment in Pakistan of a non-resident \nperson. \n \n \n(12)  A technical fee shall be Pakistan-source income if it is – \n \n(a) \npaid by a resident person, except where the fee is payable in \nrespect of services utilised in a business carried on by the resident \noutside Pakistan through a permanent establishment; or \n \n(b) \nborne by a permanent establishment in Pakistan of a non-\nresident person. \n \n1[(12A)    A fee for offshore digital services shall be Pakistan- source income, if \nit is – \n \n(a) paid by a resident person, except where the fee is payable in respect  \nof  services  utilised  in  a  business  carried  on  by the resident\n outside Pakistan through a permanent establishment; or \n \n(b) borne  by  a  permanent  establishment  in  Pakistan  of  a   non-\nresident person.] \n \n \n(13)  Any gain arising on the disposal of shares in a resident company shall \nbe Pakistan-source income. \n \n2[(13A).Any amount paid on account of insurance or re-insurance premium \nby an insurance company to an overseas insurance or re-insurance company shall \nbe deemed to be Pakistan source income.] \n \n \n(14)  Any amount not mentioned in the preceding sub-sections shall be \nPakistan-source income if it is paid by a resident person or borne by a permanent \nestablishment in Pakistan of a non-resident person.  \n \n                                            \n1Inserted  by the Finance Act, 2018. \n2Inserted by the Finance Act, 2008. \n\n\f\nChapter VII – International_______________________________ \n \n193 \n \n \n(15)  Where an amount may be dealt with under sub-section (3) and under \nanother sub-section (other than sub-section (14)), this section shall apply— \n \n(a) \nby first determining whether the amount is Pakistan-source \nincome under that other sub-section; and \n \n(b) \nif the amount is not Pakistan-source income under that sub-\nsection, then determining whether it is Pakistan-source income \nunder sub-section (3).  \n \n \n(16) An amount shall be foreign-source income to the extent to which it is \nnot Pakistan-source income. \n \n \n \n\n\f\nChapter VII – International_______________________________ \n \n194 \n \n1[101A. Gain on disposal of assets outside Pakistan.— (1) Any gain from the \ndisposal or alienation outside Pakistan of an asset located in Pakistan of a non-\nresident company shall be Pakistan-source. \n(2) \nThe gain under sub-section (1) shall be chargeable to tax at the rate \nand in the manner as specified in sub-section (10). \n(3) \nWhere  the  asset  is  any  share  or  interest  in  a  non-resident \ncompany, the asset shall be treated to be located in Pakistan, if ─ \n \n(a) the  share  or  interest derives,  directly or  indirectly,  its  value \nwholly or principally from the assets located in Pakistan; and \n \n(b) shares or  interest  representing ten per  cent or  more of  the \nshare  capital  of  the  non-resident  company  are  disposed  or \nalienated. \n(4) \nThe share or interest, as mentioned in sub-section (3), shall be  \ntreated  to  derive  its  value  principally  from  the  assets  located  in Pakistan, if \non the last day of the tax year preceding the date of transfer ofa  share  or  an  \ninterest,  the  value  of  such  assets  exceeds  one  hundred million Rupees and \nrepresents at least fifty per cent of the value of all the assets owned by the     non-\nresident company. \n \n(5) \nNotwithstanding  the  provisions  of  section  68,  the  value  as \nmentioned  in  sub-section  (4)  shall  be  the  fair  market  value,  as  may  be \nprescribed, for the purpose of this section without reduction of liabilities. \n \n(6) \nWhere  the  entire  assets  by  the  non-resident  company  are not  \nlocated  in  Pakistan,  the  income  of  the  non-resident  company,  from disposal \nor alienation outside Pakistan of a share of, or interest in, such non-resident  \ncompany  shall  be  treated  to  be  located  in  Pakistan,  to  the extent  it  is  \nreasonably  attributable  to  assets  located  in  Pakistan  and determined as may \nbe prescribed. \n \n(7) \nWhere the asset of a non-resident company derives, directly or  \nindirectly,  its  value  wholly  or  principally  from  the  assets  located  in Pakistan \nand the non-resident company holds, directly or indirectly, such assets through a \nresident company, such resident company shall, for the purposes of determination \n                                            \n1Inserted by the finance Act 2018. \n\n\f\nChapter VII – International_______________________________ \n \n195 \n \nof gain and tax thereon under sub-section (8)or, as the case may be, sub-section \n(9), shall furnish to the Commissioner within sixty days of the transaction of \n disposal or alienation of the asset by the non-resident company, the \nprescribed information or documents, in a statement as may be prescribed: \n \nProvided that the Commissioner may, by notice in writing, require the  \nresident  company,  to  furnish  information,  documents  and  statement \nwithin a period of less than sixty days as specified in the notice. \n \n(8) \nThe person acquiring the asset from the non-resident person shall \ndeduct tax from the gross amount paid as consideration for the asset at the rate of \nten percent of the fair market value of the asset and shall be paid to the \nCommissioner by way of credit to the Federal Government through remittance to \nthe Government Treasury or deposit in an authorized branch of the State Bank of \nPakistan or the National Bank of Pakistan, within fifteen days of the payment to the \nnon-resident. \n \n(9) \nThe resident company as referred to in sub-section (7) shall collect \nadvance tax as computed in sub-section (10) from the non-resident company \nwithin thirty days of the transaction of disposal or alienation of the asset by such \nnon-resident company: \n \nProvided  that  where  the  tax  has  been  deducted  and  paid  by  the \nperson  acquiring  the  asset  from  the  non-resident  person  under  sub- \nsection (8), the said tax shall be treated as tax collected and paid under this \n\n\f\nChapter VII – International_______________________________ \n \n196 \n \nsub-section and shall be allowed a tax credit for that tax in computing the \ntax under sub-section (10). \n \n(10) The tax to be collected under sub-section (9) shall be the higher of ─ \n \n(a) \n20% of A, where A – fair market value less cost of acquisition of the \nasset; or \n \n(b) \n10% of the fair market value of the asset. \n \n(11) Where tax has been paid under sub-section (8) or (9), no tax shall be \npayable by the non-resident company in respect of gain under sub-section (8) of \nsection 22 or capital gains under section 37 or 37A. \n(12) Where any gain is taxable under this section and also under any other \nprovision of this Ordinance, the said gain shall be taxable under other provision of \nthe Ordinance.] \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n\n\f\nChapter VII – International_______________________________ \n \n197 \n \nPART II \nTAXATION OF FOREIGN-SOURCE INCOME OF RESIDENTS  \n \n102.  Foreign source salary of resident individuals.— (1)  Any foreign-source \nsalary received by a resident individual shall be exempt from tax if the individual \nhas paid foreign income tax in respect of the salary. \n \n \n(2) \nA resident individual shall be treated as having paid foreign income \ntax in respect of foreign-source salary if tax has been withheld from the salary by \nthe individual’s employer and paid to the revenue authority of the foreign country \nin which the employment was exercised. \n \n103.  Foreign tax credit.— (1)  Where a resident taxpayer derives foreign source \nincome chargeable to tax under this Ordinance in respect of which the taxpayer \nhas paid foreign income tax, the taxpayer shall be allowed a tax credit of an amount \nequal to the lesser of – \n \n(a) \nthe foreign income tax paid; or \n \n(b) \nthe Pakistan tax payable in respect of the income.  \n \n \n(2) \nFor the purposes of clause (b) of sub-section (1), the Pakistan tax \npayable in respect of foreign source income derived by a taxpayer in a tax year \nshall be computed by applying the average rate of Pakistan income tax applicable \nto the taxpayer for the year against the taxpayer’s net foreign-source income for \nthe year. \n \n \n(3) \nWhere, in a tax year, a taxpayer has foreign income under more than \none head of income, this section shall apply separately to each head of income.  \n \n \n(4) \nFor the purposes of sub-section (3), income derived by a taxpayer \nfrom carrying on a speculation business shall be treated as a separate head of \nincome. \n \n \n(5) \nThe tax credit allowed under this section shall be applied in \naccordance with sub-section (3) of section 4. \n \n \n(6) \nAny tax credit or part of a tax credit allowed under this section for a \ntax year that is not credited under sub-section (3) of section 4 shall not be refunded, \ncarried back to the preceding tax year, or carried forward to the following tax year. \n \n \n(7) \nA credit shall be allowed under this section only if the foreign income \ntax is paid within two years after the end of the tax year in which the foreign income \nto which the tax relates was derived by the resident taxpayer. \n \n\n\f\nChapter VII – International_______________________________ \n \n198 \n \n \n(8) \nIn this section,— \n“average rate of Pakistan income tax” in relation to a taxpayer for a \ntax year, means the percentage that the Pakistani income tax (before \nallowance of the tax credit under this section) is of the taxable income \nof the taxpayer for the year; \n \n“foreign income tax” includes a foreign withholding tax; and   \n \n“net foreign-source income” in relation to a taxpayer for a tax year, \nmeans the total foreign-source income of the taxpayer charged to tax \nin the year, as reduced by any deductions allowed to the taxpayer \nunder this Ordinance for the year that – \n \n(a) \nrelate exclusively to the derivation of the foreign-source income; \nand  \n \n(b) \nare reasonably related to the derivation of foreign-source \nincome in accordance with sub-section (1) of section 67 and any \nrules made for the purposes of that section. \n \n104.  Foreign losses.— (1)  Deductible expenditures incurred by a person in \nderiving foreign-source income chargeable to tax under a head of income shall be \ndeductible only against that income.  \n \n \n(2) \nIf the total deductible expenditures referred to in sub-section (1) \nexceed the total foreign source income for a tax year chargeable to tax under a \nhead of income (hereinafter referred to as a “foreign loss”), the foreign loss shall \nbe carried forward to the following tax year and set off against the foreign source \nincome chargeable to tax under that head in that year, and so on, but no foreign \nloss shall be carried forward to more than six tax years immediately succeeding \nthe tax year for which the loss was computed.  \n \n \n(3) \nWhere a taxpayer has a foreign loss carried forward for more than one \ntax year, the loss for the earliest year shall be set off first. \n \n \n(4) \nSection 67 shall apply for the purposes of this section on the basis \nthat — \n \n(a) \nincome from carrying on a speculation business is a separate \nhead of income; and \n \n(b) \nforeign source income chargeable under a head of income \n(including the head specified in clause (a)) shall be a separate \nhead of income. \n \n\n\f\nChapter VII – International_______________________________ \n \n199 \n \nPART III \nTAXATION OF NON-RESIDENTS \n \n105.  Taxation of a permanent establishment in Pakistan of a non-resident \nperson.— (1)  The following principles shall apply in determining the income of a \npermanent establishment in Pakistan of a non-resident person chargeable to tax \nunder the head “Income from Business”, namely: — \n \n(a) \nThe profit of the permanent establishment shall be computed on the \nbasis that it is a distinct and separate person engaged in the same or \nsimilar activities under the same or similar conditions and dealing \nwholly independently with the non-resident person of which it is a \npermanent establishment; \n \n(b) \nsubject to this Ordinance, there shall be allowed as deductions any \nexpenses incurred for the purposes of the business activities of the \npermanent establishment including executive and administrative \nexpenses so incurred, whether in Pakistan or elsewhere; \n \n(c) \nno deduction shall be allowed for amounts paid or payable by the \npermanent establishment to its head office or to another permanent \nestablishment of the non-resident person (other than towards \nreimbursement of actual expenses incurred by the non-resident person \nto third parties) by way of: \n \n  (i) \nroyalties, fees or other similar payments for the use of any tangible \nor intangible asset by the permanent establishment; \n \n (ii) \ncompensation for any services including management services \nperformed for the permanent establishment; or \n \n(iii) \nprofit on debt on moneys lent to the permanent establishment, \nexcept in connection with a banking business; and \n \n(d) \nno account shall be taken in the determination of the income of a \npermanent establishment of amounts charged by the permanent \nestablishment to the head office or to another permanent establishment \nof the non-resident person (other than towards reimbursement of actual \nexpenses incurred by the permanent establishment to third parties) by \nway of: \n \n  (i) \nroyalties, fees or other similar payments for the use of any tangible \nor intangible asset; \n \n \n \n\n\f\nChapter VII – International_______________________________ \n \n200 \n \n (ii) \ncompensation for any services including management services \nperformed by the permanent establishment; or \n \n(iii) \nprofit on debt on moneys lent by the permanent establishment, \nexcept in connection with a banking business. \n \n \n(2) \nNo deduction shall be allowed in computing the income of a \npermanent establishment in Pakistan of a non-resident person chargeable to tax \nunder the head “Income from Business” for a tax year for head office expenditure \nin excess of the amount as bears to the turnover of the permanent establishment \nin Pakistan the same proportion as the non-resident’s total head office expenditure \nbears to its worldwide turnover. \n \n \n(3) \nIn this section, “head office expenditure” means any executive or \ngeneral administration expenditure incurred by the non-resident person outside \nPakistan for the purposes of the business of the Pakistan permanent establishment \nof the person, including — \n \n(a) \nany rent, local rates and taxes excluding any foreign income tax, \ncurrent repairs, or insurance against risks of damage or \ndestruction outside Pakistan; \n \n(b) \nany salary paid to an employee employed by the head office \noutside Pakistan; \n \n(c) \nany travelling expenditures of such employee; and \n \n(d) \nany other expenditures which may be prescribed. \n \n \n(4) \nNo deduction shall be allowed in computing the income of a \npermanent establishment in Pakistan of a non-resident person chargeable under \nthe head “Income from Business” for — \n \n(a) \nany profit paid or payable by the non-resident person on debt to \nfinance the operations of the permanent establishment; or \n \n(b) \nany insurance premium paid or payable by the non-resident \nperson in respect of such debt. \n \n106.  Thin capitalisation. — (1) Where a foreign-controlled resident company \n(other than a financial institution 1[or a banking company)] 2[or a branch of a foreign \n                                            \n1Inserted by the Finance Act, 2002 \n2Inserted by the Finance Act, 2008. \n\n\f\nChapter VII – International_______________________________ \n \n201 \n \ncompany operating in Pakistan,] has a foreign debt-to-foreign equity ratio in excess \nof three to one at any time during a tax year, a deduction shall be disallowed for \nthe profit on debt paid by the company in that year on that part of the debt which \nexceeds the three to one ratio.  \n \n \n(2) \nIn this section, — \n \n“foreign-controlled resident company” means a resident company in \nwhich fifty per cent or more of the underlying ownership of the \ncompany is held by a non-resident person (hereinafter referred to as \nthe “foreign controller”) either alone or together with an associate or \nassociates; \n \n“foreign debt” in relation to a foreign-controlled resident company, \nmeans the greatest amount, at any time in a tax year, of the sum of \nthe following amounts, namely: — \n \n(a) \nThe balance outstanding at that time on any debt obligation \nowed by the foreign-controlled resident company to a foreign \ncontroller or non-resident associate of the foreign controller on \nwhich profit on debt is payable which profit on debt is deductible \nto the foreign-controlled resident company and is not taxed \nunder this Ordinance or is taxable at a rate lower than the \n1[corporate rate] of tax applicable on assessment to the foreign \ncontroller or associate; and \n \n(b) \nthe balance outstanding at that time on any debt obligation owed \nby the foreign-controlled resident company to a person other \nthan the foreign controller or an associate of the foreign \ncontroller where that person has a balance outstanding of a \nsimilar amount on a debt obligation owed by the person to the \nforeign controller or a non-resident associate of the foreign \ncontroller; and \n \n“foreign equity” in relation to a foreign-controlled resident \ncompany and for a tax year, means the sum of the following \namounts, namely: — \n \n(a) \nThe paid-up value of all shares in the company owned by \nthe foreign controller or a non-resident associate of the \nforeign controller at the beginning of the tax year;  \n \n(b) \nso much of the amount standing to the credit of the share \npremium account of the company at the beginning of the \n                                            \n1 The words “corporate tax” substituted by the Finance Act, 2002 \n\n\f\nChapter VII – International_______________________________ \n \n202 \n \ntax year as the foreign controller or a non-resident \nassociate would be entitled to if the company were wound \nup at that time; and \n \n(c) \nso much of the accumulated profits and asset revaluation \nreserves of the company at the beginning of the tax year \nas the foreign controller or a non-resident associate of the \nforeign controller would be entitled to if the company were \nwound up at that time; \n \nreduced by the sum of the following amounts, namely: — \n \n (i) \nthe balance outstanding at the beginning of the tax \nyear on any debt obligation owed to the foreign-\ncontrolled resident company by the foreign \ncontroller or a non-resident associate of the foreign \ncontroller; and \n(ii) \nwhere the foreign-controlled resident company has \naccumulated losses at the beginning of the tax \nyear, the amount by which the return of capital to \nthe foreign controller or non-resident associate of \nthe foreign controller would be reduced by virtue of \nthe losses if the company were wound up at that \ntime. \n \n1[106A. \nRestriction on deduction of profit on debt payable to associated \nenterprise.-(1) Subject to sections 108 and 109, a part of deduction for foreign \nprofit on debt claimed by a foreign-controlled resident company(other than an \ninsurance company, or a banking company) during a tax year, shall be disallowed \naccording to the following formula, namely:-   \n \n[B] – [(A+B) x 0.15] \nwhere- \n \n \nA  \nis the taxable income before depreciation and amortization; and  \n \n \nB \nis the foreign profit on debt claimed as deduction  \n(2) \nThis section shall not apply to a foreign-controlled resident company \nif the total foreign profit on debt claimed as deduction is less than ten \nmillion rupees for a tax year. \n \n(3) \nWhere in computing the taxable income for a tax year, full effect \ncannot be given to a deduction for foreign profit on debt, the excessive \namount shall be added to the amount of foreign profit on debt for the \n                                            \n1 New section 106A inserted through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nChapter VII – International_______________________________ \n \n203 \n \nfollowing tax year and shall be treated to be part of that deduction, or \nif there is no such deduction for that tax year, be treated to be the \ndeduction for that tax year, be treated to be the deduction for that tax \nyear and so on for three tax years. \n \n(4) \nNotwithstanding the provisions of section 106, where deduction of \nforeign profit on debt is disallowed under this section and also under \nsection 106, the disallowed amount shall be the higher of the \ndisallowed amount under this section and section 106. \n \n(5) \nThis section shall apply in respect of foreign profit on debt accrued \nwith effect from the first day of July, 2020, ever if debts were \ncontracted before the first day of July, 2020. \n \n(6) \nIn this section- \n \n(a) “foreign-controlled resident company” means a resident company \nin which fifty per cent or more of the underlying ownership of the \ncompany is held by a non-resident person either alone or together \nwith an associate or association; and  \n \n(b) “foreign profit on debt” means interest paid or payable to a non-\nresident person or an associate of the foreign-controlled resident \ncompany and includes- \n \n(i) \ninterest on all forms of debt; \n \n(ii) payments made which are economically equivalent to \ninterest; \n \n(i) \nexpenses incurred in connection with the raising of finance; \n \n(ii) payments under profit participating loans; \n \n(iii) imputed interest on instruments such as convertible bonds \nand zero coupon bonds; \n \n(iv) amounts under alternative financing arrangements such as \nIslamic finance; \n(v) the finance cost element of finance lease payments; \n \n(vi) capitalized interest included in the balance sheet value of \nrelated asset, or the amortisation of capitalised interest; \n \n(vii) amounts measured by reference to a funding return under \ntransfer pricing rules; \n\n\f\nChapter VII – International_______________________________ \n \n204 \n \n \n(viii) where applicable, national interest amounts under derivative \ninstruments or hedging arrangements related to an entity’s \nborrowings; \n \n(ix) certain foreign exchange gains and losses on borrowings and \ninstruments connected with the raising of finance; \n \n(x) guarantee fees with respect to financing arrangements; and  \n \n(xi) arrangements fee and similar cost related to the borrowing \nfunds.]  \n  \n   \n \n \n \n\n\f\nChapter VII – International_______________________________ \n \n205 \n \nPART IV \nAGREEMENTS FOR THE AVOIDANCE OF DOUBLE TAXATION  \nAND PREVENTION OF FISCAL EVASION \n \n107.  Agreements for the avoidance of double taxation and prevention of \nfiscal evasion. —1[2[(1) The Federal Government may enter into a tax treaty, a \ntax information exchange agreement, a multilateral convention, an inter-\ngovernmental agreement or similar agreement or mechanism for the avoidance of \ndouble taxation 3[or assistance in the recovery of taxes] or for the exchange of \ninformation for the prevention of fiscal evasion or avoidance of taxes including \nautomatic 4[and spontaneous] exchange of information with respect to taxes on \nincome imposed under this Ordinance or any other law for the time being in force \nand under the corresponding laws in force in that country and may, by notification \nin the official Gazette, make such provisions as may be necessary for \nimplementing the said instruments.”;] and] \n \n5[“(1A) Notwithstanding anything contained in any other law to the contrary, \nthe Board shall have the powers to obtain and collect information when solicited \nby another country under a tax treaty, a tax information exchange agreement, a \nmultilateral convention, an inter-governmental agreement, a similar arrangement \nor mechanism.] \n \n6[(1B) Notwithstanding the provisions of the Freedom of Information \nOrdinance, 2002 (XCVI of 2002), 7[subject to clause (a) of sub-section (3) of \nsection 216 of this Ordinance] any information received or supplied, and any \n                                            \n1The sub-section (1) substituted by Finance Act, 2015. Substituted sub-section (1) read as follows:-  \n“(1) The Federal Government may enter into an agreement with the government of a foreign country \nfor the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income \nimposed under this Ordinance and under the corresponding laws in force in that country, and may, by \nnotification in the official Gazette make such provisions as may be necessary for implementing the \nagreement.” \n2Sub-section (1) substituted by the Finance Act, 2016. The substituted sub-section (1) reads as \nfollows:- \n“(1) The Federal Government may enter into an agreement, bilateral or multilateral with the \ngovernment or governments of foreign countries or tax jurisdictions for the avoidance of double \ntaxation and the prevention of fiscal evasion and exchange of information including automatic \nexchange of information with respect to taxes on income imposed under this Ordinance or any \nother law for the time being in force and under the corresponding laws in force in that country, \nand may, by notification in the official Gazette, make such provisions as may be necessary for \nimplementing the agreement.” \n3 Inserted by the Finance Act, 2021. \n4 The words “and spontaneous” inserted through Finance Act, 2020 dated 30th June, 2020 \n5Inserted by the Finance Act, 2015 \n6Inserted by the Finance Act, 2015 \n7The words inserted by the Finance Act, 2019. \n\n\f\nChapter VII – International_______________________________ \n \n206 \n \nconcomitant communication or correspondence made, under a tax treaty, a tax \ninformation exchange agreement, a multilateral convention, a similar arrangement \nor mechanism, shall be confidential 1[  ]. \n \n \n(2) \n2[Subject to section 109, where] any agreement is made in \naccordance with sub-section (1), the agreement and the provisions made by \nnotification for implementing the agreement shall, notwithstanding anything \ncontained in any law for the time being in force, have effect in so far as they provide \nfor 3[at least one of the following] – \n \n(a) \nrelief from the tax payable under this Ordinance; \n \n(b) \nthe determination of the Pakistan-source income of non-\nresident persons; \n \n(c) \nwhere all the operations of a business are not carried on within \nPakistan, the determination of the income attributable to \noperations carried on within and outside Pakistan, or the income \nchargeable to tax in Pakistan in the hands of non-resident \npersons, including their agents, branches, and permanent \nestablishments in Pakistan; \n \n(d) \nthe determination of the income to be attributed to any resident \nperson having a special relationship with a non-resident person; \nand \n \n(e) \nthe exchange of information for the prevention of fiscal evasion \nor avoidance of taxes on income chargeable under this \nOrdinance and under the corresponding laws in force in that \nother country. \n \n \n(3) \nNotwithstanding anything4[contained] in sub-sections (1) or (2), any \nagreement referred to in sub-section (1) may include provisions for the relief from \ntax for any period before the commencement of this Ordinance or before the \nmaking of the agreement.  \n \n \n \n                                            \n1The expression “subject to sub-section (3) of section 216” omitted by the Finance Act, 2016 \n2The word “where” substituted by the Finance Act, 2018. \n3Inserted by the Finance Act, 2016. \n4Inserted by the Finance Act, 2016. \n\n\f\nChapter VIII – Anti-Avoidance____________________________ \n \n207 \nCHAPTER VIII \nANTI-AVOIDANCE \n \n108.  Transactions between associates. — (1)  The Commissioner may, in \nrespect of any transaction between persons who are associates, distribute, \napportion or allocate income, deductions or tax credits between the persons as is \nnecessary to reflect the income that the persons would have realised in an arm’s \nlength transaction. \n \n \n(2) \nIn making any adjustment under sub-section (1), the Commissioner \nmay determine the source of income and the nature of any payment or loss as \nrevenue, capital or otherwise. \n \n1[(3) \nEvery taxpayer who has entered into a transaction with its associate \nshall: \n \n(a) maintain a master file and a local file containing documents and \ninformation as may be prescribed; \n \n(b) keep 2[, maintain and furnish to the Board] prescribed country-by-\ncountry report, where applicable; \n \n(c) \nkeep and maintain any other information and document in respect of \ntransaction with its associate as may be prescribed; and \n \n(d) keep the files, documents, information and reports specified in clauses \n(a) to (c) for the period as may be prescribed. \n \n(4) \nA taxpayer who has entered into a transaction with its associate shall \nfurnish, within thirty days the documents and information to be kept and maintained \nunder 3[clause (a), (c) or (d) of] sub-section (3) if required by the Commissioner in \nthe course of any proceedings under this Ordinance.; \n \n(5) \nThe Commissioner may, by an order in writing, grant the taxpayer an \nextension of time for furnishing the documents and information under sub-section \n(4), if the taxpayer applies in writing to the Commissioner for an extension of time \nto furnish the said documents or information: \n \nProvided that the Commissioner shall not grant an extension of more than \nforty-five days, when such information or documents were required to be furnished \nunder sub-section (4), unless there are exceptional circumstances justifying a \nlonger extension of time.] \n                                            \n1 Added by the Finance Act, 2016. \n2The words “and maintain” substituted  by the Finance Act, 2018 \n3Insertedby the Finance Act, 2018 \n \n\n\f\nChapter VIII – Anti-Avoidance____________________________ \n \n208 \n \n1[(6) Notwithstanding the provisions of sub-section (1), for the tax year 2024 \nand onwards, where any amount is claimed as deduction for the tax year or for any \nof the two preceding tax years on account of royalty paid or payable to an associate \ndirectly or indirectly in respect of use of any brand name, logo, patent, invention, \ndesign or model, secret formula or process, copyright, trademark, scientific or \ntechnical knowledge, franchise, license, intellectual property or other like property \nor right or contractual right and on a notice issued by the Commissioner, the \ntaxpayer fails to furnish any explanation or evidence that no benefit has been \nconferred on the associate, twenty five percent of the total expenditure for the tax \nyear in respect of sales promotion, advertisement and publicity shall be disallowed \nand allocated to the said associate.] \n \n2[108A. Report from independent chartered accountant or cost and \nmanagement accountant. – (1) Where the Commissioner is of the opinion that a \ntransaction has not been declared at arm’s length, the Commissioner may obtain \nreport from an independent chartered accountant or cost and management \naccountant to determine the fair market value of asset, product, expenditure or \nservice at the time of transaction.  \n \n(2) \nThe scope, terms and conditions of the report shall be as may be \nprescribed. \n \n(3) \nWhere the Commissioner is satisfied with the report of the \nindependent chartered accountant or cost and management accountant, the fair \nmarket value of asset, product, expenditure or service determined in the report \nshall be treated as definite information for the purpose of sub-section (8) of section \n122. \n \n(4) \nWhere the Commissioner is not stratified with the report of the \nindependent chartered accountant or cost and management accountant, the \nCommissioner may record reasons for being not satisfied with the report and seek \nreport from another independent chartered accountant or cost and management \naccountant, to determine the fair market value of asset, product, expenditure or \nservice at the time of transaction. \n \n(5) \nThe Commissioner shall seek report under sub-section (1) or sub-\nsection (3), as the case may be, with prior approval of the Board. \n \n108B. Transactions under dealership arrangements.- (1) Where a person \nsupplies products listed in the Third Schedule to the Sales Tax Act, 1990 or any \nother products as prescribed by the Board, under a dealership arrangement with \nthe dealers who are not registered under Sales Tax Act, 1990 and are not \nappearing in the active taxpayers’ list under this Ordinance, an amount equal to \n                                            \n1 Sub-section (6) added by the Finance Act, 2024. \n2New sections (108A) & (108B) inserted through Finance Act, 2019 \n\n\f\nChapter VIII – Anti-Avoidance____________________________ \n \n209 \n \nseventy-five percent of the dealer’s margin shall be added to the income of the \nperson making such supplies. \n \n \n(2) \nFor the purposes of operation of this section, ten percent of the sale \nprice of the manufacturer shall be treated as dealers margin.] \n \n109. Recharacterisation of income and deductions. — (1) For the purposes \nof determining liability to tax under this Ordinance, the Commissioner may – \n \n(a) recharacterise a transaction or an element of a transaction that was \nentered into as part of a tax avoidance scheme;  \n \n(b) disregard a transaction that does not have substantial economic effect; \n1[   ] \n \n(c) \nrecharacterise a transaction where the form of the transaction does not \nreflect the substance2[;] \n \n3[(d) from  tax  year  2018  and  onwards,  disregard  an  entity  or    a \ncorporate  structure  that  does  not  have  an  economic  or commercial  \nsubstance  or  was  created  as  part  of  the  tax avoidance scheme] 4[; \nor \n \n(e)    from tax year 2018 and onwards, treat a place of business in Pakistan \nas a permanent establishment, if the said place fulfills the conditions as \nspecified in sub-clause (g) of clause (41) of section 2.] \n \n(2) \nIn this section, “tax avoidance scheme” means any transaction where \none of the main purposes of a person in entering into the transaction is the \navoidance or reduction of any person’s liability to tax under this Ordinance. \n \n5[(3) Reduction in a person's liability to tax as referred to in sub-section (2) \nmeans a reduction, avoidance or deferral of tax or increase in a refund of tax and \nincludes a reduction, avoidance or deferral of tax that would have been payable \nunder this Ordinance, but are not payable due to a tax treaty for the avoidance of \ndouble taxation as referred to in section 107.] \n \n                                            \n1The word “or” omitted by the finance Act 2022. \n2Full stop substituted with a semicolon by the finance Act 2022. \n3Inserted by the finance Act 2018 \n4Full stop substituted and a new clause (e) added by the Finance Act 2022. \n5 Added by the finance Act 2018 \n\n\f\nChapter VIII – Anti-Avoidance____________________________ \n \n210 \n \n1[109A. Controlled foreign company.— (1) There shall be included in the taxable \nincome of a resident person for a tax year an income attributable to controlled \nforeign company as defined in sub- section (2). \n \n(2)  For the purpose of this section, controlled foreign company means a \nnon-resident company, if ─ \n \n(a)  more than fifty percent of the capital or voting rights of the non-\nresident company are held, directly or indirectly, by one or more \npersons resident in Pakistan o more than forty percent of the capital \nof the or voting rights of the non-resident company are held, directly  \nor indirectly, by a single resident person in Pakistan; \n \n(b) tax paid, after taking into account any foreign tax credits available to \nthe non-resident company, on the income derived or accrued, during \na foreign tax year, by the non-resident company to any  tax  authority \noutside Pakistan is less than sixty percent of the tax payable on the \nsaid income under this Ordinance; \n \n(c) the non-resident company does not derive active business  income  \nas defined under sub-section (3); and \n \n(d) the shares of the company are not traded on any stock exchange  \nrecognized by law of the country or jurisdiction of which the      non-\nresident company is resident for tax purposes. \n \n(3)   A  company  shall  be  treated  to  have  derived  active  income if─ \n \n(a)  more than eighty percent of income of the company does not  include \nincome from \ndividend, interest, property, capital gains,   royalty, \nannuity payment, supply of goods or services to an  associate, sale \nor licensing of intangibles and management,  holding or investment \nin securities and financial assets; and \n \n(b) principally derives income under the head “income from business” \nin the country or jurisdiction of which it is a resident. \n \n(4) Income of a controlled foreign company is an amount equal to the taxable \nincome of that company determined in accordance with the provisions  of  this  \nOrdinance  as  if  that  controlled  foreign  company  is  a resident taxpayer and \nshall be taxed at the rate specified in Division III of Part I of the First Schedule. \n \n(5)  The amount of attributable income under sub-section (1) for a tax   year \nshall be computed according to the following formula, namely:— \n                                            \n1Inserted by the finance Act 2018 \n\n\f\nChapter VIII – Anti-Avoidance____________________________ \n \n211 \n \n \nA x (B/100) \n \nWhere - \n \nA \nis the amount of income of a controlled foreign company under sub-\nsection (2); and \n \nB \nis the percentage of capital or voting rights, whichever is higher, \nheld by the person, directly or indirectly, in the controlled foreign \ncompany. \n \n(6) \nThe amount of attributable income shall be treated as zero, if the \ncapital or voting rights of the resident person is less than ten percent. \n \n(7) \nIncome of a controlled foreign company shall be treated as zero, if it \nis less than ten million Rupees. \n \n(8) \nThe income of a controlled foreign company in respect of a foreign tax \nyear, as defined in sub-section (9), shall be determined in the currency of that \ncontrolled foreign company and shall, for purposes of determining the amount to \nbe included in the income  of  any  resident  person  during  any  tax  year  under  \nthe provisions  of  this  section,  be  converted  into  Rupees  at  the  State Bank of \nPakistan rate applying between  that foreign currency and the Rupee on the last \nday of the tax year. \n \n(9) \nForeign tax year, in relation to a non-resident company, means any  \nyear or period of reporting for income tax purposes by that non-resident company \nin the country or jurisdiction of residence or, if that company is not subject to \nincome tax, any annual period of financial reporting by that company. \n \n(10) The income attributable to controlled foreign company under        sub-\nsection (1) and taxed in Pakistan under this section shall not be taxed again when \nthe same income is received in Pakistan by the resident taxpayer. \n \n(11) Where tax has been paid by the resident person on the income  \nattributable to controlled foreign company and in a subsequent tax year the \nresident person receives dividend distributed by the controlled foreign company,  \nafter deduction of tax on dividend, the resident person shall be allowed a tax credit \nequal to the lesser of, — \n \n(i) \nforeign tax paid, as defined in sub-section (8) of section 103, on \ndividends; and \n \n(ii) \n Pakistan tax payable, as defined in section 103, for the tax  year  \nin  which  the  dividend  is  received  by  the resident taxpayer.] \n\n\f\nChapter VIII – Anti-Avoidance____________________________ \n \n212 \n \n \n110. Salary paid by private companies. — Where, in any tax year, salary is \npaid by a private company to an employee of the company for services rendered \nby the employee in an earlier tax year and the salary has not been included in the \nemployee’s salary chargeable to tax in that earlier year, the Commissioner may, if \nthere are reasonable grounds to believe that payment of the salary was deferred, \ninclude the amount in the employee’s income under the head “Salary” in that earlier \nyear. \n \n111. Unexplained income or assets. — (1) Where — \n \n(a) \nany amount is credited in a person’s books of account; \n \n(b) \na person has made any investment or is the owner of any money \nor valuable article; 1[  ] \n \n(c) \na person has incurred any expenditure2[; or] \n \n3[(d)  any person has concealed income or furnished inaccurate \nparticulars of income including — \n \n(i)  \nthe suppression of any production, sales or any amount \nchargeable to tax; or  \n \n(ii)  \nthe suppression of any item of receipt liable to tax in \nwhole or in part,] \n \nand the person offers no explanation about the nature and source of the amount \ncredited or the investment, money, valuable article, or funds from which the \nexpenditure was made 4[suppression of any production, sales, any amount \nchargeable to tax and of any item of receipt liable to tax] or the explanation offered \nby the person is not, 5[in the Commissioner’s opinion, satisfactory-  \n \n(a)  \nthe amount credited, value of the investment, money, value of the \narticle, or amount of expenditure shall be included in the person’s \nincome chargeable to tax under the head “Income from Other \nSources” to the extent it is not adequately explained; and \n                                            \n1The word “or” omitted by the Finance Act, 2011. \n2Comma substituted by the Finance Act, 2011. \n3Added by the Finance Act, 2011 \n4Inserted by the Finance Act, 2011. \n5The expressions “in the Commissioner’s opinion, satisfactory, the amount credited, value of the \ninvestment, money, value of the article, or amount of expenditure 5[suppressed amount of production, \nsales or any amount chargeable to tax or of any item of receipt liable to tax] shall be included in the \nperson’s income chargeable to tax under head “Income from 5[Other Sources”] to the extent it is not \nadequately explained” substituted through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nChapter VIII – Anti-Avoidance____________________________ \n \n213 \n \n \n(b) \nthe suppressed amount of production, sales or any amount \nchargeable to tax or of any item of receipt liable to tax shall be included \nin the person’s income chargeable to tax under the head “Income from \nBusiness” to the extent it is not adequately explained”]  1[:] \n \n2[Provided that where a taxpayer explains the nature and \nsource of the amount credited or the investment made, money or \nvaluable article owned or funds from which the expenditure was made, \nby way of agricultural income, such explanation shall be accepted to \nthe extent of agricultural income worked back on the basis of \nagricultural income tax paid under the relevant provincial law.] \n \n3[(2) The amount referred to in sub-section (1) shall be included in the \nperson’s income chargeable to tax: \n(i) \nin the tax year to which such amount relates if the amount   \nrepresenting investment, money, valuable article or expenditure   \nis situated or incurred in Pakistan or concealed income is  \nPakistan-source; and \n \n(ii) \nin the tax year immediately preceding the tax year in which the   \ninvestment, money, valuable article or expenditure is discovered \nby the Commissioner and is situated or incurred outside  Pakistan \n4[or] concealed income is foreign-source. \n \nExplanation.—For the removal of doubt, it is clarified that where  \nthe investment, money, valuable article or expenditure is  acquired \nor incurred outside Pakistan in a prior tax year and is liable to be \nincluded in the income of tax year 2018 and  onwards  on the basis \nof discovery made by the Commissioner during tax year 2019 and \nonwards and the person explains the  acquisition  of such asset \nor expenditure from sources relating to tax year in which such \nasset was acquired or expenditure was incurred, such explanation \nshall not be rejected on the basis that the source  does  not  relate  \nto  the  tax  year  in  which  the amount chargeable to tax is to be \nincluded.] \n \n \n \n                                            \n1Full stop substituted by the Finance Act, 2013. \n2Added by the Finance Act, 2013. \n3Sub-section (2) substituted by the Finance Act, 2018. The substituted sub-section (2) read as follows:  \n“(2) The amount referred to in sub-section (1) shall be included in the person’s income chargeable to tax in the \ntax year 3[to which such amount relates.” \n4 The word “and” substituted by the Finance Act, 2021. \n\n\f\nChapter VIII – Anti-Avoidance____________________________ \n \n214 \n \n1[(2A) For the purposes of clause (ii) of sub-section (2) of this section, the \n“year of discovery of foreign assets or expenditure or concealed income”, shall \nmean the year in which the Commissioner has issued a notice requiring the person \nto explain the nature and source of such foreign assets, expenditure or concealed \nincome.] \n \n2[(3) Where the declared cost of any investment or valuable article or the \ndeclared amount of expenditure of a person is less than reasonable cost of the \ninvestment or the valuable article, or the reasonable amount of the expenditure, \nthe Commissioner may, having regard to all the circumstances, include the \ndifference in the person’s income chargeable to tax under the head “Income from \nOther Sources” in the tax year 3[to which the investment, valuable article or the \nexpenditure relates].] \n \n4[   ] \n \n5[(4) Sub-section (1) does not apply to any amount of foreign exchange \nremitted from outside Pakistan through normal banking channels not exceeding \nfive million Rupees in a tax year that is en-cashed into rupees by a scheduled bank \nand a certificate from such bank is produced to that effect.] \n \n6[Explanation.— For removal of doubt, it is clarified that the remittance through \nmoney service bureaus, exchange companies or money transfer operators shall \nbe deemed to constitute foreign exchange remitted from outside Pakistan through \nnormal banking channels as provided under this sub-section. \n                                            \n1 Sub-section (2A) inserted by the Finance Act, 2024. \n2  Sub-section (3) substituted by the Finance Act, 2003. The substituted sub-section (3) read as \nfollows:  \n“(3) \nWhere the declared value of any investment, valuable article or expenditure of a person \nis less than the cost of the investment or valuable article, or the amount of the expenditure, the \nCommissioner may, having regard to all the circumstances, include the difference in the person’s \nincome chargeable to tax under the head “Income from Other Sources” in the tax year in which the \ndifference is discovered.” \n3The words “immediately preceding the financial year in which the difference is discovered”  substituted \nby the Finance Act, 2010. \n4Sub-section (4) substituted by the Finance Act, 2004. The substituted sub-section (4) read as follows: \n“(4) \nSub-section (1) does not apply to any amount of foreign exchange remitted from outside \nPakistan through normal banking channels that is encashed into rupees by a scheduled bank and a \ncertificate from such bank is produced to that effect.” \n5 Sub-section (4) substituted by the Finance Act, 2021. The substituted sub-section read as follows: \n(4) \nSub-section (1) does not apply,— \n(a) \nto any amount of foreign exchange remitted from outside Pakistan through normal \nbanking channels 5[not exceeding 5[five] million Rupees in a tax year] that is \nencashed into rupees by a scheduled bank and a certificate from such bank is \nproduced to that effect5[.]  \n5[  ] \n5[  ] \n6 The explanation and sub-section (4A) inserted by the Finance Act, 2022. \n\n\f\nChapter VIII – Anti-Avoidance____________________________ \n \n215 \n \n(4A) Where a taxpayer, while explaining the nature and source of any \namount referred to in sub-section (1), takes into account any source of income \nwhich is subject to final tax under any provision of the Ordinance, the taxpayer \nshall not be entitled to take credit of any sum as is in excess of imputable income, \nunless the excess amount is reasonably attributed to the business activities subject \nto final tax and the taxpayer furnishes financial statements and accounts duly \naudited by a chartered accountant.] \n \n \n(5) \nThe 1[Board] may make rules under section 2[237] for the purposes of \nthis section.  \n \n \n3[   ] \n  \n4[Explanation.— For the removal of doubt, it is clarified that a separate notice \nunder this section is not required to be issued if the explanation regarding \nnature and sources of;  \n \n(i) \nany amount credited in a person’s books of account; or \n(ii) \nany investment made or ownership of money or valuable article; or \n(iii) \nfunds from which expenditure was made; or \n(iv) \nsuppression of any production, sales, or any amount chargeable to \ntax; or  \n(v) \nsuppression of any item of receipt liable to tax in whole or in part has \nbeen confronted to the taxpayer through a notice under sub-section \n(9) of section 122 of the Ordinance.] \n \n112. Liability in respect of certain security transactions.— (1) Where the \nowner of any security disposes of the security and thereafter re-acquires the \nsecurity and the result of the transaction is that any income payable in respect of \nthe security is receivable by any person other than the owner, the income shall be \ntreated, for all purposes of the Ordinance, as the income of the owner and not of \nthe other person.  \n \n \n(2) \nIn this section, “security” includes 5[bonds, certificates, debentures,] \nstocks and shares.\n                                            \n1 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2 The figure “232” substituted by the Finance Act, 2002. \n3 Added by the Finance Act, 2021.  \n4 The explanation substituted by the Finance Act, 2022. The substituted Explanation read as follows: \n“Explanation.—For the removal of doubt, a separate notice under this section is not required to be \nissued if the explanation regarding nature and sources of amount credited or the investment of money, \nvaluable article, or the funds from which expenditure was made has been confronted to the taxpayer \nthrough a notice under sub-section (9) of section 122 of this Ordinance.” \n5 Inserted by the Finance Act, 2003. \n\n\f\nChapter IX – Minimum Tax ______________________________ \n \n216 \nCHAPTER IX  \nMINIMUM TAX \n \n1[113.  Minimum tax on the income of certain persons.- (1) This section shall \napply to a resident company,2[permanent establishment of a non-resident \ncompany,] 3[, an individual (having turnover of 4[  ] 5[hundred] million rupees or \nabove in the tax year 6[2017] or in any subsequent tax year) and an association of \npersons (having turnover of 7[  ] 8[hundred] million rupees or above in the tax year \n9[2017] or in any subsequent tax year)] where, for any reason whatsoever allowed \nunder this Ordinance, including any other law for the time being in force — \n \n \n \n(a)  \nloss for the year;  \n \n(b)  \nthe setting off of a loss of an earlier year; \n \n(c) \nexemption from tax; \n \n(d)  \nthe application of credits or rebates; or \n \n(e)  \nthe claiming of allowances or deductions (including depreciation \nand amortization deductions) no tax is payable or paid by the \nperson for a tax year or the tax payable or paid by the person \nfor a tax year is less than 10[ 11[the percentage as specified in \ncolumn (3) of the Table in Division IX of Part-I of the First \n                                            \n1Inserted by the Finance Act, 2009. \n2The expressions inserted through Finance Act, 2020 dated 30th June, 2020  \n3Inserted by the Finance Act, 2010. \n4The word “fifty” substituted by the Finance Act, 2016. \n5 The word “ten” substituted by the Finance Act, 2021. \n6The figure “2009” substituted by the Finance Act, 2016 \n7The word “fifty” substituted by the Finance Act, 2016. \n8 The word “ten” substituted by the Finance Act, 2021. \n9The figure “2007” substituted by the Finance Act, 2016 \n10The word “one-half” substituted by the Finance Act, 2013. \n11The word “one per cent” substituted by the Finance Act, 2017. \n\n\f\nChapter IX – Minimum Tax ______________________________ \n \n217 \n \nSchedule] ] of the amount representing the person’s turnover \nfrom all sources for that year: \n \n \n1[    ] \n \n2[ 3[Explanation.-For the purpose of this sub-section, the expression \n“tax payable or paid” does not include-  \n \n(a) \ntax already paid or payable in respect of deemed income which \nis assessed as final discharge  of the tax liability under section \n169 or under any other provision of this Ordinance; and \n \n(b) \ntax payable or paid under section 4B 4[or 4C]. ] \n \n(2)       Where this section applies: \n \n(a) \nthe aggregate of the person’s turnover as defined in sub-section \n(3) for the tax year shall be treated as the income of the person \nfor the year chargeable to tax 5[. \n \nExplanation.—For the removal of doubt, it is clarified that the \ndefinition of turnover covers receipts from all business activities \nin line with expression “ turnover from all sources” used in sub-\nsection (1) including but not limited to receipts from sale of \nimmoveable property where such receipt is taxable under the \nhead Income from Business;] \n \n(b) \nthe person shall pay as income tax for the tax year (instead of \nthe actual tax payable under this Ordinance),6[minimum tax  \ncomputed on the basis of rates as specified in Division IX of Part \nI of First Schedule]; \n \n                                            \n1 Proviso omitted by the Finance Act, 2016. The omitted proviso reads as follows:- \n“Provided that this sub-section shall not apply in the case of a company, which has declared \ngross loss before set off of depreciation and other inadmissible expenses under the Ordinance. If the \nloss is arrived at by setting off the aforesaid or changing accounting pattern, the Commissioner may \nignore such claim and proceed to compute the tax as per historical accounting pattern and provision \nof this Ordinance and all other provisions of the Ordinance shall apply accordingly.” \n2Added by the Finance Act, 2012. \n3Explanation substituted by the Finance Act, 2016. The substituted Explanation reads as follows:- \n[“Explanation.- For the purpose of this sub-section, the expression “tax payable or paid” does \nnot include tax already paid or payable in respect of deemed income which is assessed as final \ndischarge  of the tax liability under section 169 or under any other provision of this Ordinance.] \n4 Inserted by the Finance Act, 2022. \n5 Semi colon substituted and explanation added by the Finance Act, 2021. \n6The words “an amount equal  to one percent of the person’s turnover for the year” substituted by  the \nwords “minimum tax  computed on the basis of rates as specified in Division IX of Part I of First \nSchedule”, by the Finance Act, 2014. \n\n\f\nChapter IX – Minimum Tax ______________________________ \n \n218 \n \n(c) \nwhere tax paid under sub-section (1) exceeds the actual tax \npayable under Part I,1[clause (1) of Division I, or]  Division II of \nthe First Schedule, the excess amount of tax paid shall be \ncarried forward for adjustment against tax liability under the \naforesaid Part of the subsequent tax year: \n \n2[Provided that if tax is paid under sub-section (1) due to \nthe fact that no tax is payable or paid for the year, the entire \namount of tax paid under sub-section (1) shall be carried \nforward for adjustment in the manner stated aforesaid:  \n \nProvided further that the amount under this clause shall \nbe carried forward and adjusted against tax liability for 3[  ] 4[two]  \ntax years immediately succeeding the tax year for which the \namount was paid.] \n \n \n \n \n \n5[Explanation. – For the removal of doubt it is clarified that the \naforesaid Part referred to in this clause means clause (1) of \nDivision I or Division II of Part I of the First Schedule.] \n \n(3) \n“turnover” means,- \n \n(a) \nthe 6[gross sales or] gross receipts, exclusive of Sales Tax and \nFederal Excise duty or any trade discounts shown on invoices, \nor bills, derived from the sale of goods, and also excluding any \namount taken as deemed income and is assessed as final \ndischarge of the tax liability for which tax is already paid or \npayable; \n \n(b) \nthe gross fees for the rendering of services for giving benefits \nincluding commissions; except covered by final discharge of tax \nliability for which tax is separately paid or payable; \n \n(c) \nthe gross receipts from the execution of contracts; except \ncovered by final discharge of tax liability for which tax is \nseparately paid or payable; and \n \n                                            \n1 Inserted by the Finance Act, 2013. \n2 The proviso substituted by the Finance Act, 2021. The substituted proviso read as follows: \n“Provided that the amount under this clause shall be carried forward and adjusted against \ntax liability for 2[five] tax years immediately succeeding the tax year for which the amount was paid.” \n3 The word “five” substituted by the Finance Act, 2022. \n4 The word “three” substituted by the Finance Act, 2025.  \n5 The explanation added by the Finance Act, 2023.  \n6Inserted by the Finance Act, 2011. \n\n\f\nChapter IX – Minimum Tax ______________________________ \n \n219 \n \n(d) \nthe company’s share of the amounts stated above of any \nassociation of persons of which the company is a member.] \n \n1[2[  ] ]  \n \n3[  ] \n                                            \n1Section 113A substituted by the Finance Act, 2013. The substituted section 113A read as follows:- \n“113A. Tax on Income of certain persons. — (1) Subject to this Ordinance, where a retailer being \nan individual or an association of persons has turnover upto rupees five million for any tax year, such \nperson may opt for payment of tax as a final tax at the rates specified in Division IA of Part I of the \nFirst Schedule. \n(2) \nFor the purposes of this section, — \n(a)  \n“retailer” means a person selling goods to general public for the purpose of \nconsumption; \n(b)  \n“turnover” shall have the same meaning as assigned to it in sub-section (3) of \nsection 113. \n \n(3) The tax paid under this section shall be a final tax on the income arising from the turnover \nas specified in sub-section (1). The retailer shall not be entitled to claim any adjustment of withholding \ntax collected or deducted under any head during the year.” \n2 Section 113A omitted by the Finance Act, 2016. The omitted section 113a reads as follows:-  \n“113A.    Minimum tax on builders.— (1) Subject to this Ordinance, where a person derives income \nfrom the business of construction and sale of residential, commercial or other buildings, he shall pay \nminimum tax at the rates as the Federal Government may notify in the official Gazette. The Federal \nGovernment may also specify the mode, manner and time of payment of such amount of tax. \n \n(2)  \nThe tax paid under this section shall be minimum tax on the income of the builder \nfrom the sale of such residential, commercial or other building.] \n \n2[“(3) This section shall not have effect till the 30th June, 2018.”]” \n3Section 113B substituted by the Finance Act, 2013. The substituted section 113B read as follows:- \n“113B.   Taxation of income of certain retailers. — Subject to this Ordinance, a retailer being an \nindividual or association of persons,-  \n \n \n(a)  \nwhose turnover exceeds five million rupees; and \n(b)  \nwho is subject to special procedure for payment of sales tax  under Chapter II \nof the Sales Tax Special Procedures Rules, 2007, \nshall pay final tax at the following rates which shall form part of single stage sales tax as envisaged in \nthe aforesaid rules;________________________________________________________________ \nS.No. \nAmount of turnover \nRate of tax \n________________________________________________________________ \n1. \nWhere turnover \nRs.25,000 plus  \n \nexceeds Rs.5,000,000  \n0.5% of the \n \nbut does not exceed \nturnover exceeding \n \nRs. 10,000,000 \nRs.5 ,000,000 \n \n2. \nWhere turnover \nRs. 50,000 plus \n \nexceeds \n0.75% of the \n \nRs.10,000,000 \nturnover exceeding \n \n \n \nRs.10,000,000. \n(c)  \nThe retailer shall not be entitled to claim any adjustment of withholding tax \ncollected or deducted under any head during the year: \n \n \nProvided that turnover chargeable to tax under this section shall not include the sale of \ngoods on which tax is deducted or deductible under clause (a) of sub-section (1) of section \n153.” \n\n\f\nChapter IX – Minimum Tax ______________________________ \n \n220 \n \n1[  ] \n \n2[113C. Alternative Corporate Tax.- (1) Notwithstanding anything contained in \nthis Ordinance, for tax year 2014 and onwards, tax payable by a company 3[in \nrespect of income which is subject to tax under Division II of Part I of the First \nSchedule or minimum tax under any of the provisions of this Ordinance”] shall be \nhigher of the Corporate Tax or Alternative Corporate Tax. \n \n(2) \nFor the purposes of this section.- \n \n(a) “Accounting Income” means the accounting profit before tax for \nthe tax year, as disclosed in the financial statements or as \nadjusted under sub-section (7) or sub-section (11) excluding \nshare from the associate recognized under equity method of \naccounting; \n(b) \"Alternative Corporate Tax\" means the tax at a rate of \nseventeen per cent of a sum equal to accounting income less \nthe amounts, as specified in sub-section (8), and determined in \naccordance with provisions of sub-section (7) hereinafter; \n \n4[“(c) “corporate tax” means higher of tax payable by the company \nunder Division II of Part I of the First Schedule and minimum \ntax payable under any of the provisions of this Ordinance.”]  \n \n(3) \nThe sum equal to accounting income, less any amount to be excluded \nthere from under sub-section (8), shall be treated as taxable income for the \npurpose of this section. \n \n(4) \nThe excess of Alternative Corporate Tax paid over the Corporate Tax \npayable for the tax year shall be carried forward and adjusted against the tax \npayable under Division II of Part I of the First Schedule, for following year. \n \n                                            \n1Section 113B omitted by the Finance Act, 2016. The omitted section reads as follows:- \n“113B.   Minimum tax on land developers.— (1) Subject to this Ordinance, where a person derives \nincome from the business of development and sale of residential, commercial or other plots, he shall \npay minimum tax1[at the rate of two per cent of the value of land notified by any authority for the purpose \nof stamp duty]. The Federal Government may also specify the mode, manner and time of payment of \nsuch amount of tax. \n \n(2)  \nThe tax paid under this section shall be minimum tax on the income of the developer \nfrom the sale of such residential, commercial or other plots sold or booked.\"] \n2Section 113C inserted by the Finance Act, 2014. \n3Inserted by the Finance Act, 2015 \n4 Clause (c) Substituted by the Finance Act, 2015. The substituted clause (c) read as follows:-\n“Corporate Tax” means total tax payable by the company, including tax payable on account of \nminimum tax and final taxes payable, under any of the provisions of this Ordinance but not including \nthose mentioned in sections 8, 161 and 162 and any amount charged or paid on account of default \nsurcharge or penalty and the tax payable under this section. \n\n\f\nChapter IX – Minimum Tax ______________________________ \n \n221 \n \n(5) \nIf the excess tax, as mentioned in sub-section (4), is not wholly \nadjusted, the amount not adjusted shall be carried forward to the following tax year \nand adjusted as specified in sub-section (4) in that year, and so on, but the said \nexcess cannot be carried forward to more than ten tax years immediately \nsucceeding the tax year for which the excess was first computed. \n \nExplanation.- For the purpose of this sub-section the mechanism for \nadjustment of excess of Alternative Corporate Tax over Corporate Tax, specified \nin this section, shall not prejudice or affect the entitlement of the taxpayer regarding \ncarrying forward and adjustment of minimum tax referred to in section 113 of this \nOrdinance. \n(6) \nIf Corporate Tax or Alternative Corporate Tax is enhanced or reduced \nas a result of any amendment, or as a result of any order under the Ordinance, the \nexcess amount to be carried forward shall be reduced or enhanced accordingly. \n(7) \nFor the purposes of determining the “Accounting Income”, expenses \nshall be apportioned between the amount to be excluded from accounting income \nunder sub-section (8) and the amount to be treated as taxable income under sub-\nsection (2).  \n(8) \nThe following amounts shall be excluded from accounting income for \nthe purposes of computing Alternative Corporate Tax:- \n(i) \nexempt income; \n \n1[“(ii)  \nincome which is subject to tax other than under Division II of \nPart I of the First Schedule or minimum tax under any of the \nprovisions of this Ordinance;”;] \n \n(xii) \nincome subject to tax credit under section 65D 2[,65E and 100C] \n \n3[    ] \n \n(9) \nThe provisions of this section shall not apply to taxpayers chargeable \nto tax in accordance with the provisions contained in the Fourth, Fifth and Seventh \nSchedules. \n \n                                            \n1Sub-Clause (ii) substituted by Finance Act, 2015. The substituted clause read as follows:- \n \n(ii) income subject to tax under section 37A and final tax chargeable under sub-section (7) of \n \nsection 148, section 150, sub-section (3) of section 153, sub-section (4) of sections 154, 156 \n \nand sub-section (3) of section 233;”  \n2The word and figure “and 65E” substituted by the Finance Act, 2015 \n3 Sub-clause (iv) and (v) omitted by Finance Act, 2015. The omitted clause read as follows:-  \n“(iv) income subject to tax credit under section 100C;” \n \n“(v) income of the company subject to clause (18A) of Part-II of the Second Schedule;” \n\n\f\nChapter IX – Minimum Tax ______________________________ \n \n222 \n \n(10) Tax credit under 1[sections 64B and] 65B shall be allowed against \nAlternative Corporate Tax. \n \n(11) The Commissioner may make adjustments and proceed to compute \naccounting income as per historical accounting pattern after providing an \nopportunity of being heard.”;] \n \n \n2[Explanation.— For the removal of doubt, it is clarified that taxes paid or \npayable other than payable under Division II of Part I of the First Schedule shall \nremain payable in accordance with the mode or manner prescribed under the \nrespective provisions of this Ordinance.] \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n                                            \n1The words “section” substituted by Finance Act, 2015. \n2Added by Finance Act, 2015. \n\n\f\nChapter X – Procedure__________________________________ \n \n223 \nCHAPTER X \nPROCEDURE \n \nPART I  \nRETURNS \n \n114. Return of income. — (1) Subject to this Ordinance, the following persons \nare required to furnish a return of income for a tax year, namely:– \n \n1[(a)    every company;] \n \n2[(ab) every person (other than a company) whose taxable income for the \nyear exceeds the maximum amount that is not chargeable to tax \nunder this Ordinance for the year;3[or]] \n \n4[(ac)  any non-profit organization as defined in clause (36) of section 2; 5[ ]  \n \n6[    ]  \n7[    ] \n \n8[(ae) every person whose income for the year is subject to final taxation \nunder any provision of this Ordinance;]   \n \n \n                                            \n1Clause (a) substituted by the Finance Act, 2003. The substituted clause (a) read as follows:  \n“(a) \nEvery company and any other person whose taxable income for the year exceeds the \nmaximum amount that is not chargeable to tax under this Ordinance for the year; and” \n2 Inserted by the Finance Act, 2003. \n3Inserted by the Finance Act, 2011. \n4 Inserted by the Finance Act, 2006. \n5The word “and” omitted by the Finance Act, 2011. \n6Clause (ad) Inserted by the Finance Act, 2006. \n7 Clause (ad) omitted by the Finance Act, 2021. The omitted clause read as follows: \n    “(ad)  any welfare institution approved under clause (58) of Part I of the Second Schedule;” \n8Added through Finance Act, 2020 \n\n\f\nChapter X – Procedure__________________________________ \n \n224 \n \n \n1[(b)  any person not covered by clause 2[(a), (ab), (ac) or (ad)] who,— \n \n(i)  \nhas been charged to tax in respect of any of the two preceding \ntax years; \n \n(ii)  \nclaims a loss carried forward under this Ordinance for a tax \nyear;  \n \n(iii)  \nowns immovable property with a land area of 3[five hundred] \nsquare yards or more or owns any flat located in areas falling \nwithin the municipal limits existing immediately before the \ncommencement of Local Government laws in the provinces; or \nareas in a Cantonment; or the Islamabad Capital Territory4[;] ] \n \n5[(iv)  owns immoveable property with a land area of five hundred \nsquare yards or more located in a rating area;] \n \n6[(v) owns a flat having covered area of two thousand square feet or \nmore located in a rating area;] \n \n7[(vi) owns a motor vehicle having engine capacity above 1000 CC; \n8[ ] ] \n \n \n \n9[(vii) has obtained National Tax Number10[; or] ] \n \n                                            \n1Clause (b) substituted by the Finance Act, 2005. The substituted clause (b) read as follows:  \n(b) any person not covered by clause (a) or (ab) who – \n(i) has been charged to tax in respect of any of the four preceding tax years;  \n(ii) claims a loss carried forward under this Ordinance for a tax year;  \n(iii) owns immovable property, with a land area of two hundred and fifty square yards or more, \nlocated in areas falling in the limits of a Metropolitan/Municipal Corporation, a Cantonment \nBoard, or the Islamabad Capital Territory or owns any flat; \n(iv) owns a motor vehicle (other than a motor cycle) in Pakistan; \n(v) subscribes for a telephone including a mobile phone in Pakistan; \n(vi) has undertaken foreign travel in the tax year other than travel by a non-resident person or \nany travel for the purposes of the Haj, Umrah, or Ziarat; or \n(vii) is member of a club where the monthly subscription exceeds five hundred rupees or the \nadmission fee exceeds twenty-five thousand rupees. \n2The letters and word “(a) or (ab)” substituted by the Finance Act, 2006. \n3The words “two hundred and fifty” substituted by “five hundred” through Finance Act, 2019.  \n4Full stop substituted by the Finance Act, 2009. \n5Inserted by the Finance Act, 2009. \n6Inserted by the Finance Act, 2009. \n7Inserted by the Finance Act, 2009. \n8The word “and” omitted by the Finance Act, 2011. \n9Inserted by the Finance Act, 2009. \n10Full stop substituted by the Finance Act, 2011. \n\n\f\nChapter X – Procedure__________________________________ \n \n225 \n \n1[(viii)  is the holder of commercial or industrial connection of \nelectricity where the amount of annual bill exceeds rupees \n2[five hundred thousand] 3[; 4[ ] ] \n \n5[(ix)  \nis 6[a resident person] registered with any chamber of \ncommerce and industry or any trade or business association \nor any market committee or any professional body including \nPakistan Engineering Council, Pakistan Medical and Dental \nCouncil, Pakistan Bar Council or any Provincial Bar Council, \nInstitute of Chartered Accountants of Pakistan or Institute of \nCost and Management Accountants of Pakistan 7[; or] \n \n8[(x)    \n9[is a] resident person being an individual required to file foreign \nincome and assets statement under section 116A.] \n \n10[(c)  persons or classes of persons notified by the Board with the approval    \nof the Minister in-charge.] \n \n11[(1A) Every individual whose income under the head ‘Income from \nbusiness’ exceeds rupees three hundred thousand but does not exceed rupees \n12[four hundred thousand] in a tax year is also required to furnish return of income \nfrom the tax year.] \n \n13[(2) A return of income - \n \n                                            \n1Inserted by the Finance Act, 2011. \n2The words “one million” substituted by the Finance Act, 2013. \n3Full stop substituted by the Finance Act, 2013. \n4The word “or” omitted by the Finance Act, 2018. \n5Added by the Finance Act, 2013.  \n6The words “a resident person” inserted by the Finance Act, 2014. \n7Full stop substituted by the Finance Act, 2018. \n8Added by the Finance Act, 2018. \n9The word “every” substituted through Finance Act, 2020 dated 30th June, 2020 \n10 Clause (c) inserted by the Finance, Act 2021. \n11Inserted by the Finance Act, 2011. \n12The words “three hundred and fifty thousand” substituted by the Finance Act, 2013. \n13Sub-section (2) substituted by the Finance Act, 2003. The substituted sub-section (2) read as follows:  \n \n“(2) \nA return of income – \n(a) \nshall be in the prescribed form; \n(b) \nshall state the information required by the form, including a declaration of the \nrecords kept by the taxpayer; \n(c) \nin the case of a person carrying on a business, shall include an income \nstatement, balance sheet, and any other document as may be prescribed for \nthe tax year; and \n(d) \nshall be signed by the person or the person’s representative.” \n\n\f\nChapter X – Procedure__________________________________ \n \n226 \n \n(a)  \nshall be in the prescribed form and shall be accompanied by \nsuch annexures, statements or documents as may be \nprescribed 1[: \n \n \n \n \nProvided that the Board may prescribe different returns \nfor different classes of income or persons including persons \nsubject to final taxation;]  \n \n(b)  \nshall fully state all the relevant particulars or information as \nspecified in the form of return, including a declaration of the \nrecords kept by the taxpayer; 2[ ] \n \n(c)  \nshall be signed by the person, being an individual, or the \nperson’s representative where section 172 applies3[;] ] \n \n4[(d)  shall be accompanied with evidence of payment of due tax as \nper return of income; 5[ ] \n \n6[(e)  shall be accompanied with a wealth statement as required \nunder section 116 7[; and] \n8[(f)   shall be accompanied with a foreign income and assets \nstatement as required under section 116A.] \n \n9[(2A)  A return of income filed electronically on the web or any magnetic \nmedia or any other computer readable media as may be specified by the Board \nshall also be deemed to be a return for the purpose of sub-section (1); and the \nBoard may, by notification in the official Gazette, make rules for determining \neligibility of the data of such returns and e-intermediaries who will digitise the data \nof such returns and transmit the same electronically to the Income Tax Department \nunder their digital signatures10[and other matters relating to electronic filing of \nreturns, statements or documents, etc.]] \n \n \n(3) \nThe Commissioner may, by notice in writing, require a person, or a \nperson’s representative, as the case may be, to furnish a return of income by the \ndate specified in the notice for a period of less than twelve months, where - \n \n                                            \n1Proviso added through Finance Act, 2020 dated 30th June, 2020 \n2The word “and” omitted by the Finance Act, 2011. \n3Full stop substituted by the Finance Act, 2011. \n4Inserted by the Finance Act, 2011. \n5The word “and” omitted by the Finance Act, 2018. \n6Inserted by the Finance Act, 2011. \n7 Full stop substituted by the Finance Act, 2018. \n8 Added by the Finance Act 2018.  \n9Inserted by the Finance Act, 2005. \n10Inserted by the Finance Act, 2007. \n\n\f\nChapter X – Procedure__________________________________ \n \n227 \n \n(a) \nthe person has died; \n \n(b) \nthe person has become bankrupt or gone into liquidation; \n \n(c) \nthe person is about to leave Pakistan permanently; \n \n1[  ] \n \n(e) \nthe Commissioner otherwise considers it appropriate to require \nsuch a return to be furnished.  \n(4) \nSubject to sub-section (5), the Commissioner may, by notice in writing, \nrequire any person who, in the Commissioner’s opinion, is required to file a return \nof income under this section for a tax year 2[or assessment year] but who has failed \nto do so to furnish a return of income for that year within thirty days from the date \nof service of such notice or such longer 3[or shorter] period as may be specified in \nsuch notice or as the Commissioner may allow. \n \n \n(5) \nA notice under sub-section (4) may be issued 4[in respect of one or \nmore] 5[of the] last five completed tax years 6[or assessment years] 7[:] \n \n \n8[Provided that in case of a person who has not filed return for any \nof the last five completed tax years, notice under sub-section (4) may be \nissued in respect of one or more of the last ten completed tax years] 9[: \n \nProvided further that the time-limitation provided under this sub-\nsection shall not apply if the Commissioner is satisfied on the basis of \nreasons to be recorded in writing that a person who failed to furnish \nhis return has foreign income or owns foreign assets.] \n \n                                            \n1 Clause (d) omitted by the Finance Act, 2003. Earlier this was omitted by S.R.O. 633(I)/2002 dated \n14.09.2002 which stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from \n01.07.2003. The omitted clause (d) read as follows: \n“(d) the person is otherwise about to cease carrying on business in Pakistan; or “ \n2 Inserted by the Finance Act, 2003. \n3Inserted by the Finance Act, 2013. \n4 The words “only in respect of the” substituted by Finance Act, 2003. Earlier these were substituted by \nS.R.O. 633(I)/2002 dated 14.09.2002 which stands rescinded by SRO 608(I)/2003, dated \n24.06.2003 with effect from 01.07.2003. \n5Inserted by the Finance Act, 2005. \n6Inserted by the Finance Act, 2004. \n7Full stop substituted by the Finance Act, 2016. \n8 Added by the Finance Act, 2016. \n9 Added by the Finance Act, 2021. \n\n\f\nChapter X – Procedure__________________________________ \n \n228 \n \n  \n1[(6)  Subject to sub-section (6A), any person who, having furnished a \nreturn, discovers any omission or wrong statement therein, may file revised return \nsubject to the following conditions, namely: — \n \n(a) \nit is accompanied by the revised accounts or revised audited \naccounts, as the case may be [:] 2[  ] \n \n3[Provided that Commissioner may waive this condition if the \nCommissioner is satisfied that filing of revised accounts or audited \naccounts is not necessary;] \n \n(b) \nthe reasons for revision of return, in writing, duly signed, by the \ntaxpayers are filed with the return4[; 5[ ] ] \n \n6[(ba) it is accompanied by approval of the Commissioner in writing for \nrevision of return; and] \n \n7[(c)  taxable income declared is not less than and loss declared is not more \nthan income or loss, as the case may be, determined by an order \nissued under sections 121, 122, 122A, 8[ ] 129, 132, 133 or 221:- \n \nProvided that if any of the above conditions is not fulfilled, the \nreturn furnished shall be treated as an invalid return as if it had not \nbeen furnished] 9[:] \n \n                                            \n1 Sub-section (6) substituted by the Finance Act, 2010. The substituted provision has been made effective \nfrom 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \nmade through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. The substituted sub-section \n(6) read as follows: \n \n“(6) Subject to sub-section (6A), any person who, having furnished a return, discovers any omission or \nwrong statement therein, may file revised return subject to the following conditions, namely:- \n(a) \nit is accompanied by the revised accounts or revised audited accounts, as the case may \nbe; and \n(b) \nthe reasons for revision of return, in writing, duly signed, by the taxpayers are filed with \nthe return.” \n2The word “and” omitted by the Finance Act, 2012. \n3 Added by the Finance Act, 2021. \n4Substituted by the Finance Act, 2012. \n5The word “and” omitted by the Finance Act, 2013. \n6Inserted by the Finance Act, 2013. \n7Added by the Finance Act, 2012. \n8The expression “122C,” omitted by the Finance Act, 2017. \n9 Substituted by Finance Act, 2015. \n\n\f\nChapter X – Procedure__________________________________ \n \n229 \n \n1[Provided further that the condition specified in clause (ba) \nshall not apply if revised return is filed within sixty days of filing of \nreturn: \n \nProvided also that where the Commissioner has not made an \norder of approval in writing, for revision of return, before the expiration \nof sixty days from the date when the revision of return was sought, the \napproval required under clause (ba) shall be deemed to have been \ngranted by the Commissioner, and condition specified in clause (ba) \nshall not apply: \n \n2[Provided also that condition specified in clause (ba) shall not \napply and the approval required thereunder shall be deemed to have \nbeen granted by the Commissioner, if- \n \n(a) \nthe Commissioner has not made an order of approval in \nwriting, for revision of return, before the expiration of sixty days from \nthe date when the revision of return was sought; or \n \n(b) \ntaxable income declared is more than or the loss declared \nis less than the income or loss, as the case may be, determined under \nsection 120] 3[: \n \n“Provided also that the Commissioner shall grant approval in \ncase of a bonafide omission or wrong statement.] \n \n4[(6A) If a taxpayer 5[files]  a revised return voluntarily along with deposit of \nthe amount of tax short paid or amount of tax sought to be evaded along with the \ndefault surcharge, whenever it comes to his notice, before receipt of notice under \nsections 177 or sub-section(9) of 122, no penalty shall be recovered from him: \n \nProvided that in case the taxpayer 6[deposits] the amount of tax as \npointed out by the Commissioner during the audit or before the issuance of \nnotice under sub-section (9) of section 122, he shall deposit the amount of \ntax sought to be evaded, the default surcharge and twenty-five per cent of \nthe penalties leviable under the Ordinance along with the revised return: \n \n                                            \n1Added by Finance Act, 2015. \n2 Proviso substituted by the Finance Act, 2016. Substituted proviso reads as follows:- \n“ Provided further that the mode and manner for seeking the revision shall be as prescribed by the Board.” \n3 Proviso added through Finance Act, 2020 \n4 Added by the Finance Act, 2010. \n5The words “wishes to file” substituted by the Finance Act, 2011. \n6The words “wishes to deposit” substituted by the Finance Act, 2011. \n\n\f\nChapter X – Procedure__________________________________ \n \n230 \n \nProvided further that in case the taxpayer 1[revises] the return after \nthe issuance of a show cause notice under sub-section (9) of section 122, \nhe shall deposit the amount of tax sought to be evaded, default surcharge \nand fifty per cent of the leviable penalties under the Ordinance along with \nthe revised return and thereafter, the show cause notice shall stand abated.] \n \n \n(7) \nEvery return purporting to be made or signed by, or on behalf of a \nperson shall be treated as having been duly made by the person or with the \nperson’s authority until the person proves the contrary. \n2[   ]  \n 3[114A. Business bank account.— (1) Every taxpayer shall declare to the \nCommissioner the bank account utilized by the taxpayer for business transactions.  \n  \n(2)  Business bank account shall be declared through original or modified \nregistration form prescribed under section 181.] \n                                            \n1 The words “wishes to revise” substituted by the Finance Act, 2011. \n2New section 114A added through Finance Act, 2020 dated 30th June, 2020 \n3 Section 114A substituted by the Finance Act, 2021. The substituted section read as follows: \n“114A. Taxpayer’s profile.-(1) Subject to this Ordinance, the following persons shall furnish a profile,  \nnamely:- \n(a) every person applying for registration under section 181; \n(b) every person deriving income chargeable to tax under the head, “Income from \nbusiness”; \n(c) every person whose income is subject to final taxation; \n(d) any non-profit organization as defined in clause (36) of section 2; \n(e) any trust or welfare institution; or \n(f) \nany other person prescribed by the Board. \n(2) \nA taxpayer’s profile- \n(a) \nshall be in the prescribed form and shall be accompanied by such annexures, \nstatements or documents as may be prescribed; \n(b) \nshall fully state, in the specified form and manner, the relevant particulars of – \n(i) \nbank accounts; \n(ii) \nutility connections; \n(iii) \nbusiness premises including all manufacturing, storage or retail outlets \noperated or leased by the taxpayer; \n(iv) \ntypes of businesses; and \n(v) \nsuch other information as may be prescribed; \n(c) \nshall be signed by the person being an individual, or the person’s representative \nwhere section 172 applies; and \n(d) \nshall be filed electronically on the web prescribed by the Board. \n \n(3) \nA taxpayer’s profile shall be furnished,- \n(a) \non or before the 31st day of December, 2020 in case of a person registered \nunder section 181 before the 30th day of September, 2020; and \n(b) \nwithin ninety days registration in case of a person not registered under section \n181 before the 30th day of September, 2020. \n(4) \nA taxpayer’s profile shall be updated within ninety days of change in any of the relevant \nparticulars of information as mentioned in clause (b) of sub-section (2).] \n\n\f\nChapter X – Procedure__________________________________ \n \n231 \n \n1[114B. Powers to enforce filing of returns.— (1) Notwithstanding anything \ncontained in any other law for the time being in force, the Board shall have the \npowers to issue income tax general order in respect of persons who are not \nappearing on active taxpayers’ list but are liable to file return under the provisions \nof the Ordinance. \n \n(2) The income tax general order issued under sub-section (1) may entail any \nor all of the following consequences for the persons mentioned therein, namely:– \n \n(a) disabling of mobile phones or mobile phone SIMS; \n(b) discontinuance of electricity connection; 2[  ]   \n(c) \ndiscontinuance of gas connection3[; or \n(d)  restriction on foreign travel from the country for a citizen of Pakistan, \nexcluding persons holding National Identity Card for Overseas \nPakistanis (NICOP), minors, students, persons proceeding abroad for \nHajj or Umrah and such other classes of persons as notified by the \nBoard.] \n  \n(3) The Board or the Commissioner having jurisdiction over the person \nmentioned in the income tax general order may order restoration of mobile phones, \nmobile phone SIMS and connections of electricity and gas, in cases where he is \nsatisfied that —  \n \n(a) the return has been filed; or  \n(b) person was not liable to file return under the provisions of the \nOrdinance.  \n(4) No person shall be included in the general order under sub-section (1) \nunless following conditions have been met with, namely:– \n  \n(a) notice under sub-section (4) of section 114 has been issued; \n(b) date of compliance of the notice under sub-section (4) of section 114 \nhas elapsed; and  \n(c) \nthe person has not filed the return. \n  \n(5) \nThe action under this section shall not preclude any other action \nprovided under the provisions of the Ordinance.] \n \n4[114C. Restriction on economic transactions by certain persons. — (1) \nNotwithstanding anything contained in any law for the time being in force, —  \n                                            \n1 New section 114B added through Finance Act, 2022. \n2 The word “or” omitted by the Finance Act, 2024. \n3 Full stop substituted and clause (d) added by the Finance Act, 2024. \n4 Section 114C inserted by Finance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n232 \n \n(a) \nany application, by any ineligible person, for booking, purchase or \nregistration of a motor vehicle of the value exceeding the threshold given in \nFifteenth Schedule, shall not be accepted or processed by any manufacturer \nof a motor vehicle or vehicle registering authority of Excise and Taxation \nDepartment, as the case may be;  \n \n(b) \nany application or request by any ineligible person, to any authority \nresponsible for registering, recording or attesting transfer of any immovable \nproperty, of the value exceeding the threshold given in Fifteenth Schedule, \nshall not be accepted or processed by such authority;  \n \n(c) \nAny person authorized to open and maintain an account in respect of \nsecurities, units of mutual fund or similar investment, shall not open an \naccount or maintain such account if the total investment by an ineligible \nperson in any such account exceeds the threshold specified in Fifteenth \nSchedule; and  \n \n(d) \na banking company shall not allow cash withdrawal from any of the bank \naccount of any person, exceeding the threshold as specified in Fifteenth \nSchedule.  \n \n(2) \nThe provisions of sub-section (1), shall not apply on transactions \nmade by a non-resident person or a public company except that mentioned in \nclause (d) of sub-section (1).  \n \n(3) \nThe sources of investment and expenditure statement filed by the \nperson and sufficient resources mentioned in sub-section (5), shall not be \nconstrued as nature and source of income for the purposes of section 111.  \n \n(4) \nFor the purposes of this section, –  \n \n(a) \n“eligible person” shall mean a person who has filed –  \n \n(i) \na return of income for the tax year immediately preceding \nthe year of transaction mentioned in sub-section (1) and \nhas sufficient resources in the wealth statement in case \nof an individual, or financial statement in case of a \ncompany or an association of persons, as the case may \nbe, for such transaction; or  \n \n(ii) \nsources of investment and expenditure statement \ndeclaring sufficient resources and furnishing explanation \nthereof for a particular purchase or investment \ntransaction covered in clauses (a), (b) and (c) of sub-\nsection (1):  \n\n\f\nChapter X – Procedure__________________________________ \n \n233 \n \nProvided that in case of an individual, the eligible person \nshall include his immediate family members.;  \n \n(b)  “immediate family members” in respect of an individual, shall \ninclude his parents, spouse and dependent children;  \n \n(c) \n“ineligible person” shall mean a person who is not an eligible \nperson as defined in clause (a) of this sub-section;  \n \n(d) \n“sources of investment and expenditure statement” shall mean \na declaration by a person filed on the Board‘s web portal, \nspecifying the sources of funds for making such transaction; \nand  \n \n(e) \n”sufficient resources” shall mean one hundred and thirty percent \nof the cash and equivalent assets comprising cash \ndenominated in local or foreign currency, fair market value of \ngold, net realizable value of stocks, bonds, receivables or any \nother cash equivalent asset as may be prescribed, declared by \na person either in his sources of investment and expenditure \nstatement, or wealth statement filed for the latest tax year and \nin the case of a company or association of persons, cash and \nequivalent assets, declared in the financial statements attached \nwith the income tax return for the latest tax year:  \n \nProvided that where an asset mentioned in sub-section \n(1), other than clause (d) of this sub-section, has been \npurchased by way of exchange of capital assets already \ndeclared in the wealth statement, or financial statement, or \nsources of investment and expenditure statement, the disposal \nof such capital assets shall be treated to be part of cash \nequivalent assets to the extent of the value mentioned in the \nagreement.  \n \n(5) \nAll or any of the restrictions or limitations imposed on the ineligible \nperson under this section shall come into force on such date as the Federal \nGovernment may, by notification in official Gazette, appoint with such reductions \nand enhancements in the thresholds specified in the Fifteenth Schedule as \ndeemed appropriate.] \n115. Persons not required to furnish a return of income. —1[  ] \n                                            \n1Sub-section (1) and the proviso there under omitted by the Finance Act, 2013. The omitted sub-\nsection (1) and the proviso read as follows:  \n \n“(1) Where the entire income of a taxpayer in a tax year consists of income chargeable under \nthe head “Salary”, Annual Statement of Deduction of Income Tax from Salary, filed by the employer \n\n\f\nChapter X – Procedure__________________________________ \n \n234 \n \n1[   ] \n \n \n(3) \nThe following persons shall not be required to furnish a return of \nincome for a tax year solely by reason of 2[sub-clause (iii)3[, (iv),(v) and (vi)]] of \nclause (b) of sub-section (1) of section 114 – \n \n \n(a) \nA widow; \n \n(b) \nan orphan below the age of twenty-five years; \n \n(c) \na disabled person; or \n \n(d) \nin the case of ownership of immovable property, a non-resident \nperson. \n \n \n \n4[  ] \n \n \n5[  ] \n \n6[  ] \n \n7[  ] \n                                            \nof such taxpayer, in prescribed form, the same shall, for the purposes of this Ordinance, be treated \nas a return of income furnished by the taxpayer under section 114: \nProvided that where salary income, for the tax year is five hundred thousand \nrupees or more, the taxpayer shall file return of income electronically in the prescribed \nform and it shall be accompanied by the proof of deduction or payment of tax and wealth \nstatement as required under section 116.” \n1 Sub-section (2) omitted by the Finance Act, 2004. Omitted sub-section (2) read as follows:  \n \n \n“(2) \nClause (b) of sub-section (1) shall not apply to a person whose declared income for the \ntax year, or whose last declared or assessed income, is less than two hundred thousand rupees.” \n2The words, brackets and figures “sub-clauses (iii) through (vii)” substituted by the Finance Act, 2008. \n3Inserted by the Finance Act, 2017 \n4Sub-section (4) omitted by Finance Act, 2020. The omitted sub-section  (4) read as follows:  \n (4)  Any person who is not obliged to furnish a return for a tax year because all the person’s income is subject \nto final taxation under sections 5, 6, 7, 148, 151 and 152, sub-section (3) of section 153, sections 154, 156 \nand 156A, sub-section (3) of section 233 or sub-section (3) of section 234A shall furnish to the Commissioner \na statement showing such particulars relating to the person’s income for the tax year in such form and verified \nin such manner as may be prescribed. \n5Sub-section(4A) omitted through Finance Act, 2020. The omitted sub-section (4A) read as follows: \n(4A)  Any person who, having furnished a statement, discovers any omission or wrong statement \ntherein, he may, without prejudice to any other liability which he may incur under this Ordinance, \nfurnish a revised statement for that tax year, at any time within five years from the end of the \nfinancial year in which the original statement was furnished. \n6 Sub-section (4B) omitted by the Finance Act, 2010. The omitted sub-section (4B) read as follows: \n \n \n “(4B)  Every person (other than a company) filing statement under sub-section (4), falling \nunder final tax regime (FTR) and has paid tax amounting to twenty thousand rupees or more for the \ntax year, shall file a wealth statement along with reconciliation of wealth statement.” \n7Sub section (5) and (6) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted sub-\nsections read as follows: \n \n \n \n \n\n\f\nChapter X – Procedure__________________________________ \n \n235 \n \n116. Wealth statement.— (1)  1[The] Commissioner may, by notice in writing, \nrequire any person 2[being an individual] to furnish, on the date specified in the \nnotice, a statement (hereinafter referred to as the \"wealth statement\") in the \nprescribed form and verified in the prescribed manner giving particulars of — \n \n(a) \nthe person’s total assets and liabilities 3[assets including foreign \nassets and liabilities including foreign liabilities] as on the date or dates \nspecified in such notice; \n(b) \nthe total assets and liabilities 4[assets including foreign assets and \nliabilities including foreign liabilities] of the person’s spouse, minor \nchildren, and other dependents as on the date or dates specified in \nsuch notice; \n5[Explanation. – For removal of doubt, it is clarified that assets of spouse \nshall only be included in the wealth statement of the person if the spouse is \ndependent;] \n \n(c) \nany assets 6[including foreign assets] transferred by the person \nto any other person during the period or periods specified in \nsuch notice and the consideration for the transfer; 7[ ] \n \n(d) \nthe total expenditures incurred by the person, and the person’s \nspouse, minor children, and other dependents during the period \nor periods specified in the notice and the details of such \nexpenditures 8[; and] \n \n \n \n9[(e)  the reconciliation statement of wealth.] \n                                            \n \n \n \n(5)     Subject to sub-section (6), the Commissioner may, by notice in writing, require any person  who, \nin his opinion, is required to file a prescribed statement under this section for a tax year but who has failed to do so, \nto furnish a prescribed statement for that year within thirty days from the date of service of such notice or such longer \nperiod as may be specified in such notice or as he may, allow. \n(6)    A notice under sub-section (5) may be issued in respect of one or more of the last five \ncompleted tax years. \n1 The words, brackets, figure, comma and word “Subject to sub-section (2)”. The” substituted by the \nFinance Act, 2007. \n2 Inserted by the Finance Act, 2013. \n3 The words “assets and liabilities” substituted by the Finance Act, 2024. \n4 The words “assets and liabilities” substituted by the Finance Act, 2024. \n5 The words “assets and liabilities” substituted by the Finance Act, 2024. \n6 Words inserted by the Finance Act, 2024. \n7The word “and” omitted by the Finance Act, 2009. \n8Full stop substituted by the Finance Act, 2009. \n9Inserted by the Finance Act, 2009. \n\n\f\nChapter X – Procedure__________________________________ \n \n236 \n \n \n(2) \nEvery resident taxpayer1[being an individual] filing a return of income \nfor any tax year2[  ] shall furnish a wealth statement3[and wealth reconciliation \nstatement] for that year along with such return 4[:] \n \n5[Provided that every member of an association of persons 6[  ] \nshall also furnish wealth statement and wealth reconciliation statement \nfor the year along with return of income of the association.] \n \n7[8[  ]  ]  \n \n9[(3) Where a person, who has furnished a wealth statement, discovers any \nomission or wrong statement therein, he may, without prejudice to any liability \nincurred by him under any provision of this Ordinance, furnish a revised wealth \nstatement 10[along with the revised wealth reconciliation and the reasons for filing \nrevised wealth statement,] 11[under intimation to the Commissioner in the \nprescribed form and manner,]at any time before 12[the receipt of notice under sub-\nsection (9) of section 122, for the tax year to which it relates13[:] \n \n                                            \n1Inserted by the Finance Act, 2011. \n2The words and comma “whose last declared or assessed income or the declared income for the year, \nis one million rupees or more” omitted by the Finance Act, 2013. Note: This amendment shall be \neffective for the tax year 2013 and onwards. \n3Inserted by the Finance Act, 2009. \n4Full stop substituted by the Finance Act, 2011. \n5Inserted by the Finance Act, 2011. \n6The words and commas “ whose share from the income of such association of persons, before tax, \nfor the year is one million rupees or more” omitted by the Finance Act, 2013. Note: This amendment \nshall be effective for the tax year 2013 and onwards. \n7 Sub-section (2A) substituted by the Finance Act, 2011. The substituted sub-section (2A) read as \nfollows: \n“(2A) Where a person files a return in response to a provisional assessment under section \n122C, he shall furnish a wealth statement for that year along with that return and such wealth \nstatement shall be accompanied by a wealth reconciliation statement and an explanation of sources \nof acquisition of assets specified therein.” \n8Section (2A) omitted by Finance Act 2017,the omitted section is read as under \n“(2A)  “Where a person, being an individual or an association of persons, files a return in response to \na provisional assessment order under section 122C, such return shall be accompanied by wealth \nstatement along with a wealth reconciliation statement and an explanation of source of acquisition \nof assets specified therein in the case of an individual and wealth statements of all members in the \ncase of an association of persons and such wealth statements shall be accompanied by wealth \nreconciliation statements and explanation of source of acquisition of assets specified therein.” \n9Added by the Finance Act, 2003. \n \n10 Inserted by the Finance Act, 2013. \n11The expressions inserted through Finance Act, 2020 dated 30th June, 2020 \n12The expression “an assessment, for the tax year to which it relates, is made under sub-section (1) \nor sub-section (4) of section 122”substituted by the Finance Act, 2017. \n13Full stop substituted by colon and provision and explanation inserted through Finance Act, 2020 \ndated 30th June, 2020 \n\n\f\nChapter X – Procedure__________________________________ \n \n237 \n \n \nProvided that where the Commissioner is of the opinion that the revision \nunder this sub-section is not for the purpose of correcting a bona fide omission or \nwrong statement, he may declare such revision as void through an order in writing \nafter providing an opportunity of being heard. \n \n \nExplanation.- For the removal of doubt it is clarified that wealth statement \ncannot be revised after the expiry of five years from the due date of filing of return \nof income for that tax year.]  \n \n1[  ] \n \n2[116A.   Foreign income and assets statement.– (1) Every resident taxpayer \nbeing an individual having foreign income of not less than ten thousand United  \nStates dollars or having foreign assets with a value of  not less than one hundred \nthousand United States dollars shall furnish a statement, hereinafter referred to  as \nthe foreign income and assets statement, in the prescribed form and verified  in \nthe prescribed manner giving particulars of— \n \n(a) \nthe person’s total foreign assets and liabilities as on the last day of the \ntax year; \n \n(b) \nany foreign assets transferred by the person to any other person \nduring the tax year and the consideration for the said transfer; and \n \n(c) \ncomplete particulars of foreign income, the expenditure derived during \nthe tax year and the expenditure wholly and necessarily for the \npurposes of deriving the said income. \n \n(2) \nThe Commissioner may by a notice in writing require any person being \nan individual who, in the opinion of the Commissioner on the basis of  reasons to \nbe recorded in writing, was required to furnish a foreign income and assets \nstatement under sub-section (1) but who has failed to do so to furnish the foreign \nincome and assets statement on the date specified in the notice.] \n \n117. Notice of discontinued business.— (1) Any person discontinuing a \nbusiness shall give the Commissioner a notice in writing to that effect within fifteen \ndays of the discontinuance. \n \n \n(2) \nThe person discontinuing a business shall, under the provisions of this \nOrdinance or on being required by the Commissioner by notice, in writing, furnish \na return of income for the period commencing on the first day of the tax year in \nwhich the discontinuance occurred and ending on the date of discontinuance and \nthis period shall be treated as a separate tax year for the purposes of this \nOrdinance. \n                                            \n1 Sub section (4) omitted through Finance Act, 2020 dated 30th June 2020 omitted sub-section read \nas follows; \n(4) Every person (other than a company5 [or an association of persons])filing statement under \nsub-section (4) of section 115, falling under final tax regime (FTR) 6 [ ] shall file a wealth statement \nalong with reconciliation of wealth statement.] \n2 Inserted by the Finance Act 2018. \n\n\f\nChapter X – Procedure__________________________________ \n \n238 \n \n \n(3) \nWhere no notice has been given under sub-section (1) but the \nCommissioner has reasonable grounds to believe that a business has \ndiscontinued or is likely to discontinue, the Commissioner may serve a notice on \nthe person who has discontinued the business or is likely to discontinue the \nbusiness to furnish to the Commissioner within the time specified in the notice a \nreturn of income for the period specified in the notice. \n \n \n(4) \nA return furnished under this section shall be treated for all purposes \nof this Ordinance as a return of income, including the application of Section 120. \n \n118. Method of furnishing returns and other documents. — (1) A return of \nincome under section 114, 1[  ] 2[  ] 3[,] a wealth statement under section 116 4[or a \nforeign income and assets statement under 116A,  if applicable] shall be furnished \nin the prescribed manner. \n \n \n(2) \nA return of income 5[under section 114 6[  ] ] of a company shall be \nfurnished — \n \n(a) \nin the case of a company with a tax year ending any time \nbetween the first day of January and the thirtieth day of June, \non or before the thirty-first day of December next following the \nend of the tax year to which the return relates; or \n \n(b) \nin any other case, on or before the thirtieth day of September next \nfollowing the end of the tax year to which the return relates. \n7[(2A) Where salary income for the tax year is five hundred thousand rupees \nor more, the taxpayer shall file return of income electronically in the prescribed \nform and it shall be accompanied by the proof of deduction or payment of tax and \nwealth statement as required under section 116 8[or a foreign income and assets \nstatement under 116A, if applicable”] ] 9[:]  \n \n                                            \n1The words, figure and comma “an employer’s certificate under section 115,” omitted by the Finance \nAct, 2013.  \n2The expressions “ a statement required under sub-section (4) of section 115” omitted through \nFinance Act, 2020 dated 30th June, 2020 \n3The word ‘or” ssubstituted by Finance Act, 2018. \n4 Inserted by the Finance Act, 2018. \n5Inserted by the Finance Act, 2003. \n6 The expressions “or a statement required under sub-section (4) of section 115” omitted through \nFinance Act, 2020 dated 30th June, 2020 \n7Inserted by the Finance Act, 2013. \n8Added the Finance Act, 2018. \n9Substituted by Finance Act, 2015 \n\n\f\nChapter X – Procedure__________________________________ \n \n239 \n \n1[“Provided that the Board may amend the condition specified in this \nsub-section or direct that the said condition shall not apply for a tax year.”;] \n \n2[ *  ]  \n \n3[(3) A return of income for any person (other than a company) 4[  ] 5[  ] shall \nbe furnished as per the following schedule, namely:— \n \n6[(a)  in the case of 7[ ]  a return required to be filed through e-portal \nin the case of a salaried individual, on or before the 8[30th day of \nSeptember] next following the end of the tax year to which the \nstatement or return relates; or] \n \n(b) \nin the case of a return of income for any person (other than a \ncompany), as described under clause (a), on or before the 30th \nday of September next following the end of the tax year to which \nthe return relates.]  \n \n \n(4) \nA wealth statement shall be furnished by the due date specified in the \nnotice requiring the person to furnish such statement or, where the person is \nrequired to furnish the wealth statement for a tax year under sub-section (2) of \nsection 116, by the due date for furnishing the return of income for that year. \n \n                                            \n1Substituted by Finance Act, 2015 \n2Inserted by the S.R.O. 791(I)/2015 dated 10.08.2015. \n “ *Notification \nIn exercise of the powers conferred by the proviso to sub-section (2A) of section 118 of the Income Tax \nOrdinance, 2001 (XLIX of 2001), the Federal Government is pleased to direct that all individuals earning taxable \nsalary income shall be liable to file their Income Tax returns electronically from Tax Year 2015 onwards. The \ncondition of five hundred thousand rupees or more, as provided in the said sub-section shall not be applicable \nuntil further orders.”] \n3Sub-section (3) substituted by the Finance Act, 2010. The substituted sub-section (3) read as follows: \n“(3) \nA return of income for any person (other than a company), an employer certificate of an \nindividual or a statement required under sub-section (4) of section 115 shall be furnished on or before \nthe thirtieth day of September next following the end of the tax year to which the return, certificate or \nstatement relates.” \n4The words and comma “an Annual Statement of deduction of income tax from salary, filed by the \nemployer of an individual” omitted by the Finance Act, 2013.  \n5 The expressions “or a statement required under sub-section (4) of section 115” omitted through \nFinance Act, 2020 dated 30th June, 2020 \n6Clause (a) substituted by the Finance Act, 2013. The substituted clause (a) read as follows:  \n“(a)  \nin the case of an Annual statement of deduction of income tax from salary, filed by the \nemployer of an individual, return of income through e-portal in the case of a salaried \nperson or a statement required under sub-section (4) of section 115, on or before the \n31st day of August next following the end of the tax year to which the return, Annual \nStatement of deduction of income tax from salary, filed by the employer or statement \nrelates.” \n7 The expression “a statement required under sub-section (4) of section 115 or” omitted through \nFinance Act, 2020 dated 30th June, 2020 \n8The expression “31stday of August” substituted through Finance Act, 2019. \n\n\f\nChapter X – Procedure__________________________________ \n \n240 \n \n \n(5) \nA return required to be furnished by a notice issued under section 117 \nshall be furnished by the due date specified in the notice. \n \n \n(6) \nWhere a taxpayer is not borne on the National Tax Number Register \nand fails to file an application in the prescribed form and manner with the taxpayer’s \nreturn of income 1[  ], such return 2[  ] shall not be treated as a return  3[  ] furnished \nunder this section. \n \n119. Extension of time for furnishing returns and other documents.— (1)  A \nperson required to furnish — \n \n(a) \na return of income under section 114 or 117; \n \n \n \n4[  ] \n \n5[  ]  \n \n(d) \na wealth statement under section 116, \n \nmay apply, in writing, to the Commissioner for an extension of time to furnish the \nreturn, 6[  ] or statement, as the case may be. \n \n \n(2) \nAn application under sub-section (1) shall be made by the due date \nfor furnishing the return of income, 7[  ] or 8[  ] statement to which the application \nrelates. \n \n(3) \nWhere an application has been made under sub-section (1) and the \nCommissioner is satisfied that the applicant is unable to furnish the return of \nincome, 9[ ] or 10[ ] statement to which the application relates by the due date \nbecause of — \n \n(a) \nabsence from Pakistan;  \n(b) \nsickness or other misadventure; or \n(c) \nany other reasonable cause, \n                                            \n1The words “or employer’s certificate” omitted by the Finance Act, 2013. \n2The words “or certificate” omitted by the Finance Act, 2013. \n3The words “or certificate” omitted by the Finance Act, 2013. \n4 Clause (b) omitted by the Finance Act, 2013. The omitted clause (b) read as follows: \n“(b) \nan employer’s certificate under section 115;” \n5 Clause (c) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted clause read as \nfollows:” (c) a statement required under sub-section (4) of section 115; or”. \n6The word and comma “certificate,” omitted by the Finance Act, 2013. \n7The words and comma “employer’s certificate,” omitted by the Finance Act, 2013.  \n8The word “wealth” omitted by the Finance Act, 2002 \n9The words and comma “employer’s certificate,” omitted by the Finance Act, 2013.  \n10 The word “wealth” omitted by the Finance Act, 2002 \n\n\f\nChapter X – Procedure__________________________________ \n \n241 \n \nthe Commissioner may, by 1[order], in writing, grant the applicant an extension of \ntime for furnishing the return, 2[  ] or statement, as the case may be. \n \n \n(4) \nAn extension of time under sub-section (3) should not exceed fifteen \ndays from the due date for furnishing the return of income, employer’s certificate, \nor 3[ ] statement, as the case may be, unless there are exceptional circumstances \njustifying a longer extension of time4[:] \n \n5[Provided that where the Commissioner has not granted extension for \nfurnishing return under sub-section (3) or sub-section (4), the Chief Commissioner \nmay on an application made by the taxpayer for extension or further extension, as \nthe case may be, grant extension or further extension for a period not exceeding \nfifteen days unless there are exceptional circumstances justifying a longer \nextension of time.] \n \n \n6[  ] \n \n(6) \nAn extension of time granted under sub-section (3) shall not 7[, for the \npurpose of charge of 8[default surcharge]under sub-section (1) of section \n205,]change the due date for payment of income tax under section 137. \n \n \n \n \n \n \n \n \n \n \n \n                                            \n1 Substituted for the word “notice” by the Finance Act, 2002 \n2The word and comma “certificate,” omitted by the Finance Act, 2013. \n3The word “wealth” omitted by the Finance Ordinance, 2002 \n4Full stop substituted by the Finance Act, 2017. \n5Added by the Finance Act, 2017. \n6Sub-section (5) omitted by the Finance Act, 2002. The omitted sub-section (5) read as follows: \n“(5)  \nAn applicant dissatisfied with a decision under sub-section (3) may challenge the \ndecision only under the Part III of this Chapter.” \n7 Inserted by the Finance Act, 2002 \n8The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010.  \n\n\f\nChapter X – Procedure__________________________________ \n \n242 \n \nPART II \nASSESSMENTS \n1[120. Assessments.—(1) Where a taxpayer has furnished a complete return of \nincome (other than a revised return under sub-section (6) of section 114) for a tax \nyear ending on or after the 1st day of July, 2002,— \n \n(a)  \nthe Commissioner shall be taken to have made an assessment of \ntaxable income for that tax year, and the tax due thereon 2[equal to \nthe respective amounts adjusted under sub-section (2A)] 3[  ] ; and  \n \n(b)  \nthe return shall be taken for all purposes of this Ordinance to be an \nassessment order issued to the taxpayer by the Commissioner on the \nday the 4[adjustments were made under sub-section (2A)] 5[  ] 6[return \nwas furnished] 7[: \n \n \n \nProvided that until the date specified under the fourth proviso to \nsub-section (2A) is notified, this subsection shall be in force as if sub-\nsection (2A) is not in operation: \n \nProvided further that once the date under the fourth proviso to \nsub-section (2A) is notified, clauses (a) and (b) shall only apply when \nthe provisions of sub-section (2A), if invoked, are first complied with: \n \nProvided further once compliance is made under the second \nproviso,—  \n \n(i) \nthe adjusted amount under sub-section (2A) shall be construed \nto be the tax payable and due under clause (a); and  \n                                            \n1 Section 120 substituted by the Finance Act, 2003. The substituted section 120 read as follows:  \n“120. Assessments.- Where a taxpayer has furnished a return of income (other than a revised return \nunder sub-section (6) of section 114) for a tax year ending on or after the 1st day of July, 2002, – \n(a) \nthe Commissioner shall be taken to have made an assessment of the taxable \nincome of the taxpayer for the year and the tax due thereon, equal to those \nrespective amounts specified in the return; and \n(b) \nthe taxpayer’s return shall be taken for all purposes of this Ordinance to be an \nassessment order issued to the taxpayer by the Commissioner on the day the \nreturn was furnished.” \n2 The expression inserted by the Finance Act, 2025. \n3 The expression “, equal to the respective amounts adjusted under sub-section (2A)” omitted by the \nFinance Act, 2021. Earlier this omission was made through Income Tax (Amendment) Ordinance, \n2021. \n4 The expression inserted by the Finance Act, 2025. \n5 The expressions “return was furnished” substituted through Finance Act, 2020 \n6 The expression “adjustments were made under sub-section (2A)” substituted by the Finance Act, \n2021. ” substituted by the Finance Act, 2021. Earlier the substitution was made through Income Tax \n(Amendment) Ordinance, 2021. \n7 Full stop substituted and provisos added by the Finance Act, 2021. Earlier the substitution and \naddition was made through Income Tax (Amendment) Ordinance, 2021. \n \n\n\f\nChapter X – Procedure__________________________________ \n \n243 \n \n  \n(ii) \nthe date of the compliance under sub-section (2A) shall be the \ndate for the purposes of clause (b).] \n \n1[(1A) Notwithstanding the provisions of sub-section (1), the Commissioner \nmay 2[conduct audit of the income tax affairs of a person] under section 177 and \nall the provisions of that section shall apply accordingly.] \n \n \n(2)  \nA return of income shall be taken to be complete if it is in accordance \nwith the provisions of sub-section (2) of section 114. \n \n \n3[(2A) A return of income furnished under sub-section (2) of section 114 shall \nbe processed through automated system to arrive at correct amounts of total \nincome, taxable income and tax payable by making adjustments for-  \n \n \n(i) \nany arithmetical error in the return; \n \n(ii) \nany incorrect claim, if such incorrect claim is apparent from any \ninformation in the return; \n \n(iii) \ndisallowance of any loss, deductible allowance or tax credit under \nParts VIII, IX and X respectively of Chapter III; and \n \n(iv) \ndisallowance of carry forward of any loss under clause (b) of sub-\nsection (I)of section 182A:  \n \n \n \nProvided that no such adjustments shall be made unless a \nsystem generated notice is given to the taxpayer specifying the \nadjustments intended to be made: \n \n \n \n \nProvided further that the response received from the taxpayer, \nif any, shall be considered before making any adjustment, and in a \ncase where no response is received within thirty days of the issue of \nsuch notice, adjustments shall be made. \n \n \n \nProvided also that where no such adjustments have been made \nwithin six month of filing of return, the amounts specified in the return \nas declared by the taxpayer shall be deemed to have been taken as \n                                            \n1 Inserted by the Finance Act, 2005. \n2The words “select a person for an audit of his income tax affairs” substituted by the Finance Act, 2010. \nThe substituted provision has been made effective from 05.06.2010 by sub-clause (77) of clause 8 \nof the Finance Act, 2010. Earlier the substitution was made through Finance (Amendment) \nOrdinance, 2009 which was re-promulgated as Finance (Amendment) Ordinance, 2010 and \nremained effective till 05.06.2010. \n3New sub-section (2A) inserted through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nChapter X – Procedure__________________________________ \n \n244 \n \nadjusted amounts on the day the return was filed and the taxpayer \nshall be intimated automatically through Iris] 1[: \n \n \n \nProvided also that the provisions of this sub-section shall apply \nfrom the date notified by the Federal Board of Revenue in the official \nGazette.]  \n \n \n \n(3)  \nWhere the return of income furnished is not complete, the \nCommissioner shall issue a notice to the taxpayer informing him of the deficiencies \n(other than incorrect amount of tax payable on taxable income, as specified in the \nreturn, or short payment of tax payable) and directing him to provide such \ninformation, particulars, statement or documents by such date specified in the \nnotice. \n \n \n(4)  \nWhere a taxpayer fails to fully comply, by the due date, with the \nrequirements of the notice under sub-section (3), the return furnished shall be \ntreated as an invalid return as if it had not been furnished. \n \n \n(5)  \nWhere, in response to a notice under sub-section (3), the taxpayer \nhas, by the due date, fully complied with the requirements of the notice, the return \nfurnished shall be treated to be complete on the day it was furnished and the \nprovisions of sub-section (1) shall apply accordingly. \n \n \n(6)  \nNo notice under sub-section (3) shall be issued after the 2[expiry of \none hundred and eighty days from the end of the financial year in which return was \nfurnished], and the provisions of sub-section (1) shall apply accordingly.]  \n \n \n3[(7) For the purposes of this section,- \n \n(a) \n“arithmetical error” includes any wrong or incorrect calculation \nof tax payable including any minimum or final tax payable. \n \n(b) \n“an incorrect claim apparent from any information in the return” \nshall mean a claim, on the basis of an entry, in the return,- \n \n(i) \nof an item, which is inconsistent with another entry of the \nsame or some other item in such return; \n(ii) \nregarding any tax payment which is not verified from the \ncollection system; or \n(iii) \nin respect of a deduction, where such deduction exceeds \nspecified statutory limit which may have been expressed \nas monetary amount or percentage or ratio or fraction.] \n                                            \n1 Full stop substituted and proviso added by the Finance Act, 2021. Earlier the substitution and   \naddition was made through Income Tax (Amendment) Ordinance, 2021. \n2The words “end of the financial year in which return was furnished”  the Finance Act, 2012. \n3 New sub-section 7 added through Finance Act, 2020 \n\n\f\nChapter X – Procedure__________________________________ \n \n245 \n \n1[  ]  \n \n2[120B. Restriction of proceedings.- (1) Where any person entitled to declare \nundisclosed assets, expenditure and undisclosed sales under the Assets \nDeclaration Act, 2019 declares such assets, expenditures or sales to pay tax, no \nproceedings shall be undertaken under this Ordinance in respect of such \ndeclaration. \n \n \n(2) \nNotwithstanding anything contained in any other law, for the time \nbeing in force, sub-section (3) of section 216, except the provisions of clauses (a) \nand (g) of sub-section (3) of section 216, particulars of the persons making \ndeclaration under the Assets Declaration Act, 2019 or any information received in \nany declaration made under the said Act shall be confidential.] \n \n3[121. Best judgement assessment.— (1) Where a person fails to — \n                                            \n1 Section 120A omitted by the Finance Act, 2013. The omitted section 120A read as follows:  \n“120A.Investment Tax on income.—  (1) Subject to this Ordinance, the Board may make a scheme \nof payment of investment tax in respect of undisclosed income, representing any amount or \ninvestment made in movable or immovable assets. \n  \n(2)  Where any person declares undisclosed income under sub-section (1) in accordance with \nthe scheme and the rules, the tax on such income called investment tax shall be charged at such rate \nas may be prescribed. \n  \n(3)  Where a person has paid tax on his undisclosed income in accordance with the scheme \nand the rules, he shall –  \n(a) be entitled to incorporate in his books of account such undisclosed income in tangible form; \nand \n(b) not be liable to pay any tax, charge, levy, penalty or prosecution in respect of such income \nunder this Ordinance. \n(4)  For the purposes of this section — \n(i) \n“undisclosed income” means any income, including any investment to be deemed \nas income under section 111 or any other deemed income, for any year or years, \nwhich was chargeable to tax but was not so charged; and \n(ii) \n“investment tax” means tax chargeable on the undisclosed income under the \nscheme under sub-section (1) and shall have the same meaning as given in clause \n(63) of section 2 of the Income Tax Ordinance, 2001.” \n2New Section (120B) inserted though Finance Act, 2019. \n3Section 121 substituted by the Finance Act, 2003. The substituted section 121 read as follows: \n“121. \nAssessment of persons who have not furnished a return.- (1)  Where a person \nrequired by the Commissioner through a notice] to furnish a return of income for a tax year fails to \ndo so by the due date, the Commissioner may, based on any available information and to the best \nof the Commissioner’s judgement, make an assessment of the taxable income of the person and \nthe tax due thereon for the year.  \n(2) \nAs soon as possible after making an assessment under this section, the Commissioner \nshall issue, in writing, an assessment order to the taxpayer stating – \n(a) \nthe taxable income of the taxpayer for the year; \n(b) \nthe amount of tax due; \n(c) \nthe amount of tax paid, if any; and \n(d) \nthe time, place, and manner of appealing the assessment order. \n(3) \nAn assessment order shall only be issued within five years after the end of the tax year, \nor the income year, to which it relates.” \n\n\f\nChapter X – Procedure__________________________________ \n \n246 \n \n1[ ] \n \n2[  ] \n \n3[(ab) furnish return of income in response to notice under sub- \nsection (3) or sub-section (4) of section 114; or”;]  \n \n4[(ac) furnish return of income in response to notice under sub-section \n(3) of section 117; or] \n \n(b)  \nfurnish a return as required under section 143 or section 144; \nor \n \n \n \n(c)  \nfurnish the statement as required under section 116; or  \n \n(d)  \nproduce before the Commissioner, or 5[a special audit panel \nappointed under sub-section (11) of section 177 or]any person \nemployed by a firm of chartered accountants 6[or a firm of cost \nand management accountants] under section 177, accounts, \ndocuments and records required to be maintained under section \n174, or any other relevant document or evidence that may be \nrequired by him for the purpose of making assessment of \nincome and determination of tax due thereon, \n \nthe Commissioner may, based on any available information or material and to the \nbest of his judgement, make an assessment of the taxable income 7[or income] of \nthe person and the tax due thereon 8[and the assessment, if any, treated to have \nbeen made on the basis of return or revised return filed by the taxpayer shall be of \nno legal effect]. \n \n                                            \n1Omitted by the Finance Act, 2010. The omitted clause (a) read as follows: \n“(a)  furnish a return of income as required by a notice under sub-section (3) or sub-section (4) \nof section 114; or  \n2Clause “(aa)” omitted through Finance Act, 2020 dated 30th June, 2020 the omitted clause read as \nfollows: “(aa)  furnish a statement as required by a notice under sub-section (5) of section 115; or” \n3Inserted by the Finance Act, 2017. \n4 Clause (ac) inserted by the Finance Act, 2024. \n5Inserted by the Finance Act, 2015 \n6 Inserted by the Finance Act, 2010. \n7Inserted by the Finance Act, 2010.  \n8Inserted by the Finance Act, 2012. \n\n\f\nChapter X – Procedure__________________________________ \n \n247 \n \n \n1[(1A) For the purposes of making a best judgment assessment under sub-\nsection (1), the Commissioner may determine taxable income on the basis of \nsectoral benchmark ratios prescribed by the Board.  \n \nExplanation.- The expression “sectoral benchmark ratios” means standard \nbusiness sector ratios notified by the Board on the basis of comparative cases and \nincludes financial ratios, 102 production ratios, gross profit ratio, net profit ratio, \nrecovery ratio, wastage ratio and such other ratios in respect of such sectors as \nmay be prescribed.] \n \n \n(2)  \nAs soon as possible after making an assessment under this section, \nthe Commissioner shall issue the assessment order to the taxpayer stating— \n \n \n \n(a)  \nthe taxable income; \n \n \n(b)  \nthe amount of tax due; \n \n \n(c)  \nthe amount of tax paid, if any; and  \n(d)  \nthe time, place and manner of appealing the assessment order. \n \n \n(3)  \nAn assessment order under this section shall only be issued within      \n2[six] years after the end of the tax year or the income year to which it relates 3[:] \n \n4[Provided that where notice for furnishing a return of income under \nsub-section (4) of section 114 is issued in respect of one or more of the last \nten completed tax years in pursuance of proviso to sub-section (5) of section \n114 an assessment order under this section shall only be issued  within two \nyears from the end of tax year in which such notice is issued.] \n \n122. Amendment of assessments.— (1) Subject to this section, the \nCommissioner may amend an assessment order treated as issued under section \n120 or issued under section 1215[, 6[ ] 7[or 8[ ], by making such alterations or \nadditions as the Commissioner considers necessary 9[  ].  \n \n                                            \n1 Sub-section (1A) inserted by the Finance Act, 2024. \n2 The word “five” substituted by the Finance Act, 2022. \n3Full stop substituted by the Finance Act 2018. \n4Added by the Finance Act, 2018. \n5 Inserted by the Finance Act, 2012. \n6The expression “or issued under section 122C,”omitted by the Finance Act, 2017 \n7 Inserted by the Finance Act, 2002 \n8The words, commas and the figures “issued under section 59, 59A, 62, 63 or 65 of the repealed \nOrdinance “  omitted by the Finance Act, 2012. \n9The words “to ensure that the taxpayer is liable for correct amount of tax for the tax year to which the \nassessment order relates” omitted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n248 \n \n \n1[(2)  No order under sub-section (1) shall be amended by the \nCommissioner after the expiry of five years from the end of the financial year in \nwhich the Commissioner has issued or treated to have issued the assessment \norder to the taxpayer.] \n \n \n(3) \nWhere a taxpayer furnishes a revised return under sub-section (6) \n2[or (6A)] of section 114 — \n \n(a) \nthe Commissioner shall be treated as having made an amended \nassessment of the taxable income and tax payable thereon as \nset out in the revised return; and \n \n(b) \nthe taxpayer’s revised return shall be taken for all purposes of \nthis Ordinance to be an amended assessment order issued to \nthe taxpayer by the Commissioner on the day on which the \nrevised return was furnished. \n \n \n(4) \nWhere an assessment order (hereinafter referred to as the “original \nassessment”) has been amended under sub-section (1) 3[,] (3) 4[or (5A)], the \nCommissioner may further amend,5[as many times as may be necessary,] the \noriginal assessment within the later of — \n \n(a) \nfive years 6[from the end of the financial year in which] the \nCommissioner has issued or is treated as having issued the \noriginal assessment order to the taxpayer; or \n \n(b) \none year 7[from the end of the financial year in which] the \nCommissioner has issued or is treated as having issued the \namended assessment order to the taxpayer. \n \n                                            \n1Sub-section (2) substituted by the Finance Act, 2009. The substituted sub-section (2) read as \nfollows: \n“(2) An assessment order shall only be amended under subsection (1) within five years after the \nCommissioner has issued or is treated as having issued the assessment order on the taxpayer.” \n2 Substituted by the Finance Act, 2010. The substituted provision has been made effective from \n05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \nmade through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n3The word “or” substituted by the Finance Act, 2010. \n4 Inserted by the Finance Act, 2010. Amendment made in sub-section (4) has been validated through \nsub-clause (18)(b) of clause (8) of Finance Act, 2010, with effect from the first day of July, 2003. \n5Inserted by the Finance Act, 2002 \n6The word “after” substituted by the Finance Act, 2009. \n7The word “after” substituted by the Finance Act, 2009. \n\n\f\nChapter X – Procedure__________________________________ \n \n249 \n \n1[(4A) In respect of an assessment made under the repealed Ordinance, \nnothing contained in sub-section (2) or, as the case may be, sub-section (4) shall \nbe so construed as to have extended or curtailed the time limit specified in section \n65 of the aforesaid Ordinance in respect of an assessment order passed under \nthat section and the time-limit specified in that section shall apply accordingly.] \n \n2[(5) An assessment order in respect of tax year, or an assessment year, \nshall only be amended under sub-section (1) and an amended assessment for that \nyear shall only be further amended under sub-section (4) where, on the basis of \n3[audit or on the basis of definite information] the Commissioner is satisfied that — \n(i)  \nany income chargeable to tax has escaped assessment; or \n \n(ii)  \ntotal income has been under-assessed, or assessed at too low \na rate, or has been the subject of excessive relief or refund; or  \n \n(iii)  \nany amount under a head of income has been mis-classified.] \n \n4[(5A) Subject to sub-section (9), the Commissioner may 5[, ] 6[  ] amend, or \nfurther amend, an assessment order, if he considers that the assessment order is \nerroneous in so far it is prejudicial to the interest of revenue.] \n \n                                            \n1Inserted by the Finance Act, 2003. Earlier sub-section (4A) was inserted by S.R.O. 633(I)/2002, dated \n14.09.2002 which stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from \n01.07.2003. The said sub-section (4A) read as follows: \n      “(4A)  \nAn amended assessment shall only be made within six years of the date of original \nassessment.” \n2 Sub-section (5) substituted by the Finance Act, 2003. The substituted sub-section (5) read as follows:  \n“(5) \nAn assessment order shall only be amended under sub-section (1) and an amended \nassessment shall only be amended under subsection (4) where the Commissioner – \n(a) is of the view that this Ordinance or the repealed Ordinance] has been incorrectly \napplied in making the assessment (including the misclassification  of  an amount  \nunder  a  head  of income, incorrect payment of tax with the return of income, an \nincorrect claim for tax relief or rebate, an incorrect claim for exemption of any \namount or an incorrect claim for a refund); or \n(b) has definite information acquired from an audit or otherwise that the income has \nbeen concealed or inaccurate particulars of income have been furnished or the \nassessment is otherwise incorrect.” \n3Expressions “definite information acquired from an audit or otherwise,” substituted through Finance \nAct, 2020 dated 30th June, 2020 \n4Inserted by the Finance Act, 2003. Earlier sub-section (5A) was inserted by S.R.O. 633(I)/2002, dated \n14.09.2002 which stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from \n01.07.2003. The said sub-section (5A) read as follows:  \n“(5A) \nWhere a person does not produce accounts and records, or details of expenditure, \nassets and liabilities or any other information required for the purposes of audit under section177, \nor does not file wealth statement under section 116, the Commissioner may, based on any available \ninformation and to the best of Commissioner’s judgement; make an amended assessment.”  \n5Added by Finance Act, 2012. \n6 The expression “after making, or causing to be made, such enquiries as he deems necessary,” \nomitted by the Finance Act, 2021. \n\n\f\nChapter X – Procedure__________________________________ \n \n250 \n \n1[(5AA) In respect of any subject matter which was not in dispute in an appeal the \nCommissioner shall have and shall be deemed always to have had the powers to amend \nor further amend an assessment order under sub-section (5A).] \n \n2[(5B) Any amended assessment order under sub-section (5A) may be passed \nwithin the time-limit specified in sub-section (2) or sub-section (4), as the case may be.] \n \n \n(6) \nAs soon as possible after making an amended assessment under 3[sub-\nsection (1), sub-section (4) or sub-section (5A)], the Commissioner shall issue an \namended assessment order to the taxpayer stating – \n \n(a) \nthe amended taxable income of the taxpayer; \n \n(b) \nthe amended amount of tax due; \n \n(c) \nthe amount of tax paid, if any; and \n \n(d) \nthe time, place, and manner of appealing the amended assessment. \n \n \n(7) \nAn amended assessment order shall be treated in all respects as an \nassessment order for the purposes of this Ordinance, other than for the purposes \nof sub-section (1). \n \n \n(8) \nFor the purposes of this section, “definite information” includes information \non sales or purchases of any goods made by the taxpayer, 4[receipts of the taxpayer \nfrom services rendered or any other receipts that may be chargeable to tax under this \nOrdinance,]and on the acquisition, possession or disposal of any money, asset, valuable \narticle or investment made or expenditure incurred by the taxpayer. \n \n5[(9) No assessment shall be amended, or further amended, under this section \nunless the taxpayer has been provided with an opportunity of being heard] 6[: \n \n \n7[Provided that order under this section shall be made within one year of issuance \nof show cause notice or within such extended period as the Commissioner may, for \n                                            \n1 Added by the Finance Act, 2010. \n2 Inserted by the Finance Act, 2003. \n3 The words, brackets and figures “sub-section (1) or (4)” substituted by the Finance Act, 2003. \n4 Inserted by the Finance Act, 2002 \n5 Added by the Finance Act, 2002 \n6 Full stop substituted and two provisos added by the Finance Act, 2021. \n7 Provisos substituted by the Finance Act, 2025.Substituted provisos read as follows: \n   “Provided that order under this section shall be made within one hundred and 7[eighty] days of issuance of \nshow cause notice or within such extended period as the Commissioner may, for reasons to be recorded in \nwriting, so however, such extended period shall in no case exceed ninety days. This proviso shall be applicable \nto a show cause notice issued on or after the first day of July, 2021. \nProvided further that any period during which the proceedings are adjourned on account of a stay order or \nAlternative Dispute Resolution proceedings or agreed assessment proceedings under section 122D or the \ntime taken through adjournment by the taxpayer not exceeding sixty days shall be excluded from the \ncomputation of the period specified in the first proviso.]” \n\n\f\nChapter X – Procedure__________________________________ \n \n251 \n \nreasons to be recorded in writing, so however, such extended period shall in no case \nexceed ninety days. This proviso shall be applicable to a show cause notice issued on \nor after the first day of July, 2021:  \n \nProvided further that any period during which the proceedings are adjourned on \naccount of a stay order or Alternative Dispute Resolution proceedings or agreed \nassessment proceedings under section 122D or the time taken through adjournment by \nthe taxpayer not exceeding sixty days shall be excluded from the computation of the \nperiod specified in the first proviso.] ] \n \n1[122A. Revision by the Commissioner.—(1) The Commissioner may 2[ 3[, suomoto,] \n] call for the record of any proceeding under this Ordinance or under the repealed \nOrdinance in which an order has been passed by any 4[Officer of Inland Revenue] 5[ ] .  \n \n \n(2)  \nSubject to sub-section (3), where, after making such inquiry as is \nnecessary, Commissioner considers that the order requires revision, the Commissioner \nmay 6[suomoto] make such revision to the order as the Commissioner deems fit. \n \n \n(3)  \nAn order under sub-section (2) shall not be prejudicial to the person to \nwhom the order relates. \n \n \n(4)  \nThe Commissioner shall not revise any order under sub-section (2) if— \n \n(a)  \nan appeal against the order lies to the Commissioner (Appeals) or \nto the Appellate Tribunal, the time within which such appeal may be \nmade has not expired; or  \n \n(b)  \nthe order is pending in appeal before the Commissioner (Appeals) \nor has been made the subject of an appeal to the Appellate \nTribunal.] \n \n7[(5) If any order is remanded back to any lower authority by the Commissioner \nfor modification, alteration, implementation of directions or de novo proceedings, the \norder giving effect to the directions of the Commissioner shall be issued within one \nhundred and twenty days.] \n \n \n                                            \n1Added by the Finance Act, 2003. \n2Inserted by the Finance Act, 2004. \n3The word “suomoto” substituted by the Finance Act, 2005. \n4The words “Taxation Officer” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010.  \n5 The expression “other than the Commissioner (Appeals) 5[if the value of the assessment or, as the \ncase may be, refund of the tax does not exceed twenty million rupees,]” omitted by the Finance Act, \n2024. \n6 Words added by Finance Act, 2004. \n7 Added by the Finance Act, 2021. \n\n\f\nChapter X – Procedure__________________________________ \n \n252 \n \n1[122B. Revision by the 2[Chief Commissioner].—(1) The 3[Chief Commissioner] \nmay, either of his own motion or on an application made by the taxpayer for \nrevision, call for the record of any proceedings relating to issuance of an exemption \nor lower rate certificate with regard to collection or deduction of tax at source under \nthis Ordinance, in which an order has been passed by any authority subordinate \nto him. \n \n \n(2)  \nWhere, after making such inquiry as is necessary, 4[Chief Commissioner] \nconsiders that the order requires revision, the 5[Chief Commissioner] may, after \nproviding reasonable opportunity of being heard to the taxpayer, make such order as \nhe may deem fit in the circumstances of the case.]  \n \n6[7[  ]  ]  \n                                            \n1 Added by the Finance Act, 2006. \n2 The words “Regional Commissioner” Substituted by “Chief Commissioner” by Finance Act, 2014. \n3The words “Regional Commissioner” Substituted by “Chief Commissioner” by Finance Act, 2014. \n4The words “Regional Commissioner” Substituted by “Chief Commissioner” by Finance Act, 2014 \n5 The words “Regional Commissioner” Substituted by “Chief Commissioner” by Finance Act, 2014 \n6Substituted by the Finance Act, 2010. The substituted provision has been made effective from 05.06.2010 by \nsub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was made through Finance \n(Amendment) Ordinance, 2009 which was re-promulgated as Finance (Amendment) Ordinance, 2010 and \nremained effective till 05.06.2010. The substituted section “122C” read as follows: \n“122C. Provisional assessment. —  (1) Where in response to a notice under sub-section (3) or sub-section \n(4) of section 114 a person fails to furnish return of income for any tax year, the Commissioner may, based \non any available information or material and to the best of his judgment, make a provisional assessment of \nthe taxable income of the person and issue a provisional assessment order specifying the taxable income \nassessed and the tax due thereon.  \n(2)  Notwithstanding anything contained in this Ordinance, the provisional assessment completed \nunder sub-section (1) shall be treated as the final assessment after the expiry of sixty days from the date of \nservice of order of provisional assessment and the provisions of this Ordinance shall apply accordingly: \nProvided that the provisions of sub-section (2) shall not apply if return of income along with wealth \nstatement, wealth reconciliation statement and other documents required under sub-section (2A) of \nsection 116 are filed by the person for the relevant tax year during the said period of sixty days.” \n7Section 122C omitted by Finance Act 2017,the omitted section 122C is read as under: \n“122C. Provisional assessment.—  (1) Where in response to a notice under sub-section (3) or sub-section (4) \nof section 114 a person fails to furnish return of income for any tax year, the Commissioner may, based on any \navailable information or material and to the best of his judgment, make a provisional assessment of the taxable \nincome or income of the person and issue a provisional assessment order specifying the taxable income or \nincome assessed and the tax due thereon. \n(2)  Notwithstanding anything contained in this Ordinance, the provisional assessment order completed \nunder sub-section (1) shall be treated as the final assessment order after the expiry of 7[forty-five] days from the \ndate of service of order of provisional assessment and the provisions of this Ordinance shall apply accordingly: \n7[“Provided that the provisions of this sub-section shall not apply, if— \n(a) \nreturn of income along with wealth statement, wealth reconciliation statement and other \ndocuments required under sub-section (2A) of section 116 are filed by the person being an \nindividual or an association of persons for the relevant tax year during the said period of forty-\nfive days; and \n(b) \nthe individual or an association of persons presents accounts and documents for \nconducting audit of income tax affairs for that tax year: \nProvided further that the provisions of sub-section (2) shall not apply— \n\n\f\nChapter X – Procedure__________________________________ \n \n253 \n \n1[122D. Agreed assessment in certain cases.- (1) Where a taxpayer, in \nresponse to a notice under sub-section (9) of section 122, intends to settle his \ncase, he may file offer of settlement in the prescribed form before the assessment \noversight committee, hereinafter referred to as the Committee, in addition to filing \nreply to the Commissioner. \n(2) \nThe Committee after examining the aforesaid offer may call for the \nrecord of the case and after affording opportunity of being heard to the taxpayer, \nmay decide to accept or modify the offer of the taxpayer through consensus and \ncommunicate its decision to the taxpayer. \n \n(3) \nWhere the taxpayer is stratified with the decision of the Committee,- \n \n(a) the taxpayer shall deposit the amount of tax payable including any \namount of penalty and default surcharge as per decision of the \nCommittee; \n \n(b) the Commissioner shall amend assessment in accordance with the \ndecision of the Committee after tax payable including any amount of \npenalty and default surcharge as per decision of the Committee has \nbeen paid; \n \n(c) the taxpayer shall waive the right to prefer appeal against such amended \nassessment; and \n \n(d) no further proceedings shall be undertaken under this Ordinance in \nrespect of issues decided by the Committee unless the tax as per clause \n(c) has not been deposited by the taxpayer. \n \n(4) \nWhere the Committee has not been able to arrive at a consensus or \nwhere the taxpayer is not satisfied with the decision of the Committee, the case \nshall be referred back to the Commissioner for decision on the basis of reply of the \ntaxpayer in response to notice under sub-section (9) of section 122 \nnotwithstanding proceedings or decision, if any, of the Committee. \n \n(5) \nThe Committee shall comprise the following income tax authorities \nhaving jurisdiction over the taxpayer, namely:- \n \n(a) the Chief Commissioner Inland Revenue; \n(b) the Commissioner Inland Revenue; and \n(c) the Additional Commissioner Inland Revenue. \n                                            \n(a) \nto a company, if return of income tax alongwith audited accounts or final accounts, as the \ncase may be, for the relevant tax year are filed by the company electronically during the \nsaid period of forty-five days; and  \n(b) \nif the company presents accounts and documents for conducting audit of its income tax \naffairs for that tax year.” \n1 New Section 122D inserted through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nChapter X – Procedure__________________________________ \n \n254 \n \n \n(6) \nThis section shall not apply in cases involving concealment of income \nor where interpretation of question of law is involved having effect on other cases. \n(7) \nThe Board may make rules regulating the procedure of the Committee \nand for any matter connected with, or incidental to the proceedings of the \nCommittee.]  \n \n123. Provisional assessment in certain cases.— (1)  Where a concealed asset \nof any person is impounded by any department or agency of the Federal Government \nor a Provincial Government, the Commissioner may, at any time before issuing any \nassessment order under section 121 or any amended assessment order under section \n122, issue to the person a provisional assessment order or provisional amended \nassessment order, as the case may be, for the last completed tax year of the person \ntaking into account the concealed asset. \n \n1[(1A) Where an offshore asset of any person, not declared earlier, is \ndiscovered by the Commissioner or any department or agency of the Federal \nGovernment or a Provincial Government, the Commissioner may at any time \nbefore issuing any assessment order under section 121 or amended assessment \norder under section 122, issue to the person a provisional assessment order or \nprovisional amended assessment order, as the case may be, for the last completed \ntax year of the person taking into account the offshore asset  discovered.] \n \n \n(2) \nThe Commissioner shall finalise a provisional assessment order or a \nprovisional amended assessment order as soon as practicable 2[  ].  \n \n \n(3) \nIn this section, “concealed asset” means any property or asset which, \nin the opinion of the Commissioner, was acquired from any income subject to tax \nunder this Ordinance. \n \n \n124. Assessment giving effect to an order. —  (1)  Except where sub-section \n(2) applies, where, in consequence of, or to give effect to, any finding or direction \nin any order made under Part III of this Chapter by the Commissioner (Appeals),   \n3[if the value of the assessment or, as the case may be, refund of the tax does not \nexceed twenty million rupees,] Appellate Tribunal, High Court, or Supreme Court \nan assessment order or amended assessment order is to be issued to any person, \nthe Commissioner shall issue the order within two years from the end of the \nfinancial year in which the order of the Commissioner (Appeals), 4[if the value of \nthe assessment or, as the case may be, refund of the tax does not exceed twenty \nmillion rupees,] Appellate Tribunal, High Court or Supreme Court, as the case may \nbe, was served on the Commissioner. \n \n                                            \n1 New subsection 1A inserted through Finance Supplementary (Second Amendment) Act, 2019 \n2 The words “after making it” omitted by the Finance Act, 2003. \n3 Inserted through The Tax Laws (Amendment) Act, 2024. \n4 Inserted through The Tax Laws (Amendment) Act, 2024. \n\n\f\nChapter X – Procedure__________________________________ \n \n255 \n \n \n(2) \nWhere, by an order made under Part III of this Chapter by the 1[  ] \nAppellate Tribunal, High Court, or Supreme Court, an assessment order is set \naside 2[wholly or partly,] and the Commissioner 3[or Commissioner (Appeals), as \nthe case may be,] 4[if the value of the assessment or, as the case may be, refund \nof the tax does not exceed twenty million rupees,] is directed to 5[pass] a new \nassessment order, the Commissioner 6[or Commissioner (Appeals), as the case \nmay be,] 7[if the value of the assessment or, as the case may be, refund of the tax \ndoes not exceed twenty million rupees,] shall 8[pass] the new order within 9[one \nyear from the end of the financial year in which] the Commissioner 10[or \nCommissioner (Appeals), as the case may be,] 11[if the value of the assessment \nor, as the case may be, refund of the tax does not exceed twenty million rupees,] \nis served with the order 12[:] \n \n13[Provided that limitation under this sub-section shall not \napply, if an appeal or reference has been preferred, against the order \n14[ ], passed by 15[ ] Appellate Tribunal or a High Court.] \n \n \n(3) \nWhere an assessment order has been set aside or modified, the \nproceedings may commence from the stage next preceding the stage at which \nsuch setting aside or modification took place and nothing contained in this \nOrdinance shall render necessary the re-issue of any notice which had already \nbeen issued or the re-furnishing or re-filing of any return, statement, or other \nparticulars which had already been furnished or filed. \n \n \n(4) \nWhere direct relief is provided in an order under section 129 or 132, \nthe Commissioner shall issue appeal effect orders within two months of the date \nthe Commissioner is served with the order. \n \n                                            \n1 The words “Commissioner (Appeals)” omitted by the Finance Act, 2010. \n2Inserted by the Finance Act, 2003. \n3Inserted by the Finance Act, 2008. \n4 Inserted through The Tax Laws (Amendment) Act, 2024. \n5The word “make” substituted by the Finance Act, 2010. \n6Inserted by the Finance Act, 2008. \n7 Inserted through The Tax Laws (Amendment) Act, 2024. \n8The word “make” substituted by the Finance Act, 2010. \n9 The words “six months from the date” substituted by the Finance Act, 2002. \n10Inserted by the Finance Act, 2008. \n11 Inserted through Tax Laws (Amendment) Act, 2024. \n12 The full stop substituted by the Finance Act, 2005. \n13Inserted by the Finance Act, 2005. \n14 The words “setting aside the assessment” omitted by the Finance Act, 2010. \n15 The words “a Commissioner (Appeals)” omitted by the Finance Act, 2010. \n\n\f\nChapter X – Procedure__________________________________ \n \n256 \n \n \n1[(4A)    Where the Commissioner (Appeals), Appellate Tribunal, High Court \nor Supreme Court has confirmed the tax payable as determined in the order \nappealed against no appeal effect order will be required to be issued and the \nCommissioner shall proceed to effect recovery.  \n \n(4B)   Subject to the provisions of sub-section (2) where the Appellate \nTribunal, High Court or Supreme Court has partly set aside the order and \nconfirmed or modified the order on some other issues that were subject matter of \nthe appeal, the Commissioner shall issue an appeal effect order on the prescribed \nform determining the tax payable as a result of the confirmation or modification by \nthe Appellate Tribunal, High Court or Supreme Court and excluding the tax payable \non the matters that have been set aside or remanded and the tax payable on the \nbasis of the issues that have been confirmed or modified shall be paid or recovered \nunder the provisions of the Ordinance.] \n \n \n(5) \nWhere, by any order referred to in sub-section (1), any income is \nexcluded — \n \n(a) \nfrom the computation of the taxable income of a taxpayer for \nany year and held to be included in the computation of the \ntaxable income of the taxpayer for another year; or \n \n(b) \nfrom the computation of the taxable income of one taxpayer and \nheld to be included in the computation of the taxable income of \nanother taxpayer, \n \nthe assessment or amended assessment relating to that other tax year or other \ntaxpayer, as the case may be, shall be treated as an assessment or amended \nassessment to be made in consequence of, or to give effect to, a finding or \ndirection contained in such order. \n \n \n(6) \nNothing in this Part shall prevent the issuing of an assessment order \nor an amended assessment order to give effect to an order made under Part III of \nthis Chapter by the Commissioner (Appeals), 2[if the value of the assessment or, \nas the case may be, refund of the tax does not exceed twenty million rupees,] \nAppellate Tribunal, High Court, or Supreme Court.  \n \n3[(7) The provisions of this section shall in like manner apply to any order \nissued by any High Court or the Supreme Court in exercise of original or appellate \njurisdiction.] \n \n                                            \n1 Sub-sections (4A) and (4B) inserted by the Finance Act, 2025. \n2 Inserted through Tax Laws (Amendment) Act, 2024. \n3Added by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n257 \n \n1[124A. Powers of tax authorities to modify orders, etc.—(1) Where a question \nof law has been decided by a High Court or the Appellate Tribunal in the case of a \ntaxpayer, on or after first day of July 2002, the Commissioner may, notwithstanding \nthat he has preferred an appeal against the decision of the High Court or made an \napplication for reference against the order of the Appellate Tribunal, as the case \nmay be, follow the said decision in the case of the said taxpayer in so far as it \napplies to said question of law arising in any assessment pending before the \nCommissioner until the decision of the High Court or of the Appellate Tribunal is \nreversed or modified.  \n \n \n(2)  \nIn case the decision of High Court or the Appellate Tribunal, referred \nto in sub-section (1), is reversed or modified, the Commissioner may, \nnotwithstanding the expiry of period of limitation prescribed for making any \nassessment or order, within a period of one year from the date of receipt of \ndecision, modify the assessment or order in which the said decision was applied \nso that it conforms to the final decision.] \n \n125.  Assessment in relation to disputed property.— Where the ownership of \nany property the income from which is chargeable to tax under this Ordinance is \nin dispute in any Civil Court in Pakistan, an assessment order or amended \nassessment order in respect of such income may be issued at any time within one \nyear after the end of the financial year in which the decision of the Court is made. \n \n126.  Evidence of assessment.— (1)  The production of an assessment order \nor a certified copy of an assessment order shall be conclusive evidence of the due \nmaking of the assessment and, except in proceedings under Part III of this Chapter \nrelating to the assessment, that the amount and all particulars of the assessment \nare correct. \n \n \n(2) \nAny 2[order] of assessment or other document purporting to be made, \nissued, or executed under this Ordinance may not be – \n \n(a) \nquashed or deemed to be void or voidable for want of form; or \n \n(b) \naffected by reason of any mistake, defect, or omission therein, \n \nif it is, in substance and effect, in conformity with this Ordinance and the person \nassessed, or intended to be assessed or affected by the document, is designated \nin it according to common understanding. \n \n \n \n                                            \n1 Inserted by the Finance Act, 2002. \n2The word “notice” substituted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n258 \n \nPART III \nAPPEALS \n1[  ]  \n2[   ] \n \n127. Appeal to the Commissioner (Appeals). — 3[(1) 4[ ] 5[Any person, other than \nState-Owned Enterprise (SOE),] dissatisfied with any order passed by a \nCommissioner or an6[Officer of Inland Revenue] under 7[sub-section (2A) of section \n120,] section 121,122, 143, 144, 8[162,] 170, 182, 9[  ] 10[or 205], or an order under sub-\nsection (1) of section 161 holding a person to be personally liable to pay an amount of \ntax, or an order under clause (f) of sub-section (3) of section 172 11[declaring] a person \nto be the representative of a non-resident person [or an order giving effect to any finding \n                                            \n1 Inserted through The Tax Laws (Amendment) Act, 2024. \n2 Section 126A omitted by the Finance Act, 2025. The omitted section read as follows: \n   “126A. Pecuniary jurisdiction in appeals. — (1) 2[Notwithstanding anything contained in any \nother provision of this Ordinance,– ] \n(a) \nan appeal to the Commissioner (Appeals) shall lie where the value of assessment of tax or, \nas the case may be, refund of tax does not exceed twenty million rupees; or \n(b) \nan appeal to the Appellate Tribunal Inland Revenue shall lie where the value of assessment \nof tax or, as the case may be, refund of tax exceeds twenty million rupees \n2[Explanation. – For the purposes of this section value of assessment of tax means the net increase \nin tax liability of a person as a result of order sought to be assailed and value of refund means net \nreduction in refund as a result of order sought to be assailed.]  \n(2) \nA person or, as the case may be, officer of Inland Revenue aggrieved by an order of \nthe Commissioner (Appeals) in Cases under clause (a) of sub-section (1) may file a reference before \nthe High Court in accordance with section 133.  \n(3) \nA person or, as the case may be, officer of Inland Revenue aggrieved by an order of \nthe Appellate Tribunal in cases under clause (b) of sub-section (1) may file a reference before the \nHigh Court in accordance with section 133. \n(4) \nThe cases pending before the Commissioner (Appeals) having the value of assessment \nof tax or, as the case may be, refund of tax exceeding twenty million rupees shall on 2[or before the \n31st day of December], 2024 2[and shall be deemed to have taken effect on and from the 16th day \nof June, 2024] stand transferred to the Appellate Tribunal Inland Revenue. \n(5) \nAll cases transferred from the Commissioner (Appeals) to the Appellate Tribunal under \nsub-section (4) shall be decided by the Appellate Tribunal within the period provided for under section \n132 which period shall commence from 2[the date of transfer under sub-section (4).]” \n3 Sub-section (1) substituted by the Finance Act, 2002. The substituted sub-section (1) read as follows: \n“(1) Any person dissatisfied with any proceeding under this Ordinance in which an order has \nbeen issued by a Commissioner of Income Tax (other than the Commissioner (Appeals)) or a \ntaxation officer may prefer an appeal to the Commissioner (Appeals) against the order.”  \n4 Expression inserted by the Finance Act, 2024. \n5 The expression “Subject to section 126A, any] person” substituted by the Finance Act, 2025. \n6  The words “Taxation officer” substituted by the Finance Act, 2014. \n7 The expressions inserted through Finance Act, 2020 dated 30th June, 2020 \n8Inserted by the Finance Act, 2004. \n9  The figures and commas “183, 184, 185, 186, 187, 188 and 189” omitted by the Finance Act, 2010. \n10The word and figure “or 189” substituted by the Finance Act, 2009. \n11The word “treating” substituted by the Finance Act, 2003 \n\n\f\nChapter X – Procedure__________________________________ \n \n259 \n \nor directions in any order made under this Part by the Commissioner (Appeals), \nAppellate Tribunal, High Court or Supreme Court], or an order under section 221 refusing \nto rectify the mistake, either in full or in part, as claimed by the taxpayer or an order having \nthe effect of enhancing the assessment or reducing a refund or otherwise increasing the \nliability of the person 1[, 2[ 3[ ] ]may prefer an appeal to the Commissioner (Appeals) \nagainst the order] 4[: \n \n \nProvided that an aggrieved person under sub-section (1) may have the option to \neither file appeal before Commissioner Inland Revenue (Appeals) directly or may \nsurrender his right of appeal before Commissioner Inland Revenue (Appeals) and avail \nthe next statutory appellate forum by filing the appeal directly before the Appellate \nTribunal Inland Revenue.] \n \n \n5[  ]  \n \n6[(2) No appeal under sub-section (1), shall be made by a taxpayer against \nan order of assessment unless the taxpayer has paid the amount of tax due under \nsub section (1) of section 137.]  \n \n \n(3) \nAn appeal under sub-section (1) shall — \n \n(a) \nbe in the prescribed form; \n \n(b) \nbe verified in the prescribed manner;  \n \n(c) \nstate precisely the grounds upon which the appeal is made;  \n \n(d) \nbe accompanied by the prescribed fee specified in sub-section \n(4); and \n \n                                            \n1 Inserted by the Finance Act, 2011. \n2The words “a provisional” substituted by the word “an” by the Finance Act, 2012. \n3The expression “except an assessment order under section 122C,” omitted by the Finance \nOrdinance, 2017. \n4 Full stop substituted and new proviso added by the Finance Act, 2025. \n5 Sub-section (2) substituted by the Finance Ordinance, 2002. The substituted sub-section (2) read as \nfollows:  \n \n“No appeal may be made by a taxpayer against an assessment unless the amount of tax due under \nthe assessment that is not in dispute and fifteen percent of the disputed tax has been paid by the \ntaxpayer.”   \n6 Sub-section (2) substituted by the Finance Act, 2021. The substituted sub-section (2) read as follows: \n“(2) \nNo appeal under sub-section (1), shall be made by a taxpayer against an order of  \nassessment unless the taxpayer has paid,— \n(a) \nthe amount of tax due under sub-section (1) of section 137 and \n(b) \nno appeal under sub-section (1) shall be made by a taxpayer against] an order of \nassessment unless the taxpayer has paid the amount of tax due under sub-section (1) \nof section 137.” \n\n\f\nChapter X – Procedure__________________________________ \n \n260 \n \n(e) \nbe lodged with the Commissioner (Appeals) within the time set \nout in sub-section (5). \n \n \n1[(3A) The Board may prescribe mechanism for electronic filing of the \nappeals.] \n \n \n(4) \nThe prescribed fee 2[shall be] — \n \n3[(a) in the case of appeal against an assessment- \n \n(i) where the appellant is a company, five thousand rupees; or \n \n(ii) where the appellant is not a company, two thousand and five \nhundred rupees; or] \n \n(b) \nin any other case — \n \n (i) \nwhere the appellant is a company, 4[five] thousand rupees; or \n \n(ii) \nwhere the appellant is not a company, 5[one thousand] \nrupees. \n \n6[(5)  An appeal shall be preferred to the Commissioner (Appeals) within \nthirty days of the following— \n \n(a)  \nwhere the appeal relates to any assessment or penalty, the date \nof service of the notice of demand relating to the said assessment \nor penalty, as the case may be; and  \n \n(b)  \nin any other case, the date on which the order to be appealed \nagainst is served.] \n \n \n(6) \nThe Commissioner (Appeals) may, upon application in writing by the \nappellant, admit an appeal after the expiration of the period specified in \nsub-section (5) if the Commissioner (Appeals) is satisfied that the appellant was \nprevented by sufficient cause from lodging the appeal within that period. \n \n                                            \n1 Sub-section (3) inserted by the Finance Act, 2021.  \n2The word “is” substituted by the Finance Act, 2002 \n3 Clause (a) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted clause read \nas follows: “(a) in the case of an appeal against an assessment, 3[one thousand rupees]3[ ]; or” \n  \n4 The word “one” substituted through Finance Act, 2020 dated 30th June, 2020 \n5 The word “two hundred” substituted through Finance Act, 2020 dated 30th June, 2020 \n6Sub-section (5) substituted by the Finance Act, 2002. The substituted sub-section (5) read as follows: \n“ \n“(5)   \nAn appeal shall be lodged with the Commissioner (Appeals) – \n(a) \nwhere the appeal relates to an assessment order, within thirty days of the date \nof service of the demand relating to the assessment; or \n(b) \nin any other case, within thirty days of the date of service of the notice of the \ndecision or determination appealed against.” \n\n\f\nChapter X – Procedure__________________________________ \n \n261 \n \n128. Procedure in appeal.— (1)  The Commissioner (Appeals) shall give notice \nof the day fixed for the hearing of the appeal to the appellant and to the \nCommissioner against whose order the appeal has been made. \n \n \n1[(1A) Where in a particular case, the Commissioner (Appeals) is of the \nopinion that the recovery of tax levied under this Ordinance, shall cause undue \nhardship to the taxpayer, he, after affording opportunity of being heard to the \nCommissioner against whose order appeal has been made, may stay the recovery \nof such tax for a period not exceeding thirty days in aggregate.] \n \n \n2[“(1AA) The Commissioner (Appeals), after affording opportunity of being \nheard to the Commissioner against whose order appeal has been made, may stay \nthe recovery of such tax for a further period of thirty days, provided that the order \non appeal shall be passed within the said period of thirty days.”] \n \n \n(2) \nThe Commissioner (Appeals) may adjourn the hearing of the appeal \nfrom time to time. \n \n \n(3) \nThe Commissioner (Appeals) may, before the hearing of an appeal, \nallow an appellant to file any new ground of appeal not specified in the grounds of \nappeal already filed by the appellant where the Commissioner (Appeals) is \nsatisfied that the omission of the ground from the form of the appeal was not wilful \nor unreasonable. \n \n \n(4) \nThe Commissioner (Appeals) may, before disposing of an appeal, call \nfor such particulars as the Commissioner (Appeals) may require respecting the \nmatters arising in the appeal or cause further enquiry to be made by the \nCommissioner. \n \n \n(5) \nThe Commissioner (Appeals) shall not admit any documentary \nmaterial or evidence which was not produced before the Commissioner unless the \nCommissioner (Appeals) is satisfied that the appellant was prevented by sufficient \ncause from producing such material or evidence before the Commissioner. \n \n129. Decision in appeal.— (1)  In disposing of an appeal lodged under section \n127, the Commissioner (Appeals) may – \n \n3[(a)  \nmake an order to confirm, modify or annul the assessment order \nafter examining such evidence as required by him respecting \n                                            \n1Inserted by the Finance Act, 2012. \n2Inserted by the Finance Act, 2015 \n3Clause (a) substituted by the Finance Act, 2005. The original clause (a) read as follows:  \n (a) in the case of an appeal against an assessment order – \n(i) \nmake an order to set aside the assessment order and direct the Commissioner to make a \nnew assessment order in accordance with any directions or recommendations of the \nCommissioner (Appeals); or \n(ii) \nmake an order to confirm, modify or annul the assessment order; or \n\n\f\nChapter X – Procedure__________________________________ \n \n262 \n \nthe matters arising in appeal or causing such further enquires to \nbe made as he deems fit; or] \n \n(b) \nin any other case, make such order as the Commissioner \n(Appeals) thinks fit. \n \n \n(2) \nThe Commissioner (Appeals) shall not increase the amount of any \nassessment order or decrease the amount of any refund unless the appellant has \nbeen given a reasonable opportunity of showing cause against such increase or \ndecrease, as the case may be. \n \n \n(3) \nWhere, as the result of an appeal, any change is made in the \nassessment of an association of persons or a new assessment of an association \nof persons is ordered to be made, the Commissioner (Appeals) may authorise the \nCommissioner to amend accordingly any assessment order made on a member of \nthe association and the time limit in sub-section (2) of section 122 shall not apply \nto the making such amended assessment. \n \n \n(4) \nAs soon as practicable after deciding an appeal, the Commissioner \n(Appeals) shall 1[specify in the order the amount of tax upheld and] serve 2[  ] his \norder on the appellant and the Commissioner 3[:] \n \n4[Provided that such order shall be passed not later than one hundred and \ntwenty days from the date of filing of appeal or within an extended period of sixty \ndays, for reasons to be recorded in writing by the Commissioner (Appeals): \n \nProvided further that any period during which the hearing of an appeal is \nadjourned at the request of the appellant or is postponed due to any appeal or \nproceedings or stay order, remand or alternative dispute resolution proceedings or \nfor any other reason, shall be excluded in the computation of the aforementioned \nperiods.] \n \n \n5[  ] \n \n6[  ] \n \n                                            \n1The words inserted through Finance Act, 2020 dated 30th June, 2020 \n2 The words  “notice of” omitted by the Finance Act, 2002 \n3 Full stop substituted by the Finance Act, 2009. \n4 Inserted by the Finance Act, 2009. \n5Sub-section (5) omitted by the Finance Act, 2012. The omitted sub-section (5) read as follows: \n“(5) Where the Commissioner (Appeals) has not made an order on an appeal before the \nexpiration of 5[four] months from the end of the month in which the appeal was lodged, the relief \nsought by the appellant in the appeal shall be treated as having been given and all the provisions of \nthis Ordinance shall have effect accordingly. \n6Sub-section (6) omitted by the Finance Act, 2012. The omitted sub-section (6) read as follows: \n“(6) \nFor the purposes of sub-section (5), any period during which the hearing of an appeal \nis adjourned on the request of the appellant shall be excluded in the computation of the period of \nfour months referred to in that sub-section.” \n\n\f\nChapter X – Procedure__________________________________ \n \n263 \n \n \n1[  ] \n \n2[  ] \n                                            \n1 Sub-section (7) omitted by the Finance Act, 2012. The omitted sub-section (7) read as follows: \n“(7) \nThe provisions of sub-section (5) shall not apply unless a notice by the appellant stating \nthat no order under sub-section (1) has been made is personally served by the appellant on the \nCommissioner (Appeals) not less than thirty days before the expiration of the period of four months.” \n2 Section 130 substituted through Tax Laws (Second Amendment) Ordinance, 2019 dated 26th \nDecember, 2019, the substituted section read as follows: \n  “130. Appointment of the Appellate Tribunal.—2[(1) There shall be established an Appellate Tribunal to \nbe called the Appellate Tribunal Inland Revenue to exercise the powers and perform the functions conferred \non the Appellate Inland Revenue tribunal by this Ordinance, \n \n(2) \nThe Inland Revenue Appellate Tribunal shall consist of a chairman and such other judicial \nand accountant members as are appointed in such numbers and in the manner as the Prime Minister may \nprescribe by the rules.]    \n (3) \nA person may be appointed as a judicial member of the Appellate Tribunal if the person \n– \n(a)  \nhas exercised the powers of a District Judge and is qualified to be a Judge of the  \nHigh Court; 2[ 2[or]  ] \n(b)   is or has been an advocate of a High Court and is qualified to be a Judge of the \nHigh Court 2[ 2[.]  ] \n2[ 2[  ]   ] \n \n2[(4)  \nA person may be appointed as an accountant member of an appellate tribunal if,— \n(a)  \nhe is an officer of Inland Revenue 2[Service] equivalent to the rank of Regional \nCommissioner; 2[  ] \n(b)  \na Commissioner Inland Revenue or Commissioner Inland Revenue (Appeals) \nhaving at least 2[three] years experience as Commissioner or Collector 2[; 2[ ] ]  \n2[(c)  \na person who has, for a period of not less than ten years, practiced \nprofessionally as a chartered accountant within the meaning of the Chartered \nAccountants Ordinance, 1961 (X of 1961)2[;or] \n2[(d) \na person who has, for a period of not less than ten years, practiced \nprofessionally as a cost and management accountant within the meaning of \nCost and Management Accountants Act,1966 (XIV of 1966).] \n \n(5) \nThe Federal Government shall appoint a member of the Appellate Tribunal as \nChairperson of the Tribunal2[and, except in special circumstances, the person appointed should be a \njudicial member]2[ ]. \n \n (6) \nThe powers and functions of the Appellate Tribunal shall be exercised and discharged \nby Benches constituted from members of the Tribunal by the Chairperson of the Tribunal. \n \n (7) \nSubject to sub-section (8), a Bench shall consist of not less than two members of the \nAppellate Tribunal and shall be constituted so as to contain an equal number of judicial and accountant \nmembers, or so that the number of members of one class does not exceed the number of members of \nthe other class by more than one.  \n \n (8) \nThe Federal Government may direct that all or any of the powers of the Appellate \nTribunal shall be exercised by — \n(a) \nany one member; or \n(b) \nmore members than one, jointly or severally. \n2[(8A) Notwithstanding anything contained in sub-sections (7) and (8), the 2[Chairperson] may \nconstitute as many benches consisting of a single member as he may deem necessary to hear such \ncases or class of cases as the Federal Government may by order in writing, specify.] \n2[(8AA) The 2[Chairperson] or other member of the Appellate Tribunal authorized, in this behalf by \nthe 2[Chairperson] may, sitting singly, dispose of any case where the amount of tax or penalty involved does \nnot exceed 2[one] million rupees.] \n\n\f\nChapter X – Procedure__________________________________ \n \n264 \n \n1[130. Appellate Tribunal.— (1) There shall be established an Appellate Tribunal \nInland Revenue hereinafter called as the Appellate Tribunal to exercise jurisdiction, \nconferred on it under this Ordinance:  \n \nProvided that the existing members including Chairman of the Appellate \nTribunal shall continue to hold office, on the same terms and conditions as \napplicable to them prior to the commencement of the Tax Laws (Amendment) Act, \n                                            \n \n (9) \nSubject to sub-section (10), if the members of a Bench differ in opinion on any point, \nthe point shall be decided according to the opinion of the majority. \n \n(10) \n If the members of a 2[Bench] are equally divided on a point, they shall state the point \non which they differ and the case shall be referred by the Chairperson for hearing on that point by one \nor more other members of the Appellate Tribunal, and the point shall be decided according to the \nopinion of the majority of the members of the Tribunal who have heard the case including those who \nfirst heard it. \n(11) \n If there are an equal number of members of the Appellate Tribunal, the Federal \nGovernment may appoint an additional member for the purpose of deciding the case on which there is \na difference of opinion. \n \n(12) \n Subject to this Ordinance, the Appellate Tribunal shall have the power to regulate its \nown procedure, and the procedure of Benches of the Tribunal in all matters arising out of the discharge \nof its functions including the places at which the Benches shall hold their sittings.” \n \n1 Section 130 substituted through The Tax Laws (Amendment) Act, 2024. The Substituted section \nread as follows: \n“130. \n Appellate Tribunal.- (1) There shall be established an Appellate Tribunal to be called the \nAppellate Tribunal Inland Revenue to exercise the powers and perform the functions conferred on the \nAppellate Tribunal Inland Revenue by this Act. \n(2) \nThe Appellate Tribunal Inland Revenue shall consist of a chairman and such other judicial and \naccountant members who shall be appoints in such numbers and in such manner as the Prime Minister \nmay prescribe by rules, which may be made and shall take effect notwithstanding anything contained \nin section 237 or any other law or rules for the time being in force. \n(3) \nNo person shall be appointed as judicial member of an Appellate Tribunal Inland Revenue \nunless he -   \n(a) has been a Judge of a High Court; \n(b) is or has been a District Judge; or  \n(c) is an advocate of a High Court with a standing of not less than ten years; or  \n(d) possesses such other qualification as may be prescribed under sub-section (2) of this \nsection. \n(4) \nNo person shall be appointed as an accountant member of a Appellate Tribunal Inland Revenue \nunless he - \n (a) \nis an officer of the Inland Revenue Service equivalent in rank to that of 1[Chief \nCommissioner Inland Revenue]; \n(b) is a Commissioner Inland Revenue or Commissioner Inland Revenue (Appeals) having \nnot less than three years experience as Commissioner 1[  ]; \n(c) has for a period of not less than ten years practiced professionally as a chartered \naccountant within the meaning of the Chartered Accountants’ Ordinance, 1961 (X of \n1961); or \n(d) has for a period of not less than ten years practiced professionally as a cost and \nmanagement accountant within the meaning of the Cost and Management Accountant’ \nAct, 1966 (XIV of 1966). \n(5) \nThe constitution, functioning of benches and procedure of the Appellate Tribunal Inland \nRevenue shall be regulated by rules which the Prime Minister may prescribe. \n \n(6) \nThe rules in respect of the matters covered under this section made prior to commencement of \nthe Tax Laws (Second Amendment) Ordinance, 2019 shall continue in force unless amended or \nrepealed.]” \n\n\f\nChapter X – Procedure__________________________________ \n \n265 \n \n2024 ( of 2024), till the completion of their term of office unless resigned or \nremoved earlier on the grounds provided in the proviso to sub-section (5).  \n \n(2) \nThe Appellate Tribunal shall consist of members who shall be \nappointed by the Federal Government in such numbers, in accordance with such \nprocedure and on such terms and conditions as the Federal Government may \nprescribe by rules, which shall be made and take effect notwithstanding anything \ncontained in section 237 of this Ordinance or the Federal Public Service \nCommission Ordinance, 1977 (XLV of 1977) or any other law or rules, for the time \nbeing in force.  \n \n(3) \nA person shall be eligible to be appointed as a member of the \nAppellate Tribunal, if he — \n \n(a) \nis an advocate of a High Court for not less than fifteen years and \npossesses such other qualifications as may be prescribed by rules \nunder this section; \n  \n 1[(b)  \nhas, for an aggregate period of not less than ten years, been –  \n \n(i) \nin practice as a chartered accountant, either individually or in a \nfirm of the chartered accountants, within the meaning of \nChartered Accountants Ordinance, 1961 (X of 1961); or  \n \n(ii) \na chartered accountant, within the meaning of the Chartered \nAccountants Ordinance, 1961 (X of 1961), and has been in \nemployment of a chartered accountant in practice as specified \nin sub-clause (i) above at least for a period of ten years;] \n \n(c) \nhas for a period of not less than ten years practiced professionally as \na cost and management accountant within the meaning of the Cost \nand Management Accountants Act, 1966 (XIV of 1966); \n  \n(d) \nis an officer of the Inland Revenue in BS-21 or above; or  \n \n(e) \nis an officer of the Inland Revenue in BS-20, having served in such \ngrade for three years or more. \n \n(4) \nThe Federal Government shall appoint any member possessing \nqualifications provided in clauses (a), (13) and (c) of sub-section (3) as Chairman \nof the Appellate Tribunal. The Chairman shall hold office for a period of three years \nprovided that the Federal Government may reappoint the Chairman for such \nfurther term or terms as it may deem appropriate.  \n \n                                            \n1 Clause (b) substituted by the Finance Act, 2025. The substituted clause read as follows: \n   “(b) \nhas for a period of not less than ten years practiced professionally as a chartered accountant \nwithin the meaning of the Chartered Accountants’ Ordinance, 1961 (X of 1961);”  \n\n\f\nChapter X – Procedure__________________________________ \n \n266 \n \n(5) \nThe members including the Chairman shall cease to hold office on \nattaining the age of sixty-two years provided that the members falling under \nclauses (c) and (d) of sub-section (3) shall cease to hold office on attaining the age \nof superannuation, under the law regulating their service: \n  \nProvided that a member including the Chairman may resign or may be \nremoved by the Federal Government, on the recommendation of performance \nreview committee, to be constituted by the rules made under sub-section (2), at \nany time before the expiry of his term or attaining the age of superannuation, as \nthe case may be, on grounds, interalia, of inefficiency or misconduct, as prescribed \nby the rules made under sub-section (2).  \n \n(6) \nThe procedure of the Appellate Tribunal Inland Revenue including \nconstitution of benches, case management system, distribution of cases and other \nmatters ancillary or incidental thereto shall be regulated by the rules made under \nsub-section (2).] \n \n\n\f\nChapter X – Procedure__________________________________ \n \n267 \n \n1[131. Appeal to the Appellate Tribunal. — 2[(1) Where the taxpayer, or the \nCommissioner objects to an order passed by the Commissioner (Appeals), the \ntaxpayer or Commissioner may appeal to the Appellate Tribunal against such order \nwithin thirty days of the receipt of such order:  \n \nProvided that the taxpayer may directly appeal against the order of the \nOfficer Inland Revenue or the Commissioner as the case may be to the Appellate \nTribunal by exercising the option as provided in sub-section (1) of section 127.]  \n \n(2) \nAn appeal under sub-section (1) shall be — \n \n(a)  in the prescribed form;  \n(b)   verified in the prescribed manner;  \n                                            \n1 Section 131 substituted through The Tax Laws (Amendment) Act, 2024. The Substituted section \nread as follows: \n“131. \nAppeal to the Appellate Tribunal.— (1)  Where the 1[taxpayer] or Commissioner objects to an order \npassed by the Commissioner (Appeals), the 1[taxpayer] or Commissioner may appeal to the Appellate \nTribunal against such order. \n \n(2) \nAn appeal under sub-section (1) shall be –  \n \n(a)    in the prescribed form; \n(b)    verified in the prescribed manner;  \n(c) accompanied 1[, except in case of an appeal preferred by the Commissioner,] by the \nprescribed fee specified in sub-section (3); and \n1[(d) preferred to the Appellate Tribunal within sixty days of the date of service of order of the \nCommissioner (Appeals) on the taxpayer or the Commissioner, as the case may be.] \n \n1[(3)  \nThe prescribed fee shall be five thousand rupees in case of a company and two \nthousand rupees in case other than a company.]  \n \n(4) \nThe Appellate Tribunal may, upon application in writing, admit an appeal after the \nexpiration of the period specified in clause (d) of sub-section (2) if it is satisfied that the person appealing \nwas prevented by sufficient cause from filing the appeal within that period. \n \n1[(5)  \nNotwithstanding that an appeal has been filed under this section, tax shall, unless \nrecovery thereof has been stayed by the Appellate Tribunal, be payable in accordance with the \nassessment made in the case:  \n1[Provided that if on filing of application in a particular case, the Appellate Tribunal is of the \nopinion that the recovery of tax levied under this Ordinance and upheld by the Commissioner (Appeals), \nshall cause undue hardship to the taxpayer, the Tribunal, after affording opportunity of being heard to \nthe Commissioner, may stay the recovery of such tax for a period not exceeding one hundred and \neighty days in aggregate 1[:] \n1[Provided further that where recovery of tax has been stayed under this section, such stay \norder shall cease to have effect on expiration of the said period of one hundred and eighty days \nfollowing the date on which the stay order was made and the Commissioner shall proceed to recover \nthe said tax: ] \n \nProvided further that in computing the aforesaid period of one hundred and eighty days, the \nperiod, if any, for which the recovery of tax was stayed by a High Court, shall be excluded.]”. \n2 Sub-section (1) substituted by the Finance Act, 2025. The substituted sub-section read as follows: \n“(1) Subject to section 126A, any person, other than an SOE, aggrieved by any order passed by an \nofficer of Inland Revenue or Commissioner or Chief Commissioner or the Board 2[ ] under this \nOrdinance or the rules made thereunder may, within thirty days of the receipt of such order, prefer \nan appeal to the Appellate Tribunal or, as the case may be, a reference to the High Court:  \nProvided that where sub-section (11) of section 134A apply, an SOE may prefer an appeal \nunder this sub-section.” \n\n\f\nChapter X – Procedure__________________________________ \n \n268 \n \n(c)   accompanied, by the prescribed fee specified in sub-section (3); and  \n(d)  preferred to the Appellate Tribunal within thirty days of the date of    \nservice of order on the taxpayer. \n \n(3) The prescribed fee shall be twenty thousand rupees in case of a \ncompany and five thousand rupees in case other than a company.  \n \n(4) The Appellate Tribunal may, upon application in writing, admit an \nappeal after the expiration of the period specified in clause (d) of sub-section (2) if \nit is satisfied that the person preferring appeal was prevented by sufficient cause \nfrom filing the appeal within that period.  \n \n(5) Notwithstanding that an appeal has been filed under this section, tax \nshall, unless recovery thereof has been stayed by the Appellate Tribunal, be \npayable in accordance with the assessment made in the case:  \n \nProvided that on filing of application in a particular case, the Appellate \nTribunal may after affording an opportunity of being heard to the Commissioner \nhaving jurisdiction, for reasons to be recorded, stay the recovery of tax for ninety \ndays:  \n \nProvided further that the stay order shall cease to have effect, and the \nCommissioner shall be entitled to recover tax, if the taxpayer does not adhere to \nthe hearing schedule for the appeal, as determined by the Appellate Tribunal in \naccordance with the rules made under sub-section (2) of section 130:  \n \nProvided also that where an appeal is not decided within the statutory \nperiod by the Appellate Tribunal, the stay order under the second proviso shall not \ncease to have effect till finalization of the appeal by the Appellate Tribunal.] \n \n1[132. Decision of appeals by the Appellate Tribunal. — (1) The Appellate \nTribunal shall decide the appeal within ninety days of its filing:  \n                                            \n1 Section 132 substituted through The Tax Laws (Amendment) Act, 2024. The Substituted section read \nas follows: \n“132. \nDisposal of appeals by the Appellate Tribunal.— (1)  The Appellate Tribunal may, before \ndisposing of an appeal, call for such particulars as it may require in respect of the matters arising on \nthe appeal or cause further enquiry to be made by the Commissioner. \n1[(2) \nThe Appellate Tribunal shall afford an opportunity of being heard to the parties to the appeal \nand, in case of default by any of the party on the date of hearing, the Tribunal 1[ ] may proceed ex parte \nto decide the appeal on the basis of the available record.] \n1[(2A) The Appellate Tribunal shall decide the appeal within six months of its filing;] \n(3) \nWhere the appeal relates to an assessment order, the Appellate Tribunal may, 1[without \nprejudice to the powers specified in sub-section (2),]  make an order to — \n(a) \naffirm, modify or annul the assessment order; or \n1[  ] \n1[(c) \nremand the case to the Commissioner or the Commissioner (Appeals) for making such \nenquiry or taking such action as the Tribunal may direct.] \n\n\f\nChapter X – Procedure__________________________________ \n \n269 \n \nProvided that appeals pending before the Appellate Tribunal on the date \nof commencement of the Tax Laws (Amendment) Act, 2024 (ACT NO. V of 2024), \nshall be decided within one hundred and eighty days:  \n \nProvided further that where an appeal is not decided within the aforesaid \nperiod, the Appellate Tribunal shall seek condonation from the Minister of Law and \nJustice and such condonation shall not extend beyond ninety days.  \n \n(2)   At the first hearing of appeal, the Appellate Tribunal shall — \n  \n(a) bring to the notice of the taxpayer, the provisions relating to \nalternative dispute resolution under section 134A of this Ordinance; \nand  \n \n(b) if the taxpayer declines the option of alternative dispute resolution \nand wishes to continue with the appeal, fix date or dates for hearing \nand decision of the appeal in consultation with the taxpayer and \nCommissioner and in accordance with the rules.  \n \n(3) The Appellate Tribunal shall ensure strict adherence by the taxpayer \nand the Commissioner, to the hearing schedule as prescribed, and shall hear and \ndecide the appeal on the date or dates fixed, and no adjournment shall be granted, \nexcept — \n  \n(a) \nwhere there are compelling reasons for adjournment, to be recorded \nby the Appellate Tribunal; and \n  \n(b)  \non mandatory payment of such cost as the Appellate Tribunal may \ndeem fit, which shall not be less than fifty thousand rupees.  \n \n(4) Where the appeal relates to an assessment order, the Appellate \nTribunal may, without prejudice to the powers specified in sub-section (3), make \nan order to —  \n                                            \n(4) \nThe Appellate Tribunal shall not increase the amount of any assessment 1[or penalty] or \ndecrease the amount of any refund unless the taxpayer has been given a reasonable opportunity of \nshowing cause against such increase or decrease, as the case may be.  \n(5) \nWhere, as the result of an appeal, any change is made in the assessment of an association of \npersons or a new assessment of an association of persons is ordered to be made, the Appellate \nTribunal may authorise the Commissioner to amend accordingly any assessment order made on a \nmember of the association and the time limit in sub-section (2) of section 122 shall not apply to the \nmaking of such amended assessment. \n(6) \nWhere the appeal relates to a decision other than in respect of an assessment, the Appellate \nTribunal may make an order to affirm, vary or annul the decision, and issue such consequential \ndirections as the case may require. \n1[(7) \nThe Appellate Tribunal shall communicate its order to the taxpayer and the Commissioner.] \n1[  ] \n1[  ] \n(10) \nSave as provided in section 133, the decision of the Appellate Tribunal on an appeal shall be \nfinal.” \n\n\f\nChapter X – Procedure__________________________________ \n \n270 \n \n \n(a) \naffirm, modify or annul the assessment order; \n  \n(b) \nremand the case to the Commissioner for making such enquiry or \ntaking such action as the Tribunal may direct; or  \n \n(c)  \nmake such order as the Appellate Tribunal may deem fit. \n \n(5)     The Appellate Tribunal shall not increase the amount of any \nassessment or penalty or decrease the amount of any refund unless the taxpayer \nhas been given a reasonable opportunity of showing cause against such increase \nor decrease, as the case may be.  \n \n(6)   Where, as the result of an appeal, any change is made in the \nassessment of an association of persons or a new assessment of an association \nof persons is ordered to be made, the Appellate Tribunal may authorize the \nCommissioner to amend accordingly any assessment order made on a member of \nthe association and the time limit in sub-section (2) of section 122 shall not apply \nto the making of such amended assessment. \n \n(7)    Where the appeal relates to a decision other than in respect of an \nassessment, the Appellate Tribunal may make an order to affirm, vary or annul the \ndecision, and issue such consequential directions as the case may require.  \n \n(8)   The Appellate Tribunal shall communicate its order to the taxpayer \nand the Commissioner.  \n \n(9)  Save as provided in section 133, the decision of the Appellate \nTribunal on an appeal shall be final.] \n \n1[   ] \n                                            \n1Section 133 substituted by the Finance Act, 2005. The original section 133 read as follows:  \n133. \n Reference to High Court.- (1)  Where the Appellate Tribunal has made an order on an appeal under \nsection132, the taxpayer or Commissioner may, by application in such form and accompanied by such \ndocuments as may be prescribed, require the Appellate Tribunal to refer any question of law arising out of such \norder to the High Court.  \n(2) An application under sub-section (1) shall be made within ninety days of the date on which the taxpayer \nor Commissioner, as the case may be, was served with the Appellate Tribunal’s order.  \n(3) Where, on an application under sub-section (1), the Appellate Tribunal is satisfied that a question of law \narises out of its order, it shall, within ninety days of receipt of the application, draw up a statement of the case \nand refer it to the High Court. \n(4) Where, on an application under sub-section (1), the Appellate Tribunal refuses to state the case on the \nground that no question of law arises, the taxpayer or the Commissioner, as the case may be, may apply to the \nHigh Court and the High Court may, if it is not satisfied with the correctness of the decision of the Appellate \nTribunal, frame a question of law for its consideration.  \n(5) An application under sub-section (4) shall be made within one-hundred and twenty days from the date \non which the taxpayer or Commissioner, as the case may be, was served with order of the refusal.  \n(6) Sub-sections (10) through (14) shall apply to a question of law framed by the High Court in the same \nmanner as they apply to a reference made under sub-section (1). \n\n\f\nChapter X – Procedure__________________________________ \n \n271 \n \n                                            \n(7) If, on an application under sub-section (1), the Appellate Tribunal rejects the application on the ground \nthat it is time-barred, the taxpayer or Commissioner may apply to the High Court and, if the High Court is not \nsatisfied with the correctness of the Appellate Tribunal’s decision, the Court may require the Appellate Tribunal \nto treat the application as made within the time allowed under sub-section (2). \n(8) An application under sub-section (7) shall be made within ninety days from the date on which the \ntaxpayer or Commissioner, as the case may be, was served with order of the rejection.  \n(9) If the High Court is not satisfied that the statement in a case referred under sub-section (3) is sufficient \nto enable it to determine the question raised thereby, the Court may refer the case back to the Appellate Tribunal \nto make such modification therein as the Court may direct. \n(10) A reference to the High Court under this section shall be heard by a Bench of not less than two Judges \nof the High Court and, in respect of the reference, the provisions of section 98 of the Code of Civil Procedure, \n1908 (V of 1908) shall apply, so far as may be, notwithstanding anything contained in any other law for the time \nbeing in force. \n(11) The High Court upon hearing a reference under this section shall decide the questions of law raised by \nthe reference and deliver judgment thereon containing the grounds on which such decision is founded. \n(12) A copy of the judgment of the High Court shall be sent under the seal of the Court and the signature of \nthe Registrar to the Appellate Tribunal which shall pass such orders as are necessary to dispose of the case \nconformably to such judgment. \n(13) The costs of a reference to the High Court under this section shall be at the discretion of the Court. \n(14) Where a reference relates to an assessment, the tax due under the assessment shall be payable in \naccordance with the assessment, unless recovery of the tax has been stayed by the High Court. \n(15) Section 5 of the Limitation Act, 1908 (IX of 1908) shall apply to an application under sub-section \n(1). \n(16) An application under sub-section (1) by a person other than the Commissioner shall be \naccompanied by a fee of one hundred rupees.” \n\n\f\nChapter X – Procedure__________________________________ \n \n272 \n \n1[133. Reference to High Court. — (1) 2[ ] 3[Within sixty] days of the \ncommunication of the order of the Appellate Tribunal 4[ ], the aggrieved person or \nthe Commissioner may file a reference, in the prescribed form along with a \nstatement of the case, before the High Court, stating any question of law 5[ ] arising \nout of such order: \n \nProvided that the applicant shall also file complete record of the Appellate \nTribunal 6[ ] 7[ ] within fifteen days of preferring an application under this section. \n \n                                            \n1 Section 133 substituted through The Tax Laws (Amendment) Act, 2024. The Substituted section \nread as follows: \n“133. Reference to High Court.— (1) Within ninety days of the communication of the order of the \nAppellate Tribunal under sub-section (7) of section 132, the aggrieved person or the Commissioner \nmay prefer an application, in the prescribed form along with a statement of the case, to the High Court, \nstating any question of law arising out of such order. \n(2)  \nThe statement to the High Court referred to in sub-section (1), shall set out the facts, the \ndetermination of the Appellate Tribunal and the question of law which arises out of its order. \n(3)  \nWhere, on an application made under sub-section (1), the High Court is satisfied that a question \nof law arises out of the order referred to in sub-section (1), it may proceed to hear the case. \n(4)  \nA reference to the High Court under this section shall be heard by a Bench of not less than two \njudges of the High Court and, in respect of the reference, the provisions of section 98 of the Code of \nCivil Procedure, 1908 (Act V of 1908), shall apply, so far as may be, notwithstanding anything contained \nin any other law for the time being in force. \n(5)  \nThe High Court upon hearing a reference under this section shall decide the question of law \nraised by the reference and pass judgment thereon specifying the grounds on which such judgment is \nbased and the Tribunal’s order shall stand modified accordingly. The Court shall send a copy of the \njudgment under the seal of the Court to the Appellate Tribunal. \n(6)  \nNotwithstanding that a reference has been made to the High Court, the tax shall be payable in \naccordance with the order of the Appellate Tribunal: \nProvided that, if the amount of tax is reduced as a result of the judgment in the reference by the \nHigh Court and the amount of tax found refundable, the High Court may, on application by the \nCommissioner within thirty days of the receipt of the judgment of the High Court that he wants to prefer \npetition for leave to appeal to the Supreme Court, make an order authorizing the Commissioner to \npostpone the refund until the disposal of the appeal by the Supreme Court. \n(7)  \nWhere recovery of tax has been stayed by the High Court by an order, such order shall cease \nto have effect on the expiration of a period of six months following the day on which it was made unless \nthe appeal is decided or such order is withdrawn by the High Court earlier. \n(8)  \nSection 5 of the Limitation Act, 1908 (IX of 1908), shall apply to an application made to the High \nCourt under sub-section (1). \n(9)  \nAn application under sub-section (1) by a person other than the Commissioner shall be \naccompanied by a fee of one hundred rupees.” \n2 The word “Within” substituted by the Finance Act, 2024. \n3 The expression “Subject to section 126A, within thirty” substituted by the Finance Act, 2025. \n4 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \n2025. \n5 The expression “or a mixed question of law and facts” omitted by the Finance Act, 2025. \n6 Expression inserted by the Finance Act, 2024. \n7 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \n2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n273 \n \n1[ ] 2[ ]  \n \n(2) The statement to the High Court referred to in sub-section (1), shall set \nout the facts, the determination of the Appellate Tribunal 3[ ] 4[ ] and the question \nof law 5[ ] which arises out of its order.  \n \n(3) Where, on an application made under sub-section (1), the High Court \nis satisfied that a question of law 6[ ] arises out of such order referred to in sub-\nsection (1), it may proceed to hear the case.  \n \n(4) A reference to the High Court under this section shall be heard by \nSpecial Bench or the Special Benches, as the case may be, to be constituted by \nthe Chief Justice, as deemed necessary for hearing cases under this section, \ncomprising of not less than two judges of the High Court and, in respect of the \nreference, the provisions of section 98 of the Code of Civil Procedure, 1908 (Act V \nof 1908), shall apply, so far as may be, notwithstanding anything contained in any \nother law for the time being in force.  \n \n(5) The Special Bench shall decide a reference within six months from the \ndate of its filing. \n \n(6) The High Court shall establish a case management system to ensure \nthat sufficient number of Special Benches are constituted, so as to ensure that a \nreference filed under this section is decided within the stipulated six months.  \n \n(7) The High Court upon hearing a reference under this section shall \ndecide the question of law 7[ ] raised by the reference and pass judgment thereon \nspecifying the grounds on which such judgment is based and the Appellate \nTribunal's order 8[ ] 9[ ] shall stand modified accordingly.  \n \n                                            \n1 Explanation added by the Finance Act, 2024. \n2 Explanation omitted by the Finance Act, 2025. The omitted Explanation read as follows: \n“Explanation.– For the removal of doubt it is clarified that reference against order of the Commissioner \n(Appeals), communicated after the date of commencement of the Tax Laws (Amendment) Act, 2024 \n(V of 2024), shall lie before the High Court notwithstanding the proceedings pending prior to the date \nof commencement of the said Act.]” \n3 Expression inserted by the Finance Act, 2024. \n4 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \n2025. \n5 The expression “or a mixed question of law and facts” omitted by the Finance Act, 2025. \n6 The expression “or a mixed question of law and facts” omitted by the Finance Act, 2025. \n7 The expression “or a mixed question of law and facts” omitted by the Finance Act, 2025. \n8 Expression inserted by the Finance Act, 2024. \n9 The expression “or, as the case may be, the Commissioner (Appeals)’s order” omitted by the \nFinance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n274 \n \n(8) The High Court shall send a copy of the judgment under the seal of the \nHigh Court to the Appellate Tribunal 1[ ]. \n \n(9) Notwithstanding that a reference has been made to the High Court, the \ntax shall be payable in accordance with the order of the Appellate Tribunal 2[ ]:  \n \nProvided that the tax recovery shall not be made by the Commissioner for \nthirty days from the date of communication of the order of the Appellate Tribunal \n3[ ]:  \n \nProvided further that, if the amount of tax is reduced as a result of the \njudgment in the reference by the High Court and some amount of tax is found to \nbe refundable, the High Court may, on application by the Commissioner within \nthirty days of the receipt of the judgment of the High Court that he wants to prefer \npetition for leave to appeal to the Supreme Court, make an order authorizing the \nCommissioner to postpone the refund until the disposal of the appeal by the \nSupreme Court.  \n \n(10) On an application filed in a particular reference and after affording an \nopportunity of being heard to the Commissioner, the High Court may stay recovery \nof tax, subject to deposit with the assessing authority of not less than thirty percent \nof the tax determined by the Appellate Tribunal 4[ ] 5[ ]. Where recovery of tax has \nbeen stayed by the High Court by an order, such order shall cease to have effect \non the expiration of a period of six months following the day on which it was made \nunless the reference is decided or such order is withdrawn by the High Court \nearlier. \n \n(11) Section 5 of the Limitation Act, 1908 (IX of 1908), shall apply to an \napplication made to the High Court under sub-section (1).  \n \n(12) An application under sub-section (1) 6[, by the aggrieved person other \nthan the Commissioner,] shall be accompanied by a fee of fifty thousand rupees.  \n \n                                            \n1 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \n2025. \n2 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \n2025. \n3 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \n2025. \n4 Expression inserted by the Finance Act, 2024. \n5 The expression “or, as the case may be, the Commissioner (Appeals)” omitted by the Finance Act, \n2025. \n6 Expression inserted by the Finance Act, 2024. \n\n\f\nChapter X – Procedure__________________________________ \n \n275 \n \n(13) No application filed by the Commissioner under subsection (1) shall \nbe entertained unless it is accompanied by a written authorization by the relevant \nChief Commissioner.] \n \n1[  ] \n2[   ] \n                                            \n1Section 134 omitted by the Finance Act, 2005. The omitted section 134 read as follows:  \n“134. Appeal to Supreme Court.- (1)  An appeal shall lie to the Supreme Court from any judgment \nof the High Court delivered on a reference made or question of law framed under section 133 in any \ncase which the High Court certifies to be a fit one for appeal to the Supreme Court. \n \n(2) \nThe provisions of the Code of Civil Procedure, 1908 (V of 1908), relating to appeals to \nthe Supreme Court shall apply, so far as may be, in the case of an appeal under this section in like \nmanner as they apply in the case of an appeal from decrees of a High Court. \n \n(3) \nWhere the judgment of the High Court is varied or reversed in appeal under this section, \neffect shall be given to the order of the Supreme Court in the manner provided in sub-section (12) of \nsection 133 in the case of a judgment of the High Court. \n \n(4) \nThe provisions of sub-sections (11), (12) and (13) of section 133 shall apply in the case \nof an appeal to the Supreme Court made under this section as they apply to an appeal to the High \nCourt under section 133.” \n2The section 134A substituted by the Finance Act 2020 dated 30th June, 2020, the substituted section \nread as follows:134A. Alternative Dispute Resolution.— (1) Notwithstanding any other provision of this \nOrdinance, or the rules made thereunder, an aggrieved person in connection with any dispute pertaining to— \n(a) \nthe liability of tax against the aggrieved person, or admissibility of refunds, as the case may be; \n(b) \nthe extent of waiver of default surcharge and penalty; or \n(c) \nany other specific relief required to resolve the dispute, \nmay apply to the Board for the appointment of a committee for the resolution of  any hardship or dispute mentioned \nin detail in the application, which is under  litigation in any court of law or an Appellate Authority, except where criminal \nproceedings have been initiated or where interpretation of question of law is involved having effect on other cases. \n(2) \nThe Board may, after examination of the application of an aggrieved person, appoint a committee, \nwithin sixty days of receipt of such application in the Board, comprising,— \n(i) \nan officer of Inland Revenue not below the rank of a Commissioner; \n(ii) \nperson to be nominated by the taxpayer from a panel notified by the Board comprising,— \n(a) \n2[  ] chartered \naccountants, 2[cost and management accountants] and 2[  ] \nadvocates having 2[minimum ten years] experience in the field of taxation; and \n(b) \nreputable businessmen as nominated by Chambers of Commerce and  industry: \nProvided that the taxpayer shall not nominate a Chartered Accountant 2[or cost and \nmanagement accountant] or an advocate if the said Chartered Accountant 2[or cost and \nmanagement accountant] or the advocate is or has been an auditor or an authorized \nrepresentative of the taxpayer; and \n(iii) \na retired Judge not below the rank of District and Sessions Judge, to be nominated through \nconsensus by the members appointed under clauses (i) and (ii). \n(3) \nThe aggrieved person, or the Commissioner, or both, as the case may be, shall withdraw the appeal \npending before any court of law or an Appellate Authority, after constitution of the committee by the Board under sub-\nsection (2). \n(4) \nThe committee shall not commence the proceedings under          sub-section (5) unless the order of \nwithdrawal by the court of law or the Appellate Authority is communicated to the Board: \nProvided that if the order of withdrawal is not communicated within seventy five days of the \nappointment of the committee, the said  committee  shall  be  dissolved  and  provisions  of  this  section shall \nnot apply. \n(5) \nThe Committee appointed under sub-section (2) shall examine the issue and may, if it deems \nnecessary, conduct inquiry, seek expert opinion, direct any officer of the Inland Revenue or any other person to \nconduct an audit and shall decide the dispute by majority, within one hundred and twenty days of its appointment: \nProvided that in computing the aforesaid period of one hundred and twenty days, the period, if any, \nfor communicating the order of withdrawal under sub-section (4) shall be excluded. \n(6) \nThe recovery of tax payable by a taxpayer in connection with any dispute for which a Committee \nhas been appointed under sub- section (2) shall be deemed to have been stayed on withdrawal of appeal up to the \ndate of decision by the Committee. \n(7) \nThe decision of the committee under sub-section (5) shall be binding on the Commissioner and the \naggrieved person. \n\n\f\nChapter X – Procedure__________________________________ \n \n276 \n \n                                            \n(8) \nIf the Committee fails to decide within the period of one hundred and  twenty days under sub-section \n(5), the Board shall dissolve the committee by an order in writing and the matter shall be decided by the court of law \nor the  Appellate Authority which issued the order of withdrawal under sub-section (4) and the appeal shall be treated \nto be pending before such court of law or the Appellate Authority as if the appeal had never been withdrawn. \n(9) \nThe Board shall communicate the order of dissolution to the court of law or the Appellate Authority \nand the Commissioner. \n \n(10) \nThe aggrieved person, on receipt of the order of dissolution, shall communicate it to the court of law \nor the Appellate Authority, which \nshall \ndecide the appeal within six months of the communication of said order. \n(11) \nThe aggrieved person may make the payment of income tax and other taxes as decided by the \ncommittee under sub-section (5) and all decisions, orders and judgments made or passed shall stand modified to that \nextent. \n(12) \nThe Board may prescribe the amount to be paid as remuneration for the services of the members \nof the Committee, other than the member appointed under clause (i) of sub-section (2). \n(13) \nThe Board may, by notification in the official Gazette, make rules for carrying out the purposes of \nthis section. \n\n\f\nChapter X – Procedure__________________________________ \n \n277 \n \n1[134A. Alternative Dispute Resolution. – 1[(1) Notwithstanding any other \nprovision of this Ordinance, or the rules made thereunder, an aggrieved person in \nconnection with any dispute pertaining to — \n                                            \n1 Section 134A substituted by the Finance Act, 2023. The Substituted section read as follows: \n“134A. Alternative Dispute Resolution. — (1) Notwithstanding any other provision of the Ordinance, \nor the rules made thereunder, an aggrieved person in connection with any dispute pertaining to— \n(a) \nthe liability of tax of one hundred million and above against the aggrieved person or \nadmissibility of refund, as the case may be; \n(b) \nthe extent of waiver of default surcharge and penalty; or \n(c) \nany other specific relief required to resolve the dispute; may apply to the Board for the \nappointment of a committee for the resolution of any hardship or dispute mentioned in \ndetail in the application, which is under litigation in any court of law or an Appellate \nAuthority, except where criminal proceedings have been initiated. \n   \n(2) \nThe application for dispute resolution shall be accompanied by an initial proposition for \nresolution of the dispute, including an offer of tax payment, from which, the applicant would not be \nentitled to retract. \n(3) \nThe Board may, after examination of the application of an aggrieved person, appoint a \ncommittee, within forty five days of receipt of such application in the Board, comprising,— \n(i) \nChief Commissioner Inland Revenue having jurisdiction over the case; \n(ii) \nperson to be nominated by the taxpayer from a panel notified by the Board comprising \n– \n(a) chartered accountants, cost and management accountants and advocates having \na minimum of ten years’ experience in the field of taxation; \n(b) officers of the Inland Revenue Service who have retired in BS 21 or above; or \n(c) reputable businessmen as nominated by Chambers of Commerce and Industry: \nProvided that the taxpayer shall not nominate a Chartered Accountant or an \nadvocate if the said Chartered Accountant or the advocate is or has been an \nauditor or an authorized representative of the taxpayer; and \n(d) person to be nominated through consensus by the members appointed under (i) \nand (ii) above, from the panel as notified by the Board in clause (ii) above: \nProvided that where the member under this clause cannot be appointed \nthrough consensus, the Board may nominate a member proposed by the taxpayer \neligible to be nominated as per clause (ii). \n(4) \nThe aggrieved person, or the Commissioner, or both, as the case may be, shall \nwithdraw the appeal pending before any court of law or an Appellate Authority, after constitution of \nthe committee by the Board under sub-section (3), in respect of dispute as mentioned in sub-section \n(1). \n(5) \nThe committee shall not commence the proceedings under sub-section (6) unless the \norder of withdrawal by the court of law or the Appellate Authority is communicated to the Board:  \nProvided that if the order of withdrawal is not communicated within seventy five days of \nthe appointment of the committee, the said committee shall be dissolved and provisions of this \nsection shall not apply. \n(6) \nThe Committee appointed under sub-section (3) shall examine the issue and may, if it \ndeems necessary, conduct inquiry, seek expert opinion, direct any officer of the Inland Revenue or \nany other person to conduct an audit and shall decide the dispute by majority, within one hundred and \ntwenty days of its appointment:  \nProvided that in computing the aforesaid period of one hundred and twenty days, the period, if \nany, for communicating the order of withdrawal under sub-section (5) shall be excluded. \n(7) \nThe decision by the Committee under sub-section (6) shall not be cited or taken as a \nprecedent in any other case or in the same case for a different tax year. \n(8) \nThe recovery of tax payable by a taxpayer in connection with any dispute for which a \nCommittee has been appointed under sub-section (3) shall be deemed to have been stayed on \nwithdrawal of appeal up to the date of decision by the Committee or the dissolution of the Committee \nwhichever is earlier. \n\n\f\nChapter X – Procedure__________________________________ \n \n278 \n \n  \n \n(a) \nthe liability of tax of fifty million rupees or above against the aggrieved \nperson or admissibility of refund, as the case may be;  \n \n(b)  \nthe extent of waiver of default surcharge and penalty; or  \n \n(c)  \nany other specific relief required to resolve the dispute,  \n \nmay apply, except where criminal proceedings have been initiated, to the Board \nfor the appointment of a committee for the resolution of any hardship or dispute \nmentioned in detail in the application:  \n \nProvided that where the aggrieved person is a state-owned enterprise \n(SOE), the limit of tax liability of fifty million rupees or above mentioned in clause \n(a) of sub-section (1) shall not apply and it shall be mandatory for such aggrieved \nSOE to apply to the Board for the appointment of a committee for the resolution \nof any dispute under this section: \n  \nProvided further that no suit, prosecution, or other legal proceedings shall \nlie against the SOE or the committee in relation to the dispute resolved under this \nsection. \n                                            \n(9) \nThe decision of the committee under sub-section (6) shall be binding on the \nCommissioner and the aggrieved person. \n(10) \nIf the Committee fails to decide within the period of one hundred and twenty days under \nsub-section (6), the Board shall dissolve the committee by an order in writing and the matter shall be \ndecided by the court of law or the Appellate Authority which issued the order of withdrawal under sub-\nsection (5) and the appeal shall be treated to be pending before such court of law or the Appellate \nAuthority as if the appeal had never been withdrawn. \n(11) \nThe Board shall communicate the order of dissolution to the court of law or the Appellate \nAuthority and the Commissioner. \n(12) \nThe aggrieved person, on receipt of the order of dissolution, shall communicate it to the \ncourt of law or the Appellate Authority, which shall decide the appeal within six months of the \ncommunication of said order. \n(13) \nThe aggrieved person may make the payment of income tax and other taxes as decided \nby the committee under sub-section (6) and all decisions, orders and judgments made or passed shall \nstand modified to that extent. \n(14) \nThe Board may prescribe the amount to be paid as remuneration for the services of the \nmembers of the Committee, other than the member appointed under clause (i) of sub-section (3).  \n(15) \nThe Board may, by notification in the official Gazette, make rules for carrying out the \npurposes of this section.] \n1 Sub-sections (1) and (2) substituted through The Tax Laws (Amendment) Act, 2024. The substituted \nsub-sections read as follows: \n“(1) Notwithstanding any other provision of this Ordinance, or the rules made thereunder, an \naggrieved person in connection with any dispute pertaining to –  \n(a) the liability of tax of one hundred million rupees or above against the aggrieved person or \nadmissibility of refund, as the case may be;  \n(b) the extent of waiver of default surcharge and penalty; or  \n(c) \nany other specific relief required to resolve the dispute, may apply to the Board for the \nappointment of a committee for the resolution of any hardship or dispute mentioned in detail in the \napplication, which is under litigation in any court of law or an appellate authority, except where \ncriminal proceedings have been initiated.  \n(2) The application for dispute resolution under sub-section (1) shall be accompanied by an initial \nproposition for resolution of the dispute, including an offer of tax payment.” \n\n\f\nChapter X – Procedure__________________________________ \n \n279 \n \n Explanation.—State-owned enterprise shall have the same meaning as \nassigned thereto in the State-Owned Enterprises (Governance and Operations) \nAct, 2023 (VII of 2023). \n \n(2)     The application for dispute resolution under sub-section (1) shall be \naccompanied by —  \n \n(a)  an initial proposition for resolution of the dispute, including an offer \nof tax payment; and \n  \n(b) an undertaking that the applicant shall accept the decision of the \nCommittee which shall be binding on him in all respects and shall \non receipt of the decision immediately withdraw any and all pending \nlitigation or cases of any kind in respect of the dispute, mentioning \ndetails thereof: \n \nProvided that if the applicant is an SOE, it shall withdraw any and all such \npending litigation and cases immediately and mention the details thereof in the \nundertaking: \n \nProvided further that the SOE may file an appeal to the Appellate Tribunal \nor a reference to the High Court or a petition for leave to appeal the Supreme \nCourt, as the case may be, where subsection (11) is applicable.] \n \n(3) \nThe Board may, after examination of the application of an aggrieved \nperson, appoint a committee, within fifteen days of receipt of such application in \nthe Board, comprising, –  \n \n(i) \na retired judge not below the rank of a judge of a High Court, \nwho shall also be the Chairperson of the Committee, to be \nnominated by the Board from a panel notified by the Law and \nJustice Division for such purpose;  \n \n(ii) \nthe Chief Commissioner Inland Revenue having jurisdiction \nover the case; and \n  \n(iii) \na person to be nominated by the taxpayer from a panel notified \nby the Board comprising –  \n \n(a) \nchartered \naccountants, \ncost \nand \nmanagement \naccountants and advocates having a minimum of ten \nyears’ experience in the field of taxation;  \n \n(b)  \nofficers of the Inland Revenue Service who stood retired \nin BS 21 or above; or \n  \n(c)  \nreputable businessmen as nominated by the Chambers \nof Commerce and Industry:  \n \n\n\f\nChapter X – Procedure__________________________________ \n \n280 \n \nProvided that the taxpayer shall not nominate a chartered \naccountant or an advocate if the said chartered accountant or \nthe advocate is or has been an auditor or an authorized \nrepresentative of the taxpayer. \n  \n(4)  \nThe Board shall communicate the order of appointment of Committee \nto the aggrieved person, court of law or the appellate authority where the dispute \nis pending and to the concerned Commissioner.  \n \n(5)  \nThe Committee appointed under sub-section (3) shall examine the \nissue and may, if it deems necessary, conduct inquiry, seek expert opinion, direct \nany officer of the Inland Revenue or any other person to conduct an audit and shall \ndecide the dispute by majority, within forty-five days of its appointment extendable \nby another fifteen days for the reasons to be recorded in writing.  \n \n(6)  \nThe decision by the Committee under sub-section (5) shall not be cited \nor taken as a precedent in any other case or in the same case for a different tax \nyear.  \n \n(7)  \nThe recovery of tax payable by a taxpayer in connection with any \ndispute for which a Committee has been appointed under sub-section (3) shall be \ndeemed to have been stayed on the constitution of Committee till the final decision \nor dissolution of the Committee, whichever is earlier.  \n \n(8)  \nThe decision of the Committee under sub-section (5) shall be binding \non the Commissioner when the aggrieved person, being satisfied with the decision, \nhas withdrawn the appeal pending before the court of law or any appellate authority \nin respect of dispute as mentioned in sub-section (1) and has communicated the \norder of withdrawal to the Commissioner:  \n \nProvided that if the order of withdrawal is not communicated to the \nCommissioner within sixty days of the service of decision of the Committee upon \nthe aggrieved person, the decision of the Committee shall not be binding on the \nCommissioner.  \n \n(9) \nSubject to sub-section (10), the Commissioner shall also withdraw the \nappeal, if any, pending before any court of law or an appellate authority in respect \nof dispute as mentioned in sub-section (1) within thirty days of the communication \nof the order of withdrawal by the aggrieved person to the Commissioner.  \n \n(10)  The aggrieved person shall make the payment of income tax and \nother taxes and within such time as decided by the Committee under sub-section \n(5) and all decisions and orders made or passed shall stand modified to that extent.  \n \n(11)  1[Subject to sub-section (11A), if] the Committee fails to decide within \nthe period of sixty days under sub-section (5), the Board shall dissolve the \n                                            \n1 The word “If” substituted by the Finance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n281 \n \nCommittee by an order in writing and the matter shall be decided by the court of \nlaw or the appellate authority where the dispute is pending under litigation.  \n \n1[(11A) In the case of a state-owned enterprise, if the Committee fails to \ndecide within a period of sixty days, the Board shall reappoint a Committee under \nsub-section (3), that shall decide the dispute in accordance with sub-section (5) of \nthis section. \n \n(11B) Sub-section (11) shall apply, in case of a state-owned enterprise, if \nthe reappointed Committee fails to decide the matter within a further period of sixty \ndays.] \n \n(12)  The Board shall communicate the order of dissolution to the aggrieved \nperson, court of law or the appellate authority and to the Commissioner.  \n \n2[(13)   On receipt of the order of dissolution, the court of law or the Appellate \nTribunal shall decide the appeal within ninety days of the communication of the \nsaid order.] \n \n(14)  The Board may prescribe the amount to be paid as remuneration for \nthe services of the members of the Committee, other than the member appointed \nunder clause (ii) of sub-section (3).  \n \n(15)  The Board may, by notification in the official Gazette, make rules for \ncarrying out the purposes of this section.] \n \n3[ ] \n                                            \n1 Sub-sections (11A) and (11B) inserted by the Finance Act, 2025. \n2 Sub-section (13) substituted through Tax Laws (Amendment) Act, 2024. The substituted sub-section \nread as follows: \n“(13)  On receipt of the order of dissolution, the court of law or the appellate authority shall decide the \nappeal within six months of the communication of the said order.” \n3Section 135 omitted by the Finance Act, 2002. The omitted section 135 read as follows: \n“135. Revision by the Commissioner.- (1)  The Commissioner may either of the Commissioner’s own motion or \non application in writing by a person for revision, call for the record of any proceeding under this Ordinance in which \nan order has been passed by any taxation officer other than the Commissioner (Appeals).  \n(2) \nSubject to sub-section (3), where, after making such inquiry as is necessary, Commissioner \nconsiders that the order requires revision, the Commissioner may make such revision to the order as the \nCommissioner thinks fit. \n(3) \nAn order under sub-section (2) shall not be prejudicial to the person to whom the order relates. \n(4) \nThe Commissioner shall not revise any order under sub-section (2) if – \n(a) \nwhere an appeal against the order lies to the Commissioner (Appeals) or to the Appellate \nTribunal, the time within which such appeal may be made has not expired, or the person \nhas not waived their right of appeal; \n(b) \nthe order is pending on appeal before the Commissioner (Appeals) or has been made the \nsubject of an appeal to the Appellate Tribunal; or \n(c) \nin the case of an application made by a person, the application has not been made within \nninety days of the date on which such order was served on the person, unless the \nCommissioner is satisfied that the person was prevented by sufficient cause from making \nthe application within the time allowed. \n(5)  No application for revision of an assessment order may be made under sub-section (1) unless the amount \nof tax due under the assessment that is not in dispute has been paid by the taxpayer. \n\n\f\nChapter X – Procedure__________________________________ \n \n282 \n \n136.  Burden of proof.— In any appeal 1[by a taxpayer] under this Part, the \nburden shall be on the taxpayer to prove, on the balance of probabilities — \n \n(a) in the case of an assessment order, the extent to which the order does \nnot correctly reflect the taxpayer’s tax liability for the tax year; or \n \n(b) in the case of any other decision, that the decision is erroneous. \n                                            \n(6)  An application under sub-section (1) shall be accompanied by – \n(a) \nin relation to an assessment order, a fee of the lesser of two thousand five hundred rupees \nor ten per cent of the tax assessed; or \n(b) \nin any other case – \n(i) \nwhere the applicant is a company, a fee of two thousand rupees; or \n(ii) \nwhere the applicant is not a company, a fee of five hundred rupees. \n(7)  An order by the Commissioner declining to interfere shall not be treated as an order prejudicial to the \napplicant.” \n1 Inserted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n283 \n \nPART IV \nCOLLECTION AND RECOVERY OF TAX \n \n137.  Due date for payment of tax.— (1)  The tax payable by a taxpayer on the \ntaxable income of the taxpayer 1[including the tax payable under 2[ ] ] 3[section \n4[113 or] 113A] for a tax year shall be due on the due date for furnishing the \ntaxpayer’s return of income for that year. \n \n5[(2) Where any tax is payable under an assessment order or an amended \nassessment order or any other order issued by the Commissioner under this \nOrdinance, a notice shall be served upon the taxpayer in the prescribed form \nspecifying the amount payable and thereupon the sum so specified shall be paid \nwithin 6[ 7[thirty]  ] days from the date of service of the notice 8[:] 9[ ] \n \n10[Provided that the due date for payment of tax payable under sub- section \n(7) of section 147 shall be the date specified in sub-section (5) or sub-section (5A) \nor first proviso to sub-section (5B) of section 147.] \n \n11[ 12[ ]  ] \n \n13[ 14[ ]  ] \n                                            \n1 Inserted by the Finance Act, 2003. Earlier this was inserted by S.R.O. 633(I)/2002, dated 14.09.2002 \nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. \n2The words and figure “section 113 or” omitted by the Finance Act, 2008. \n3 Inserted by the Finance Act, 2004. \n4 Inserted by the Finance Act, 2009. \n5 Substituted by the Finance Act, 2003. The substituted sub-section (2) read as follows:  \n“(2) \nWhere an assessment order or amended assessment order is issued by the  \nCommissioner, the tax payable under the order shall be payable within fifteen days from the date of \nthe assessment order is issued. “ \n6The word “thirty” substituted by the Finance Act, 2008. \n7The word “fifteen” substituted by the Finance Act, 2015. \n8 Full stop substituted by the Finance Act, 2018 \n9Colon substituted by the Finance Act, 2017. \n10Added by the Finance Act, 2018. \n11Added by the Finance Act, 2010. \n12 Proviso omitted by the Finance Act, 2017. The omitted provision read as follows: \n \n \n“Provided that the tax payable as a result of provisional assessment order under section 122C, \nas specified in the notice under sub-section (2) shall be payable immediately after a period of forty-\nfive days from the date of service of the notice” \n13Added by the Finance Act, 2012. \n14Proviso omitted by the Finance Act, 2017. The omitted provision read as follows: \n \n \n“Provided further that the taxpayer may pay the tax payable prior to expiry of the period of forty-\nfive days specified in the first proviso.” \n\n\f\nChapter X – Procedure__________________________________ \n \n284 \n \n \n(3) \nNothing in sub-section (2) 1[or (4)] shall affect the operation of sub-\nsection (1). \n \n \n(4) \nUpon written application by a taxpayer, the Commissioner may, where \ngood cause is shown, grant the taxpayer an extension of time for payment of tax \ndue 2[under sub-section (2)] or allow the taxpayer to pay 3[such tax] in instalments \nof equal or varying amounts as the Commissioner may determine having regard \nto the circumstances of the case. \n \n \n(5) \nWhere a taxpayer is permitted to pay tax by instalments and the \ntaxpayer defaults in payment of any instalments, the whole balance of the tax \noutstanding shall become immediately payable. \n \n \n(6) \nThe grant of an extension of time to pay tax due or the grant of \npermission to pay tax due by instalments shall not preclude the liability for 4[default \nsurcharge] arising under section 205 from the due date of the tax under sub-\nsection 5[(2)]. \n \n6[  ] \n \n7[138. Recovery of tax out of property and through arrest of taxpayer.— (1) \nFor the purpose of recovering any tax due by a taxpayer, the Commissioner may \nserve upon the taxpayer a notice in the prescribed form requiring him to pay the \nsaid amount within such time as may be specified in the notice. \n \n \n(2)  \nIf the amount referred to in the notice issued under sub-section (1) is \nnot paid within the time specified therein or within the further time, if any, allowed \n                                            \n1Inserted by the Finance Act, 2003. Earlier this was inserted by S.R.O. 633(I)/2002, dated 14.09.2002 \nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. \n2 Inserted by the Finance Act, 2003. \n3The words “any tax due” substituted by the Finance Act, 2003. \n4The word s “additional tax” substituted by the Finance Act, 2010. \n5The brackets and figure “(1)” substituted by the Finance Act, 2003. \n6Sub-section (7) omitted by the Finance Act, 2002. The omitted sub-section (7) read as under: \n“(7) \nA taxpayer dissatisfied with a decision under sub-section (4) may challenge the decision \nonly under Part III of this Chapter.” \n7Section 138 substituted by Finance Act, 2002. The substituted section 138 read as follows: \n“138. Tax as a debt due to the Federal Government.- (1)  Any tax due under this Ordinance by a \ntaxpayer shall be a debt due to the Federal Government and shall be payable in the manner and at \nthe place prescribed. \n(2) \nAny tax that has not been paid by the due date may be sued for and recovered in any \ncourt of competent jurisdiction by the Commissioner acting in the Commissioner’s official name. \n(3) \nIn any suit under sub-section (2), the production of a certificate signed by the \nCommissioner stating the name and address of the taxpayer and the amount of tax due shall be \nconclusive evidence of the amount of tax due by such taxpayer.”  \n\n\f\nChapter X – Procedure__________________________________ \n \n285 \n \nby the Commissioner, the Commissioner may proceed to recover from the \ntaxpayer the said amount by one or more of the following modes, namely:— \n \n(a)  \nattachment and sale of any movable or immovable property of \nthe taxpayer; \n \n(b)  \nappointment of a receiver for the management of the movable \nor immovable property of the taxpayer; 1[  ]  \n \n(c)  \narrest of the taxpayer and his detention in prison for a period not \nexceeding six months 2[; and \n \n(d) \nas specified under clauses (a), (ca) and (d) of sub-section (I) of \nsection 48 of the Sales Tax Act, 1990.] \n \n \n(3)  \nFor the purposes of recovery of tax under sub-section (2), the \nCommissioner shall have the same powers as a Civil Court has under the Code of \nCivil Procedure, 1908 (Act V of 1908), for the purposes of the recovery of any \namount due under a decree. \n \n3[(3A) Notwithstanding anything contained in this Ordinance or any other law \nor any rule, any decision or judgment of any court, forum or authority, the tax \npayable under any provision of this Ordinance or any assessment order shall \nbecome immediately payable subject to the following conditions —  \n \n(a) \nthat the case has been decided in the favor of the department at three \nappellate forums including the High Court;  \n \n(b) \nthat the recovery under this section shall only be made to the extent \nof lowest amount of demand which has been confirmed by any of the \nthree appellate forums; and  \n \n(c) \nthat the tax payable exceeds rupees two hundred million,  \n \nand the Commissioner shall proceed to recover the said amount irrespective of the \ntime provided under any other provision or the said decision or judgment.] \n \n(4) \nThe 4[Board] may make rules regulating the procedure for the \nrecovery of tax under this section and any other matter connected with, or \nincidental to, the operation of this section.] \n \n                                            \n1 The word “and” omitted through Finance Act, 2020 dated 30th June, 2020  \n2 Full stop substituted by “semi colon” and the word “and” thereafter new clause (d) added through \nFinance Act, 2020 dated 30th June, 2020  \n3 Sub-section (3A) inserted by the Finance Act, 2025. \n4 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nChapter X – Procedure__________________________________ \n \n286 \n \n1[138A. Recovery of tax by District Officer (Revenue).— (1) The Commissioner \nmay forward to the District Officer (Revenue) of the district in which the taxpayer \nresides or carries on business or in which any property belonging to the taxpayer \nis situated, a certificate specifying the amount of any tax due from the taxpayer, \nand, on receipt of such certificate, the District Officer (Revenue) shall proceed to \nrecover from the taxpayer the amount so specified as, it were an arrear of land \nrevenue. \n \n \n(2)  \nWithout prejudice to any other power of the District Officer (Revenue) \nin this behalf, he shall have the same powers as a Civil Court has under the Code \nof Civil Procedure, 1908 (Act V of 1908), for the purpose of the recovery of the \namount due under a decree.] \n \n2[138B. Estate in bankruptcy.—(1) If a taxpayer is declared bankrupt, the tax \nliability under this Ordinance shall pass on to the estate in bankruptcy. \n \n \n(2)  \nIf tax liability is incurred by an estate in bankruptcy, the tax shall be \ndeemed to be a current expenditure in the operations of the estate in bankruptcy \nand shall be paid before the claims preferred by other creditors are settled.] \n \n139.  Collection of tax in the case of private companies and associations of \npersons.—(1) Notwithstanding anything in the 3[Companies Act, 2017 (XIX of \n2017)], where any tax payable by a private company (including a private company \nthat has been wound up or gone into liquidation) in respect of any tax year cannot \nbe recovered from the company, every person who was, at any time in that tax \nyear — \n \n(a) \na director of the company, other than an employed director; or \n \n(b) \na shareholder in the company owning not less than ten per cent of \nthe paid-up capital of the company, \n \nshall be jointly and severally liable for payment of the tax due by the company. \n \n \n(2)     Any director who pays tax under sub-section (1) shall be entitled to \nrecover the tax paid from the company or a share of the tax from any other director. \n \n \n(3) \nA shareholder who pays tax under sub-section (1) shall be entitled to \nrecover the tax paid from the company or from any other shareholder to whom \nclause (b) of sub-section (1) applies in proportion to the shares owned by that other \nshareholder. \n \n                                            \n1Inserted by the Finance Act, 2002. \n2Added by the Finance Act, 2010. \n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \n\n\f\nChapter X – Procedure__________________________________ \n \n287 \n \n \n(4) \nNotwithstanding anything in any law, where any tax payable by a \nmember of an association of persons in respect of the member’s share of the \nincome of the association in respect of any tax year cannot be recovered from the \nmember, the association shall be liable for the tax due by the member.  \n \n \n1[(5) Notwithstanding anything contained in any other law, for the time \nbeing in force, where any tax payable by an association of persons in respect of \nany tax year cannot be recovered from the association of persons, every person \nwho was, at any time in that year, a member of the association of persons, shall \nbe jointly and severally liable for payment of the tax due by the association of \npersons. \n \n \n(6) \nAny member who pays tax under sub-section (5) shall be entitled to \nrecover the tax paid from the association of persons or a share of the tax from any \nother member.]  \n \n \n2[(7)] The provisions of this Ordinance shall apply to any amount due under \nthis section as if it were tax due under an assessment order. \n \n140. Recovery of tax from persons holding money on behalf of a taxpayer.— \n(1)  For the purpose of recovering any tax due by a taxpayer, the Commissioner \nmay, by notice, in writing, require any person – \n \n(a) \nowing or who may owe money to the taxpayer; or \n \n(b) \nholding or who may hold money for, or on account of the taxpayer; \n \n(c) \nholding or who may hold money on account of some other person for \npayment to the taxpayer; or \n \n(d) \nhaving authority of some other person to pay money to the taxpayer, \n \nto pay to the Commissioner so much of the money as set out in the notice by the \ndate set out in the notice3[:] \n \n4[Provided that the Commissioner shall not issue notice under this \nsub-section for recovery of any tax due from a taxpayer if the said taxpayer \nhas filed an appeal under section 127 in respect of the order under which \nthe tax sought to be recovered has become payable and the appeal has not \nbeen decided by the Commissioner (Appeals), subject to the condition that \n5[ten] per cent of the said amount of tax due has been paid by the taxpayer.] \n \n                                            \n1New sub-sections (5) and (6) inserted through Finance Act, 2019. \n2Sub-section (5) re-numbered as sub-section (7) through Finance Act, 2019.  \n3 Full-stop substituted by the Finance Act, 2016. \n4 Added by the Finance Act,  2016. \n5The expression “twenty-five” substituted by the Finance Act, 2018 \n\n\f\nChapter X – Procedure__________________________________ \n \n288 \n \n \n(2) \nSubject to sub-section (3), the amount set out in a notice under sub-\nsection (1) — \n \n(a) \nwhere the amount of the money is equal to or less than the \namount of tax due by the taxpayer, shall not exceed the amount \nof the money; or \n \n(b) \nin any other case, shall be so much of the money as is sufficient \nto pay the amount of tax due by the taxpayer.  \n \n \n(3) \nWhere a person is liable to make a series of payments (such as salary) to \na taxpayer, a notice under sub-section (1) may specify an amount to be paid out of each \npayment until the amount of tax due by the taxpayer has been paid.  \n \n \n(4) \nThe date for payment specified in a notice under sub-section (1) shall \nnot be a date before the money becomes payable to the taxpayer or held on the \ntaxpayer’s behalf.  \n \n(5) \nThe provisions of sections 160, 161, 162 and 163, so far as may be, \nshall apply to an amount due under this section as if the amount were required to \nbe deducted from a payment under Division III of Part V of this Chapter. \n \n \n(6) \n Any person who has paid any amount in compliance with a notice \nunder sub-section (1) shall be treated as having paid such amount under the \nauthority of the taxpayer and the receipt of the Commissioner constitutes a good \nand sufficient discharge of the liability of such person to the taxpayer to the extent \nof the amount referred to in such receipt. \n \n \n1[(6A) Notwithstanding anything contained in this Ordinance or any other law \nor any rule, any decision or judgment of any court, forum or authority, the tax \npayable under any provision of this Ordinance or any assessment order shall \nbecome immediately payable subject to the following conditions —  \n \n(a) \nthat the case has been decided in the favor of the department at three \nappellate forums including the High Court;  \n \n(b) \nthat the recovery under this section shall only be made to the extent \nof lowest amount of demand which has been confirmed by any of the \nthree appellate forums; and  \n \n(c) \nthat the tax payable exceeds rupees two hundred million,  \n \nand the Commissioner shall proceed to recover the said amount irrespective of the \ntime provided under any other provision or the said decision or judgment.] \n \n                                            \n1 Sub-section (6A) inserted by the Finance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n289 \n \n \n1[  ] \n \n2[  ] \n \n3[  ] \n \n \n(10)  In this section, \"person\" includes any Court, Tribunal or any other \nauthority. \n141. Liquidators.— (1)  Every person (hereinafter referred to as a “liquidator”) \nwho is – \n(a) \na liquidator of a company; \n(b) \na receiver appointed by a Court or appointed out of Court; \n(c) \na trustee for a bankrupt; or \n(d) \na mortgagee in possession, \nshall, within fourteen days of being appointed or taking possession of an asset in \nPakistan, whichever occurs first, give written notice thereof to the Commissioner. \n \n(2) \nThe Commissioner shall, within three months of being notified under \nsub-section (1), notify the liquidator in writing of the amount which appears to the \nCommissioner to be sufficient to provide for any tax which is or will become \npayable by the person whose assets are in the possession of the liquidator. \n \n(3) \nA liquidator shall not, without leave of the Commissioner, part with any \nasset held as liquidator until the liquidator has been notified under sub-section (2). \n \n(4) \nA liquidator — \n(a) \nshall set aside, out of the proceeds of sale of any asset by the \nliquidator, the amount notified by the Commissioner under sub-\nsection (2), or such lesser amount as is subsequently agreed to \nby the Commissioner;  \n(b) \nshall be liable to the extent of the amount set aside for the tax \nof the person who owned the asset; and  \n                                            \n1 Sub-section (7) omitted by the Finance Act, 2003. The omitted sub-section (7) read as follows:  \n“(7) \nWhere an amount has been paid under sub-section (1), the taxpayer shall be allowed \na tax credit for the amount (unless the amount paid represents a final tax on the taxpayer’s income) \nin computing the tax due by the taxpayer on the taxpayer’s taxable income for the tax year in which \nthe amount was paid.” \n2Sub-section (8) omitted by the Finance Act, 2003. The omitted sub-section (8) read as follows: \n“(8) \nThe tax credit allowed under this section shall be applied in accordance with sub-section \n(3) of section 4.” \n3 Sub-section (9) omitted by the Finance Act, 2003. The omitted sub-section (9) read as follows:  \n“(9) \nA tax credit or part of a tax credit allowed under this section for a tax year that is not \nable to be credited under sub-section (3) of section 4 for the year must be refunded to the taxpayer \nin accordance with section 170.” \n\n\f\nChapter X – Procedure__________________________________ \n \n290 \n \n(c) \nmay pay any debt that has priority over the tax referred to in this \nsection notwithstanding any provision of this section. \n \n(5) \nA liquidator shall be personally liable to the extent of any amount \nrequired to be set aside under sub-section (4) for the tax referred to in sub-section \n(2) if, and to the extent that, the liquidator fails to comply with the requirements of \nthis section. \n \n(6) \nWhere the proceeds of sale of any asset are less than the amount \nnotified by the Commissioner under sub-section (2), the application of sub-sections \n(4) and (5) shall be limited to the proceeds of sale. \n \n \n(7) \nThis section shall have effect notwithstanding anything contained in \nany other law for the time being in force. \n \n \n(8) \nThe provisions of this Ordinance shall apply to any amount due under \nthis section as if it were tax due under an assessment order. \n \n142. Recovery of tax due by non-resident member of an association of \npersons.— (1)  The tax due by a non-resident member of an association of \npersons in respect of the member’s share of the profits of the association shall be \nassessable in the name of the association or of any resident member of the \nassociation and may be recovered out of the assets of the association or from the \nresident member personally. \n \n \n(2) \nA person making a payment under this section shall be treated as \nacting under the authority of the non-resident member and is hereby indemnified \nin respect of the payment against all proceedings, civil or criminal, and all \nprocesses, judicial or extra-judicial, notwithstanding any provisions to the contrary \nin any written law, contract or agreement. \n \n \n(3) \nThe provisions of this Ordinance shall apply to any amount due under \nthis section as if it were tax due under an assessment order. \n \n143.  Non-resident ship owner or charterer.— (1)  Before the departure of a \nship owned or chartered by a non-resident person from any port in Pakistan, the \nmaster of the ship shall furnish to the Commissioner a return showing the gross \namount specified in sub-section (1) of section 7 in respect of the ship. \n \n \n(2) \nWhere the master of a ship has furnished a return under sub-section \n(1), the Commissioner shall 1[, after calling for such particulars, accounts or \ndocuments as he may require,]  determine the amount of tax due under section 7 \nin respect of the ship and, as soon as possible, notify the master, in writing, of the \namount payable. \n \n                                            \n1 Inserted by the Finance Act, 2002. \n\n\f\nChapter X – Procedure__________________________________ \n \n291 \n \n \n(3) \nThe master of a ship shall be liable for the tax notified under sub-\nsection (2) and the provisions of this Ordinance shall apply to such tax as if it were \ntax due under an assessment order.  \n \n \n(4) \nWhere the Commissioner is satisfied that the master of a ship or non-\nresident owner or charterer of the ship is unable to furnish the return required under \nsub-section (1) before the departure of the ship from a port in Pakistan, the \nCommissioner may allow the return to be furnished within thirty days of departure \nof the ship provided the non-resident owner or charterer has made satisfactory \narrangements for the payment of the tax due under section 7 in respect of the ship. \n \n \n(5) \nThe Collector of Customs or other authorised officer shall not grant a \nport clearance for a ship owned or chartered by a non-resident person until the \nCollector or officer is satisfied that any tax due under section 7 in respect of the \nship has been paid or that arrangements for its payment have been made to the \nsatisfaction of the Commissioner. \n \n \n(6) \nThis section shall not relieve the non-resident owner or charterer of \nthe ship from liability to pay any tax due under this section that is not paid by the \nmaster of the ship. \n \n144.  Non-resident aircraft owner or charterer. — (1)  A non-resident owner or \ncharterer of an aircraft 1[  ] liable for tax under section 7, or an agent authorised by the \nnon-resident person for this purpose, shall furnish to the Commissioner, within forty-\nfive days from the last day of each quarter of the financial year, a return, in respect of \nthe quarter, showing the gross amount specified in sub-section (1) of section 7 of the \nnon-resident person for the quarter.  \n \n \n(2) \nWhere a return has been furnished under sub-section (1), the \nCommissioner shall 2[, after calling for such particulars, accounts or documents as \nhe may require,] determine the amount of tax due under section 7 by the non-\nresident person for the quarter and notify the non-resident person, in writing, of the \namount payable. \n \n \n(3) \nThe non-resident person shall be liable to pay the tax notified under \nsub-section (2) within the time specified in the notice and the provisions of this \nOrdinance shall apply to such tax as if it were tax due under an assessment order. \n \n \n(4) \nWhere the tax referred to in sub-section (3) is not paid within three \nmonths of service of the notice, the Commissioner may issue to the authority by \nwhom clearance may be granted to the aircraft operated by the non-resident \nperson a certificate specifying the name of the non-resident person and the amount \nof tax due. \n \n                                            \n1 The words “shall be” omitted by the Finance Act, 2003. \n2 Inserted by the Finance Act, 2002 \n\n\f\nChapter X – Procedure__________________________________ \n \n292 \n \n \n(5) \nThe authority to whom a certificate is issued under sub-section (4) \nshall refuse clearance from any airport in Pakistan to any aircraft owned or \nchartered by the non-resident until the tax due has been paid. \n \n1[145. Assessment of persons about to leave Pakistan.— (1) Where any person is \nlikely to leave Pakistan during the currency of tax year or shortly after its expiry with no \nintention of returning to Pakistan, he shall give to the Commissioner a notice to that \neffect not less than fifteen days before the probable date of his departure (hereinafter \nin this section referred to as the ‘said date’). \n \n \n(2)  \nThe notice under sub-section (1) shall be accompanied by a return or \nreturns of taxable income in respect of the period commencing from the end of the \nlatest tax year for which an assessment has been or, where no such assessment \nhas been made, a return has been made, as the case may be, and ending on the \nsaid date, or where no such assessment or return has been made, the tax year or \ntax years comprising the period ending on the said date; and the period \ncommencing from the end of the latest tax year to the said date shall, for the \npurposes of this section, be deemed to be a tax year (distinct and separate from \nany other tax year) in which the said date falls. \n \n \n(3) \nNotwithstanding anything contained in sub-sections (1) and (2), the \nCommissioner may serve a notice on any person who, in his opinion, is likely to leave \nPakistan during the current tax year or shortly after its expiry and has no intention of \nreturning to Pakistan, to furnish within such time as may be specified in such notice, a \nreturn or returns of taxable income for the tax year or tax years for which the taxpayer \nis required to furnish such return or returns under sub-section (2). \n \n \n(4) \nThe taxable income shall be charged to tax at the rates applicable to \nthe relevant tax year and all the provisions of this Ordinance shall, so far as may \nbe, apply accordingly.] \n \n2[(5) Notwithstanding anything contained in any other law, for the time \nbeing in force, where on the basis of information received from any offshore \n                                            \n1Section 145 substituted by the Finance Act, 2003. The substituted section 145 read as follows:  \n“145. Collection of tax from persons leaving Pakistan permanently.- (1)  Where the \nCommissioner has reasonable grounds to believe that a person may leave Pakistan permanently \nwithout paying tax due under this Ordinance, the Commissioner may issue a certificate containing \nparticulars of the tax due to the Commissioner of Immigration and request the Commissioner of \nImmigration to prevent that person from leaving Pakistan until that person - \n(a) \nmakes payment of tax in full; or \n(b) \nmakes an arrangement satisfactory to the Commissioner for payment of the tax \ndue. \n(2) \nA copy of a certificate issued under sub-section (1) shall be served on the person named \nin the certificate if it is practicable to do so. \n(3) \nPayment of the tax specified in the certificate to a customs or immigration officer or the \nproduction of a certificate signed by the Commissioner stating that the tax has been paid or \nsatisfactory arrangements for payment have been made shall be sufficient authority for allowing the \nperson to leave Pakistan.” \n2New sub-section (5) added through Finance Act, 2019. \n\n\f\nChapter X – Procedure__________________________________ \n \n293 \n \njurisdiction, the Commissioner has reason to believe that such person who is likely \nto leave Pakistan may be involved in offshore tax evasion or such person is about \nto dispose of any such  asset, the Commissioner may freeze any domestic asset \nof the person including any asset beneficially owned by the person for a period of \none hundred and twenty days or till the finalization of proceeding including but not \nlimited to recovery proceedings under this Ordinance whichever is earlier.]  \n \n146.  Recovery of tax from persons assessed in Azad Jammu and Kashmir \n1[and Gilgit-Baltistan.]— (1)  Where any person assessed to tax for any tax year \nunder the law relating to income tax in the Azad Jammu and Kashmir 2[or  Gilgit-\nBaltistan] has failed to pay the tax and the income tax authorities of the Azad Jammu \nand Kashmir 3[or Gilgit-Baltistan] cannot recover the tax because — \n \n(a) the person’s resi44dence is in Pakistan; or \n \n(b) the person has no movable or immovable property in the Azad \nJammu and Kashmir4[or Gilgit-Baltistan], \n \nthe Deputy Commissioner in the Azad Jammu and Kashmir 5[or Gilgit-Baltistan] \nmay forward a certificate of recovery to the Commissioner and, on receipt of such \ncertificate, the Commissioner shall recover the tax referred to in the certificate in \naccordance with this Part. \n \n \n(2) \nA certificate of recovery under sub-section (1) shall be in the \nprescribed form specifying — \n \n(a) \nthe place of residence of the person in Pakistan; \n \n(b) \nthe description and location of movable or immovable property \nof the person in Pakistan; and \n \n(c) \nthe amount of tax payable by the person. \n \n6[146A. Initiation, validity, etc., of recovery proceedings.— (1) Any proceedings \nfor the recovery of tax under this Part may be initiated at any time. \n \n                                            \n1Inserted by the Finance Act, 2017. \n2Inserted by the Finance Act 2017. \n3Inserted by the Finance Act 2017. \n4Inserted by the Finance Act 2017. \n5Inserted by the Finance Act 2017. \n6 Inserted by the Finance Act, 2002. \n\n\f\nChapter X – Procedure__________________________________ \n \n294 \n \n \n(2) \nThe Commissioner may, at any time, amend the certificate issued \nunder section 138A, or recall such certificate and issue fresh certificate, as he \nthinks fit. \n \n \n(3) \nIt shall not be open to a taxpayer to question before the District Officer \n(Revenue) the validity or correctness of any certificate issued under section 138A, \nor any such certificate as amended, or any fresh certificate issued, under sub-\nsection (2). \n \n \n(4) \nThe several modes of recovery provided in this Part shall be deemed \nto be neither mutually exclusive nor affect in any way any other law for the time \nbeing in force relating to the recovery of debts due to the Government and the \nCommissioner may have recourse to any such mode of recovery notwithstanding \nthat the tax due is being recovered from a taxpayer by any other mode.] \n \n1[146B. Tax arrears settlement incentives scheme.— (1) Subject to provisions \nof this Ordinance, the Board may make scheme in respect of recovery of tax \narrears or withholding taxes and waiver of 2[default surcharge]or penalty levied \nthereon.  \n \n(2) The Board may make rules under section 237 for implementation of such \nscheme.] \n \n3[146C. Assistance in the recovery and collection of taxes.— The provisions \nof sections 138, 138A, 138B, 139, 140, 141, 142, 143, 144, 145, 146, 146A, and \n146B shall mutatis mutandis apply in respect of assistance in collection and \nrecovery of taxes in pursuance of a request from a foreign jurisdiction under a tax \ntreaty, a multilateral convention, an intergovernmental agreement or similar \narrangement or mechanism.] \n \n4[146D. Recovery of liability outstanding under other laws. – (1) Where any \noutstanding liability in or under any other statute or law for the time being in force \nenacted through an Act of Parliament, in respect of any defaulter is –  \n \n(a)  treated as Income Tax arrears in that law;  \n \n(b) required to be recovered or collected by Commissioner (Inland \nRevenue); or  \n \n                                            \n1Inserted by the Finance Act, 2008. \n2The word “additional tax”  substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n3 Section 146C inserted by the Finance Act, 2021. \n4 Section 146D inserted by the Finance Act, 2023. \n\n\f\nChapter X – Procedure__________________________________ \n \n295 \n \n(c)  is referred to Commissioner (Inland Revenue) for the recovery –  \n \nthe Commissioner (Inland Revenue) shall recover the said liability and deposit the \nreceipts in the designated account specified in that law.] \n \n \n \n \n\n\f\nChapter X – Procedure__________________________________ \n \n296 \n \nPART V \nADVANCE TAX AND DEDUCTION OF TAX AT SOURCE \n \nDivision I \nAdvance Tax Paid by the Taxpayer \n \n147. Advance tax paid by the taxpayer.— (1) Subject to sub-section (2), every \ntaxpayer 1[whose income was charged to tax for the latest tax year under this \nOrdinance or latest assessment year under the repealed Ordinance] other than – \n \n \n \n2[  ] \n \n(b) \nincome chargeable to tax under sections 5, 6 and 7;  \n \n \n \n3[  ] \n \n(c) \nincome subject to deduction of tax at source under section 149; \n4[and] \n \n \n \n5[  ] \n \n(d) \nincome from which tax has been collected under Division II or \ndeducted under Division III6[or deducted or collected under \nChapter XII]  and for which no tax credit is allowed as a result of \nsub-section (3) of section 168, \n \nshall be liable to pay advance tax for the year in accordance with this section.  \n \n \n(2) \nThis section does not apply to an individual  where the individual’s 7[] \nlatest assessed taxable income excluding income referred to in clauses 8[(b),] (c) \nand (d) of sub-section (1) is less than 9[ 10[ 11[one million] ] rupees. \n                                            \n1 The words “who derives or expects to derive income chargeable to tax under this Ordinance in a tax \nyear” substituted by the Finance Act, 2003. \n2Clause (a) omitted by the Finance Act, 2010. Omitted clause (a) read as follows: \n \n   “(a) income chargeable to tax under the head “Capital Gains”; \n3 Clause (ba) omitted by the Finance Act, 2013. The omitted clause (ba) read as follows: \n“(ba)   income chargeable to tax under section 15;” \n4The word “or” substituted by the Finance Act, 2009. \n5Clause (ca) omitted by the Finance Act, 2009. The omitted clause (ca) read as follows: \n“(ca)  income chargeable to tax under section 233 and clauses (a) and (b) of sub-section (1) of \nsection 233A;” \n6Inserted by the Finance Act, 2009. \n7The words “or association of persons” omitted by the Finance Act, 2010. \n8 The words “(a), (b),(ba)” substituted by (b) through Finance Act, 2020 dated 30th June, 2020 \n9 The words “one hundred and fifty thousand” substituted by the Finance Act, 2003. \n10The word “two” substituted by the Finance Act, 2010. \n11The words “five hundred thousand” substituted by the Finance Act, 2017. \n\n\f\nChapter X – Procedure__________________________________ \n \n297 \n \n \n1[  ] \n \n \n2[(4)  Where the taxpayer is 3[an association of persons or] a company, the \namount of advance tax due for a quarter shall be computed according to the \nfollowing formula, namely:- \n \n(A x B/C) –D \n \n \n \nWhere –  \n \n \n \n \nA  \nis the taxpayer’s turnover for the quarter 4[:] \n \n5[Provided that where the taxpayer fails to provide \nturnover or the turnover for the quarter is not known, it \nshall be taken to be one-fourth of one hundred and \n6[twenty] percent of the turnover of the latest tax year for \nwhich a return has been filed;] \n \nB  \nis the tax assessed to the taxpayer for the latest tax year \n7[.] \n \n                                            \n1 Sub-section (3) omitted by the Finance Act, 2004. The omitted sub-section (3) read as follows:  \n“(3) Advance tax shall be payable by a taxpayer in respect of the following periods, namely:– \n(a) 1st of July to 30th September (referred to as the “September quarter”); \n(b) 1st October to 31st December (referred to as the “December quarter”); \n(c) 1st January to 31st March (referred to as the “March quarter”); and \n(d) 1st April to 30th June (referred to as the “June quarter”).” \n2 Sub-section (4) substituted by the Finance Act, 2009. The substituted sub-section (4) read as \nfollows:  \n“(4) where the taxpayer is a company, the amount of advance tax due for a quarter shall be \ncomputed according to the following formula, namely:-  \n \n(A/4)  - B \nWhere – \nA \nis the tax assessed to the taxpayer for the latest tax year or latest assessment year under the \nrepealed Ordinance; and  \nB \nis the tax paid in the quarter for which a tax credit is allowed under section 168, other than \ntax deducted under section 149 or 155.” \n3Inserted by the Finance Act, 2010. \n4The semi colon substituted by the Finance Act, 2018 \n5Added by the Finance Act, 2018. \n6 The word “ten” substituted by the Finance Act, 2024. \n7 Semicolon substituted by the Finance Act, 2016. \n\n\f\nChapter X – Procedure__________________________________ \n \n298 \n \n1[“Explanation.- For removal of doubt it is clarified \nthat tax assessed includes  tax under sections 2[4C,] 113 \nand 113C.”] \n \n \n \n \nC  \nis the taxpayer’s turnover for the latest tax year; and  \n \nD  \nis the tax paid in the quarter for which a tax credit is \nallowed under section 1683[  ].] \n \n \n4[(4A) Any taxpayer 5[including a banking company] who is required to make \npayment of advance tax in accordance with sub-section (4), shall estimate the tax \npayable for the relevant tax year, at any time before the second installment is due. \nIn case the tax payable is likely to be more than the amount that the taxpayer \n6[including a banking company] is required to pay under sub-section (4), the \ntaxpayer 7[including a banking company]  shall furnish to the Commissioner on or \nbefore the due date of the second quarter an estimate of the amount of tax payable \nby the taxpayer 8[including a banking company] and thereafter pay fifty per cent of \nsuch amount by the due date of the second quarter of the tax year after making \nadjustment for the amount, if any, already paid in terms of sub-section (4). The \nremaining fifty per cent of the estimate shall be paid after the second quarter in two \nequal installments payable by the due date of the third and fourth quarter of the \ntax year.”] \n \n \n \n \n9[(4AA) Tax liability under 10[sections 11[4C,] 113 and 113C] shall also be \ntaken into account while working out payment of advance tax liability under this \nsection.] \n \n                                            \n1Added by the Finance Act, 2016. \n2 Expression inserted by the Finance Act, 2023. \n3The words, comma and figure “, other than tax deducted under section 155” omitted by the Finance \nAct, 2013.   \n4Sub-section (4A) omitted by Finance Act, 2015. The substituted sub-section read as follows:- \n \n“(4A) Any taxpayer who is required to make payment of advance tax in accordance with sub-\nsection (4), shall estimate the tax payable by him for the relevant tax year, at any time before \nthe last instalment is due. In case the tax payable is likely to be more than the amount he is \nrequired to pay under sub-section (4), the taxpayer shall furnish to the Commissioner an \nestimate of the amount of tax payable by him and thereafter pay such amount after making \nadjustment for the amount (if any) already paid in terms of sub-section (4)”. \n5Inserted by the Finance Act, 2018 \n6Inserted by the Finance Act, 2018. \n7Inserted by the Finance Act, 2018. \n8Inserted by the Finance Act, 2018. \n9Inserted by the Finance Act, 2009. \n10The expression “section 113” substituted by the Finance Act, 2016. \n11 Expression inserted by the Finance Act, 2023. \n\n\f\nChapter X – Procedure__________________________________ \n \n299 \n \n \n1[(2[4B]) Where the taxpayer is an individual 3[  ] having latest assessed \nincome of 4[ 5[one million] rupees or more as determined under sub-section (2), the \namount of advance tax due for a quarter shall be computed according to the \nfollowing formula, namely: - \n“(A/4) - B \nWhere – \n \nA \nis the tax assessed to the taxpayer for the latest tax year or latest \nassessment year under the repealed Ordinance; and \n \nB \nis the tax paid in the quarter for which a tax credit is allowed under section \n168, other than tax deducted under section 149 6[  ].] \n \n7[Explanation. – For removal of doubt, it is clarified that tax assessed \nincludes tax liability under section 4C.] \n \n \n(5) \nAdvance tax is payable by 8[an individual 9[]] to the Commissioner— \n \n(a) \nin respect of the September quarter, on or 10[before] the 11[15th \nday of September]; \n \n(b) \nin respect of the December quarter, on or before the 12[15th day \nof December]; \n \n(c) \nin respect of the March quarter, on or before the 13[15th day of \nMarch]; and \n \n(d) \nin respect of the June quarter, on or before the 14[15th day of June]. \n \n                                            \n1 Inserted by Finance Act, 2003. \n2 Sub-section (4A) re-numbered by the Finance Act, 2006. \n3The words “or an association of persons” omitted by the Finance Act, 2010. \n4The word “two” substituted by the Finance Act, 2010. \n5The word “five hundred thousand” substituted by the Finance Act 2017. \n6The words and figure “or 155” omitted by the Finance Act, 2013. \n7 Explanation added by the Finance Act, 2023. \n8The words “a taxpayer” substituted by the Finance Act, 2009. \n9The words “or an association of persons” omitted by the Finance Act, 2010. \n10 The word “by” substituted by the Finance Act, 2005. \n11 The figure and words “7th day of October” substituted by the Finance Act, 2004. \n12 The figure and words “7th day of January” substituted by the Finance Act, 2004. \n13The figure and words “7th day of April” substituted by the Finance Act, 2004. \n14 The figure and words “21st day of June” substituted by the Finance Act, 2004. \n\n\f\nChapter X – Procedure__________________________________ \n \n300 \n \n \n1[(5A) Advance tax shall be payable by an association of persons or a \ncompany to the Commissioner — \n \n(a)  \nin respect of the September quarter, on or before the 25th day \nof September; \n \n(b) \nin respect of the December quarter, on or before the 25th day of \nDecember; \n \n(c)  \nin respect of the March quarter, on or before the 25th day of \nMarch; and  \n \n(d)  \nin respect of the June quarter, on or before the 15th day of June.] \n \n \n2[(5B) Adjustable advance tax on capital gain from sale of securities shall be \nchargeable as under, namely:— \n \n \nTABLE \n________________________________________________________________ \nS.No.                      Period                             Rate of Advance Tax \n----------------------------------------------------------------------------------------------------------- \n            1                               2                                                 3 \n----------------------------------------------------------------------------------------------------------- \n1. \nWhere holding period of a \nsecurity is less than six months. \n \n2% of the capital gains \nderived during the quarter. \n2. \nWhere holding period of a \nsecurity is more than six months \nbut less than twelve months. \n1.5% of the capital gains \nderived during the quarter: \n------------------------------------------------------------------------------------------------------------ \nProvided that such advance tax shall be payable to the \nCommissioner within a period of 3[twenty-one] days after the close of \neach quarter: \n \nProvided further that the provisions of this sub-section shall not \nbe applicable to individual investors.] \n \n                                            \n1Sub-section (5A) substituted by the Finance Act, 2010. The substituted sub-section (5A) read as \nfollows: \n \n \n“(5A)  Advance tax is payable by a company to the Commissioner –  \n(a)  \nin respect of the September quarter, on or before the 15th day of \nOctober; \n(b)  \nin respect of the December quarter, on or before the 15th day of January; \n(c)   \nin respect of the March quarter, on or before the 15th day of April; and \n(d)  \nin respect of the June quarter, on or before the 15th day of June.” \n2 Inserted by the Finance Act,  2010. \n3The word “seven” substituted by the Finance Act, 2011. \n\n\f\nChapter X – Procedure__________________________________ \n \n301 \n \n \n1[(5C) Notwithstanding anything contained in this section, every person \nderiving income from the business of –  \n \n(i) \nconstruction and disposal of residential, commercial or other \nbuildings; or  \n \n(ii)  \ndevelopment and sale of residential, commercial or other plots for \nitself or otherwise, shall be liable to pay adjustable advance tax on \nProject-by-Project basis, as may be prescribed, for the tax year as per \nthe rates specified in Part IIB of the First Schedule in four equal \ninstallments:  \n \nProvided that such advance tax shall be payable to the \nCommissioner in accordance with sub-sections (5) and (5A):  \n \nProvided further that the provisions of sub-sections (7) to (10) \nshall mutatis mutandis apply.] \n \n \n2[(6)  If any taxpayer who is required to make payment of advance tax under \nsub-section (1) estimates at any time before the last installment is due, that the tax \npayable by him for the relevant tax year is likely to be less than the amount he is \nrequired to pay under sub-section (1), the taxpayer may furnish to the \nCommissioner an estimate of the amount of the tax payable by him, and thereafter \npay such estimated amount, as reduced by the amount, if any, already paid under \nsub-section (1), in equal installments on such dates as have not expired 3[:] \n \n4[Provided that an estimate of the amount of tax payable shall contain \nturnover for the completed quarters of the relevant tax  year, estimated turnover  \nof the remaining quarters along with reasons for any decline in estimated turnover,  \ndocumentary  evidence  of  estimated  expenses  or deductions  which  may result \nin lower payment of advance tax and the computation of the estimated taxable \nincome of the relevant tax year 5[.] \n \n6[    ]  ] \n                                            \n1 Sub-section (5C) inserted by the Finance Act, 2023. \n2Sub-section (6) substituted by the Finance Act, 2004. The substituted sub-section (6) read as \nfollows:  \n“(6) \nThe turnover of a taxpayer for the period from 16th to 30th June of the June quarter shall \nbe taken to be equal to the turnover for the period from 1st to 15th June of that quarter.” \n3 Full stop substituted by the Finance Act, 2018. \n4 Added by the Finance Act 2018. \n5 Colon substituted by the Finance Act, 2021. \n6 Second proviso omitted by the Finance Act, 2021. The omitted proviso read as follows: \n“Provided further that where the Commissioner is not satisfied with the  documentary \nevidence provided or where an estimate of the amount of tax payable is not accompanied by \ndetails mentioned in the first proviso, the Commissioner may reject the estimate after providing an \nopportunity of being  heard to the taxpayer and the taxpayer shall pay advance tax according to \nthe  formula contained in sub-section (4).” \n\n\f\nChapter X – Procedure__________________________________ \n \n302 \n \n \n1[(6A) Notwithstanding anything contained in this section, where the \ntaxpayer is a company or an association of persons, advance tax shall be payable \nby it in the absence of last assessed income or declared turnover also. The \ntaxpayer shall estimate the amount of advance tax payable on the basis of \nquarterly turnover of the company or an association of persons, as the case may \nbe, and thereafter pay such amount after, — \n \n(a)  \ntaking into account tax payable under 2[sections 113 and 113C] \nas provided in sub-section (4AA); and \n \n \n \n(b)  \nmaking adjustment for the amount (if any) already paid.] \n \n \n \n3[  ] \n \n4[  ] \n \n \n \n \n5[(6B) Where an estimate of the amount of tax payable has been filed by the \ntaxpayer under sub-section (6) as the case may be, the estimate shall contain \nturnover for the completed quarters of the relevant tax year, estimated turnover for \nthe remaining quarters, supporting evidence of expenses or deductions in \ncomputing income, evidence of tax payments and tax credits and computation of \nestimated taxable income:  \n \nProvided that where the Commissioner is not satisfied with the documentary \nevidence provided or where an estimate of the amount of tax payable is not \naccompanied by details mentioned in this sub-section, the Commissioner may \nreject the estimate after providing an opportunity of being heard to the taxpayer \nand the taxpayer shall pay advance tax according to the formula set out in sub-\nsection (4) or sub-section (4B), as the case may be. \n \n(6C) Notwithstanding anything contained in this Ordinance, the persons \nspecified in sub-sections (1), (3), (3A), (3B) and (3C) of section 154 shall, at the \ntime of realization of foreign exchange proceeds, or realization of the proceeds on \naccount of sale of goods, or export of goods, or at the time of making payment to \n                                            \n1Sub-section (6A) substituted by the Finance Act, 2009. The substituted sub-section (6A) read as \nfollows: \n“(6A) \nNotwithstanding anything contained in this section, where the taxpayer is a company, \nadvance tax shall be payable by it in the absence of last assessed income also. The taxpayer shall \nestimate the amount of advance tax payable on the basis of estimated Inserted by the Finance Act, \n2009.” \n2 The expression “section 113” substituted by the Finance Act, 2016. \n3 Clause (a) omitted by the Finance Act, 2008. The omitted clause (a) read as follows: \n“(a) \ntaking into account tax payable under section 113 as provided in sub-section (4AA);” \n4Clause (b) omitted by the Finance Act, 2008. The omitted clause (b) read as follows: \n“(b) \nmaking adjustment for the amount (if any) already paid.” \n5 New sub-sections (6B) and (6C) inserted by the Finance Act, 2024. \n\n\f\nChapter X – Procedure__________________________________ \n \n303 \n \nan indirect exporter, or clearing of goods exported, respectively, deduct or collect, \nas the case may be, advance income tax under this section at the rate of one \npercent of such foreign exchange proceeds, or export proceeds, or exports, or \npayment, in addition to tax collectable or deductible under section 154 of this \nOrdinance.] \n \n(7) \nThe provisions of this Ordinance shall apply to any advance tax due \nunder this section as if the amount due were tax due under an assessment order. \n \n \n1[(7A) The Board may prescribe the manner for furnishing of the estimate \nand calculation of the amount of tax payable under this section through Iris or any \nother automated system specified by the Board.] \n \n \n(8) \nA taxpayer who has paid advance tax under this section for a tax year \nshall be allowed a tax credit for that tax in computing the tax due by the taxpayer \non the taxable income of the taxpayer for that year. \n \n \n(9) \n A tax credit allowed for advance tax paid under this section shall be \napplied in accordance with sub-section (3) of section 4. \n \n \n(10)  A tax credit or part of a tax credit allowed under this section for a tax \nyear that is not able to be credited under sub-section (3) of section 4 for the year \nshall be refunded to the taxpayer in accordance with section 170. \n \n \n2[  ] \n \n3[147A. Advance tax from provincial sales tax registered person.- (1) Every \nprovincial sales tax registered person shall be liable to pay adjustable advance tax \nat the rate of three per cent of the turnover declared before the provincial revenue \nauthority. \n \n(2) \nThe advance tax under sub-section (1) shall be paid monthly at the \ntime when sales tax return is to be filed with the provincial revenue authority. \n \n(3) \nAdvance tax paid under this section may be taken into account while \nworking out advance tax payable under section 147. \n \n(4) \nThe provisions of this Ordinance shall apply to any advance tax due \nunder this section as if the amount due were tax due under an assessment order. \n \n                                            \n1New sub-section (7A) inserted through Finance Act, 2020 dated 30th June, 2020 \n2Sub-section (11) omitted by the Finance Act, 2004. The omitted sub-section (11) read as follows:  \n“(11)  In this section, “turnover” shall not include amounts referred to in clauses (a), (b), (ba), (c) and \n(d) of sub-section (1).” \n3Inserted by the Finance Act, 2016. \n\n\f\nChapter X – Procedure__________________________________ \n \n304 \n \n(5) \nA taxpayer who has paid advance tax under this section for a tax year \nshall be allowed a tax credit for that tax in computing the tax due by the taxpayer \non the taxable income of the taxpayer for that year. \n \n(6) \nA tax credit allowed for advance tax paid under this section shall be \napplied in accordance with sub-section (3) of section 4. \n \n(7) \nA tax credit or part of a tax credit allowed under this section for a tax \nyear that is not able to be credited under sub-section (3) of section 4 for the year \nshall be refunded to the taxpayer in accordance with section 170. \n \n(8) \nThis section shall not apply to a person 1[whose name was appearing \nin the active taxpayers’ list] on the thirtieth day of June of the previous tax year.] \n \nDivision II \nAdvance Tax Paid to a Collection Agent \n \n148.  Imports.— (1)  The Collector of Customs shall collect advance tax from \nevery importer of goods on the value of the goods at the rate specified in Part II of \nthe First Schedule 2[in respect of goods classified in Parts I to III of the Twelfth \nSchedule] 3[: \n \n \n \nProvided that the Board may, by a notification in the official Gazette, add in \nthe Twelfth Schedule any entry thereto or omit any entry therefrom or amend any \nentry therein: \n \n \n \nProvided further that in case of goods classified under Part III of the Twelfth \nSchedule which are used both as raw material and finished goods, the Board may, \nby notification in the official Gazette, specify that goods imported by a person or \nclass of persons as raw material for its own use shall be treated as classified under \nPart II of the Twelfth Schedule, subject to such conditions and procedure as may \nbe prescribed] 4[: \n \nProvided also that the Collector of Customs, shall not collect tax under this \nsection, where the recipient of goods is also liable under the Digital Presence \nProceeds tax, Act, 2025 and same has been collected by the payment intermediary \nas defined in section 153.] \n                                            \n1Words “who was filer” substituted from Finance Act, 2019 \n2 The expression inserted through Finance Act, 2020 dated 30th June, 2020 \n3 The “full stop” substituted by “colon” and thereafter proviso added through Finance Act, 2020 dated \n30th June, 2020 \n4 Full stop substituted and a new proviso inserted by the Finance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n305 \n \n \n1[ 2[    ]  ]  \n \n \n3[(2A) Notwithstanding omission of sub-section (2), any notification issued \nunder the said sub-section and for the time being in force, shall continue to remain \nin force, unless 4[amended or] rescinded by the Board through notification in the \nofficial Gazette.”;] \n \n \n5[  ] \n \n6[  ] \n \n \n7[  ] \n \n \n(5) \nAdvance tax shall be collected in the same manner and at the same \ntime as the customs-duty payable in respect of the import or, if the goods are \nexempt from customs-duty, at the time customs-duty would be payable if the goods \nwere dutiable. \n \n                                            \n1 Sub-section (2) substituted by the Finance Act, 2007. The substituted sub-section (2) read as \nfollows:  \n“(2) This section shall not apply to – \n(a) \nthe re-importation of re-usable containers for re-export qualifying for customs-\nduty and sales tax exemption on temporary import under the Customs \nNotification No. S.R.O. 344(1)/95, dated the 25th day of April, 1995; or \n(b) \nthe importation of the following petroleum products – \n“Motor Spirit (MS), Furnace Oil (FO), JP-1 and MTBE”.” \n2 Omitted by Finance act, 2015. The omitted sub-section (2) read as follows:- \n“(2)Nothing contained in sub-section (1) shall apply to any goods or class of goods or persons or \nclass of persons importing such goods or class of goods as may be specified by the Board.” \n3 Inserted by Finance Act, 2015. \n4Inserted by the Finance Act, 2018. \n5Sub-section (3) omitted by the Finance Act, 2007. The omitted sub-section (3) read as follows: \n“(3) Where a manufacturer imports raw materials (other than edible oils) exclusively for the \nmanufacturer’s own use, the Commissioner may certify a reduction (of up to seventy five per cent) \nof the rate of advance tax applicable under this section if the aggregate of tax paid or collected in a \ntax year equals the amount of tax paid by the manufacturer in the immediately preceding year.” \n6 Sub-section (4) omitted by the Finance Act, 2007. The omitted sub-section (4) read as follows: \n“ (4)  Notwithstanding the provisions of sub-section (3), a person being a manufacturer who is liable \nto pay advance tax under section 147, imports raw materials (other than edible oils) exclusively for \nhis, or as the case may be, its own use, the Commissioner shall upon application in writing by such \nperson, issue an exemption certificate effective from the date on which the certificate is issued to the \n30th day of June next falling: \n \nProvided that where the person to whom an exemption certificate has been issued fails to \npay any instalment due, the Commissioner may cancel the certificate.” \n7Sub-section (4A) omitted by the Finance Act, 2008. The omitted sub-section (4A) read as follows:- \n“(4A) Where, in the case of a person whose income is not subject to final taxation, the Commissioner \nis satisfied that such person is not likely to pay any tax (other than tax under section 113), the \nCommissioner shall, upon application in writing made by such person, issue certificate allowing \npayment of tax collectable under this section at a reduced rate of 0.5%” \n\n\f\nChapter X – Procedure__________________________________ \n \n306 \n \n \n(6) \n1[Subject to sub-section (6A), the] provisions of the Customs Act, 1969 \n(IV of 1969), in so far as relevant, shall apply to the collection of tax under this \nsection. \n \n2[(6A) The Board may, by notification in the official Gazette, determine the \nminimum value of goods for the purpose of collection of advance tax under this \nsection.] \n \n3[(7)  The tax 4[required to be] collected under this section shall be \n5[minimum] tax 6[  ] on the income of the importer arising from the imports subject \nto sub-section (1) and this sub-section shall not apply in the case of import of \n7[goods on which tax is required to be collected under this section 8[   ] by an \nindustrial undertaking for its own use.] 9[  ] \n \n                                            \n1 The word “The” substituted by the Finance Act, 2024. \n2 Sub-section (6A) inserted by the Finance Act, 2024. \n3Sub-section (7) substituted by the Finance Act, 2006. The substituted sub-section (7) read as \nfollows: \n“(7) \nExcept in the case of an industrial undertaking importing goods as raw materials, plant, \nmachinery and equipment for its own use, the tax collected under this section shall be a final tax on \nthe income of the importer arising from the imports subject to sub-section (1).” \n4Inserted by  the Finance Act, 2012. \n5Words “a final” substituted through Finance Act, 2019.  \n6Expression “except as provided under sub-section (8)” omitted through Finance Act, 2019. \n7The expression inserted through Finance Act, 2020 dated 30th June, 2020 \n8 Words “at the rate of 1% or 2%” omitted by the Finance Act, 2022.  \n9The hyphen and clauses (a),(c),(d)and (e) omitted through Finance Act 2020 dated 30th June, 2020      \n— (a)  raw material, plant, machinery, equipment and parts by an industrial  undertaking for its own \nuse; \n[ ] \n(c)  \n [motor vehicles] in CBU condition by manufacturer of [motor vehicles] [;] \n[(d)  \nlarge import houses, who,— \n(i) \nhave paid-up capital of exceeding Rs. [250] million; \n(ii) \nhave imports exceeding Rs.500 million during the tax year; \n(iii) \nown total assets exceeding Rs [350] million at the close of the tax year; \n(iv) \nis single object company; \n(v) \nmaintain computerized records of imports and sale of goods;  \n(vi) \nmaintain a system for issuance of 100% cash receipts on sales; \n(vii) \npresent accounts for tax audit every year; \n(viii) \nis registered9[under the Sales Tax Act, 1990] and \n(ix) \nmake sales of industrial raw material of manufacturer registered [Under the Sales Tax \nAct,1990] [; and] ] \n [(e)  \na foreign produced film imported for the purposes of screening and viewing.] \n\n\f\nChapter X – Procedure__________________________________ \n \n307 \n \n1[(7A) Notwithstanding anything contained in sub-section (7), the tax required \nto be collected under this section shall be minimum tax on the income every person \narising from imports of following goods – \n \n(i) \nedible oil;  \n \n(ii) \npackaging material; \n \n(iii) \npaper and paper board; or \n \n(iv) \nplastics:  \n  \n \nProvided that the Board with the approval of Minister in-charge may, by a \nnotification in the official Gazette, add any entry thereto or omit any entry therefrom \nor amend any entry therein this sub-section.]  \n \n2[  ] \n \n(9) \nIn this section – \n \n“Collector of Customs” means the person appointed as Collector of \nCustoms under section 3 of the Customs Act, 1969 (IV of 1969), and \nincludes a Deputy Collector of Customs, an Additional Collector of \nCustoms, or an officer of customs appointed as such under the \naforesaid section; 3[  ] \n \n4[Value of goods means – \n \n(a) in case of goods chargeable to tax at retail price under the Third \nSchedule of the Sales Tax Act, 1990, the retail price of such goods \nincreased by sales tax payable in respect of the import and \ntaxable supply of the goods; 5[  ] ] \n \n                                            \n1 The sub-section (7A) inserted by the Finance Act, 2022. \n2 Sub-section (8) and (8A) omitted through Finance Act, 2020 dated 30th June 2020 the omitted sub-\nsection read as follows: \n[ ]  [(8) The tax required to be collected from a person under this section shall be minimum tax \nfor a tax year on the import of─ \n [(a)] \n \n(b) \nedible oil; \n(c) \npacking material; and \n(d) \nplastic raw material imported by an industrial undertaking falling   under PCT \nheadings 39.01 to 39.12.] \n  [(8A) The tax collected under this section at the time of import of ships   by ship-breakers shall \nbe  [minimum] tax.] \n \n3The word “and” omitted by the Finance Act, 2004. \n4 The expressions substituted by the Finance Act, 2020 dated 30th June, 2020 the substituted \nexpressions read as follows:  \n“value of the goods means the value of the goods as determined under the Customs Act, 1969 (IV of \n1969), as if the goods were subject to ad valorem duty increased by the customs-duty, federal excise \nduty and sales tax, if any, payable in respect of the import of the goods.”  \n5 The word “and” omitted by the Finance Act, 2024. \n\n\f\nChapter X – Procedure__________________________________ \n \n308 \n \n(b) in case of 1[goods other than those specified in clauses (a) and \n(c)]; the value of the goods as determined under the Customs Act, \n1969 (IV of 1969), as if the goods were subject to ad valorem duty \nincreased by the custom-duty, federal excise duty and sales tax, \nif any, payable in respect of the import of the goods 2[; and] ; and]] \n \n3[(c)  minimum value as notified by the Board under subsection (6A) as \nif such goods were subject to ad valorem duty as increased by the \ncustom-duty, federal excise duty and sales tax, payable in respect \nof the import of the goods.] \n4[  ] \n \n5[  ] \n \nDivision III \nDeduction of Tax at Source \n \n149.  Salary. — (1)  Every 6[person responsible for] paying salary to an employee \nshall, at the time of payment, deduct tax from the amount paid at the employee’s \naverage rate of tax computed at the rates specified in Division I of Part I of the First \nSchedule on the estimated income of the employee chargeable under the head \n“Salary” for the tax year in which the payment is made 7[including tax under section \n4AB] after making 8[adjustment of tax withheld from employee under other heads \nand tax credit admissible under section 61 9[and 63] during the tax year after \nobtaining documentary evidence], as may be necessary, for 10[:] \n \n                                            \n1 The words “all other goods” substituted by the Finance Act, 2024. \n2 The word “and” omitted by the Finance Act, 2024. \n3 Clause (c) added by the Finance Act, 2024. \n4The Explanation omitted through Finance Act, 2020 dated 30th June, 2020 the omitted explanation \nread as follows: \n“Explanation.- For the purpose of this section the expression “edible   oils” includes crude oil, \nimported as raw material for manufacture of ghee or cooking oil” \n5Section 148(A) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted section read as \nfollows: \n“148A. Tax on local purchase of cooking oil or vegetable ghee by certain persons.— (1)The \nmanufacturers of cooking oil or vegetable ghee, or both, shall be chargeable to tax at the rate of two \npercent on purchase of locally produced edible oil. \n \n(2) The tax payable under sub-section (1) shall be final tax in respect of income accruing from \nlocally produced edible oil.” \n6 The word “employer” substituted by the Finance Act, 2013. \n7 Expression inserted by the Finance Act, 2024. \n8The words “such adjustment” substituted by the Finance Act, 2007. \n9The expression “62, 63 and 64” substituted by the Finance Act, 2022. \n10Inserted by the Finance Act, 2007. \n\n\f\nChapter X – Procedure__________________________________ \n \n309 \n \n1[(i)    tax withheld from the employee under this Ordinance during the tax \nyear; \n(ii) \nany excess deduction or deficiency arising out of any previous \ndeduction; or \n(iii)     failure to make deduction during the year;] \n \n2[(1A) Notwithstanding the provisions of sub-section (1), any person \nresponsible for paying pension to a former employee who is below the age of \nseventy years and deriving pension income during a tax year in which the payment \nexceeds rupees ten million, shall at the time of payment, deduct tax from the \namount which is over and above rupees ten million at the rate provided in Division \nI of Part I of the First Schedule of the Ordinance, along with tax deducted under \nsection 4AB after making adjustment of tax withheld from former employee under \nother heads and tax credit admissible under sections 61 and 63 of the Ordinance \nduring the tax year after obtaining documentary evidence, as may be necessary, \nfor –  \n \n(i) \ntax withheld from the former employee under this Ordinance during the tax \nyear; or  \n(ii)    any excess deduction or deficiency arising out of any previous deduction; or  \n(iii)   failure to make deduction during the year.] \n \n(2) \nThe average rate of tax of an employee for a tax year for the purposes \nof sub-section (1) shall be computed in accordance with the following formula, \nnamely:– \n \nA/B \nwhere – \n \nA \nis the tax that would be payable if the amount referred to in component B of \nthe formula were the employee’s taxable income for that year; and \n \nB \nis the employee’s estimated income under the head “Salary” for that year \n3[plus tax chargeable under section 4AB]. \n \n4[(3) Notwithstanding anything contained in sub-sections (1) and (2), every \nperson responsible for making payment for directorship fee or fee for attending \nboard meeting or such fee by whatever name called, shall at the time of payment, \ndeduct tax at the rate of twenty percent of the gross amount payable. \n \n(4) Tax deductible under sub-section (3) shall be adjustable.] \n                                            \n1The words “any excess deduction or deficiency arising out of any previous deduction or failure to make \na deduction during the year.” substituted by the Finance Act, 2007. \n2 Sub-section (1A) inserted by the Finance Act, 2025. \n3 Expression inserted by the Finance Act, 2024. \n4 Sub-section (3) and (4) added by the Finance Act, 2014. \n\n\f\nChapter X – Procedure__________________________________ \n \n310 \n \n150.  Dividends. — Every 1[person] paying a dividend shall deduct tax from the \ngross amount of the dividend paid 2[or collect tax from the amount of dividend in \nspecie]  3[  ] at the rate specified in 4[Division I of Part III] of the First Schedule. \n \n5[   ]  \n6[   ]  \n \n151. Profit on debt. — (1)  Where – \n \n7[(a) a person pays yield on an account, deposit or a certificate    under the \nNational Savings Scheme or Post Office Savings Account;] \n \n  (b) a banking company 8[or] financial institution pays any profit on a debt, \nbeing an account or deposit maintained with the company or institution; \n9[  ] \n10[(c) the Federal Government, a Provincial Government or a 11[Local \nGovernment] pays to any person 12[ ] profit on any security 13[other than \nthat referred to in clause (a)] issued by such Government or authority; \nor]  \n \n14[(d)   a banking company, a financial institution,  a company referred  \n                                            \n1The words “resident company” substituted by the Finance Act, 2009. \n2 Inserted by the Finance Act, 2021. \n3The words “or collect tax from the shareholder in the case of bonus shares,” omitted by the Finance \nAct, 2002. \n4The expression “Division III of Part I” substituted by the expression “Division I of Part III” by the Finance \nAct, 2014. \n5 Inserted by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016. \n6 Section 150A omitted by the Finance Act, 2021. The omitted section read as follows: \n “150A. Return on investment in Sukuks— Every special purpose vehicle, or a company, at the time \nof]making payment of a return on investment in sukuks to a sukuk holder shall deduct tax from the \ngross amount of return on investment at the rate specified in Division IB of Part III of the First \nSchedule.”] \n7Clause (a) substituted by the Finance Act, 2003. The substituted clause (a) read as follows:  \n“(a) \na person pays yield on a National Savings Deposit Certificate, including a Defence Savings \nCertificate, under the National Savings Scheme;” \n8 The word “and” substituted by the Finance Act, 2003. \n9The word “or” omitted by the Finance Act, 2002. \n10 Clause (c) substituted by the Finance Act, 2002. The substituted clause (c) read as follows: \n“(c)  the Federal Government, a Provincial Government, a local authority, banking company, \nfinancial institution, company referred to in clauses (a) and (b) of the definition of “company” in sub-\nsection (2) of section 80, or finance society pays any profit on any bond, certificate, debenture, security \nor instrument of any kind (other than a loan agreement between a borrower and a banking company \nor a development finance institution) to any person other than a financial institution, “  \n11The words “local authority” substituted by the Finance Act, 2008. \n12The commas and words “, other than a financial institution,” omitted by the Finance Act, 2003. \n13 Inserted by the Finance Act, 2003. \n14Added by the Finance Act, 2002. \n\n\f\nChapter X – Procedure__________________________________ \n \n311 \n \nto in 1[sub-clauses (i) and (ii) of clause (b)] of sub-section (2) of section \n80, or a finance society pays any profit on any bond, certificate, \ndebenture, security or instrument of any kind (other than a loan \nagreement between a borrower and a banking company or a \ndevelopment finance institution) to any person other than financial \ninstitution.] \n \nthe payer of the profit shall deduct tax at the rate specified in Division IA of Part III \nof the First Schedule from the gross amount of the yield or profit paid as reduced \nby the amount of Zakat, if any, paid by the recipient under the Zakat and Ushr \nOrdinance, 1980 (XVII of 1980), at the time the profit is paid to the recipient. \n \n \n2[(1A)  Every special purpose vehicle or a company, at the time of making \npayment of a return on investment in sukuks to a sukuk holder shall deduct tax \nfrom the gross amount of return on investment at the rate specified in Division IB \nof Part III of the First Schedule.]  \n \n \n(2) \nThis section shall not apply to any profit on debt that is subject to sub-\nsection (2) of section 152. \n \n3[(3) Tax deductible under this section shall be a 4[minimum] tax on the profit \non debt arising to a taxpayer, except where — \n \n(a) taxpayer is a company; or \n \n \n(b) profit on debt is taxable under section 7B.] \n \n5[151A. Gain arising on disposal of certain debt securities. — (1) Every \ncustodian of debt securities including a banking company responsible to maintain \nInvestor Portfolio Securities (IPS) Account on behalf of holder of a debt security \nshall at the time of disposal of debt securities including government securities \ndeduct tax at the rate specified in Division IIIAA of Part III of the First Schedule on \nthe gross amount of capital gain arising to such holder and deposit the same in \ngovernment treasury:  \n \nProvided that this section shall not apply on disposal of debt securities made \nthrough registered stock exchange and which are settled through NCCPL.  \n                                            \n1The words, letters and brackets “clauses (a) and (b)” substituted by the Finance Act, 2003. \n2 Sub-section (1A) inserted by the Finance Act, 2021. \n3 Substituted by the Finance Act, 2015. The substituted sub-section (3) read as follows:- \n \n“(3)  \nTax deductible under this section shall be a final tax on the profit on debt arising to a \ntaxpayer other than a company:  \n  \nProvided that in the case of a non-filer other than a company the final tax shall be equal \nto the tax deductible in the case of filer and the tax deducted in excess of that shall be advance \nincome tax adjustable against tax liability.” \n4The word “final” substituted through Finance Act, 2019. \n5 Section 151A inserted by the Finance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n312 \n \n \n(2) \nThe capital gain arising to the holder on disposal of debt security \nmentioned in sub-section (1) shall be computed in accordance with the formula \nprovided in sub-section (1A) of section 37A of the Ordinance.] \n \n152. Payments to non-residents.— (1) Every person paying an amount of \n1[royalty] or fees for technical services to a non-resident person that is chargeable \nto tax under section 6 shall deduct tax from the gross amount paid at the rate \nspecified in Division IV of Part I of the First Schedule. \n \n \n2[(1A) Every person making a payment in full or part (including a payment \nby way of advance) to a non-resident person on the execution of –  \n \n(a)  \na contract or sub-contract under a construction, assembly or  \ninstallation project in Pakistan, including a contract for the supply of \nsupervisory activities in relation to such project; or \n \n(b)  \nany other contract for construction or services rendered relating  \nthereto; or \n \n(c)  \na contract for advertisement services rendered by T.V. Satellite  \nChannels, \n \nshall deduct tax from the gross amount payable under the contract at the rate \nspecified in Division II of Part III of the First Schedule.] \n \n3[(1AA) Every person making a payment of insurance premium or re-\ninsurance premium to a non-resident person shall deduct tax from the gross \namount paid at the rate specified in Division II of Part III of the First Schedule.]  \n \n \n4[(1AAA)Every person making a payment for advertisement services to a \nnon-resident media person relaying from outside Pakistan shall deduct tax from \nthe gross amount paid at the rate specified in  5[Division II] of Part III of the First \nSchedule.] \n \n \n6[   ] \n \n                                            \n1Substituted for the word  “royalties” by the Finance Act, 2002. \n2Inserted by the Finance Act, 2006. \n3 Inserted by the Finance Act, 2008. \n4Inserted by the Finance Act, 2012. \n5The expression “Division IIIA” substituted by the Finance Act, 2017. \n6Sub-section (1B) inserted by the Finance Act, 2006. \n\n\f\nChapter X – Procedure__________________________________ \n \n313 \n \n 1[(1B)  The tax deductible under sub-sections (1A), (1AA) and (1AAA) shall \nbe a minimum tax on the income of the non-resident persons in respect of \npayments mentioned therein.  \n \n(1BA) Every person responsible for making payment directly or through an \nagent or intermediary to a non-resident person for foreign produced commercial \nfor advertisement on any television channel or any other media, shall deduct tax \nat the rate of twenty percent from the gross amount paid. The tax deductible under \nthis sub-section shall be final tax on the income of non-resident person arising out \nof such payment.]  \n \n2[  ]  \n \n \n3[  ]   \n4[   ]  \n \n5[(1C) Every banking company or a financial institution remitting outside  \nPakistan an amount of fee for offshore digital services, chargeable to tax under  \nsection 6, to a non-resident person on behalf of any resident or a permanent  \nestablishment of a non-resident in Pakistan shall deduct tax from the gross amount \npaid at the rate specified in Division IV of Part I of the First Schedule] 6[: \n \nProvided that the banking company and financial institution shall not deduct \nthe tax under this sub-section where the recipient is also liable to Digital Presence \nProceeds tax and same has been collected.] \n \n7[(1D) Every banking company or a financial institution maintaining 8[, for a \nperiod not less than six months,] special convertible rupee account (SCRA) of a \n                                            \n1 Sub-sections (1B), (1BB) and (1BBB) substituted by the Finance Act, 2021. The substituted sub-\nsections read as follows: \n  “(1B) The tax 1[deductible] under sub-section (1A) shall be a 1[minimum] tax on the income of a non-\nresident person arising from a contract 1[.] \n    (1BB) The tax 1[deductible] under sub-section (1AA) shall be a 1[minimum] tax on the income of the   \nnon-resident person arising out of such payment.] \n    (1BBB) The tax deductible under sub-section (1AAA) shall be minimum tax on the income of non-  \nresident person arising out of such payment.” \n2Proviso omitted by the Finance Act, 2019 omitted proviso read as follow:  \nProvided that the provisions of this sub-section shall not apply in respect of a non-resident person \nunless he opts for the final tax regime. \n3 Sub-section (1BB) inserted by the Finance Act, 2008. \n4The new Sub-section (1BBB) inserted through Finance Act, 2020 dated 30th June, 2020.  \n5 Inserted by the Finance Act, 2018. \n6 Full stop substituted with a colon and thereafter a new proviso added by the Finance Act, 2025. \n7 New sub-sections (1D) and (1E) inserted through Tax Laws (Second Amendment), 2019 dated 26th \nDecember, 2019. \n8 Words inserted by the Finance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n314 \n \nnon-resident company having no permanent establishment in Pakistan shall \ndeduct tax from capital gain arising on the disposal of debt instruments and \nGovernment securities including treasury bills and Pakistan investment bonds \ninvested through SCRA at the rate specified in Division II of Part III of the First \nSchedule] 1[: \n \nProvided that in case of holding period of debt instruments and Government \nsecurities including treasury bills and Pakistan investment bonds is less than six \nmonths, the capital gain arising on the disposal of such securities to the non-\nresident person shall be taxed at the rates provided in paragraph (2) of Division II \nof Part III of the First Schedule of the Ordinance.] \n \n2[(1DA) Every banking company maintaining a Foreign Currency Value \nAccount (FCVA) or a non-resident Pakistani Rupee Value Account (NRVA) of a \nnon-resident individual holding Pakistan Origin Card (POC) or National ID Card for \nOverseas Pakistanis (NICOP) or Computerized National ID Card (CNIC) shall \ndeduct tax from capital gain arising on the disposal of debt instruments and \ngovernment securities and certificates (including Shariah compliant variant) \ninvested through aforesaid accounts at the rate specified in Division II of Part III of \nthe First Schedule.]  \n \n3[(1DB) Every special purpose vehicle or a company, at the time of making \npayment of a return on investment in sukuks to a non-resident sukuk holder shall \ndeduct tax from the gross amount of return on investment at the rate specified in \nDivision IB of Part III of the First Schedule.] ] \n \n4[(1DC) Every exchange company licensed by the State Bank of Pakistan \nshall deduct tax at the time of making payment of service charges or commission \nor fee, by whatever name called, to the global money transfer operators, \ninternational money transfer operators or such other persons engaged in \ninternational money transfers or cross-border remittances for facilitating outward \nremittances, at the rates given in Division IV, Part I of the First Schedule: \n \nProvided that where such person retains service charges or \ncommission or fee, by whatever name called from the amount payable to the \nexchange company on any account, the exchange company shall be \ndeemed to have paid the service charges or commission or fee, by whatever \nname called and the exchange company shall collect the tax accordingly. \n  \n                                            \n1 Full stop substituted with a colon and thereafter a new proviso added by the Finance Act, 2025. \n2 Sub-section (1DA) inserted by the Finance Act, 2021. Earlier this insertion was made through Tax \nLaws (Amendment) Ordinance, 2021. \n3  Sub-section (1DB) inserted by the Finance Act, 2021. \n4  Sub-sections (1DC) and (1DD) inserted by the Finance Act, 2022. \n\n\f\nChapter X – Procedure__________________________________ \n \n315 \n \n(1DD) Every banking company while making payment to card network \ncompany or payment gateway or any other person, of any transaction fee or \nlicensing fee or service charges or commission or fee by whatever name called \nor interbank financial telecommunication services, shall deduct tax at the rates \ngiven in Division IV, Part I of the First Schedule: \n \nProvided that where card network company or payment gateway or \nany other person retains money in relation to aforementioned services from \nthe amount payable to the banking company on any account, the banking \ncompany shall be deemed to have paid the amount and the banking \ncompany shall collect the tax accordingly] \n \n1[(1E) The tax deductible under sub-sections (1D), (1DA) 2[(IDB), (1DC) and \n(IDD)] shall be a final tax in respect of persons and income mentioned therein.]    \n \n(2) \nSubject to sub-section (3), every person paying an amount to a             \nnon-resident person (other than an amount to which sub-section (1) 3[or sub-\nsection (1A) 4[, (1AA)] 5[, (1AAA), 6[(1C)] or (2A)] applies)] shall deduct tax from \nthe gross amount paid at the rate specified in Division II of Part III of the First \nSchedule. \n \n \n7[(2A) Every prescribed person making a payment in full or part including a \npayment by way of advance to a permanent establishment in Pakistan of a    non-\nresident person— \n \n8[(a)] \nfor the sale of goods 9[except where the sale is made by the \nimporter of the goods and tax under section 148 in respect of \nsuch goods has been paid and the goods are sold in the same \ncondition as they were when imported]; \n \n10[(b)] for the rendering of or providing services; and \n \n                                            \n1  Sub-section (1E) substituted by the Finance Act, 2021. Earlier an amendment was made through \nTax Laws (Amendment) Ordinance, 2021. The substituted sub-section read as follows: \n“(1E) \nThe tax deductible under sub-section (1D) shall be a final tax on the income of the non-\nresident company arising out of such capital gain.” \n2  The expression “and (1DB)” substituted by the Finance Act, 2022. \n3Inserted by the Finance Act, 2007. \n4Inserted by the Finance Act, 2010. \n5 Inserted by the Finance Act, 2012. \n6Inserted by the Finance Act, 2019 \n7 Added by the Finance Act, 2012. \n8Clause (i) re-numbered by Finance Act 2017. \n9Added by the Finance Act, 2016. \n10Clause (ii) re-numbered by Finance Act 2017. \n\n\f\nChapter X – Procedure__________________________________ \n \n316 \n \n1[(c)] \non the execution of a contract, other than a contract for the sale \nof goods or the rendering of or providing services, shall, at the \ntime of making the payment, deduct tax from the gross amount \npayable (including sales tax, if any) at the rate specified in \nDivision II of Part III of the First Schedule.] \n \n2[(2AA)  sub-section (1AA) shall not apply to an amount, with the written \napproval of the Commissioner, hat is taxable to a permanent establishment in \nPakistan of the non-resident person.] \n \n3[(2B) the tax deductible under sub-section (2A) shall be minimum tax: \n \n \n \nProvided that tax deductible under clause (a) of sub-section (2A) \nshall not be minimum tax where payments are received for sale of goods by a \ncompany being a manufacturer of such goods.] \n \n(3) \nSub-section (2) does not apply to an amount — \n \n(a) \nthat is subject to deduction of tax under section 149, 150, 4[  ] 5[  \n] 156 6[or 233]; \n \n(b) \nwith the written approval of the Commissioner, that is taxable to \na permanent establishment in Pakistan of the non-resident \nperson; \n \n(c) \nthat is payable by a person who is liable to pay tax on the \namount as representative of the non-resident person under sub-\nsection (3) of section 172; or \n \n(d) \nwhere the non-resident person is not chargeable to tax in \nrespect of the amount. \n \n \n(4) \nWhere a person claims to be a representative of a non-resident \nperson for the purposes of clause (c) of sub-section (3), the person shall file a \ndeclaration to that effect with the Commissioner prior to making any payment to \nthe non-resident person.  \n \n                                            \n1Clause (iii) re-numbered  by Finance Act 2017. \n2 Added by the Finance Act, 2012. \n3Sub-section (2B) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted sub-\nsection read as follows: \n“(2B) The tax deductible under clause (b) of sub-section (2A) shall be a minimum tax and the provisions of \nsub-clauses (i), (ii) and (iii) of clause (b) of \nsub-section (3) 3[  ] of section 153 shall mutatis mutandis apply.” \n4 The figure and comma “153,” omitted by the Finance Act, 2012. \n5The figure and comma “155,” omitted by the Finance Act, 2013. \n6Inserted by the Finance Act, 2006. \n\n\f\nChapter X – Procedure__________________________________ \n \n317 \n \n1[2[(4A) \nThe Commissioner may, on application made 3[in the prescribed \nform] by the recipient of payment referred to in sub-section (1A) having permanent \nestablishment in Pakistan, or by a recipient of payment referred to in sub-section \n(2A), as the case may be, and after making such inquiry as the Commissioner \nthinks fit, allow by order in writing, in cases where the tax deductable under sub-\nsection (1) or sub-section (2A) is 4[not minimum tax], any person to make the \npayment 5[after deduction of tax at a reduced rate but such reduction shall not \nexceed eighty percent of the rate specified in the said Division].] ] \n \n6[(4B) \nThe Commissioner may, in case of payment that constitutes part of \nan overall arrangement of a cohesive business operation as referred to in \nparagraph (ii) of sub-clause (g) of clause (41) of section 2, on application made by \nthe person making payment and after making such inquiry, as the Commissioner \nthinks fit, allow by order in writing, the person to make payment after deduction of \ntax equal to 7[twenty] percent of the tax chargeable on such payment under sub-\nsection (1A): \n \n \nProvided that the credit of the tax so deducted shall be available to \nthe permanent establishment of the non-resident accounting for overall \nprofits arising on the overall cohesive business operation.] \n \n \n(5) \nWhere a person intends to make a payment to a non-resident person \nwithout deduction of tax under this section,8[other than payments liable to reduced \nrate under relevant agreement for avoidance of double taxation,] the person shall, \nbefore making the payment, furnish to the Commissioner a notice in writing setting \nout — \n \n(a) \nthe name and address of the non-resident person; 9[  ]   \n \n                                            \n1Inserted by the Finance Act, 2015. \n2Sub-section (4A) substituted by the Finance Act, 2017. The substituted sub-section (4A) reads as \nfollows: \n “(4A) The Commissioner may, on application made by the recipient of a payment referred to in sub-section (2A) \nand after making such inquiry as the Commissioner thinks fit, may allow in cases where the tax deductable under \nsub-section (2A) is adjustable, by order in writing, any person to make the payment, without deduction of tax or \ndeduction of tax at a reduced rate.”;] \n3The words inserted through Finance Act, 2020 dated 30th June, 2020 \n4The word “adjustable” substituted through Finance Act, 2019. \n5 The expression “without deduction of tax or deduction of tax at a reduced rate” substituted by the \nFinance Act, 2024. \n6New sub-section (4B) inserted through Finance Act, 2019.  \n7The word “thirty” substituted by “twenty” through Finance Act, 2020 dated 30th June, 2020  \n8Inserted by the Finance Act, 2008. \n9The word “and” omitted through Finance Act, 2020 dated 30th June, 2020  \n\n\f\nChapter X – Procedure__________________________________ \n \n318 \n \n(b) \nthe nature and amount of the payment 1[;and \n \n(c) \nsuch other particulars as may be prescribed.]  \n \n2[(5A) The Commissioner on receipt of notice shall 3[, within thirty days,] pass \nan order accepting the contention or making the order under sub-section (6)] 4[: \n \nProvided that the Commissioner shall be deemed to have issued the \nexemption certificate upon the expiry of thirty days and the certificate shall be \nautomatically processed and issued by Iris subject to the condition that in \ncomputing the said period of thirty days, there shall be excluded days taken for \nadjournment by the applicant:  \n \nProvided further that the Commissioner may modify or cancel the certificate \nissued automatically by Iris on the basis of reasons to be recorded in writing after \nproviding an opportunity of being heard.] \n \n \n(6) \nWhere a person has notified the Commissioner of a payment under \nsub-section (5) and the Commissioner has reasonable grounds to believe that the \nnon-resident person is chargeable to tax under this Ordinance in respect of the \npayment, the Commissioner may, by 5[order] in writing, direct the person making \nthe payment to deduct tax from the payment in accordance with sub-section (2). \n \n \n(7) \nSub-section (5) shall not apply to a payment on account of – \n \n6[(a) an import of goods where title to the goods passes outside \nPakistan and is supported by import documents, except where — \n \n                                            \n1The “full stop” substituted by “semi colon” and the word “and” thereafter new clause (c) added \nthrough Finance Act, 2020 dated 30th June, 2020. \n2 Inserted by the Finance Act, 2003. \n3Inserted by the Finance Act, 2004. \n4 Full stop substituted with a colon and new provisos added by the Finance Act, 2023. \n5 The word “notice” substituted by the Finance Act, 2004. \n6Clause (a) substituted by the finance Act 2018, the substituted clause (a) is read as follows \n“(a) \nan import of goods where title to the goods passes outside Pakistan6[and is supported by \nimport documents], except an 6[ ] import that is part of an overall arrangement for the \nsupply of goods, their installation, and any commission and guarantees in respect of the \nsupply where – \n (i) the supply is made by the head office outside Pakistan of a person to a permanent \nestablishment of the person in Pakistan; \n (ii) the supply is made by a permanent establishment of the person outside Pakistan to a \npermanent establishment of the person in Pakistan; \n(iii) the supply is made between associates; or \n(iv) the supply is made by a resident person or a Pakistan permanent establishment of a non-\nresident person; or” \n\n\f\nChapter X – Procedure__________________________________ \n \n319 \n \n(i) \nthe supply is made in connection with the overall arrangement \nfor the supply of goods, installation, construction, assembly, \ncommission, guarantees or supervisory activities and all or \nprincipal activities are undertaken or performed either by the \nassociates of the person supplying the goods or its \npermanent establishment, whether or not the title passes \noutside Pakistan and whether or not the goods are imported \nin the name of the associate or any other person; or \n \n(ii) \nthe supply is made by a resident person or a Pakistan \npermanent establishment of a non-resident person in \nconnection with the overall arrangement as referred to in \nsub-clause (i); or” ] \n \n(b) \neducational and medical expenses remitted in accordance with \nthe regulations of the State Bank of Pakistan. \n \n \n1[(8)  In this section “prescribed person” means a prescribed person as \ndefined in sub-section (7) of section 153.] \n \n2[  ] \n \n 3[  ]  \n \n                                            \n1 Added by the Finance Act, 2012. \n2 Inserted by the Finance Act, 2016. \n3 Section 152A omitted by the Finance Act, 2021. The omitted section read as follows: \n  “152A. Payment for foreign produced commercials.─ (1) Every person responsible for making  \npayment directly or through an agent or intermediary to a non-resident person for foreign produced \ncommercial for advertisement on any television channel or any other media shall deduct tax at the \nrate of twenty percent from the gross amount paid. \n(2) \nThe tax deductable under sub-section (1), shall be final tax on the income of non- \nresident person arising out of such payment.”  \n\n\f\nChapter X – Procedure__________________________________ \n \n320 \n \n1[153. Payments for goods, services and contracts.— (1) Every prescribed \nperson making a payment in full or part including a payment by way of advance to \na resident person 1[  ] 2[  ] — \n                                            \n1 Section 153 substituted by the Finance Act, 2011. The substituted section 153  read as follows: \n“153. \n Payments for goods and services. — (1)  Every prescribed person making a payment in full \nor part including a payment by way of advance to a resident person or permanent establishment in \nPakistan of a non-resident person— \n(a) \nfor the sale of goods;  \n(b) \nfor the rendering of or providing of services;  \n(c) \non the execution of a contract, other than a contract for the sale of  goods or the \nrendering of or providing of services, \nshall, at the time of making the payment, deduct tax from the gross amount payable at the rate specified \nin Division III of Part III of the First Schedule. \n \n(1A) Every exporter or an export house making a payment in full or part including a payment by \nway of advance to a resident person or permanent establishment in Pakistan of a non-resident person \nfor the rendering of or providing of services of stitching, dying, printing, embroidery, washing, sizing \nand weaving, shall at the time of making the payment, deduct tax from the gross amount payable at \nthe rate specified in Division IV of Part III of the First Schedule. \n \n(2) \nThe gross amount payable for a sale of goods shall include the sales tax, if any, payable \nin respect of the sale. \n \n(3)  \nOmitted.  \n \n(4) \nThe Commissioner may, on application made by the recipient of a payment referred to \nin sub-section (1) and after making such enquiry as the Commissioner thinks fit, allow, by order in \nwriting, any person to make the payment without deduction of tax. \n \n(5) \nSub-section (1) shall not apply to – \n(a) \na sale of goods where – \n  (i) \nthe sale is made by the importer of the goods; \n (ii) \nthe importer has paid tax under section 148 in respect of the goods; and \n(iii) \nthe goods are sold in the same condition they were in when imported; \n(b) \na refund of any security deposit;  \n(ba) \na payment made by the Federal Government, a Provincial Government or a \nLocal Government] to a contractor for construction materials supplied to the \ncontractor by the said Government or the authority; \n(bb)  \na cotton ginner who deposits in the Government Treasury, an amount equal to \nthe amount of tax deductible on the payment being made to him, and evidence \nto this effect is provided to the “prescribed person”; \n(c) \nthe purchase of an asset under a lease and buy back agreement by a modaraba, \nleasing company, banking company or financial institution; or \n(d) \nany payment for securitization of receivables by a Special Purpose Vehicle to \nthe Originator.  \n \n \n(e)  \nOmitted. \n \n (6)  \nThe tax deducted under this section shall be a final tax on the income of a resident \nperson arising from transactions referred to in sub-section (1) or (1A): \nProvided that sub-section (6) shall not apply to companies in respect of \ntransactions referred to in clause (b) of sub-section (1): \nProvided further that this sub-section shall not apply to payments received on \naccount of— \n \n \n \n(i) \nadvertisement services, by owners of newspapers and magazines; \n(ii) \nsale of goods and execution of contracts by a public company listed on \na registered stock exchange in Pakistan; and \n(iii)  \nthe rendering of or providing of services referred to in sub-clause (b) of \nsub-section (1): \nProvided that tax deducted under sub-clause (b) of sub-section (1) of section \n153 shall be minimum tax. \n\n\f\nChapter X – Procedure__________________________________ \n \n321 \n \n(a) for the sale of goods 3[including toll manufacturing] 4[, except \nwhere payment is less than seventy-five thousand Rupees in \naggregate, during a financial year];  \n \n(b)  for the rendering of or providing of services 5[except where \npayment is less than thirty thousand Rupees in aggregate, during \na financial year]; \n \n(c) on the execution of a contract, 6[including contract signed by a \nsportsperson] 7[but not including] a contract for the sale of goods \nor the rendering of or providing services, shall, at the time of \n                                            \n (6A)  The provisions of sub-section (6) in so far as they relate to payments on account of \nsupply of goods from which tax is deductible under this section shall  not  apply in respect of a company \nbeing a manufacturer of such goods.  \n \n(6B) \nOmitted previously. \n \n(7) \nOmitted previously. \n \n(8) \nWhere any tax is deducted by a person making a payment to a Special Purpose Vehicle, \non behalf of the Originator, the tax is credited to the Originator. \n \n(8A) \nOmitted previously. \n \n(9) \nIn this section, – \n“prescribed person” means – \n(a) \nthe Federal Government; \n(b) \na company; \n(c) \nan association of persons constituted by, or under law;  \n \n \n(cc)  \na non-profit organization; \n(d) \na foreign contractor or consultant;  \n(e) \na consortium or joint venture;  \n(f)  \nan exporter or an export house for the purpose of sub-section  (1A); \n(g) \nan association of persons, having turnover of fifty million rupees or above in tax \nyear 2007 1[or in any subsequent tax year . \n(h)  \nan individual, having turnover of fifty million rupees or above in the tax year 2009 \nor in any subsequent year. \n“services” includes the services of accountants, architects, dentists, doctors, engineers, \ninterior decorators and lawyers, otherwise than as an employee. \n“sale of goods” includes a sale of goods for cash or on credit, whether under written \ncontract or not “manufacturer” for the purpose of this section means, a person who is \nengaged in production or manufacturing of goods, which includes- \n (a)  \nany process in which an article singly or in combination with other articles, \nmaterial, components, is either converted into another distinct article or produce \nis so changed, transferred, or reshaped that it becomes capable of being put to \nuse differently or distinctly; or  \n(b)  \na process of assembling, mixing, cutting or preparation of goods in any other manner.” \n1 The word “or” omitted through Finance Act, 2020 dated 30th June, 2020 \n2 The words “permanent establishment in Pakistan of a non-resident person” omitted by the Finance \nAct, 2012. \n3 The words inserted through Finance Act, 2020 dated 30th June, 2020 \n4 Inserted by the Finance Act, 2018. \n5 Inserted by the Finance Act, 2018. \n6 Inserted by the Finance Act, 2014. \n7 The words “other than” substituted by the words “but not including” by the Finance Act, 2014. \n\n\f\nChapter X – Procedure__________________________________ \n \n322 \n \nmaking the payment, deduct tax from the gross amount payable \n(including sales tax, if any) at the rate specified in Division III of \nPart III of the First Schedule 1[;] \n \n \n  \n2[Provided that where the recipient of the payment under \nclause (b) receives the payment through an agent or any other \nthird person and the agent or, as the case may be, the third person \nretains service charges or fee, by whatever name called, from the \npayment remitted to the recipient, the agent or the third person \nshall be treated to have been paid the service charges or fee by \nthe recipient and the recipient shall collect tax along with the \npayment received.] \n \n \n(2)  \nEvery exporter or an export house making a payment in full or part \nincluding a payment by way of advance to a resident person or permanent \nestablishment in Pakistan of a non-resident person for rendering of or providing \nservices of stitching, dying, printing, embroidery, washing, sizing and weaving, \nshall at the time of making the payment, deduct tax from the gross amount payable \nat the rate specified in Division IV of Part III of the First Schedule. \n \n \n3[(2A) Notwithstanding the provision of sub-section (1), –  \n \n(i) \nevery payment intermediary at the time of processing payment \nthrough digital means, on behalf of a seller of digitally ordered \ngoods or services through locally operated e-commerce \nplatforms (including websites); and  \n \n(ii) \nevery courier business providing courier services collecting \ncash from a buyer under Cash on Delivery (CoD) payment \nterms on behalf of a seller for the supply of digitally ordered \ngoods and services through e-commerce platforms (including \nwebsites);  \n \nshall collect tax from the gross amount payable (including sales tax, if any) to the \nseller at the rate specified in Division IVA of Part I of the First Schedule to the \nOrdinance and deposit to government treasury.] \n \n \n                                            \n1 Full stop substituted by the Finance Act, 2017. \n2 Added by the Finance Act, 2017. \n3 Sub-section (2A) inserted by the Finance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n323 \n \n(3)  \nThe tax 1[deductible] under 2[ ]  sub-section (1) and under sub-section \n(2) of this section, on the income of a resident person or 3[  ], shall be 4[minimum] \ntax.  \n \n \n \nProvided that,— \n \n(a)  \ntax deducted under clause (a) of sub-section (1) shall 5[not be \nminimum tax]  where payments are received on sale or supply \nof goods, by a, — \n \n \n \n \n(i)  \ncompany being a manufacturer of such goods; or  \n \n(ii)  \npublic company listed on a registered stock exchange in \nPakistan; \n \n6[  ] \n \n(c) \ntax deducted under clause (c) of sub-section (1) shall be \nadjustable if payments are received by a public company listed \non a registered stock exchange in Pakistan, on account of \nexecution of contracts7[  ] 8[     ] 9[. \n                                            \n1 The words “deducted” substituted by the Finance Act, 2012. \n2 The words “clauses (a) and (c) of” omitted through Finance Act, 2020 dated 30th June, 2020 \n3 The words “ permanent establishment in Pakistan of a non-resident person” omitted by the Finance \nAct, 2012. \n4 The word “final” substituted by the Finance Act, 2019  \n5 The words “be adjustable” substituted through Finance Act, 2019. \n6 Clause (b) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted clause reads as \nfollow:- \n“(b) tax deductible shall be a minimum tax on transactions referred to in clause (b) of sub-section (1).\" \n6[“(i)  \nwhere the aforesaid minimum tax for providing or rendering services, in respect of \nsectors as specified in clause (94) of Part IV of the Second Schedule is in excess of tax payable \nunder Division II of Part. I of the First Schedule, the excess amount of tax paid shall be carried \nforward for adjustment against tax liability under the aforesaid Part of the subsequent tax year;”] \n \n6[“(ii) where the excess tax is not wholly adjusted, the amount not adjusted shall be carried forward \nto the following tax year and adjusted against tax liability under the aforesaid Part for that \nyear, and so on, but the said excess shall not be carried forward to more than five tax years \nimmediately succeeding the tax year for which the excess was first paid; and”] \n \n6[“(iii) \nthe said excess amount shall not be carried forward in case of a company for which \nprovisions of this clause are not applicable under clause (94) of Part IV of the Second \nSchedule; 6[   ] \";] \n \n7substituted “.” by the Finance Act, 2015 \n8The word “and” omitted by the Finance Act, 2016.  \n9 Semi colon substituted with  a full stop and new explanation added by the by the Finance \n(Supplementary) Act, 2022.  \n\n\f\nChapter X – Procedure__________________________________ \n \n324 \n \n \n \n\"Explanation.— For the removal of doubt, it is explained that the \nincome of resident person referred to in sub-section (3) means \nthe amount on which tax is deductible under sub-section (1) or \n(2) of this section.]   \n \n1[  ] \n \n2[  ] \n \n \n3[(4) The Commissioner may, on application made by the recipient of a \npayment referred to in sub-section (1) and after making such inquiry as the \nCommissioner thinks fit, may allow in cases where tax deductible under sub-\nsection (1) is not minimum, by an order in writing, any person to make the payment \nafter deduction of tax at reduced rate but such reduction shall not exceed eighty \npercent of the rate specified in the said Division 4[except in cases of public limited \ncompanies where the Commissioner may allow payment without deduction of any \ntax]: \n \nProvided that the Commissioner shall issue reduced rate certificate within \nfifteen days of filing of application to a company if advance tax liability has been \ndischarged:  \n \nProvided further that the Commissioner shall be deemed to have issued the \nreduced rate certificate upon the expiry of fifteen days to the aforesaid company \nand the certificate shall be automatically processed and issued by Iris:  \n                                            \n1 Claude (d) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted clause read as \nfollows: “(d)tax deducted under clause (c) of sub-section (1) in respect of a sportsperson shall be \n1[minimum] tax 1[   ] 1[; and] “ \n2 Claude (e) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted clause read as \nfollows: “(e) tax deducted under clause (b) of sub-section (1) by person making payments to \nelectronic and print media for advertising services shall be 2[minimum] tax 2[  ].” \n3 Sub-section (4) substituted by the Finance Act, 2024. The substituted sub-section read as follows: \n“(4)  The Commissioner may, on application made by the recipient of a payment referred to in sub-\nsection (1) and after making such inquiry as the Commissioner thinks fit, may allow in cases where \ntax deductible under sub-section (1) is 3[not minimum], by an order in writing, any person to make \nthe payment,— \n \n \n(a)  \nwithout deduction of tax; or \n \n \n(b)  \ndeduction of tax at a reduced rate 3[; \nProvided that the Commissioner shall issue certificate for payment under clause (a) of sub-section \n(1) without deduction of tax within fifteen days of filing of application to a 3[company] if advance tax \nliability has been discharged: \nProvided further that the Commissioner shall be deemed to have issued the exemption certificate \nupon the expiry of fifteen days to the aforesaid 3[  ] company and the certificate shall be automatically \nprocessed and issued by Iris: \nProvided also that the Commissioner may modify or cancel the certificate issued automatically by \nIris on the basis of reasons to be recorded in writing after providing an opportunity of being heard.]” \n4  Words inserted by the Finance Act, 2025.  \n\n\f\nChapter X – Procedure__________________________________ \n \n325 \n \nProvided also that the Commissioner may modify or cancel the certificate \nissued automatically by Iris on the basis of reasons to be recorded in writing after \nproviding an opportunity of being heard.]  \n \n1[  ] \n \n \n(5)  \nSub-section (1) shall not apply to — \n \n(a)  \na sale of goods where the sale is made by the importer of the \ngoods and tax under section 148 in respect of such goods has \nbeen paid and the goods are sold in the same condition as they \nwere when imported;  \n \n2[   ]  \n \n \n(c)  \na refund of any security deposit; \n \n(d)  \na payment made by the Federal Government, a Provincial \nGovernment or a Local Government to a contractor for \nconstruction materials supplied to the contractor by the said \nGovernment or the authority; \n \n3[    ]  \n \n(f)  \nthe purchase of an asset under a lease and buy back \nagreement by a modaraba, leasing company, banking company \nor financial institution; or \n \n(g)  \nany payment for securitization of receivables 4[or issuance of \nsukuks] by a Special Purpose Vehicle to the Originator. \n \n \n(6)  \nWhere any tax is deducted by a person making a payment for a \nSpecial Purpose Vehicle, on behalf of the Originator, the tax is credited to the \nOriginator. \n                                            \n1Sub-section (4A) omitted through Finance Act, 2019, omitted sub-section read as follows: \n(4A) The Commissioner, on an application made by the recipient of a payment referred to in \nclause (94) of Part IV of the Second Schedule, in cases where the said recipient has fulfilled the \nconditions as specified in the said clause, by an order in writing for a period of at least three months, \nmay allow any person to make the payment without deduction of tax in respect of payments as referred \nto in clauses (b) of sub-section (1) of section 153: \nProvided that the recipient of the payment has made advance payment of tax equal to two \npercent of the total turnover of the corresponding period of the immediately preceding tax year. \n2 Clause (b) omitted by the Finance Act, 2021. The omitted clause read as follows: \n   “(b)  payments made to traders of yarn by the taxpayers specified in the zero- rated regime of sales \ntax (as provided under clause (45A) of Part-IV of the Second Schedule);” \n3 Clause (e) omitted by the Finance Act, 2016. The omitted clause (e) read as follows:- \n“(e)  a cotton ginner who deposits in the Government Treasury, an amount equal to the amount of \ntax deductible on the payment being made to him, and evidence to this effect is provided to the \n“prescribed person”. \n4 Inserted by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016.  \n\n\f\nChapter X – Procedure__________________________________ \n \n326 \n \n \n(7)  \nIn this section, — \n \n \n \n(i)  \n“prescribed person” means— \n \n \n \n \n(a)  \nthe Federal Government; \n \n \n \n \n(b)  \na company; \n \n \n \n \n(c)  \nan association of persons constituted by, or under law; \n \n \n \n \n(d)  \na non-profit organization; \n \n \n \n \n(e)  \na foreign contractor or consultant; \n \n \n \n \n(f)  \na consortium or joint venture; \n \n(g)  \nan exporter or an export house for the purpose of sub-\nsection (2); \n \n \n \n \n \n(h)  \nan association of persons, having turnover of 1[one \nhundred] million rupees or above in 2[any of the preceding \ntax years]; 3[  ] \n \n(i)  \nan individual, having turnover of 4[one hundred] million \nrupees or above in 5[any of the preceding tax years]; 6[ ] \n \n[(j)  \na person registered under the Sales Tax Act, 1990        \n7[having turnover of one hundred million rupees or more \nin any of the preceding tax years]; 8[ ] 9[ ] ]  \n \n10[(k) a person deriving income from the business of \nconstruction  and sale of residential, commercial or other \nbuildings (builder); 11[ ] \n \n                                            \n1 The word “fifty” substituted through Finance Act, 2020 dated 30th June, 2020 \n2 The expression “tax year 2007 or in any subsequent tax year” substituted by the finance Act 2018. \n3 The word “or” omitted by the Finance Act, 2013. \n4 The word “fifty” substituted through Finance Act, 2020 dated 30th June, 2020 \n5 The expression “the tax year 2009 or in any subsequent tax year” substituted by the finance Act 2018. \n6 The word “or” omitted by the finance Act 2018. \n7 The expression inserted through Finance Act, 2020 dated 30th June, 2020 \n8 Inserted by the finance Act 2018. \n9 The word “or” omitted by the Finance Act, 2025.  \n10Added by the Finance Act, 2018. \n11 The word “or” omitted by the Finance Act, 2025.  \n\n\f\nChapter X – Procedure__________________________________ \n \n327 \n \n(l) \na person deriving income from the business of \ndevelopment and sale of residential, commercial or other \nplots (developer)] 1[;] \n \n2[(m) for the purpose of sub-section (2A), a payment \nintermediary; or  \n   \n  (n) \nfor the purpose of sub-section (2A), a courier service.] \n \n(ii)  \n“services” includes the services of accountants, architects, \ndentists, doctors, engineers, interior decorators and lawyers, \notherwise than as an employee; \n \n3[(iia) “courier service” means any specialized entity that provides \nfast, secure and often tracked transportation of documents, \npackages and small freight, typically offering door-to-door \ndelivery solutions of goods within specific timeframes and in \ncase of digitally ordered goods in e-commerce delivery and \ncollection of cash (CoD) on behalf of the seller and such delivery \nservice provider includes but not limited to –  \n \n(a) \nLogistics services;  \n \n(b) \nride-haling services;  \n \n(c) \nfood delivery platforms; and  \n \n(d) \ne-commerce services;  \n  \n(iib) “payment intermediary” means any third party entity including a \nbanking company, financial institution, a licensed foreign \nexchange company or payments gateways that facilitate the \ntransfer of funds or payment instructions between two or more \nparties to enable, process, route or settle payments in a \nfinancial transaction, without being the ultimate source or \nrecipient of the payment;] \n \n(iii)  \n“sale of goods” includes a sale of goods for cash or on credit, \nwhether under written contract or not; 4[and] \n \n                                            \n1 Full stop substituted by the Finance Act, 2025.  \n2 Sub-clauses (m) and (n) added by the Finance Act, 2025.  \n3 Sub-clauses (m) and (n) added by the Finance Act, 2025.  \n4 Word added by the Finance Act, 2025.  \n\n\f\nChapter X – Procedure__________________________________ \n \n328 \n \n(iv)  “manufacturer” means a person who is engaged in production \nor manufacturing of goods, which includes— \n \n(a)  \nany process in which an article singly or in combination \nwith other articles, material, components, is either \nconverted into another distinct article or product is so \nchanged, transferred, or reshaped that it becomes \ncapable of being put to use differently or distinctly; or  \n \n(b)  \na process of assembling, mixing, cutting or preparation of \ngoods in any other manner; and  \n \n \n \n(v)  \n“turnover” means— \n \n(a)  \nthe gross sales or gross receipts, inclusive of sales tax \nand federal excise duty or any trade discounts shown on \ninvoices, or bills, derived from the sale of goods;  \n \n(b)  \nthe gross fees for the rendering of services for giving \nbenefits including commissions;  \n \n \n \n \n \n \n \n(c)  \nthe gross receipts from the execution of contracts; and \n \n(d)  \nthe company’s share of the amounts stated above of any \nassociation of persons of which the company is a \nmember.] \n \n1[  ] \n2[   ] \n 3[   ]  \n \n154.  Exports. — (1)  Every authorised dealer in foreign exchange shall, at the \ntime of realisation of foreign exchange proceeds on account of the export of goods \n                                            \n1 Section 153A omitted by the Finance Act, 2013. Earlier it was substituted by the Finance Act, 2012, \nwhich was inserted by the Finance Act, 2008. The omitted section 153A read as follows: \n“153A. Payment to traders and distributors.— (1) Every manufacturer, at the time of sale to \ndistributors, dealers and wholesalers, shall collect tax at the rate specified in Part IIA of the First \nSchedule, from the aforesaid persons, to whom such sales have been made. \n(2) \nTax credit for the tax collected under sub-section (1) shall be allowed in computing the \ntax due by the person on the taxable income for the tax year in which the tax was collected.” \n2New section 153B inserted through Finance Act, 2019.  \n3 Section 153B omitted by the Finance Act, 2021. The omitted section read as follows: \n“153B. Payment of royalty to resident persons.- (1) Every person paying an amount of royalty, in \nfull or in part including by way of advance, to a resident person shall deduct tax from the gross amount \npayable (including Federal excise duty and provincial sales tax, if any) at the rate specified in Division \nIIIB of Part III of the First Schedule. \n \n(2) \nThe tax deductible under sub-section (1) shall be adjustable.” \n\n\f\nChapter X – Procedure__________________________________ \n \n329 \n \nby an exporter, deduct tax 1[including advance tax] from the proceeds at the rate \nspecified in Division IV of Part III of the First Schedule.  \n \n \n2[   ]    \n \n(3) \nEvery banking company shall, at the time of realisation of the \nproceeds on account of a sale of goods to an exporter under an inland back-to-\nback letter of credit or any other arrangement as prescribed by the 3[Board], deduct \ntax from the amount of the proceeds at the rate specified in Division IV of Part III \nof the First Schedule. \n \n4[(3A) The Export Processing Zone Authority established under the Export \nProcessing Zone Authority Ordinance, 1980 (VI of 1980), shall at the time of export of \ngoods by an industrial undertaking located in the areas declared by the Federal \nGovernment to be a Zone within the meaning of the aforesaid Ordinance, collect tax at \nthe rate specified in Division IV of Part III of the First Schedule.] \n \n5[(3B) Every direct exporter and an export house registered under the Duty \nand Tax Remission for Exports Rules, 2001 provided in Sub-Chapter 7 of Chapter \nXII of the Customs Rules, 2001 6[and Export Facilitation Scheme, 2021] shall, at \nthe time of making payment for a firm contract to an indirect exporter defined under \nthe said rules, deduct tax at the rates specified in Division IV of Part III of the First \nSchedule.] \n \n \n7[(3C) The Collector of Customs at the time of clearing of goods exported \nshall collect tax from the gross value of such goods at the rate specified in Division \nIV of Part III of the First Schedule.] \n \n \n(4) \nThe tax 8[deductible] under 9[this section] shall be a 10[minimum] tax \non the income arising from the 11[transactions referred to in this section]. \n \n12[  ] \n                                            \n1  Words inserted by the Finance Act, 2024. \n2  Sub-sections (2) omitted by the Finance Act, 2022. The omitted sub-section read as follows: \n“(2) Every authorised dealer in foreign exchange shall, at the time of realisation of foreign exchange \nproceeds on account of the commission due to an indenting commission agent, deduct tax from the \nproceeds at the rate specified in Division IV of Part III of the First Schedule.” \n3 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n4 Inserted by the Finance Act, 2003. \n5 Inserted by the Finance Act, 2003. \n6 Expression inserted by the Finance Act, 2023. \n7 Inserted by the Finance Act, 2009. \n8The words “deducted” substituted by the Finance Act, 2012. \n9The word, figures, brackets and commas “sub-section (1), (3), (3A) or (3B)” substituted by the Finance \nAct, 2006. \n10 The word “final” substituted by the Finance Act, 2024. \n11The words ”export or sale to an exporter” substituted by the Finance Act, 2007. \n12 Sub-section (5) inserted by the Finance Act, 2015. \n\n\f\nChapter X – Procedure__________________________________ \n \n330 \n \n1[  ]  \n \n2[154A. Export of Services. — (1) Every authorized dealer in foreign exchange \nshall, at the time of realization of foreign exchange proceeds on account of the \nfollowing, deduct tax from the proceeds at the rates specified in Division IVA of \nPart III of the First Schedule –   \n  \n(a)   exports of computer software or IT services or IT enabled services     \n3[where the exporter is registered with and duly certified by the \nPakistan Software Export Board (PSEB).];  \n  \n(b) services or technical services rendered outside Pakistan or    \nexported from Pakistan; \n \n(c)   royalty, commission or fees derived by a resident company from a \nforeign enterprise in consideration for the use outside Pakistan of any \npatent,  invention, model, design, secret process or formula or similar \nproperty right, or information concerning industrial, commercial or \nscientific knowledge, experience or skill made available or provided \nto such enterprise;   \n  \n(d) construction contracts executed outside Pakistan 4[: \n \n (da)  foreign commission due to an indenting commission agent;] \n  \n  \n \n \n(e)  other services rendered outside Pakistan as notified by the Board    \nfrom time to time;   \n  \n(2) The tax deductible under this section shall be a final tax on the income \narising from the transactions referred to in this section, upon fulfilment of the \nfollowing conditions –  \n  \n(a) \nreturn has been filed; \n \n                                            \n1 Sub-section (5) omitted by the Finance Act, 2024. The omitted sub-section read as follows: \n“[(5) The provisions of sub-section (4) shall not apply to a person who opts not to be subject to final \ntaxation: \nProvided that this sub-section shall be applicable from tax year 2015 and the option shall be \nexercised every year at the time of filing of return under section 114: \nProvided further that the tax deducted under this sub-section shall be minimum tax.]” \n” \n2 Section 154A inserted by the Finance Act, 2021. \n3 The expression “in case tax credit under section 65F is not available” substituted by the Finance Act, \n2022. \n4 The expression “; and“ substituted with colon and new clause (da) inserted by the Finance Act, 2022. \n\n\f\nChapter X – Procedure__________________________________ \n \n331 \n \n1[(b)  withholding tax statements for the relevant tax year have been filed if  \nrequired under the Ordinance;] and \n \n(c) \nsales tax returns under Federal or Provincial laws have been filed, if \nrequired under the law 2[: \n \n \nProvided that this condition shall not apply in case of an \nexporter mentioned in clause (a) of sub-section (1) of this section.] \n   \n  (d)   no credit for foreign taxes paid shall be allowed.  \n  \n            (3) The provisions of sub-section (2) shall not apply to a person who does \nnot fulfill the specified conditions or who opts not to be subject to final taxation:  \n  \nProvided that the option shall be exercised every year at the time of \nfiling of return under section 114.  \n  \n3[  ] \n \n(5) The Board in consultation with State Bank of Pakistan shall prescribe \nmode, manner and procedure of payment of tax under this section.  \n  \n(6) The Board shall have power to include or exclude certain services for \napplicability of provisions of this section.] \n \n155. 4[Rent of immoveable] property.— (1) 5[Every]  prescribed person making \na payment in full or part (including a payment by way of advance) to any person \non account of rent of immovable property (including rent of furniture and fixtures, \nand amounts for services relating to such property) shall deduct tax from the gross \namount of rent paid at the rate specified in Division V of Part III of the First \nSchedule. \n \n \n6[Explanation.- “gross amount of rent” includes the amount referred to in sub-\nsection (1) or (3) of section 16, if any.] \n                                            \n1 Clause (b) substituted by the Finance Act, 2022. The substituted clause read as follows: \n“(b) withholding tax statements for the relevant  tax year have been filed;” \n2 Full stop substituted with a colon and proviso added by the Finance Act, 2023. \n3 Sub-section (4) omitted by the Finance Act, 2022. The omitted sub-section read as follows: \n“(4) Where a taxpayer, while explaining the nature and source of any amount, investment, money, \nvaluable article, expenditure, referred to in section 111, takes into account any source of income which \nis subject to final tax in accordance with the provisions of this section, he shall not be entitled to take \ncredit of a sum that can be reasonably attributed to the business activity or activities mentioned in sub-\nsection (1).]  \n4 The words “income from” substituted by the Finance Act, 2021. \n5 The words, brackets, figure and comma “Subject to sub-section (2), every” substituted by the Finance \nAct, 2006. \n6Inserted by the Finance Act, 2006. \n\n\f\nChapter X – Procedure__________________________________ \n \n332 \n \n \n1[Explanation.— For removal of doubt, it is clarified that the sub section (1) \nshall apply when a payment is made on account of rent of immoveable property \nirrespective of head of income] \n \n \n2[  ] \n \n \n \n3[(3)  In this section, “prescribed person” means – \n \n (i)  \nthe Federal Government;  \n \n \n(ii)  \na Provincial Government; \n \n \n(iii)  \n4[Local Government]; \n \n \n(iv)  a company; \n \n \n(v)  \na non-profit organization5[or a charitable institution]; \n \n \n(vi)  a diplomatic mission of a foreign state; 6[  ] \n \n7[(via) a private educational institution, a boutique, a beauty parlour, a \nhospital, a clinic or a maternity home;] \n \n8[(vib)  individuals or association of persons paying gross rent of rupees one \nand a half million and above in a year; or] \n \n(vii)  any other person notified by the 9[Board] for the purpose of this \nsection.] \n \n156. Prizes and winnings.—(1)  Every person paying 10[prize on] a prize bond, \nor winnings from a raffle, lottery, 11[prize on winning a quiz, prize offered by \ncompanies for promotion of sale,] or cross-word puzzle shall deduct tax from the \n                                            \n1 Added by the Finance Act, 2021.  \n2 Sub-section (2) omitted by the Finance Act, 2010. The omitted sub-section (2) read as follows: \n \n“(2) The tax deducted under sub-section (1) shall be a final tax on the income from property.” \n3Sub-section (3) substituted  by the Finance Act, 2006. The substituted sub-section (3) read as follows: \n \n“(3) In this section, “prescribed person” means the Federal Government, a Provincial Government, \nlocal authority, a company, a non-profit organisation or a diplomatic mission of a foreign state.” \n4The words “local authority” substituted by the Finance Act, 2008. \n5Inserted by the Finance Act, 2013. \n6 The word “or” omitted by the Finance Act, 2013.  \n7 Inserted by the Finance Act, 2013. \n8 Inserted by the Finance Act, 2013. \n9 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n10 Inserted by the Finance Act, 2002. \n11Inserted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n333 \n \ngross amount paid at the rate specified in Division VI of Part III of the First \nSchedule.  \n \n \n(2) Where a prize, referred to in sub-section (1), is not in cash, the person \nwhile giving the prize shall collect tax on the fair market value of the prize. \n \n1[(3) The tax 2[deductible] under sub-section (1) or collected under \n3[sub-]section (2) shall be final tax on the income from prizes or winnings referred \nto in the said sub-sections.] \n \n4[156A. Petroleum Products.— (1) Every person selling petroleum products to a \npetrol pump operator shall deduct tax from the amount of commission or discount \nallowed to the operator at the rate specified in Division VIA of Part III of the First \nschedule. \n \n \n(2) \nThe tax 5[deductible] under sub-section (1) shall be a final tax on the \nincome arising from the sale of petroleum products to which sub-section (1) applies.] \n \n6[  ] \n                                            \n1 Sub-section (3) substituted by the Finance Act, 2002. The substituted sub-section (3) read as follows: \n“(3) The tax deducted under sub-section (1) shall be a final tax on the prize bond or winnings.“  \n2 The words “deducted” substituted by the Finance Act, 2012. \n3Inserted by the Finance Act, 2014. \n4 Added by the Finance Act, 2004. \n5 The words “deducted” substituted by the Finance Act, 2012. \n6 Section 156B omitted through Finance Act, 2020 dated 30th June, 2020 the omitted section read as \nfollows: 156B. Withdrawal of balance under Pension Fund.— (1) A pension fund manager making \npayment from individual pension accounts, maintained under any approved Pension Fund, shall deduct \ntax at the rate specified in sub-section (6) of section 12 from any amount – \n(a) \nwithdrawn before the retirement age 6[:] \n6[Provided that the tax shall not be deducted in case of the eligible person suffering from any disability \nas mentioned in sub-rule (2) of rule 17 of the Voluntary Pension System Rules, 2005 which renders \nhim unable to continue with any employment at the age which he may so elect to be treated as the \nretirement age or the age as on the date of such disability if not so elected by him.] \n \n6[Provided further that the tax shall not be deducted on the share of the nominated survivor of the \ndeceased eligible person and would be treated as if the eligible person had reached the age of \nretirement.] \n(b)  \nwithdrawn, if in excess of 6[fifty per cent] of his accumulated balance at or after the retirement \nage: \n \n6[Provided that the tax shall not be deducted in case, the balance in the eligible persons’ individual \npension account is invested in an approved income payment plan of a pension fund manager or paid \nto a life insurance company for the purchase of an approved annuity plan or is transferred to another \nindividual pension account of the eligible person or the survivors’ pension account in case of death of \nthe eligible person maintained with any other pension fund manager as specified in the Voluntary \nPension System Rules, 2005. \n\n\f\nChapter X – Procedure__________________________________ \n \n334 \n \n1[  ] \n \n2[158.Time of deduction of tax.— A person required to deduct tax from an  \namount paid by the person shall deduct tax — \n \n(a)  \nin the case of deduction under section 151, at the time the \namount is 3[paid or] credited to the account of recipient 4[, \nwhichever is earlier]; and  \n \n(b)  \nin other cases, at the time the amount is actually paid 5[;and] \n \n6[“(c) amount actually paid shall have the meaning as may be \nprescribed.”;] \n \n                                            \n1 Omitted by the Finance Act, 2002. The omitted section 157 read as follows: \n “157. Petroleum products.- (1)  Every person selling petroleum products to a petrol pump operator \nshall deduct tax from the amount of commission or discount allowed to the operator at the rate \nspecified in Division VII of Part III of the First Schedule.  \n \n(2) \nThe tax deducted under sub-section (1) shall be a final tax on the income arising from \nthe sale of petroleum products to which sub-section (1) applies.”  \n2Substituted by the Finance Act, 2002. The substituted section 158 read as follows: \n “158. Time of deduction of tax.- A person required to deduct tax from an amount paid by the person \nshall deduct the tax at the earlier of – \n(a) \nthe time the amount is credited to the account of the recipient; or \n(b) \nthe time of amount is actually paid.” \n3 Inserted by the Finance Act, 2003. \n4 Inserted by the Finance Act, 2003. \n5Substituted “.” By Finance Act, 2015. \n6Added by the Finance Act, 2015. \n\n\f\nChapter X – Procedure__________________________________ \n \n335 \n \nDivision IV \nGeneral Provisions Relating to the Advance Payment of Tax or the \nDeduction of Tax at Source \n \n159.  Exemption or lower rate certificate.— (1)  Where the Commissioner is \nsatisfied that an amount 1[  ] to which Division II or III of this Part 2[or Chapter XII] \napplies is – \n \n(a) \nexempt from tax under this Ordinance; or \n \n(b) \nsubject to tax at a rate lower than that specified in the First Schedule \n3[; or \n \n(c) \nis subject to hundred percent tax credit under 4[under this Ordinance],] \n \nthe Commissioner shall, upon application in writing by the person,5[in the \nprescribed form] issue the person with an exemption or lower rate certificate 6[: \n \n  Provided that in case of a company, the Commissioner shall issue \nexemption or lower rate certificate under this section within fifteen days of filing of \napplication by the company:  \n  \n   Provided further that the Commissioner shall be deemed to have issued \nthe  exemption certificate upon the expiry of fifteen days from filing of application \nby the aforesaid company and the certificate shall be automatically processed and \nissued by Iris:   \n  \n   Provided also that the Commissioner may modify or cancel the certificate \nissued automatically by Iris on the basis of reasons to be recorded in writing after \nproviding an opportunity of being heard.] \n \n7[(1A) The Commissioner shall, upon application from a person,8[in the \nprescribed form] whose income is not likely to be chargeable to tax under 9[  ] this \nOrdinance, issue exemption certificate for the profit on debt referred to in clause \n(c) of sub-section (1) of section 151.] \n                                            \n1The words “paid to a person” omitted by the Finance Act, 2003. \n2Inserted by the Finance Act, 2002. \n3Comma substituted by a semi colon and a new clause (c) added by the Finance Act, 2014. \n4 The expression “section 100C” substituted by the Finance Act, 2021. \n5The words inserted through Finance Act, 2020 dated 30th June, 2020 \n6 Full stop substituted and three provisos added by the Finance Act, 2021.  \n7 Inserted by the Finance Act, 2003. \n8The words inserted through Finance Act, 2020 dated 30th June, 2020 \n9 The word “the” omitted by the Finance Act, 2004. \n\n\f\nChapter X – Procedure__________________________________ \n \n336 \n \n1[(1B) The Commissioner shall, upon application from a person, in the \nprescribed form whose income from capital gains is not chargeable to tax under \nsub-section (1A) of section 37, issue exemption certificate for collection of advance \ntax under section 236C, in respect of a residential immovable property, which —  \n \n(a) \nhas been in the personal use for the last fifteen years;  \n \n(b) \nhas been declared by the person in his wealth statement under \nsection 116 for the last fifteen years; and  \n \n(c) \nappears as residence for personal use in tax record of the person:  \n \nProvided that the exemption certificate under this section shall \nbe issued once in fifteen years.] \n \n \n \n(2) \nA person required to collect advance tax under Division II of this Part \nor deduct tax from a payment under Division III of this Part 2[or deduct or collect \ntax under Chapter XII] shall collect or deduct the full amount of tax specified in \nDivision II or III 3[or Chapter XII], as the case may be, unless there is in force a \ncertificate issued under sub-section (1) relating to the collection or deduction of \nsuch tax, in which case the person shall comply with the certificate.  \n \n \n4[ 5[   ]  ] \n \n6[  ] \n \n \n7[  [   ] ] \n                                            \n1 Sub-section (1B) inserted by the Finance Act, 2025. \n2 Inserted by the Finance Act, 2003. \n3 Inserted by the Finance Act, 2003. \n4Sub-section (3) substituted  by the Finance Act, 2008. The substituted sub-section (3) read as follows: \n“(3) The Board may, from time to time, by notification in the official Gazette, amend the rates of \nwithholding tax prescribed under the Ordinance.”  \n5Omitted by Finance Act, 2015. The omitted sub-section (3) read as follows:-   \n“(3)  \nThe Board may, from time to time, by notification in the official Gazette – \n(a)   \namend the rates of withholding tax prescribed under this Ordinance; or   \n(b) \nexempt persons, class of persons, goods or class of goods from withholding tax \nunder this Ordinance.” \n6Omitted by Finance Act, 2015. The omitted sub-section (4) read as follows:-   \n“(4)All such amendments shall have effect in respect of any tax year beginningon any date \nbefore or after the commencement of the financial year in which the notification is issued and \nshall not be applicable in respect of income on which tax withheld is treated as discharge of \nfinal tax liability. \n7Omitted by Finance Act, 2015. The omitted sub-section (4) read as follows:-   \n“(5) \nThe Board shall place all notifications issued under sub-section (3) in a financial \nyear before both Houses of Majlis-e-Shoora (Parliament).” \n\n\f\nChapter X – Procedure__________________________________ \n \n337 \n \n \n1[(6) Notwithstanding omission of sub-sections (3), (4) and (5), any \nnotification issued under the said sub-sections and for the time being in force, shall \ncontinue to remain in force, unless rescinded by the Board through notification in \nthe official Gazette.] \n \n160.  Payment of tax collected or deducted.— Any tax that has been collected \nor purported to be collected under Division II of this Part or deducted or purported \nto be deducted under Division III of this Part 2[or deducted or collected, or \npurported to be deducted or collected under Chapter XII] shall be paid to the \nCommissioner by the person making the collection or deduction within the time \nand in the manner as may be prescribed.  \n \n161.  Failure to pay tax collected or deducted.— (1)  Where a person– \n \n(a) fails to collect tax as required under Division II of this Part 3[or Chapter \nXII] or deduct tax from a payment as required under Division III of this \nPart 4[or Chapter XII] 5[or as required under section 50 of the repealed \nOrdinance]; or \n \n(b) having collected tax under Division II of this Part 6[or Chapter XII] or \ndeducted tax under Division III of this Part 7[or Chapter XII] fails to pay \nthe tax to the Commissioner as required under section 160, 8[or having \ncollected tax under section 50 of the repealed Ordinance pay to the \ncredit of the Federal Government as required under sub-section (8) of \nsection 50 of the repealed Ordinance,] \n \nthe person shall be personally liable to pay the amount of tax to the Commissioner \n9[who may 10[pass an order to that effect and] proceed to recover the same.] \n \n11[(1A) \nNo recovery under sub-section (1) shall be made unless the \nperson referred to in sub-section (1) has been provided with an opportunity of \nbeing heard.  \n                                            \n1Inserted by the Finance Act, 2015 \n2 Inserted by the Finance Act, 2002. \n3 Inserted by the Finance Act, 2003. \n4 Inserted by the Finance Act, 2002. \n5Inserted by the Finance Act, 2003. Earlier this was inserted by S.R.O. 633(I)/2002, dated 14.09.2002 \nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. \n6Inserted by the Finance Act, 2003. \n7 Inserted by the Finance Act, 2002. \n8 Inserted by the Finance Act, 2003. Earlier this was inserted by S.R.O. 633(I)/2002, dated 14.09.2002 \nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. \n9Inserted by the Finance Act, 2002. \n10 Inserted by the Finance Act, 2003. \n11New sub-sections “(1A) & (1B)” inserted by the Finance Act, 2002. \n\n\f\nChapter X – Procedure__________________________________ \n \n338 \n \n         (1B) \n Where at the time of recovery of tax under sub-section (1) it is \nestablished that the tax that was to be deducted from the payment made to a \nperson or collected from a person has meanwhile been paid by that person, no \nrecovery shall be made from the person who had failed to collect or deduct the tax \nbut the said person shall be liable to pay 1[default surcharge]at the rate of \n2[twelve”]per cent per annum from the date he failed to collect or deduct the tax to \nthe date the tax was paid.] \n \n \n(2) \nA person personally liable for an amount of tax under sub-section (1) \nas a result of failing to collect or deduct the tax shall be entitled to recover the tax \nfrom the person from whom the tax should have been collected or deducted.  \n \n \n3[(3) The Commissioner may, after making, or causing to be made, such \nenquiries as he deems necessary, amend or further amend an order of recovery \nunder sub-section (1), if he considers that the order is erroneous in so far it is \nprejudicial to the interest of revenue: \n \n \n \nProvided that the order recovery shall not be amended, unless the \nperson referred to in sub-section (1) has been provided an opportunity of being \nheard.] \n \n162.  Recovery of tax from the person from whom tax was not collected or \ndeducted.— (1)  Where a person fails to collect tax as required under Division II \nof this Part 4[or Chapter XII] or deduct tax from a payment as required under \nDivision III of this Part 5[or Chapter XII,] the Commissioner may 6[pass an order to \nthat effect and] recover the amount not collected or deducted from the person from \nwhom the tax should have been collected or to whom the payment was made.  \n \n \n(2) \nThe recovery of tax under sub-section (1) does not absolve the person \nwho failed to deduct tax as required under Division III of this Part          7[or Chapter \nXII] from any other legal action in relation to the failure, or from a charge of 8[default \nsurcharge] or the disallowance of a deduction for the expense to which the failure \nrelates, as provided for under this Ordinance.  \n \n                                            \n1The words  “additional tax”  substituted by the Finance Act, 2010. \n2The word “eighteen” substituted by Finance Act, 2015. \n3New sub-section (3) added through Finance Act, 2019.  \n4 Inserted by the Finance Act, 2003. \n5 Inserted by the Finance Act, 2002. \n6 Inserted by the Finance Act, 2003. \n7 Inserted by the Finance Act, 2002. \n8The words  “additional tax”  substituted by the Finance Act, 2010. The substituted provision has been made effective \nfrom 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was made through \nFinance (Amendment) Ordinance, 2009 which was re-promulgated as Finance (Amendment) Ordinance, 2010 and \nremained effective till 05.06.2010. \n\n\f\nChapter X – Procedure__________________________________ \n \n339 \n \n163.  Recovery of amounts payable under this Division.— The provisions of \nthis Ordinance shall apply to any amount required to be paid to the Commissioner \nunder this Division as if it were tax due under an assessment order. \n \n164.  Certificate of collection or deduction of tax.—(1) Every person collecting \ntax under Division II of this Part or deducting tax from a payment under Division III \nof this Part 1[or 2[deducting or collecting tax under] Chapter XII] shall, at the time \nof collection or deduction of the tax, furnish to the person from whom the tax has \nbeen collected or to whom the payment from which tax has been deducted has \nbeen made, 3[copies of the 4[Computerized Payment Receipt (CPR)] or any other \nequivalent document along with] a certificate setting out the amount of tax collected \nor deducted and such other particulars as may 5[  ] be prescribed6[: \n \n \n Provided that in case of persons or class of persons notified as \nSWAPS agent, SWAPS Payment Receipt (SPR) shall be replaced with \nComputerized Payment Receipt (CPR).] \n \n \n(2) \nA person required to furnish a return of taxable income for a tax year \nshall attach to the return 7[copies of the 8[Computerized Payment Receipt (CPR) \nor SWAPS Payment Receipt (SPR)] on the basis of which a certificate is] provided \nto the person under this section in respect of tax collected or deducted in that year \n9[  ].] \n \n10[164A. 11[Settlement of transactions liable to Withholding Tax by SWAPS \nagents]. – (1) Subject to the Ordinance, the Board may, by notification in the \nofficial gazette, notify any person or class of persons required to deduct or collect \ntax under the Ordinance to integrate with Synchronized Withholding Administration \nand Payment System and to act as SWAPS agent within the time and in the \nmanner as may be prescribed.  \n   \n(2) \nThe tax collected or purported to be collected or deducted or \npurported to be deducted under the Ordinance by a notified SWAPS agent and \n                                            \n1 Inserted by the Finance Act, 2002. \n2 Inserted by the Finance Act, 2003. \n3 Inserted by the Finance Act, 2009. \n4 The words “challan of payment“ substituted by the Finance Act, 2022. \n5 The words “pass an order to that effect and” omitted by the Finance Act, 2004.  \n6 The Full stop substituted with colon and proviso added by the Finance Act, 2022. \n7 The words “any certificate” substituted by the Finance Act, 2009.  \n8 The words “challan of payment“ substituted by the Finance Act, 2022. \n9 The words and figure “and such certificate shall be treated as sufficient evidence of the collection or deduction for \nthe purposes of section 168”. \n10 Section 164A inserted by the Finance Act, 2022. \n11 The words “Payment of tax collected or deducted by SWAPS agents” substituted by the Finance Act,  \n2023 \n\n\f\nChapter X – Procedure__________________________________ \n \n340 \n \ncredited to the Commissioner through digital mode, shall be treated to have been \npaid under section 160 of the Ordinance. \n \n(3) \nWhere tax has been paid by a notified SWAPS agent in accordance \nwith sub-section (2) of this section, copy or number of SWAPS Payment Receipt \n(SPR) shall replace copy or number of Computerized Payment Receipts (CPR) for \nthe purposes of the Ordinance. \n \n(4) \nAny notified SWAPS agent shall not be eligible for tax credit under \nPart X of Chapter III of the Ordinance and exemption under any of the provisions \nof the Ordinance if notified SWAPS agent fails to integrate with Board.  \n \n(5) \nAll persons from whom the tax has been collected or deducted by the \nnotified SWAPS agents shall be eligible for credit of tax withheld against SPR \nissued by SWAPS Agent. \n(6) \nAll other provisions of the Ordinance, not specifically dealt with in this \nsection, shall, mutatis mutandis, apply to the notified SWAPS agents.] \n \n165.  Statements.— (1)  Every person collecting tax under Division II of this Part \n1[or Chapter XII 2[or the Tenth Schedule]] or deducting tax from a payment under \nDivision III of this Part 3[or Chapter XII 4[or the Tenth Schedule]] shall, 5[  ] furnish \nto the Commissioner a 6[quarterly] statement in the prescribed form setting out— \n \n(a) the name, 7[Computerized National Identity Card Number, National \nTax Number] and address of each person from whom tax has been \ncollected under Division II of this Part 8[or Chapter XII 9[or the Tenth \nSchedule]] or to whom payments have been made from which tax has \nbeen deducted under Division III of this Part 10[or Chapter XII 11[or the \nTenth Schedule]] in 12[each 13[quarter]] \n \n                                            \n1 Inserted by the Finance Act, 2003. \n2After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \n3Inserted by the Finance Act, 2002. \n4After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019. \n5The words  “within two months after the end of the financial year or within such further time as the Commissioner \nmay allow by order in writing, ”  omitted by the Finance Act, 2010. \n6The word “biannual” substituted through Finance Act 2020 dated 30th June, 2020 \n7Inserted by the Finance Act, 2011. \n8 Inserted by the Finance Act, 2003. \n9After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019. \n10Inserted by the Finance Act, 2002. \n11After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \n12The words  “the year” substituted by the Finance Act, 2010. \n13 The word ”half year” substituted through Finance Act, 2020 dated 30th June, 2020 \n \n\n\f\nChapter X – Procedure__________________________________ \n \n341 \n \n(b) the total amount of payments made to a person from which tax has \nbeen deducted under Division III of this Part 1[or Chapter XII 2[or the \nTenth Schedule]] in 3[each 4[quarter]] \n \n(c) \nthe total amount of tax collected from a person under Division II of this \nPart 5[or Chapter XII 6[or the Tenth Schedule]] or deducted from \npayments made to a person under Division III of this Part 7[or Chapter \nXII 8[or the Tenth Schedule]] in9[each 10[quarter]]; and  \n \n(d) such other particulars as may be prescribed 11[:] \n \n12[Provided that every person as provided in sub-section (1) \nshall be required to file withholding statement even where no \nwithholding tax is collected or deducted during the period 13[:] \n \n \n \n“Provided further that this section shall not apply where \ninformation required under sub-section (1) has been furnished under \nsection 165A.”;] \n \n \n     14[Explanation.— For the removal of doubt, it is clarified that this sub-\nsection overrides all conflicting provisions contained in the Protection of \nEconomic Reforms Act, 1992 (XII of 1992), the Banking Companies \nOrdinance, 1962 (LVII of 1962), the Foreign Exchange Regulation Act, 1947 \n(VII of 1947) and the regulations made under the State Bank of Pakistan Act, \n1956 (XXXIII of 1956), if any, on the subject, in so far as divulgence of \ninformation under section 165 is concerned.] \n \n15[(1A) Every person involved or engaged in economic transactions as \nprescribed by the Board shall furnish to the Commissioner a quarterly statement \nin the prescribed form and manner. ”;and] \n \n                                            \n1Inserted by the Finance Act, 2002. \n2After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \n3The words  “the year” substituted by the Finance Act, 2010. \n4The word “half year” substituted through Finance Act, 2020 dated 30th June, 2020 \n \n5 Inserted by the Finance Act, 2003. \n6After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019. \n7Inserted by the Finance Act, 2002. \n8After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \n9The words  “the year” substituted by the Finance Act, 2010. \n10 The word “half year” substituted through Finance Act, 2020 dated 30th June, 2020 \n \n11Full stop substituted by the Finance Act, 2010. \n12Inserted by the Finance Act, 2010. \n13Full stop substituted by colon and thereafter new provision added through Finance Act 2020 dated \n30th June, 2020 \n14 Added by the Finance Act, 2013.  \n15New sub-section (1A) inserted through Finance Act, 2020 dated 30th June 2020. \n\n\f\nChapter X – Procedure__________________________________ \n \n342 \n \n1[(2) Every prescribed person collecting tax under Division II of this Part or \nChapter XII 2[or the Tenth Schedule] or deducting tax under Division III of this  \n \nPart of Chapter XII 3[or the Tenth Schedule] shall furnish statements under sub-\nsection (l) 4[or (1A)] as per the following schedule, namely:-  \n \n5[(a) in respect of quarter ending on the 31st day of March, on or before the \n20th day of April; \n \n(b) in respect of quarter year ending on the 30th day of June, on or before \nthe 20th day of July; \n \n(c) in respect of quarter ending on the 30th day of September, on or before \nthe 20th day of October; and \n \n(d) in respect of quarter ending on or before the 31st day of December, on or \nbefore the 20th day of January.]   \n \n  \n \n6[(2A)    Any person who, having furnished statement under sub-section (1) \nor sub-section (2), discovers any omission or wrong statement therein, may file a \nrevised statement within sixty days of filing of statement under sub-section (1) or \nsub-section (2), as the case may be.] \n \n7[(2B) Notwithstanding anything contained in this section, the Commissioner \nas he deems lit may by notice in writing require any person, collecting or deducting \ntax under this Ordinance, to furnish a statement for any period specified in the \nnotice within such period of time as may be specified in the notice.] \n \n                                            \n1Sub-section (2) substituted through Finance Supplementary (Second Amendment) Act, 2019. \n2In section 165 expression “Chapter XII” wherever occurs the words “or the Tenth Schedule” inserted \nby the Finance Act, 2019.  \n3After expression “Chapter XII” the words “or the Tenth Schedule” inserted by the Finance Act, 2019.  \n4The expression added through Finance Act, 2020 dated 30th June, 2020 \n5The clauses (a) and (b) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted \nclauses read as follows: \n(a) in respect of the half-year ending on the 30th June, on or before the 31st day of July; and  \n   (b) in respect of the half-year ending on the 31st December, on or before the 31st day of January. \n6Inserted by the Finance Act, 2017. \n \n7 Sub-section (2B) inserted through Finance Supplementary (Second Amendment) Act, 2019. \n\n\f\nChapter X – Procedure__________________________________ \n \n343 \n \n \n1[(3) \n2[Board] may prescribe a statement requiring any person to furnish \ninformation 3[  ] in respect of any transactions in the prescribed form and verified \nin the prescribed manner 4[.] ] \n \n \n5[(4) A person required to furnish a statement under sub-section 6[(1)], may \napply in writing, to the Commissioner for an extension of time to furnish the \nstatement after the due date and the Commissioner if satisfied that a reasonable \ncause exists for non-furnishing of the statement by the due date may, by an order \nin writing, grant the applicant an extension of time to furnish the statement.] \n \n \n7[(5)  The Board may make rules relating to electronic furnishing of \nstatements under this section including,-  \n \n \n \n(a)  \nmandatory electronic filing of statements; and \n \n(b)  \ndetermination of eligibility of the data of such statements and e-\nintermediaries, etc.] \n \n \n8[(6)  Every person deducting tax from payment under section 149 shall \nfurnish to the Commissioner an annual statement in the prescribed form and \nmanner 9[.] \n \n \n10[  ] \n \n11[(7) Every prescribed person collecting tax under Division II of this Part, \nChapter XII or the Tenth Schedule or deducting tax from a payment under Division \nIII of this Part, Chapter XII or the Tenth Schedule shall, e-file to the Commissioner \nan annual statement for the relevant tax year within thirty days of the end of tax \nyear in addition to statement to be filed under sub-section (6) of this section.  \n  \n                                            \n4Inserted by the Finance Act, 2006. \n5The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n6The word “periodically” omitted by the Finance Act, 2011. \n7Colon substituted by the Finance Act, 2011. \n9Inserted by the Finance Act, 2006. \n10The figure “(2)” substituted by the Finance Act, 2010. \n7Inserted by the Finance Act, 2006. \n8Added by the Finance Act, 2011. \n9Semi-colon substituted by the Finance Act, 2013.  \n10 Proviso omitted by the Finance Act, 2013. The omitted proviso read as follows: \n“Provided that annual statement shall also be filed where the income exceeds three \nhundred thousand rupees but does not exceed three hundred and fifty thousand rupees in a \ntax year.” \n11 Sub-sections (7) and (8) added by the Finance Act, 2021.  \n\n\f\nChapter X – Procedure__________________________________ \n \n344 \n \n(8) Every prescribed person collecting tax under Division II of this Part or \nChapter XII, the Tenth Schedule or deducting tax from a payment under Division \nIII of this Part, Chapter XII or the Tenth Schedule shall also e-file to the \nCommissioner a statement in the prescribed form  reconciling the amounts \nmentioned in annual statement filed under sub-section (7) with the amounts \ndeclared in the return, audited accounts or financial statements by the due date of \nfiling of return of income as provided under section 118 of the Ordinance.] \n  \n1[165A.  Furnishing of information by banks.— (1) Notwithstanding anything \ncontained in any law for the time being in force including but not limited to the \nBanking Companies Ordinance, 1962 (LVII of 1962), the Protection of Economic \nReforms Act, 1992 (XII of 1992), the Foreign Exchange Regulation Act, 1947 (VII \nof 1947) and the regulations made under the State Bank of Pakistan Act, 1956 \n(XXXIII of 1956), if any, on the subject every banking company shall make \narrangements to provide to the Board in the prescribed form and manner,— \n \n2[(a) a list of persons containing particulars of cash withdrawals exceeding \nfifty thousand Rupees in a day and tax deductions thereon 3[  ], \naggregating to Rupees one million or more during each preceding \ncalendar month.\";] \n \n(b)  \na list containing particulars of deposits aggregating rupees 4[ten]  \nmillion or more made during the preceding calendar month; \n \n(c)  \na list of payments made by any person against bills raised in respect \nof a credit card issued to that person, aggregating to rupees 5[two] \nhundred thousand or more during the preceding calendar month; \n \n6[(d)  \na list of persons receiving profit on debt 7[  ] 8[  ] and tax deductions \nthereon during preceding financial year] 9[; and \n                                            \n1Added by the Finance Act, 2013. \n2 Clause (a) substituted by the Finance Act, 2018 ,the substituted clause is read as follows:- \n“ (a) online access to its central database containing details of its account  holders and all transactions made in their \naccounts;” \n3 Words “for filers and non-filers” omitted through Finance Act, 2019. \n4The word  “one” substituted by the Finance Act, 2018. \n5The word  “one” substituted by the Finance Act, 2018. \n6 Clause (d) substituted by the Finance Supplementary (Amendment) Act, 2018. The substituted clause \n(d) read as follows: \n“a consolidated list of loans written off exceeding rupees one million during a calendar year” and \n7The expressions “exceeding 7[  ] five hundred thousand rupees” omitted through Finance Act, 2020 \ndated 30th June, 2020 \n8Words “for non-filers” omitted through Finance Act, 2019. \n9 Full stop substituted with semi colon and the word “and” and a new clause added by the by the \nFinance (Supplementary) Act, 2022.  \n\n\f\nChapter X – Procedure__________________________________ \n \n345 \n \n1[  ] \n \n(f)  \na list of persons containing particulars of their business accounts \nopened or re-designated during each preceding calendar month.] \n \n  \n \n \n(2)  \nEach banking company shall also make arrangements to nominate a \nsenior officer at the head office to coordinate with the Board for provision of any \ninformation and documents in addition to those listed in sub-section (1), as may be \nrequired by the Board. \n \n \n(3) \nThe banking companies and their officers shall not be liable to any \ncivil, criminal or disciplinary proceedings against them for furnishing information \nrequired under this Ordinance.  \n \n(4) Subject to section 216, all information received under this section shall \nbe used only for tax purposes and kept confidential.] \n \n2[165B. Furnishing of information by financial institutions including banks.— (1) \nNotwithstanding anything contained in any law for the time being in force including \nbut not limited to the Banking Companies Ordinance, 1962 (LVII of 1962), the \nProtection of Economic Reforms Act,1992 (XII of 1992), the Foreign Exchange \nRegulation Act, 1947 (VII of1947) and any regulations made under the State Bank \nof Pakistan Act,1956 (XXXIII of 1956) on the subject, every financial institution \nshall make arrangements to provide information regarding non-resident3[or any \nother reportable] persons to the Board in the prescribed form and manner for the \npurpose of automatic exchange of information under bilateral agreement or \nmultilateral convention. \n \n(2) 4[All] information received under this section shall be used only for tax \nand related purposes and kept confidential.”] \n \n5[(3) For the purpose of this section, the terms \"reportable person\" and \n\"financial institution\" shall have the meaning as provided in Chapter XIIA of the \nIncome Tax Rules, 2002.] \n \n                                            \n1 Clause (e) omitted by the Finance Supplementary (Amendment) Act, 2018. The omitted clause (e) \nread as follows: \n “(e)  \na copy of each currency transactions report and suspicious transactions report \ngenerated and submitted by it to the Financial Monitoring Unit under the Anti-Money \nLaundering Act, 2010 (VII of 2010).” \n2Inserted by the Finance Act, 2015. \n3Inserted by the Finance Act, 2017. \n4The word and figure “Subject to section 216, all” substituted by the Finance Act, 2016. \n5Added by the Finance Act, 2017 \n\n\f\nChapter X – Procedure__________________________________ \n \n346 \n \n1[165C. Furnishing of information by online marketplace, payment \nintermediary and courier service. – (1) Notwithstanding the provisions of section \n165 of the Ordinance, every payment intermediary and courier service responsible \nfor deducting tax under sub-section (2A) of section 153 of the Ordinance shall file \na quarterly withholding statement to the Commissioner for tax deduction regarding \nsale of digitally ordered goods and services for each quarter of a tax year in the \nprescribed form setting out –  \n \n(a) \nname, identification number (NTN/CNIC) and address of the seller;  \n \n(b) \ntransaction date, unique identifier (invoice number) and total transaction \nvalue;  \n \n(c) \nthe total amount of tax deducted at the time of payments to the seller; and  \n \n(d) \nany other particular may be prescribed.  \n \n(2) \nEvery online marketplace in Pakistan shall submit a monthly \nstatement containing name, address, Sales Tax and Income Tax registration \nnumber of every vendor registered on its platform supplying digitally ordered goods \nand services in e-commerce, transactional and aggregated quantum of seller‘s \nmonthly turnover and the amount deposited into the vendor‘s bank account against \nsuch sale transactions.  \n \n(3) \nAll the provisions of the section 165 excluding sub-sections (1), (1A) \nand (6) shall mutatis mutandis apply with respect to the due date of the filing of the \nwithholding statements, revision of the statements, power to call for statement by \nthe Commissioner, extension of time to furnish the statement after due date, power \nof the Board, filing of annual withholding statement and reconciliation of the \nwithholding statement with the annual income tax return.] \n \n166.  Priority of tax collected or deducted. — (1) Tax collected by a person \nunder Division II 2[of this Part or Chapter XII] or deducted from a payment under \nDivision III of this Part 3[or Chapter XII] shall be — \n \n(a) held by the person in trust for the 4[Federal] Government; and \n \n(b) not subject to attachment in respect of any debt or liability of the person. \n \n                                            \n1 Section 165C inserted by the Finance Act, 2025. \n2Inserted by the Finance Act, 2003. \n3Inserted by the Finance Act, 2002. \n4 Inserted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n347 \n \n \n(2) \nIn the event of the liquidation or bankruptcy of a person who has \ncollected 1[  ] or deducted tax from a payment under Division III of this Part 2[or \nChapter XII], the amount collected or deducted shall not form part of the estate of \nthe person in liquidation or bankruptcy and the Commissioner shall have a first \nclaim for that amount before any distribution of property is made. \n \n \n(3) \nEvery amount that a person is required to deduct from a payment \nunder Division III of this Part 3[or Chapter XII] shall be – \n \n(a) \na first charge on the payment; and \n \n(b) \ndeducted prior to any other amount that the person may be \nrequired to deduct from the payment by virtue of an order of any \nCourt or under any other law. \n \n167. Indemnity.— A person who has deducted tax from a payment under \n4[Division III of this Part] 5[or Chapter XII] and remitted the deducted amount to the \nCommissioner shall be treated as having paid the deducted amount to the recipient \nof the payment for the purposes of any claim by the recipient for payment of the \ndeducted tax. \n \n168. Credit for tax collected or deducted. — (1) For the purposes of this \nOrdinance — \n \n(a) the amount of any tax deducted from a payment under Division III of this \nPart 6[or Chapter XII] shall be treated as income derived by the person \nto whom the payment was made; and \n \n(b) the amount of any tax collected under Division II of this Part 7[or \nChapter XII] or deducted under Division III of this Part  8[or Chapter XII] \nshall be treated as tax paid by the person from whom the tax was \ncollected or deducted. \n \n \n(2) \nSubject to sub-sections 9[(2A), (2B),] (3) and (4), where an amount of \ntax has been collected from a person under Division II of this Part 10[or Chapter \nXII] or deducted from a payment made to a person under Division III of this Part \n                                            \n1 The words “tax under Division II of this Part” omitted by the Finance Act, 2003. \n2 Inserted by the Finance Act, 2002. \n3 Inserted by the Finance Act, 2003. \n4 Substituted for the words, figure and comma “Division II, Division III” by the Finance Act, 2003. \n5 Inserted by the Finance Act, 2002. \n6Inserted by the Finance Act, 2002. \n7Inserted by the Finance Act, 2003. \n8 Inserted by the Finance Act, 2002. \n9Inserted by the Finance Act, 2018. \n10 Inserted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n348 \n \n1[or Chapter XII], the person shall be allowed a tax credit for that tax in computing \nthe tax due by the person on the taxable income of the person for the tax year in \nwhich the tax was collected or deducted. \n \n2[(2A) Where a company is a member of an association of persons which is \ntaxed in accordance with section 92 and an amount of tax has been collected from \nan association of persons under Division II of this Part or Chapter XII or deducted \nfrom a payment made to the said association under Division III of this Part or \nChapter XII, the company shall be allowed a tax credit, in respect of tax  collected \nor deducted from the association of persons, according to the following formula, \nnamely:— \n \n(A/B) x C \n \nWhere — \n \nA \nis the amount of share of profits before tax received by the company \nas a member from the association of persons; \n \nB \nis the taxable income of the association of persons; and \n \nC \nis  the  amount  of  tax  withheld  in  the  name  of  the association of \npersons. \n \n(2B) No tax credit shall be allowed for any tax collected or deducted from an \nassociation of persons in respect of an amount for which credit has been  allowed \nunder sub-section (2A) to a company being a member of the association.]  \n \n3[(3)  No tax credit shall be allowed for any tax collected or deducted that is \na final tax under— \n \n \n \n4[   ]   \n \n \n                                            \n1Inserted by the Finance Act, 2002. \n2Inserted by the Finance Act, 2018. \n3Sub-section (3) substituted by the Finance Act, 2011. The substituted sub-section (3) read as \nfollows: \n \n \n“(3) \nNo tax credit shall be allowed for any tax collected or deducted that is a final tax under \nclauses (a), (b) and (d) of sub-section (1) of section 151, sub-section (1B) of section 152,  sub-section \n(6)] of section 153, sub-section (4) of section 154, section 155 sub-section (3) of section 156, sub-\nsection (2) of section 156A, section 233, clauses (a) and (b) of sub-section (1) of section 233A or \nsub-section (5) of section 234 or section 234A. \n4 In section 168 in sub-section (3) clause (a) omitted by the Finance Act, 2019. The omitted clause \nread as follows: (a) sub-section (7) of section 148;  \n\n\f\nChapter X – Procedure__________________________________ \n \n349 \n \n \n \n1[   ]   \n \n \n2[   ]   \n \n \n3[(ca) sub-section (1E) of section 152; \n \n \n(cb) sub-section (2) of section 152A;] \n4[   ]  5[  ] \n \n \n6[   ]   \n \n \n7[(ea) sub-section (2) of section 154A;] \n \n \n(f)  \nsub-section (3) of section 156; \n \n \n(g)  \nsub-section (2) of section 156A; \n \n \n8[  ]  \n9[and] \n \n \n10[  ] \n \n \n11[(j)] ] \n \n \n12[(k)    sub-section (7) of section 236Z.] \n \n(4) \nA tax credit allowed under this section shall be applied in accordance \nwith sub-section (3) of section 4. \n \n                                            \n1 In section 168 in sub-section (3) clause (b) omitted by the Finance Act, 2019 the omitted clause read \nas follows: (b) sub-section (3) of section 151; \n2 In section 168 in sub-section (3) clause (c) omitted by the Finance Act, 2019 the omitted clause read \nas follows: (c) sub-section (1B) and (1BB) of section 152; \n3 After omitted clause (c) new clauses (ca) and (cb) inserted through Finance Act, 2020 dated 30th \nJune, 2020 \n4 In section 168 in sub-section (3) clause (d) omitted by the Finance Act, 2019 the omitted clause read \nas follows: [(d)] sub-section (3) of section 153;  \n5The words, comma and brackets “clauses (a), (c) and (d) of” omitted by the Finance Act, 2013. \n6 Clause (e) omitted by the Finance Act, 2024. The omitted clause read as follow: \n“(e) sub-section (4) of section 154;” \n7 Clause (ea) inserted by the Finance Act, 2021. \n8In section 168 in sub-section (3) clause (b) omitted by the Finance Act, 2019 the omitted clause read \nas follows: (h) sub-section (3) of section 233;2[and]  \n9Added by the Finance Act, 2013. \n10Clause (i) omitted by the Finance Act, 2013. The omitted clause (i) read as follows: \n \n“(i)  \nsub-section (5) of section 234; and” \n11 In section 168 in sub-section (3) clause (b) omitted by the Finance Act, 2019 the omitted clause \nread as follows: Sub-section (3) of section 234(A)  \n12 Clause (k) added by the Finance Act, 2023. \n\n\f\nChapter X – Procedure__________________________________ \n \n350 \n \n \n(5) \nA tax credit or part of a tax credit allowed under this section for a tax \nyear that is not able to be credited under sub-section (3) of section 4 for the year \nshall be refunded to the taxpayer in accordance with section 170. \n \n \n1[(6)  Notwithstanding anything contained in any other law or any rules for \nthe time being in force, no amount shall be deducted on account of service charges \nfrom the tax withheld or collected by any person under the provisions of this \nOrdinance.] \n \n \n2[(7)  In case any amount is deducted on account of service charges, by the \nperson, the said person will be liable to pay the said amount to the Federal \nGovernment and all the provisions of this Ordinance shall apply in so far as they \napply to the recovery of tax.] \n \n169.  Tax collected or deducted as a final tax.— (1) This section shall apply \nwhere — \n \n3[  ] \n  \n(b) \nthe 4[tax required to be deducted] is a final tax under 5[sub-\nsection (1E) of section 152, 152A], 6[  ] 7[sub-section (2) of \nsection 154A] 8[  ] sub-section (3) of section 156, 9[  ] 10[sub-\n                                            \n1 Added by the Finance Act, 2009. \n2 Added by the Finance Act, 2009. \n3 Clause (a) omitted through Finance Act, 2020 the substituted clause read as follows: “(a) the \n3[advance tax required to be collected 3[or paid]] is a final tax under sub-section (7) of section 148 \n3[,148A] 3[  ] 3[or section 234A]  on the income to which it relates; or”  \n \n4 The words “deduction of tax” substituted by the Finance Act, 2012. \n5 The expressions  “sub-section (3) of section 151], sub-section (1B) 5[or sub-section (1BB)] of \nsection 152, 5[ 5[  ] sub-section (3) of section 153], 5[ 5[sub-section (1AAA) of section \n152”substituted by Finance Act, 2020 dated 30th June, 2020 \n6  The expression “sub-section (4) of section 154,” omitted by the Finance Act, 2024. \n7 Inserted by the Finance Act, 2021. \n8 The word, digit and comma “section 155,” omitted by the Finance Act, 2010. \n9 The words, figures and brackets “or sub-section (2) of section 157” omitted by the Finance Act, \n2002 \n10 Inserted by the Finance Act, 2004. \n\n\f\nChapter X – Procedure__________________________________ \n \n351 \n \nsection (2) [or] 1section 156A or 2[sub-section (7) of section \n236Z] 3[  ]4[ ] ] on the income from which it 5[was deductible]. \n \n(2) \nWhere this section applies — \n \n(a) \nthe income shall not be chargeable to tax under any head of \nincome in computing the taxable income of the person; \n \n(b) \nno deduction shall be allowable under this Ordinance for any \nexpenditure incurred in deriving the income; \n \n(c) \nthe amount of the income shall not be reduced by — \n \n (i) \nany deductible allowance under Part IX of Chapter III; or \n \n(ii) \nthe set off of any loss; \n \n(d) \nthe tax deducted shall not be reduced by any tax credit allowed \nunder this Ordinance; 6[  ] \n \n(e) \nthere shall be no refund of the tax collected or deducted \n7[unless the tax so collected or deducted is in excess of the \namount for which the taxpayer is chargeable under this \nOrdinance8[; and].] \n \n9[(f)  tax deductible has not been deducted, or short deducted, the   \nsaid non-deduction or short deduction may be recovered under \nsection 162, and all the provisions of this Ordinance shall apply \naccordingly.] \n \n \n(3) \nWhere all the income derived by a person in a tax year is subject to \nfinal taxation under the provisions referred to in sub-section (1) or under sections \n                                            \n1 The word “of” substituted by the word “or” by the Finance Act, 2014. \n2 Expression inserted by the Finance Act, 2023. \n3 The expressions omitted through Finance Act, 2020 dated 30th June, 2020 the omitted expressions \nread as follows: “sub-section 3[(1) and] (3) of section 233” \n4 The words, brackets, figure and letters “or clause (a) and clause (b) of sub-section (1) of section \n233A” omitted by the Finance Act, 2008. \n5 The words “has been deducted” substituted by the Finance Act, 2012. \n6The word “and” omitted by the Finance Act, 2012. \n7Added by the Finance Act, 2002. \n8Full stop substituted by the Finance Act, 2012. \n9Added by the Finance Act, 2008. \n\n\f\nChapter X – Procedure__________________________________ \n \n352 \n \n5, 6 1[and] 7 2[ ] 3[an assessment shall be treated to have been made under section \n120 4[  ]  \n \n5[Explanation.— The expression, “an assessment shall be treated to \nhave been made under section 120” means,— \n \n(a)  \nthe Commissioner shall be taken to have made an assessment \nof income for that tax year, and the tax due thereon equal to \nthose respective amounts specified in the return 6[  ] ; and \n \n(b)  \nthe return 7[  ] shall be taken for all purposes of this Ordinance \nto be an assessment order.] \n \n \n8[  ] \n \n9[(4) Where the tax collected or deducted is final tax under any provision of \nthis Ordinance and hundred percent higher tax rate has been prescribed for the \nsaid tax under the Tenth Schedule, the final tax shall be the tax rate prescribed in \nthe First Schedule and the excess tax collected under the Tenth Schedule \nspecified for persons not appearing in the active taxpayers’ list shall be adjustable \n                                            \n1Comma substituted by the  Finance Act, 2013. \n2The words, figure, comma and brackets “and 15, (other than dividend received by a company)” \nomitted by the Finance Act, 2013.  \n3Inserted by the Finance Act, 2002. \n4The expression omitted through Finance Act, 2020 dated 30th June, 2020 the omitted expressions \nread as follows: “and the person shall not be required to furnish a return of income under section \n114 for the year” \n5Inserted by the Finance Act, 2010. \n6 The expression omitted through Finance Act, 2020 dated 30th June, 2020 the omitted expressions \nread as follows: “or statement under “sub-section (4) of section 115” \n7 The expression omitted through Finance Act, 2020 dated 30th June, 2020 the omitted expressions \nread as follows: “or statement under “sub-section (4) of section 115” \n \n8 Omitted by the Finance Act, 2004. The omitted sub-section (4) read as follows:  \n “(4)  Where a taxpayer, while explaining the nature and source of any amount, investment, money, \nvaluable article, expenditure, referred to in section 111, takes into account any source of income \nwhich is subject to tax in accordance with the provisions of sections 148, 153, 154, 156 or sub-\nsection (5) of section 234, he shall not be entitled to take credit of any sum as is in excess of an \namount which if taxed at a rate or rates, other than the rate applicable to the income chargeable to \ntax under aforesaid sections 148, 153, 154, 156 or sub-section (5) of section 234 would have resulted \nin tax liability equal to the tax payable in respect of income under any of the aforesaid sections.” \n9 In section 169 for sub-section (4) substituted through Finance Act, 2019, substituted sub-section \nread as follows:  \n(4) Where the tax collected or deducted is final tax under any provision of the Ordinance and separate \nrates for filer and non-filer have been prescribed for the said tax, the final tax shall be the tax rate for \nfiler and the excess tax deducted or collected on account of higher rate of non-filer shall be adjustable \nin the return filed for the relevant tax year. \n\n\f\nChapter X – Procedure__________________________________ \n \n353 \n \nin case the return is filed before finalization of assessment as provided in rule 4 of \nthe Tenth Schedule.] \n \n\n\f\nChapter X – Procedure__________________________________ \n \n354 \n \nPART VI \nREFUNDS \n \n170.  Refunds.— (1)  A taxpayer who has paid tax in excess of the amount which \nthe taxpayer is properly chargeable under this Ordinance may apply to the \nCommissioner for a refund of the excess. \n \n1[(1A) Where any advance or loan, to which sub-clause (e) of clause (19) of \nsection 2 applies, is repaid by a taxpayer, he shall be entitled to a refund of the \ntax, if any, paid by him as a result of such advance or loan having been treated as \ndividend under the aforesaid provision.] \n \n \n(2) \nAn application for a refund under sub-section (1) shall be – \n \n(a) \nmade in the prescribed form;  \n \n(b) \nverified in the prescribed manner; and \n \n(c) \nmade within 2[three] years of the later of - \n \n (i) \nthe date on which the Commissioner has issued the \nassessment order to the taxpayer for the tax year to which \nthe refund application relates; or \n \n(ii) \nthe date on which the tax was paid. \n \n \n(3) \nWhere the Commissioner is satisfied that tax has been overpaid, the \nCommissioner shall —  \n \n(a) \napply the excess in reduction of any other tax due from the \ntaxpayer under this Ordinance;  \n \n(b) \napply the balance of the excess, if any, in reduction of any \noutstanding liability of the taxpayer to pay other taxes; and \n \n(c) \nrefund the remainder, if any, to the taxpayer. \n \n \n(4) \nThe Commissioner shall, within 3[sixty] days of receipt of a refund \napplication under sub-section (1), serve on the person applying for the refund an \norder in writing of the decision 4[after providing the taxpayer an opportunity of being \nheard]. \n                                            \n1Inserted by the Finance Act, 2003. \n2The word “two” substituted by the Finance Act, 2016. \n3The word “forty five” substituted by the Finance Act, 2009. \n4Inserted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n355 \n \n \n1[(5)  A person aggrieved by— \n \n \n \n(a)  \nan order passed under sub-section (4); or \n \n(b)  \nthe failure of the Commissioner to pass an order under sub-\nsection (4) within the time specified in that sub-section,  \n \n \n \nmay prefer an appeal under Part III of this Chapter.] \n \n \n2[(6) The Board may make rules regulating procedure for expeditious \nprocessing and automatic payment of refunds through centralized processing \nsystem with effect from a date to be notified by the Board.] \n \n \n3[170A. Electronic processing and electronic issuance of Refunds by the \nBoard.—Notwithstanding anything contained in section 170 of this Ordinance, \ncommencing from tax year 2021, the Board may process and issue refund to the \ntaxpayer who has filed the return of income without requiring refund application by \nthe taxpayer to the extent of tax credit verified by the Board’s computerized system \nas may be prescribed. The refund amount sanctioned under this section shall be \nelectronically transferred in the taxpayer’s notified bank account.] \n \n171. Additional payment for delayed refunds.—(1) Where a refund due to a \ntaxpayer is not paid within three months of the date on which it becomes due, the \nCommissioner shall pay to the taxpayer a further amount by way of compensation \nat the rate of 4[ 5[KIBOR plus 0.5 per cent] ] per annum of the amount of the refund \ncomputed for the period commencing at the end of the three month period and \nending on the date on which it was paid 6[:] \n \n \n7[Provided that where there is reason to believe that a person has claimed \nthe refund which is not admissible to him, the provision regarding the payment of \nsuch additional amount shall not apply till the investigation of the claim is \ncompleted and the claim is either accepted or rejected.] \n \n \n(2) \nFor the purposes of this section, a refund shall be treated as having \nbecome due — \n \n                                            \n1 Sub-section (5) substituted by the Finance Act, 2003. The substituted sub-section (5) read as follows: \n“(5) \nA person dissatisfied with a decision referred to in sub-section (4) may challenge the \ndecision only under Part III of this Chapter.” \n2New sub-section (6) added through Finance Act, 2020 dated 30th June,2020 \n3 Section 170A inserted by the Finance Act, 2021.  \n4The word “KIBOR” substituted by the Finance Act, 2012. \n5 The word “fifteen” substituted by Finance Act, 2015. \n6Full stop substituted by the Finance Act, 2009. \n7 Inserted by the Finance Act, 2009. \n\n\f\nChapter X – Procedure__________________________________ \n \n356 \n \n(a) \nin the case of a refund required to be made in consequence of \nan order on an appeal to the Commissioner (Appeals), an \nappeal to the Appellate Tribunal, a reference to the High Court \nor an appeal to the Supreme Court, on the date of receipt of \nsuch order by the Commissioner; 1[or] \n \n(b) \nin the case of a refund required to be made as a consequence \nof a revision order under section 2[122A], on the date the order \nis made by the Commissioner; or \n \n(c) \nin any other case, on the date the refund order is made.  \n  \n3[Explanation.—For the removal of doubt, it is clarified that \nwhere a refund order is made on an application under sub-\nsection (1) of section 170, for the purpose of compensation, the \nrefund becomes due from the date refund order is made and not \nfrom the date the assessment of income treated to have been \nmade by the Commissioner under section 120.] \n \n4[171A. Payment of refund through income tax refund bonds.- (1) \nNotwithstanding anything contained in sections 170 and 171, the income tax \nrefunds payable under this Ordinance may also be paid through income tax refund \nbonds to be issued by FBR Refund Settlement Company Limited, in book-entry \nform through an establishment licensed by the Securities and Exchange \nCommission of Pakistan as a central depository under the Securities Act, 2015 (III \nof 2015), in lieu of payment to be made through issuance of cheques or bank debit \nadvice. \n \n(2) \nThe Board shall issue a promissory note to FBR Refund Settlement \nCompany Limited, hereinafter referred to as the company, incorporating the details \nof refund claimants and the amount of refund determined as payable to each for \nissuance of income tax refund bonds, hereinafter referred to as the bonds, of the \nsame amount. \n \n(3) \nThe bonds shall be issued in value in multiples of one hundred \nthousand rupees. \n \n(4) \nThe bonds so issued have maturity period of three years and shall \nbear annual simple profit at ten percent. \n \n(5) \nThe bonds shall be traded freely in the country’s secondary markets. \n                                            \n1 Inserted by the Finance Act, 2003. \n2 Substituted for the figure “135” by the Finance Act, 2003. \n3Added by the Finance Act, 2013. \n4New Section 171A inserted through Finance Act, 2019. \n\n\f\nChapter X – Procedure__________________________________ \n \n357 \n \n \n(4) \nThe bonds shall be approved security for calculating the statutory \nliquidity reserve. \n \n(5) \nThe bonds shall be accepted by the banks as collateral. \n \n(6) \nThere shall be no compulsory deduction of Zakat against bonds and \nSahib-e-Nisab may pay Zakat voluntarily according to Shariah. \n \n(7) \nAfter period of maturity, the company shall return the promissory note \nto the Board and the Board shall make the payment of amount due \nunder the bonds, along with profit due, to the bond holders. \n \n(8) \nThe bonds shall be redeemable in the manner as in sub-section (9) \nbefore maturity only at the option of the Board along with simple profit \npayable at the time of redemption in the light of general or specific \npolicy to be formulated by the Board. \n \n(9) \nThe refund under sub-section (1) shall be paid in the aforesaid manner \nto the claimants who opt for payment in such manner. \n \n(10) The Federal Government may notify procedure to regulate the \nissuance, redemption and other matters relating to the bonds, as may \nbe required.] \n \n\n\f\nChapter X – Procedure__________________________________ \n \n358 \n \nPART VII \nREPRESENTATIVES \n \n172.  Representatives.— (1)  For the purposes of this Ordinance and subject to \nsub-sections (2) and (3), “representative” in respect of a person for a tax year, \nmeans – \n \n(a) where the person is an individual under a legal disability, the guardian \nor manager who receives or is entitled to receive income on behalf, or \nfor the benefit of the individual; \n \n(b) where the person is a company (other than a trust, a Provincial \nGovernment, or 1[Local Government] in Pakistan), the principal officer \nof the company; \n \n(c) \nwhere the person is a trust declared by a duly executed instrument in \nwriting whether testamentary or otherwise (including any Wakf deed \nwhich is valid under the MussalmanWakf Validation Act, 1913 (VI of \n1913)), any trustee of the trust; \n \n(d) where the person is a Provincial Government, or 2[Local Government] \nin Pakistan, any individual responsible for accounting for the receipt \nand payment of moneys or funds on behalf of the Provincial \nGovernment or3[Local Government]; \n \n(e) where the person is an association of persons, the principal officer of \nthe association or, in the case of a firm, any partner in the firm; \n \n(f) \nwhere the person is the Federal Government, any individual \nresponsible for accounting for the receipt and payment of moneys or \nfunds on behalf of the Federal Government; or \n \n(g) where the person is a public international organisation, or a foreign \ngovernment or political sub-Division of a foreign government, any \nindividual responsible for accounting for the receipt and payment of \nmoneys or funds in Pakistan on behalf of the organisation, \ngovernment, or political sub-Division of the government. \n \n \n(2) \nWhere the Court of Wards, the Administrator General, the Official \nTrustee, or any receiver or manager appointed by, or under, any order of a Court \nreceives or is entitled to receive income on behalf, or for the benefit of any person, \n                                            \n1The words “local authority” substituted by the Finance Act, 2008. \n2The words “local authority” substituted by the Finance Act, 2008. \n3The words “local authority” substituted by the Finance Act, 2008. \n\n\f\nChapter X – Procedure__________________________________ \n \n359 \n \nsuch Court of Wards, Administrator General, Official Trustee, receiver, or manager \nshall be the representative of the person for a tax year for the purposes of this \nOrdinance. \n \n \n(3) \nSubject to sub-sections (4) and (5), where a person is a non-resident \nperson, the representative of the person for the purposes of this Ordinance for a \ntax year shall be any person in Pakistan – \n \n(a) \nwho is employed by, or on behalf of, the non-resident person; \n \n(b) \nwho has any business connection with the non-resident \nperson1[:]  \n \n2[Explanation.— In this clause the expression “business \nconnection” includes transfer of an asset or business in Pakistan \nby a non-resident;] \n \n(c) \nfrom or through whom the non-resident person is in receipt of \nany income, whether directly or indirectly;  \n \n(d) \nwho holds, or controls the receipt or disposal of any money \nbelonging to the non-resident person;  \n \n(e) \nwho is the trustee of the non-resident person; or \n \n(f) \nwho is declared by the Commissioner by 3[an order] in writing to \nbe the representative of the non-resident person. \n \n \n(4) \nA bonafide independent broker in Pakistan who, in respect of any \ntransactions, does not deal directly with, or on behalf of, a non-resident principal \nbut deals with, or through a non-resident broker, shall not be treated as a \nrepresentative of the non-resident principal in respect of such transactions, if – \n \n(a) \nthe transactions are carried on in the ordinary course of \nbusiness through the first-mentioned broker; and \n \n(b) \nthe non-resident broker is carrying on such transactions in the \nordinary course of its business and not as a principal. \n \n \n(5) \nNo person shall be declared 4[  ] as the representative of a non-\nresident person unless the person has been given an opportunity by the \nCommissioner of being heard. \n \n                                            \n1Semi-colon substituted by the Finance Act, 2013.  \n2 Added by the Finance Act, 2013. \n3 Substituted for the word “notice” by the Finance Act, 2003. \n4The words “or treated” omitted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n360 \n \n173.  Liability and obligations of representatives. — (1) Every representative \nof a person shall be responsible for performing any duties or obligations imposed \nby or under this Ordinance on the person, including the payment of tax. \n \n \n(2) \nSubject to sub-section (4), any tax that, by virtue of sub-section (1), is \npayable by a representative of a taxpayer shall be recoverable from the \nrepresentative only to the extent of any assets of the taxpayer that are in the \npossession or under the control of the representative. \n \n \n(3) \nEvery representative of a taxpayer who pays any tax owing by the \ntaxpayer shall be entitled to recover the amount so paid from the taxpayer or to \nretain the amount so paid out of any moneys of the taxpayer that are in the \nrepresentative’s possession or under the representative’s control. \n \n1[(3A) Any representative, or any person who apprehends that he may be \nassessed as a representative, may retain out of any money payable by him to the \nperson on whose behalf he is liable to pay tax (hereinafter in this section referred \nto as the “principal”), a sum equal to his estimated liability under this Ordinance, \nand in the event of disagreement between the principal and such a representative \nor a person as to the amount to be so retained, such representative or person may \nobtain from the Commissioner a certificate stating the amount to be so retained \npending final determination of the tax liability, and the certificate so obtained shall \nbe his authority for retaining that amount.] \n \n \n(4) \nEvery representative shall be personally liable for the payment of any \ntax due by the representative in a representative capacity if, while the amount \nremains unpaid, the representative - \n \n(a) \nalienates, charges or disposes of any moneys received or \naccrued in respect of which the tax is payable; or \n \n(b) \ndisposes of or parts with any moneys or funds belonging to the \ntaxpayer that is in the possession of the representative or which \ncomes to the representative after the tax is payable, if such tax \ncould legally have been paid from or out of such moneys or \nfunds. \n \n \n(5) \nNothing in this section shall relieve any person from performing any \nduties imposed by or under this Ordinance on the person which the representative \nof the person has failed to perform. \n                                            \n1Inserted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n361 \n \nPART VIII \nRECORDS, INFORMATION COLLECTION AND AUDIT \n \n174.  Records.— (1)  Unless otherwise authorised by the Commissioner, every \ntaxpayer shall maintain in Pakistan such accounts, documents and records as may \nbe prescribed. \n \n \n(2) \nThe Commissioner may disallow 1[or reduce] a taxpayer’s claim for a \ndeduction if the taxpayer is unable, without reasonable 2[cause], to provide a \nreceipt, or other record or evidence of the transaction or circumstances giving rise \nto the claim for the deduction. \n \n \n(3) \nThe accounts and documents required to be maintained under this \nsection shall be maintained for 3[six]years after the end of the tax year to which \nthey relate 4[:] \n \n5[Provided that where any proceeding is pending before any authority \nor court the taxpayer shall maintain the record till final decision of the \nproceedings.] \n \n6[Explanation.— Pending proceedings include proceedings for assessment \nor amendment of assessment, appeal, revision, reference, petition or \nprosecution and any proceedings before an Alternative Dispute Resolution \nCommittee”] 7[: \n \nProvided that limitation prescribed under this sub-section shall not \napply to the records pertaining to income, assets, expenses or transactions \nto which clause (ii) of sub-section (2) of section 111 applies.] \n \n8[(4) For the purpose of this section, the expression “deduction” means any \namount debited to trading account, manufacturing account, receipts and expenses \naccount or profit and loss account.] \n \n                                            \n1 Inserted by the Finance Act, 2003. \n2The word “excuse” substituted by the Finance Act, 2003. \n3The word “five”  substituted by the Finance Act, 2010. \n4Full stop substituted by the Finance Act, 2010. \n5Added by the Finance Act, 2010. \n6Added by the Finance Act, 2010. \n7Full stop substituted and proviso added by the Finance Act, 2022. \n8 Added by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n362 \n \n \n1[(5) The Commissioner may require any person to install and use an \nElectronic Tax Register of such type and description as may be prescribed for the \npurpose of storing and accessing information regarding any transaction that has a \nbearing on the tax liability of such person.] \n \n175.  Power to enter and search premises.— (1)  In order to enforce any \nprovision of this Ordinance (including for the purpose of making an audit of a \ntaxpayer or a survey of persons liable to tax), the Commissioner or any officer \nauthorised in writing by the Commissioner for the purposes of this section – \n \n(a) \nshall, at all times and without prior notice, have full and free \naccess2[including real-time electronic access]to any premises, place, \naccounts, documents or computer; \n \n(b) \nmay stamp, or make an extract or copy of any accounts, documents \nor computer-stored information to which access is obtained under \nclause (a); \n \n(c) \nmay impound any accounts or documents and retain them for so long \nas may be necessary for examination or for the purposes of \nprosecution;  \n \n(d) \nmay, where a hard copy or computer disk of information stored on a \ncomputer is not made available, impound and retain the computer for \nas long as is necessary to copy the information required; and \n \n(e) \nmay make an inventory of any articles found in any premises or place \nto which access is obtained under clause (a). \n \n3[(2)  The Commissioner may authorize any valuer or expert to enter any \npremises and perform any task assigned to him by the Commissioner.] \n \n \n(3) \nThe occupier of any premises or place to which access is sought \nunder sub-section (1) shall provide all reasonable facilities and assistance for the \neffective exercise of the right of access. \n \n                                            \n1Added by the Finance Act, 2008. \n2The expression inserted through Finance Act, 2020 dated 30th June, 2020 \n3Sub-section (2) substituted by the Finance Act, 2003. The substituted sub-section (2) read as \nfollows:  \n“(2) \nThe Commissioner may authorise any valuer to enter any premises or place to inspect such \naccounts and documents as may be necessary to enable the valuer to make a valuation of an asset \nfor the purposes of this Ordinance.” \n\n\f\nChapter X – Procedure__________________________________ \n \n363 \n \n \n(4) \nAny accounts, documents or computer impounded and retained under \nsub-section (1) shall be signed for by the Commissioner or an authorised officer. \n \n \n(5) \nA person whose accounts, documents or computer have been \nimpounded and retained under sub-section (1) may examine them and make \nextracts or copies from them during regular office hours under such supervision as \nthe Commissioner may determine. \n \n \n(6) \nWhere any accounts, documents or computer impounded and \nretained under sub-section (1) are lost or destroyed while in the possession of the \nCommissioner, the Commissioner shall make reasonable compensation to the \nowner of the accounts, documents or computer for the loss or destruction. \n \n \n(7) \nThis section shall have effect notwithstanding any rule of law relating \nto privilege or the public interest in relation to access to premises or places, or the \nproduction of accounts, documents or computer-stored information. \n \n \n(8) \nIn this section, “occupier” in relation to any premises or place, means \nthe owner, manager or any other responsible person on the premises or place.  \n \n1[(9) For the purpose of clause (a) of sub-section (1), the Board may make \nrules relating to electronic real-time assess for audit or a survey of persons liable \nto tax.] \n \n2[175A. \nReal-time \naccess \nto \ninformation \nand \ndatabases.- \n(1) \nNotwithstanding anything contained in any law for the time being in force, including \nbut not limited to the National Database and Registration Authority Ordinance, \n2000 (Ordinance VIII of 2000), and the Emigration Ordinance, 1979(Ordinance \nXVIII of 1979), arrangements shall be made to provide real-time access of \ninformation and database to the Board in the prescribed form and manner by- \n \n(a) the National Database and Registration Authority with respect to \ninformation pertaining to National Identity Card, Pakistan Origin Card, \nOverseas Identity Card, Alien Registration Card, and other particulars \ncontained in the Citizen Database. \n \n(b) the Federal Investigation Agency and the Bureau of Emigration and \nOverseas Employment with respect to details of international travel; \n \n(c) the Federal Investigation Agency and the Bureau of Emigration and \nOverseas Employment with respect to details of international entry and \nexit of all persons and information pertaining to work permits, \nemployment visas and immigration visas;  \n                                            \n1New sub-section (9) added through Finance Act, 2020 dated 30th June, 2020 \n2New section 175A inserted through Finance Act, 2020 dated 30th June, 2020  \n\n\f\nChapter X – Procedure__________________________________ \n \n364 \n \n(d) the Islamabad Capital Territory and provincial and local land record and \ndevelopment authorities with respect to record-of-rights including \ndigitized edition of record-of-rights, periodic record, record of mutations \nand report of acquisition of right; \n \n(e) the Islamabad Capital Territory and provincial Excise and Taxation \nDepartments with respect to information regarding registration of \nvehicles, transfer of ownership and other associated record; \n \n(f) All electricity suppliers and gas transmission and distribution companies \nwith respect to particulars of a consumer, the units consumed and the \namount of bill charged or paid: \n \nProvided that where the connection is shared or is used by a \nperson other than the owner, the name and CNIC of the owner and the \nuser shall also be furnished: \n \nProvided further that all electricity suppliers and gas \ntransmission and distribution companies shall make arrangements by the \n1st day of January, 2021 for allowing consumers to update the ratio of \nsharing of a connection or the particulars of users, as the case may be; \nand \n \n(g) any other agency, authority, institution or organization notified by the \nBoard. \n \n(2) \nThe Board shall make arrangements for laying the infrastructure for \nreal-time access to information and database under sub-section (1) and aligning it \nwith its own database in the manner as may be prescribed. \n \n(3) \nUntil real-time access to information and database is made available \nunder sub-section (1), such information and data shall be provided periodically in \nsuch form and manner as may be prescribed. \n \n(4) \nSubject to section 216, all information received under this section shall \nbe used only for tax purposes and kept confidential.] \n   \n1[175AA. Exchange of banking and tax information related to high-risk \npersons. — (1) Notwithstanding anything contained in any law for the time being \nin force, including but not limited to the Banking Companies Ordinance, 1962 (LVII \nof 1962), section 216 of this Ordinance and any regulations made under the State \nBank of Pakistan Act,1956 (XXXIII of 1956), —  \n \n                                            \n1 Section 175AA inserted by the Finance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n365 \n \n(a) \nthe Board may share information obtained from the tax declarations with \nscheduled banks in Pakistan, in respect of persons or classes of persons, \nfor the purpose of cross-matching with the bank data through the data-based \nalgorithms, as may be prescribed; and  \n \n(b) \nthe Scheduled banks shall provide to the Board the final results where the \nbanking data is at variance with the algorithms provided under clause (a) of \nthis sub-section.  \n \n(2) \nAll information received under this section shall be used only for tax \nand related purposes and kept confidential.] \n \n1[175B. National Database and Registration Authority (NADRA). (1) The \nNational Database and Registration Authority shall, on its own motion or upon \napplication by the Board, share its records and any information available or held \nby it, with the Board, for broadening of the tax base or carrying out the purposes \nof the Ordinance. \n \n(2) The National Database and Registration Authority may — \n(i) submit proposals and information to the Board with a view to \nbroadening the tax base; \n \n(ii) \nidentify in relation to any person, whether a taxpayer or not –  \n \n(a) \nincome, \nreceipts, \nassets, \nproperties, \nliabilities, \nexpenditures, \nor \ntransactions \nthat \nhave \nescaped \nassessment or are under-assessed or have been assessed \nat a low rate, or have been subjected to excessive relief or \nrefund or have been misdeclared or misclassified under a \nparticular head of income or otherwise; \n \n(b) \nthe value of anything mentioned in sub-clause (a) of clause \n(ii), if such value is at variance with the value notified by the \nBoard or the district authorities, as the case may be, or if no \nsuch value has been notified the true or market value; and \n \n(iii)  enter into a memorandum of understanding with the Board for a \nsecure exchange and utilization of a person's information. \n \n(3) The Board may use and utilize any information communicated to it by \nthe National Database and Registration Authority and forward such information to \nan income tax authority having jurisdiction in relation to the subject matter \nregarding the information, who may utilize the information for the purposes of the \nOrdinance. \n                                            \n1New section 175B inserted through Finance Act, 2022. \n\n\f\nChapter X – Procedure__________________________________ \n \n366 \n \n \n(4) The National Database and Registration Authority may compute \nindicative income and tax liability of anyone mentioned under sub-sections (1) or \n(2) by use of artificial intelligence, mathematical or statistical modeling or any other \nmodern device or calculation method.  \n \n(5) The indicative income and tax liability computed by the National \nDatabase and Registration Authority under sub-section (4) shall be notified by the \nBoard to the person in respect of whom such indicative income and tax liability has \nbeen determined, who shall have the option to pay the determined amount on such \nterms, conditions, installments, discounts, reprieves pertaining to penalty and \ndefault surcharge, and time limits that may be prescribed by the Board. \n \n(6) In case the person against whom a liability has been determined \nunder sub-section (4), does not pay such liability within the time prescribed under \nsub-section (5), the Board shall take action under the Ordinance, upon the basis \nof tax liability computed under sub-section (4). \n \n(7) If the person against whom the liability has been determined under \nsub-section (4) pays such liability in terms of sub-section (5), such payment shall \nbe construed to be an amended assessment order under section 120 or sub-\nsection (1) of section 122 or sub-section (4) of section 122, as the case may be. \n \n(8) For the purposes of sub-sections (4) and (5), the Board may prescribe \nthe extent of installments, reprieves pertaining to penalty and default surcharge \nand time limits.] \n \n1[175C. Posting of officer of Inland Revenue. — Subject to such conditions and \nrestrictions, as deemed fit to be imposed, the Board or the Chief Commissioner \nmay post an officer of Inland Revenue or such other officials with any designation \nworking under the control of the Board or the Chief Commissioner, to the business \npremises of any person or class of such persons, to monitor production, supply of \ngoods or rendering of services and the stock of goods not sold at any time for \ndetermining tax payable under this Ordinance.]  \n \n176.  Notice to obtain information or evidence.— (1)  The Commissioner may, \nby notice in writing, require any person, whether or not liable for tax under this \nOrdinance – \n \n2[(a)   to furnish to the Commissioner or an authorised officer, any information \nrelevant to any tax leviable under this Ordinance or to fulfill any \n                                            \n1 Section 175C inserted by the Finance Act, 2025. \n2 Substituted by the Finance Act, 2015. The substituted clause (a) read as follows:-  \n“(a) \nto furnish to the Commissioner or an authorised officer, any information relevant to any \ntax 2[leviable] under this Ordinance as specified in the notice; or” \n\n\f\nChapter X – Procedure__________________________________ \n \n367 \n \nobligation under any agreement with foreign government or \ngovernments or tax jurisdiction, as specified in the notice; or; and] \n \n(b) \nto attend at the time and place designated in the notice for the purpose \nof being examined on oath by the Commissioner or an authorised \nofficer concerning the tax affairs of that person or any other person \nand, for that purpose, the Commissioner or authorised officer may \nrequire the person examined to produce any accounts, documents, or \ncomputer-stored information in the control of the person 1[; “or”] \n \n2[(c)  the firm of chartered accountants 3[ 4[ ] or a firm of cost and \nmanagement accountants as defined under the Cost and \nManagement Accountants Act, 1966 (XIV of 1966)], as appointed by \nthe 5[Board or the Commissioner], to conduct audit under section 177, \nfor any tax year, may with the prior approval of the Commissioner \nconcerned, enter the business premises of a taxpayer, 6[  ] to obtain \nany information, require production of any record, on which the \nrequired information is stored and examine it within such premises; \nand such firm may if specifically delegated by the Commissioner, also \nexercise the powers as provided in sub-section (4).] \n \n \n7[(1A) A special audit panel appointed under sub-section (11)of section 177, \nfor any tax year, may, with the prior approval of the Commissioner concerned, \nenter the business premises of a taxpayer, to obtain any information, require \nproduction of any record, on which the required information is stored and examine \nit within such premises and such panel may if specifically delegated by the \nCommissioner, also exercise the powers as provided in subsection(4).] \n \n \n(2) \nThe Commissioner may impound any accounts or documents \nproduced under sub-section (1) and retain them for so long as may be necessary \nfor examination or for the purposes of prosecution. \n \n \n(3) \n8[The person from whom information is required, may at his option, \nfurnish the same electronically in any computer readable media.] Where a hard \n                                            \n1 Full stop substituted by the Finance Act, 2009. \n2 Inserted by the Finance Act, 2009. \n3 Inserted by the Finance Act, 2017. \n4 Comma omitted by the Finance Act, 2022.  \n5 The word “Board” substituted by the Finance Act, 2010. The substituted provision has been made \neffective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n6 The words and comma “selected for audit,” omitted by the Finance Act, 2012. \n7 Added by the Finance Act, 2015. \n8Inserted by the Finance Act, 2005. \n\n\f\nChapter X – Procedure__________________________________ \n \n368 \n \ncopy or computer disk of information stored on a computer is not made available \nas required under sub-section (1), the Commissioner may require production of \nthe computer on which the information is stored, and impound and retain the \ncomputer for as long as is necessary to copy the information required. \n \n \n(4) \nFor the purposes of this section, the Commissioner shall have the \nsame powers as are vested in a Court under the Code of Civil Procedure, 1908 \n(Act V of 1908), in respect of the following matters, namely: — \n \n(a) \nenforcing the attendance of any person and examining the \nperson on oath or affirmation; \n \n(b) \ncompelling the production of any accounts, records, computer-\nstored information, or computer; \n \n(c) \nreceiving evidence on affidavit; or \n \n(d) \nissuing commissions for the examination of witnesses. \n \n \n(5) \nThis section shall have effect notwithstanding any 1[law or rules]  \nrelating to privilege or the public interest in relation to the production of accounts, \ndocuments, or computer-stored information or the giving of information. \n \n                                            \n1The words “rule of law” substituted by the Finance Act, 2011. \n\n\f\nChapter X – Procedure__________________________________ \n \n369 \n \n1[177. Audit.— 2[(1) The Commissioner may call for any record or documents including \nbooks of accounts maintained under this Ordinance or any there law for the time being \nin force for conducting audit of the income tax affairs of the person and where such \nrecord or documents have been kept on electronic data, the person shall allow access \nto the Commissioner or the officer authorized by the Commissioner for use of machine \nand software on which such data is kept and the Commissioner or the officer may have \naccess to the  required information and data and duly attested hard copies of such \ninformation or data for the purpose of investigation and proceedings under this \nOrdinance in respect of such person or any other person: \n \n \nProvided that— \n \n(a)  the Commissioner may, after recording reasons in writing \ncall for record or documents including books of accounts \nof the taxpayer; and \n \n                                            \n1 Section 177 substituted by the Finance Act, 2004. The Substituted section 177 read as follows:- \n “177. Audit:- (1)  The commissioner may select any person for an audit of the person’s income tax \naffairs having regard to- \n(a) the person’s history of compliance or non-compliance with this Ordinance; \n(b) \nthe amount of tax payable by the person; \n(c) \nthe class of business conducted by the person; and \n(d) any other matter that the commissioner considers relevant. \n (1A)  \nAfter selection of a person for audit under sub-section (1), the Commissioner shall conduct an audit of \nthe income tax affairs (including examination of accounts and records, enquiry into expenditure, assets and \nliabilities) of that person. \n(1B) \nAfter completion of the audit under sub-section (1A) or sub-section (3), the Commissioner may, if \nconsidered necessary, after obtaining taxpayer’s explanation on all the issues raised in the audit, amend the \nassessment under sub-section (1) or sub-section (4) of section 122, as the case may be. \n (2) \nThe fact that a person has been audited in a year shall not preclude the person from being \naudited again in the next and following years where there are reasonable grounds for such audits, \nparticularly having regard to the factors in sub-section (1). \n(3) \nThe Central Board of Revenue may appoint a firm of Chartered Accountants as defined under \nthe Chartered Accountants Ordinance, 1961(X of 1961), to conduct an audit of the income tax affairs \nof any person and the scope of such audit shall be as determined by the Central Board of Revenue on \na case by case basis. \n(4) \nAny person employed by a firm referred to in sub-section (3) may  by authorised by the \ncommissioner, in writing, to exercise the powers in sections 175 and 176 for the purposes of the \nconducting audit under that subsection.”  \n2 Sub-section (1) substituted by the Finance Act, 2010. The substituted sub-section (1) read as follows:  \n“(1) The Commissioner may call for any record or documents including books of accounts \nmaintained under this Ordinance or any other law for the time being in force for conducting audit of \nthe income tax affairs of the person and where such record or documents have been kept on \nelectronic data, the person shall allow access to the Commissioner or the officer authorized by the \nCommissioner for use of machine and software on which such data is kept and the Commissioner \nor the officer may take into possession such machine and duly attested hard copies of such \ninformation or data for the purpose of investigation and proceedings under this Ordinance in respect \nof such person or any other person:  \nProvided that the Commissioner shall not call for record or documents of the taxpayer \nafter expiry of six years from the end of the tax year to which they relate.” \n\n\f\nChapter X – Procedure__________________________________ \n \n370 \n \n(b)  \nthe reasons shall be communicated to the taxpayer while \ncalling record or documents including books of accounts \nof the taxpayer: \n \nProvided further that the Commissioner shall not call for record or \ndocuments of the taxpayer after expiry of six years from the end of the tax \nyear to which they relate.] \n \n1[(2) After obtaining the record of a person under sub-section (1) or where \nnecessary record is not maintained, the Commissioner shall conduct an audit of \nthe income tax affairs (including examination of accounts and records, enquiry into \nexpenditure, assets and liabilities) of that person or any other person and may call \nfor such other information and documents as he may deem appropriate.] \n \n2[(2A) For the purpose of sub-section (2), the Commissioner may conduct \naudit proceedings electronically through video links, or any other facility as \nprescribed by the Board. \n  \n(2AA) Where a taxpayer— \n \n(a) has not furnished record or documents including books of \naccounts; \n \n(b) has furnished incomplete record or books of accounts; or \n \n(c) is unable provide sufficient explanation regarding the defects in \nrecords, documents or books of accounts,  \n \nit shall be construed that taxable income has not been correctly declared and the \nCommissioner shall determine taxable income on the basis of sectoral benchmark \nratios prescribed by the Board. \n \nExplanation.—The expression “sectoral benchmark ratios” means standard \nbusiness sector ratios notified by the Board on the basis of comparative cases and \nincludes financial ratios, production ratios, gross profit ratio, not profit ratio, \nrecovery ratio, wastage ratio and such other ratios in respect of such sectors as \nmay be prescribed.] \n \n                                            \n1Sub-section (2) substituted by the Finance Act, 2010. The substituted sub-section (2) read as follows: \n \n \n“(2) \n After obtaining the record of a person under sub-section (1) or where necessary record \nis not maintained, the Commissioner shall conduct an audit of the income tax affairs (including \nexamination of accounts and records, enquiry into expenditure, assets and liabilities) of that person \nor any other person and may call for such other information and documents as he may deem \nappropriate.” \n2New sub-sections (2A) and (2AA) inserted through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nChapter X – Procedure__________________________________ \n \n371 \n \n1[  ] \n \n2[  ] \n \n3[  ] \n \n \n4[(6) After compilation of the audit, the Commissioner shall, after obtaining \ntaxpayer’s explanation on all the issues raised in the audit, issue an audit report \ncontaining audit observations and finding.] \n \n5[(6A) After issuing the audit report, the Commissioner may, if considered \nnecessary, amend the assessment under sub-section (1) or sub-section (4) of \nsection 122, as the case may be, after providing an opportunity of being heard to \nthe taxpayer under sub-section (9) of section 122.] \n \n \n(7)  \nThe fact that a person has been audited in a year shall not preclude \nthe person from being audited again in the next and following years where there \nare reasonable grounds for such audits 6[ ]. \n \n \n(8)  \nThe 7[Board] may appoint a firm of Chartered Accountants as defined \nunder the Chartered Accountants Ordinance, 1961 (X of 1961) 8[or a firm of Cost \nand Management Accountants as defined under the Cost and Management \nAccountants Act, 1966 (XIV of 1966)], or a firm of Cost and Management \nAccountants as defined under the Cost and Management Accountants Act, 1966 \n                                            \n1 Sub-section (3) omitted by the Finance Act, 2010. The omitted sub-section (3) read as follows: \n \n“(3)  \nThe Board shall keep the criteria confidential.” \n2 Sub-section (4) omitted by the Finance Act, 2010. The omitted sub-section (4)  read as follows: \n \n“(4)  \nIn addition to the selection referred to in sub-section (2), the Commissioner may also select \na person or classes of persons for an audit of the person’s income tax affairs having regard to - \n(a)  \nthe person’s history of compliance or non-compliance with this Ordinance; \n \n \n(b)  \nthe amount of tax payable by the person; \n \n \n(c)  \nthe class of business conducted by the person; and \n(d)  \nany other matter which in the opinion of Commissioner is material for \ndetermination of correct income.” \n3Sub-section (5) omitted by the Finance Act, 2010. The omitted sub-section  (5)  read as follows: \n \n \n“(5)  \nAfter selection of a person or classes of persons for audit under sub-section (2) or (4), \nthe Commissioner shall conduct an audit of the income tax affairs (including examination of accounts \nand records, enquiry into expenditure, assets and liabilities) of such person or classes of persons.” \n4Sub-section (6) substituted through Finance Act, 2019 substituted sub-section (6) read as follows:  \n(6) After completion of the audit 4[ ], the Commissioner may, if considered necessary, after obtaining \ntaxpayer’s explanation on all the issues raised in the audit, amend the assessment under sub-section \n(1) or sub-section (4) of section 122, as the case may be. \n  \n5 New sub-section (6A) inserted through Finance Act, 2019. \n6The words, comma, brackets and figure “particularly having regard to the factors in sub-section (4)“ \nomitted by the Finance Act, 2010. \n7The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n8 Inserted by the Finance Act, 2010. \n\n\f\nChapter X – Procedure__________________________________ \n \n372 \n \n(XIV of 1966) to conduct an audit of the income tax affairs of any person 1[or \nclasses of persons 2[  ] ] and the scope of such audit shall be as determined by the \n3[Board] 4[or the Commissioner] on a case to case basis. \n \n \n(9) \nAny person employed by a firm referred to in sub-section (8) may be \nauthorized by the Commissioner, in writing, to exercise the powers in sections 175 \nand 176 for the purposes of conducting an audit under that sub-section.] \n \n5[(10) Notwithstanding anything contained in sub-sections (2) and (6) where \na person fails to produce before the Commissioner or a firm of Chartered \nAccountants or a firm of Cost and Management Accountants appointed by the \nBoard or the Commissioner under sub-section (8) to conduct an audit, any \naccounts, documents and records, required to be maintained  under section 174 \nor any other relevant document, electronically kept record, electronic machine or \nany other evidence that may be required by the Commissioner or the firm of \nChartered Accountants or the firm of Cost and Management Accountants for the \npurpose of audit or determination of income and tax due thereon, the \nCommissioner may proceed to make best judgment assessment  under section \n121  of this Ordinance and the assessment treated to have been made on the \nbasis of return or revised return filed by the taxpayer shall be of no legal effect.] \n \n6[Explanation.— For the removal of doubt, it is declared that the \npowers of the Commissioner under this section are independent of the \npowers of the Board under section 214C and nothing contained in \nsection 214C restricts the powers of the Commissioner to call for the \nrecord or documents including books of accounts of a taxpayer for \naudit and to conduct audit under this section.] \n \n7[(11) The Board may appoint as many special audit panels as may be \nnecessary, comprising two or more members from the following:— \n \n(a)  an officer or officers of Inland Revenue; \n \n(b)  a firm of chartered accountants as defined under the Chartered \nAccountants Ordinance, 1961 (X of 1961); \n \n(c)  a firm of cost and management accountants as defined under the Cost \nand Management Accountants Act, 1966 (XIV of 1966); or \n \n                                            \n1Inserted by the Finance Act, 2009. \n2The  words “selected for audit by the Commissioner or by the Board” omitted by the Finance Act, 2010. \n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n4Inserted by the Finance Act, 2010. \n5 Added by the Finance Act, 2010. \n6 Added by the Finance Act, 2013. \n7 Added by Finance Act, 2015. \n\n\f\nChapter X – Procedure__________________________________ \n \n373 \n \n(d)  any other person 1[including a foreign expert or specialist] as directed \nby the Board, to conduct an audit, including a forensic audit, of the \nincome tax affairs of any person or classes of persons and the scope \nof such audit shall be as determined by the Board or the \nCommissioner on case-to-case basis. \n \n2[(e) a tax audit expert deployed under an audit assistance programme of  \nan international tax organization or a tax authority outside Pakistan: \n \nProvided that in case the member is not an officer of Inland \nRevenue, the person shall only be included as a member in the special \naudit panel if an agreement of confidentiality has been  entered into \nbetween the Board and the person, international tax organization or a \ntax authority, as the case may be.] \n \n(12)  Special audit panel under sub-section (1) shall be headed by a \nChairman who shall be an officer of Inland Revenue. \n \n(13)  Powers under sections 175 and 176 for the purposes of conducting \nan audit under sub-section (11), shall only be exercised by an officer or officers of \nInland Revenue, who are member or members of the special audit panel, and \nauthorized by the Commissioner. \n \n(14)  Notwithstanding anything contained in sub-sections (2) and(6), where \na person fails to produce before the Commissioner or a special audit panel under \nsub-section (11) to conduct an audit, any accounts, documents and records, \nrequired to be maintained under section 174 or any other relevant document, \nelectronically kept record, electronic machine or any other evidence that may be \nrequired by the Commissioner or the panel, the Commissioner may proceed to \nmake best judgment assessment under section 121 and the assessment treated \nto have been made on the basis of return or revised return filed by the taxpayer \nshall be of no legal effect. \n \n(15) If any one member of the special audit panel, other than the Chairman, \nis absent from conducting an audit, the proceedings of the audit may continue, and \nthe audit conducted by the special audit panel shall not be invalid or be called in \nquestion merely on the ground of such absence. \n \n(16)  Functions performed by an officer or officers of Inland Revenue as \nmembers of the special audit panel, for conducting audit, shall be treated to have \nbeen performed by special audit panel. \n \n(17)  The Board may prescribe the mode and manner of constitution, \nprocedure and working of the special audit panel.”] \n                                            \n1Inserted by Finance Act, 2018 \n2Added by Finance Act, 2018 \n\n\f\nChapter X – Procedure__________________________________ \n \n374 \n \n178. Assistance to Commissioner.— Every Officer of Customs, 1[  ] Provincial \nExcise and Taxation, District Coordination Officer, District Officers including \nDistrict Officer – Revenue, the Police and the Civil Armed Forces is empowered \nand required to assist the Commissioner in the discharge of the Commissioner’s \nfunctions under this Ordinance. \n \n179.  Accounts, documents, records and computer-stored information not \nin Urdu or English language.— Where any account, document, record or \ncomputer-stored information referred to in section 174, 175 or 176 is not in the \nUrdu or English language, the Commissioner may, by notice in writing, require the \nperson keeping the account, document, record or computer-stored information to \nprovide, at the person's expense, a translation into the Urdu or English language \nby a translator approved by the Commissioner for this purpose. \n \n180.  Power to collect information regarding exempt income.— The 2[Board] \nmay, by notification in the official Gazette, authorise any department or agency of \nthe Government to collect and compile any data in respect of incomes from \nindustrial and commercial undertakings exempt from tax under this Ordinance. \n \n                                            \n1The words and commas “Federal Excise, Sales Tax,” omitted by the Finance Act, 2013.  \n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nChapter X – Procedure__________________________________ \n \n375 \n \n1[PART IX \nTAXPAYER’S REGISTRATION \n \n181. Taxpayer’s registration.— (1)  Every taxpayer 2[including a person selling \ndigitally ordered goods or services from within Pakistan using online marketplace \nor a courier service, as the case may be,] shall apply in the prescribed form and in \nthe prescribed manner for registration. \n \n3[(1A) Every online marketplace or courier service, involved in e-commerce \nby supplying or delivering digitally ordered goods or services from within Pakistan, \nshall not allow any vendor to use its platform services to carry out e-commerce \ntransactions unless such vendors have been registered under this Ordinance.] \n \n(2) \nThe Commissioner having jurisdiction over a case, where \nnecessitated by the facts of the case, may also register a taxpayer in the prescribed \nmanner. \n \n(3) \nTaxpayers’ registration scheme shall be regulated through the rules \nto be notified by the Board 4[ 5[“.”] ] ] \n \n6[ 7[ ] ] \n \n \n8[(4) From tax year 2015 and onwards, in case of individuals having \nComputerized National Identity Card (CNIC) issued by the National Database and \nRegistration Authority, CNIC shall be used as National Tax Number.] \n                                            \n1 Part IX ssubstituted by the Finance Act,  2008. The substituted “Part IX” read as follows: \n“PART IX \nNATIONAL TAX NUMBER CERTIFICATE \n181.  National Tax Number Certificate.- (1)  Every taxpayer shall apply in the prescribed form and \nin the prescribed manner for a National Tax Number Certificate.  \n \n(2) \nAn application under sub-section (1) shall be accompanied by the prescribed fee. \n(3) The Commissioner having jurisdiction over an applicant under sub-section (1) may after \nexamination of all relevant documents and evidence, and after satisfying himself of the genuineness \nof the application, may direct issuance of the National Tax Number Certificate for a period prescribed \nby Commissioner: \nProvided that the Board may in the case of individuals allow use of National Identity Card, \nissued by the National Database and Registration Authority, in place of National Tax Number.” \n2 Expression inserted by the Finance Act, 2025. \n3 Section (1A) inserted by the Finance Act, 2025. \n4 Full stop substituted by the Finance Act, 2013.  \n5 Substituted “:” by the Finance Act, 2015. \n6 Added by the Finance Act, 2013.  \n7 Omitted by the Finance Act, 2015. The omitted proviso read as follows:- \n“Provided that the Board may in case of individuals allow, in place of National Tax \nNumber, use of Computerized National Identity Card issued by the National Database and \nRegistration Authority.” \n8 Added by the Finance Act, 2015. \n\n\f\nChapter X – Procedure__________________________________ \n \n376 \n \n1[181A. Active taxpayers’ list.— (1) The Board shall have the power to institute \nactive taxpayers’ list. \n \n \n(2) \nActive taxpayers’ list shall be regulated as may be prescribed.] \n \n2[181AA. Compulsory registration in certain cases.-(1) Notwithstanding \nanything contained in any law, for the time being in force, any application for \ncommercial or industrial connection of electricity or natural gas, shall not be \nprocessed and such connection shall not be provided unless the person applying \nfor electricity or gas connection is registered under section 181.] \n \n3[181B. Taxpayer card.— Subject to this Ordinance, the Board may make a \nscheme for introduction of a tax-payer honour card for individual taxpayers, who \nfulfill a minimum criteria to be eligible for the benefits as contained in the scheme.] \n \n4[181C. Displaying of National Tax Number.— Every person deriving income \nfrom business chargeable to tax, who has been issued a National Tax Number, \nshall display his National Tax Number at a conspicuous place at every place of his \nbusiness.] \n \n5[181D. Business licence scheme.- 6[(1)] Every person engaged in any business, \nprofession or vocation shall be required to obtain and display a business licence \nas prescribed by the Board.] \n \n \n7[(2) \nWhere a person fails to obtain business licence under sub-section (1), \nthe Commissioner may, in addition to and not in derogation of any punishment to \nwhich the person may be liable under this Ordinance or any other law, impose a \nfine of – \n \n(a) twenty thousand Rupees, in case of a taxpayer deriving income \nchargeable to tax under this Ordinance; or  \n \n(b) five thousand Rupees, in all other cases. \n \n                                            \n1 Inserted by the Finance Act, 2010.  \n2Inserted by the Finance Act, 2014. \n3 Added by the Finance Act, 2012. \n4 Added by the Finance Act, 2013. \n5 New Section (181D) inserted through Finance Act, 2019. \n6 Provision re-numbered as sub-section (1) through Tax Law (Second Amendment) 2019 dated 26th  \nDecember, 2019  \n7 New sub-sections (2) & (3) inserted through Tax Law (Second Amendment) 2019, dated 26th \nDecember, 2019 \n\n\f\nChapter X – Procedure__________________________________ \n \n377 \n \n \n(3) \nThe Commissioner may, by an order in writing, cancel a business \nlicence issued under sub-section (1) after providing an opportunity of being \nheard to the person, if –  \n \n \n(a) such person fails to notify any change in particulars within thirty days of \nsuch charge; or  \n \n(b) such person is convicted of any offence under any federal tax law.] \n \n1[181E. Record of beneficial owners.- (1) Every company and association of \npersons shall electronically furnish particulars of its beneficial owners in such \nform and manner as may be prescribed. \n \n(2) Every company and association of persons shall update the particulars of its \nbeneficial owners as and when there is a change in the particulars of the \nbeneficial owners.]    \n  \n \n \n                                            \n1 New Section 181E inserted by the Finance Act, 2022. \n\n\f\nChapter X – Procedure__________________________________ \n \n378 \n \nPART X \nPENALTY \n \n1[182. Offences and penalties.— (1) Any person who commits any offence \nspecified in column (2) of the Table below shall, in addition to and not in derogation \nof any punishment to which he may be liable under this Ordinance or any other \nlaw, be liable to the penalty mentioned against that offence in column (3) thereof:— \n  \n \nTABLE \n \n                                            \n1Section 182 substituted by the Finance Act, 2010. The substituted section 182 read as follows: \n \n“182.  Penalty for failure to furnish a return or statement.- (1)  Any person who, without reasonable excuse, \nfails to furnish, within the time allowed under this Ordinance, return of income or a statement as required under \nsub-section (4) of section 115 or wealth statement for any tax year as required under this Ordinance shall be \nliable for a penalty equal to one-tenth of one per cent of the tax payable for each day of default subject to a \nminimum penalty of five hundred rupees and a maximum penalty of twenty-five per cent of the tax payable in \nrespect of that tax year. \n \n \n(2) \nAny person who, without reasonable excuse, fails to furnish, within the time allowed under this \nOrdinance, any statement required under section 165 shall be liable for a penalty of two thousand rupees. \n \n \n(3) \nWhere a person liable to a penalty under sub-section (2) continues to fail to furnish the \nstatement, the person shall be liable for an additional penalty of two hundred rupees for each day of default \nafter the imposition of the penalty under sub-section (2).” \n\n\f\nChapter X – Procedure__________________________________ \n \n379 \n \nS. \nNo. \nOffences \nPenalties \nSection of \nthe \nOrdinance \nto which \noffence has \nreference \n(1) \n(2) \n(3) \n(4) \n1. \n1[Where any person \nfails to furnish a return \nof income as required \nunder \nsection \n114 \nwithin the due date.] \n2[   ] \n \n3[Such person shall pay a penalty equal to higher \nof – \n \n(a) \n0.1% of the tax payable in respect of that tax \nyear for each day of default; or \n(b) \nrupees one thousand for each day of \ndefault: \n \nProvided that minimum penalty shall be \n—  \n(i) rupees ten thousand in case of \nindividual having seventy-five percent or \nmore income from salary; or \n(ii)  rupees fifty thousand in all other cases: \n \n  Provided further that maximum penalty \nshall not exceed two hundred percent of tax \npayable by the person in a tax year:  \n \nProvided also that the amount of \npenalty shall be reduced by 75%, 50% and \n25% if the return is filed within one, two and \nthree months respectively after the due date \nor extended due date of filing of return as \nprescribed under the law; \n \nExplanation.— For the purposes of this \nentry, it is declared that the expression \"tax \npayable\" means tax chargeable on the \ntaxable income on the basis of assessment \nmade or treated to have been made under \nsection 120, 121, 122 or 122D;] \n \n114 *[and 118] \n4[1A. \nWhere any person \nfails \nto \nfurnish \na \nstatement as required \nunder section \n5[ ] \n6[165, 165A, 165B  or \n165C] within the due \ndate.] \n7[Such person shall pay a penalty of Rs. 8[50000] if the \nperson had already paid the tax collected or withheld \nby him within the due date for payment and the \nstatement is filed within ninety days from the due date \nfor filing the statement and, in all other cases, a penalty \nof Rs.2500 for each day of default from the due date \nsubject to a minimum penalty of Rs. 10,000] 9[: \n \nProvided that where it stands established that no \ntax was required to be deducted or collected during the \nrelevant period, minimum amount of penalty shall be \nten thousand Rupees.”; \n \n10[ \n] \n11[165, \n165A, 165B  and \n165C]   \n\n\f\nChapter X – Procedure__________________________________ \n \n380 \n \n                                            \n1The words and figures “Where any person fails to furnish a return of income or a statement as required under \nsection 115 or wealth statement or wealth reconciliation statement or statement under section 165 within the \ndue date” substituted by the Finance Act, 2013 \n2 The words and figures “Such person shall pay a penalty equal to 0.1% of the tax payable for each day of default \nsubject to a minimum penalty of five thousand rupees and a maximum penalty of 25% of the tax payable in \nrespect of that tax year” substituted by the Finance Act, 2013. \n3The expression “Such person shall pay a penalty equal to 0.1% of the tax payable in respect of that tax \nyear for each day of default subject to a maximum penalty of 50% of the tax payable provided that if \nthe penalty worked out as aforesaid is less than 3[forty] thousand rupees or no tax is payable for that \ntax year such person shall pay a penalty of 3[forty] thousand rupees] 3[:] \n3[Provided that If seventy-five percent of the income is from salary and the amount of income under \nsalary is less than five million Rupees, the minimum amount of penalty shall be five thousand Rupees] \n3[: \n“Provided further that if taxable income is up-to eight hundred thousand Rupees, the minimum \namount of penalty shall be five thousand Rupees:  \n  Provided also that the amount of penalty shall be reduced by 75%, 50% and 25% if the return is filed \nwithin one, two and three months respectively after the due date or extended due date of filing of return \nas prescribed under the law.] \n3[Explanation.— For the purposes of this entry, it is declared that the expression “tax payable” means \ntax chargeable on the taxable income on the basis of assessment made or treated to have been \nmade under section 120, 121, 122 or 122C.” substituted by the Finance Act, 2022. \n4 Inserted by the Finance Act, 2013. \n5 In column (2) the figure “115” omitted through Finance Act, 2020 dated 30th June, 2020 \n6 The expression “165, or 165A,165A or 165B” substituted by the Finance Act, 2025. \n7 The expression “Such person shall pay a penalty of Rs. 2500 for each day of default subject to a   \nminimum penalty of ten thousand rupees” substituted by the Finance Act, 2018. \n8 The figure “5000” substituted by the Finance Act, 2025. \n9 Full stop substituted and proviso added by the Finance Act, 2021. Earlier these amendments were \nmade through Tax Laws (Second  Amendment) Ordinance, 2021. \n10 In column (4) the figure “115” omitted through Finance Act, 2020 dated 30th June, 2020  \n11 The expression “165 and 165A,165A and 165B” substituted by the Finance Act, 2025. \n\n\f\nChapter X – Procedure__________________________________ \n \n381 \n \n1[1AA. Where any person \nfails to furnish wealth \nstatement or wealth \nreconciliation \nstatement. \nSuch person shall pay a penalty of 2[“0.1% of the \ntaxable \nincome \nper \nweek \nor \nRs.3[100,000] \nwhichever is higher.”] \n114, \n4[ ] and \n116] \n \n \n \n \n5[IAAA \nWhere any person \nfails \nto \nfurnish \na \nforeign assets   and \nincome \nstatement \nwithin the due date. \nSuch persons shall pay a penalty   of 2 percent of \nthe foreign income   or value of the foreign assets \nfor each year of default. \n116A] \n6[1B \nWhere any person \nfails to furnish a return \nof income as required \nunder sub-section (3) \nof section 117 within \nthe time specified in \nthe notice \nSuch person shall pay a penalty equal to higher of \n–  \n(a)  \n0.1% of the tax  \npayable \nin \n \nrespect  \nof that  tax \nyear \nfor \n \neach day of  \ndefault;  \nor  \n(b) \nRs. 1,000 per  day of  default:  \n \n \n \n \n \nProvided \nthat \nminimum \n \npenalty shall be Rs.10,000 in case of an \n \nindividual and Rs.50,000 in all other cases. \n117(3)] \n2. \nAny person who fails \nto issue cash memo \nor invoice or receipt \nwhen required under \nthis Ordinance or the \nrules \nmade \nthereunder. \nSuch person shall pay a penalty of five thousand \nrupees or three per cent of the amount of the tax \ninvolved, whichever is higher. \n \n174 \nand \nChapter VII of \nthe Income Tax \nRules. \n3. \nAny person who is \nrequired to apply for \nregistration under this \nOrdinance but fails to \nmake an application \nfor registration. \nSuch person shall pay a penalty of 7[ten] thousand \nrupees. \n \n181 \n8[3A. \nWhere any person \nbeing a trader or a \nshopkeeper who is \nrequired to apply for \nregistration under this \nOrdinance but fails to \nregister or fails to pay \nadvance \ntax \nas \nspecified in a scheme \nof special procedure \nprescribed \nunder \nsection 99B. \nThe shop of such person shall be sealed for seven \ndays for first default and for twenty one days for \neach subsequent default \n99B] \n4. \nAny person who fails \nto notify the changes \nof material nature in \nthe \nparticulars \nof \nregistration.  \nSuch person shall pay a penalty of five thousand \nrupees.  \n181 \n9[  ]  \n \n10[    ] \n \n \n \n \n4B \nAny \nperson \nwho \ncontravenes \nthe \nprovisions of section \n181AA. \nSuch a person shall pay a penalty at the rate of Rs. \n11[100,000] for each connection provided to an \nunregistered person. \n181AA] \n\n\f\nChapter X – Procedure__________________________________ \n \n382 \n \n                                            \n1Inserted by the Finance Act, 2013. \n2Substituted “Rs.100 for each day of default.” by the Finance Act, 2015. \n3 Figure “20,000” substituted by “100,000” though Finance Act, 2019.  \n4In column (4) the figure “115” omitted through Finance Act, 2020 dated 30th June, 2020  \n5Inserted by the Finance Act, 2018. \n6 Inserted by the Finance Act, 2024. \n7Word “five” substituted by “ten” through Finance Act, 2019.  \n8 Inserted by the Finance Act, 2024. \n9New serials “4A” and “4B” inserted through Finance Act, 2020 dated 30th June, 2020  \n10 S. No. 4A and entries relating thereto in column (2), (3) and (4) omitted by the Finance Act, 2021. \nThe omitted S. No. 4 read as follows: \n“4A. \nAny person who is required to furnish \nor update a taxpayer’s profile but fails \nto furnish or update within the due \ndate. \nSuch a person shall pay a penalty of Rs. \n2,500 for each day of default from the \ndue date subject to a minimum penalty \nof Rs. 10,000. \n114A” \n \n11 The figure “10,000” substituted by the Finance Act, 2021. \n\n\f\nChapter X – Procedure__________________________________ \n \n383 \n \n5. \nAny person who fails \nto deposit the amount \nof tax due or any part \nthereof in the time or \nmanner \nlaid \ndown \nunder this Ordinance \nor \nrules \nmade \nthereunder. \n \n \n1[Provided \nthat if the person opts \nto pay the tax due on \nthe basis of an order \nunder section 129 on \nor before the due date \ngiven in the notice \nunder sub-section (2) \nof section 137 issued \nin consequence of the \nsaid order, and does \nnot file an appeal \nunder section 131 the \npenalty payable shall \nbe reduced by 50%.] \n \nSuch person shall pay a penalty of five per cent of \nthe amount of the tax in default. \nFor the second default an additional penalty of 25% \nof the amount of tax in default. \n \nFor the third and subsequent defaults an additional \npenalty of 50% of the amount of tax in default. \n \n137 \n6. \nAny \nperson \nwho \nrepeats \nerroneous \ncalculation \nin \nthe \nreturn for more than \none \nyear \nwhereby \namount of tax 2[paid \nis] less than the actual \ntax payable under this \nOrdinance 3[  ]. \n \nSuch person shall pay a penalty of 4[thirty] thousand \nrupees or three per cent of the amount of the tax \ninvolved, whichever is higher] 5[: \n \nProvided that no penalty shall be imposed to \nthe extent of the tax shortfall occurring as a result of \nthe taxpayer taking a reasonably arguable position \non the application of this Ordinance to the \ntaxpayer’s position.] \n \n137 \n7. \nAny person who fails \nto maintain records \nrequired under this \nOrdinance or the rules \nmade thereunder. \nSuch person shall pay a penalty of ten thousand \nrupees or five per cent of  the amount of tax on \nincome whichever is higher. \n174 6[,108] \n8. \nWhere a taxpayer who, \nwithout any reasonable \ncause, \nin \nnon-\ncompliance \nwith \nprovisions of section \n177— \n \n \n177 \n \n(a) \nfails \nto \nproduce the record \n \nof documents \non receipt  \nof first \nnotice. \n \nSuch person shall pay a penalty of 7[twenty-five] \nthousand rupees; \n \n \n(b)  \nfails \nto \nproduce the record \n \nor documents \non receipt  \nof \nsecond notice; and  \n \nsuch person shall pay a penalty of 8[fifty]  thousand \nrupees; and  \n \n\n\f\nChapter X – Procedure__________________________________ \n \n384 \n \n                                            \n1Inserted by the Finance Act, 2011. \n2 Inserted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws (Second  \nAmendment) Ordinance, 2021. \n3 The words “is paid” omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. \n4Word “five” substituted by “thirty” through Finance Act, 2019.  \n5 Full stop substituted and proviso added by the Finance Act, 2021. Earlier this amendment was made \nthrough Tax Laws (Second  Amendment) Ordinance, 2021. \n6Added by the Finance Act, 2017. \n7The word “five” substituted by the Finance Act, 2013. \n8The word “ten” substituted by the Finance Act, 2013. \n\n\f\nChapter X – Procedure__________________________________ \n \n385 \n \n \n(c) \nFails \nto \nproduce the  \nrecord \n \nor documents \non  \nreceipt of third \nnotice. \n \nsuch person shall pay a penalty of 1[one hundred] \nthousand rupees. \n \n9. \nAny person who fails \nto \nfurnish \nthe \ninformation \nrequired \nor to comply with any \nother term of the \nnotice served under \nsection 1762[or 108]. \nSuch person shall pay a penalty of 3[twenty-five] \nthousand rupees for the first default and 4[fifty] \nthousand rupees for each subsequent default. \n \n176 \n10. \nAny person who— \n \n \n \n(a) makes a false or \nmisleading \nstatement to an \nInland \nRevenue \nAuthority either in \nwriting or orally or \nelectronically \nincluding \na \nstatement in an \napplication, \ncertificate, \ndeclaration, \nnotification, return, \nobjection or other \ndocument \nincluding books of \naccounts \nmade, \nprepared, \ngiven, \nfiled or furnished \nunder \nthis \nOrdinance; \nSuch person shall pay a penalty of twenty five \nthousand rupees or            5[50%] of the amount of \ntax shortfall whichever is higher: \n \nProvided that in case of an assessment order \ndeemed under section 120, no penalty shall be \nimposed to the extent of the tax shortfall occurring \nas a result of the taxpayer taking a reasonably \narguable position on the application of this \nOrdinance to the taxpayers’ position. \n \n114, 6[ ], 116, \n174, 176, 177 7[ \n[118]  \n \n(b)furnishes or files a \nfalse \nor \nmis-\nleading \ninformation \nor \ndocument \nor \nstatement to an \nIncome \nTax \nAuthority either in \nwriting or orally or \nelectronically; \n \n \n \n(c) \nomits \nfrom \na \nstatement made or \ninformation \nfurnished to an \nIncome \nTax \nAuthority \nany \nmatter or  thing \nwithout which the \nstatement or the \ninformation is false \nor misleading in a \nmaterial particular. \n \n \n\n\f\nChapter X – Procedure__________________________________ \n \n386 \n \n                                            \n1 The word “fifty” substituted by the Finance Act, 2013. \n2Added by the Finance Act, 2017. \n3 The word “five” substituted by the Finance Act, 2013. \n4 The word “ten” substituted by the Finance Act, 2013. \n5 Figure “100%” substituted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. \n6In column (4) the figure “115” omitted through Finance Act, 2020 dated 30th June, 2020  \n7 The words “and general” substituted by the Finance Act, 2021. Earlier this amendment was made \nthrough Tax Laws (Second  Amendment) Ordinance, 2021. \n\n\f\nChapter X – Procedure__________________________________ \n \n387 \n \n1[10A \nAny person who fails \nto comply with income \ntax \ngeneral \norder \nissued by the Board \nwithin fifteen days of \nissue of such order. \nSuch person shall pay penalty of fifty million rupees \nfor first default and one hundred million for each \nsubsequent default:  \n \n \nProvided that said penalty shall be imposed \neffective from such date as the Board may notify. \n114B] \n11. \nAny person who denies \nor obstructs the access \nof the Commissioner or \nany officer authorized \nby the Commissioner to \nthe premises, place, \naccounts, documents, \ncomputers or stocks. \nSuch person shall pay a penalty of 2[fifty] thousand \nrupees or 3[fifty] per cent of the amount of tax \ninvolved, whichever, is higher. \n175 and 177 \n12. \nWhere a person has \nconcealed income or \nfurnished \ninaccurate \nparticulars \nof \nsuch \nincome, including but \nnot \nlimited \nto \nthe \nsuppression \nof \nany \nincome \nor \namount \nchargeable to tax, the \nclaiming \nof \nany \ndeduction \nfor \nany \nexpenditure not actually \nincurred or any act \nreferred \nto \nin \nsub-\nsection (1) of section \n111, in the course of any \nproceeding under this \nOrdinance before any \nIncome Tax authority or \nthe appellate tribunal. \n \nSuch person shall pay a penalty of   4[one hundred] \nthousand rupees or an amount equal to the tax \nwhich the person sought to evade whichever is \nhigher. However, no penalty shall be payable on \nmere disallowance of a claim of exemption from tax \nof any income or amount declared by a person or \nmere disallowance of any expenditure declared by \na person to  be deductible, unless it is proved that \nthe person made the claim knowing it to be wrong. \n \n20, \n111 \nand \nGeneral \n5[12A \nWhere any person \nfails to pay tax at the \ntime \nof \nmaking \npayment \nas \nconsideration \nof \nshares or at the time \nof \nregistration \nof \nshares \nby \nthe \nSecurities \nand \nExchange \nCommission \nof \nPakistan or the State \nBank \nof \nPakistan, \nwhichever is earlier. \nSuch person shall pay a penalty equal to fifty \npercent of the amount of tax involved \n37(6)] \n                                            \n1 Inserted by the Finance Act, 2024. \n2The Word “twenty five” substituted by “fifty” through Finance Act, 2019. \n3 The words “one hundred” substituted by the Finance Act, 2021. Earlier this amendment was made \nthrough Tax Laws (Second  Amendment) Ordinance, 2021. \n4The words “twenty five” substituted by “one hundred” through Finance Act, 2019. \n5 Inserted by the Finance Act, 2024. \n\n\f\nChapter X – Procedure__________________________________ \n \n388 \n \n1[12B \nWhere \na \nbanking \ncompany or payment \ngateway or a courier \nservice provider, as \nthe case may be, fails \nto deduct tax at the \ntime \nof \nmaking \npayment to a seller, or \nfails to pay the tax \ndeducted as required \nunder section 160, \nwith \nrespect \nto \ndigitally \nordered \ngoods or rendering or \nproviding of digitally \ndelivered \nservices \nusing \ne-commerce \nplatform. \nSuch person shall pay a penalty equal to hundred \npercent of the amount of tax involved. \n153(2A)] \n13. \nAny \nperson \nwho \nobstructs any Income \nTax Authority in the \nperformance of his \nofficial duties. \nSuch person shall pay a penalty of twenty five \nthousand rupees. \n209, 210 and \nGeneral. \n14. \nAny \nperson \nwho \ncontravenes any of the \nprovision \nof \nthis \nOrdinance for which no \npenalty has, specifically, \nbeen provided in this \nsection. \nSuch person shall pay a penalty of five thousand \nrupees or three per cent of the amount of tax \ninvolved, which-ever is higher.  \n \nGeneral. \n15. \nAny person who fails to \ncollect or deduct tax as \nrequired \nunder \nany \nprovision \nof \nthis \nOrdinance or fails to pay \nthe tax collected or \ndeducted as required \nunder section 160. \nSuch person shall pay a penalty of 2[forty] thousand \nrupees or the 10% of the amount of tax which-ever \nis higher. \n1[Division II or \nDivision III \n2[, \nexcluding \nsub-\nsection (2A) of \nsection 153,] of \nPart \nV \nof \nChapter \nX \nor \nChapter XII] \n3[15A \nAny seller supplying \ndigitally ordered goods \nand digitally delivered \nservices through online \nmarketplace \nwho \nis \nrequired to registered \nunder \nIncome \nTax \nOrdinance, 2001 (XLIX \nof 2001) fails to register. \nSuch seller shall pay a penalty of five hundred \nthousand rupees for the first default and one million \nrupees for every subsequent default. \n181] \n4[16. \nAny person who fails to \ndisplay his NTN \n5[or \nbusiness licence] at the \nplace of business as \nrequired \nunder \nthis \nOrdinance or the rules \nmade thereunder. \nSuch person shall pay a penalty of five thousand \nrupees. \n181C \n6[and \n181D] ] \n                                            \n1 S. No. 12B and corresponding entries inserted by the Finance Act, 2025. \n2The words “twenty five” substituted by “forty” through Finance Act, 2019.  \n\n\f\nChapter X – Procedure__________________________________ \n \n389 \n \n7[17. \nAny reporting financial \ninstitution or reporting \nentity who fails to furnish \ninformation or country-\nby-country report to the \nBoard \nas \nrequired \nunder section 107, 108 \nor 165B within the due \ndate.  \nSuch reporting financial institution or reporting entity \nshall pay a penalty of two thousand rupees for each \nday of default subject to a minimum penalty of \ntwenty five thousand rupees. \n \n \n107, 108 and \n165B \n18. \nAny person who fails to \nkeep \nand \nmaintain \ndocument \nand \ninformation \nrequired \nunder section 108 or \nIncome \nTax \nRules, \n2002. \n1% of the value of transactions, the record of which \nis required to be maintained under section 108 and \nIncome Tax Rules, 2002. \n108.] \n8[  9[   \n \n \n \n \n                                            \n1 The entries “148, 149, 150, 151, 152, 153, 153A, 154, 155, 156, 156A, 156B, 158, 160, 231A, 231B, \n233, 233A, 234, 234A, 235, 236, 236A,” in column (4), substituted by the Finance Act, 2021. Earlier \nthis amendment was made through Tax Laws (Second  Amendment) Ordinance, 2021. \n2 Expression and corresponding entries inserted by the Finance Act, 2025. \n3 S. No. 15A and corresponding entries added by the Finance Act, 2025. \n4 Added by the Finance Act, 2013. \n5 Inserted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws (Second  \nAmendment) Ordinance, 2021. \n6 Inserted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws (Second  \nAmendment) Ordinance, 2021. \n7Added by the Finance Act, 2017. \n8Inserted by the Finance Supplementary (Amendment) Act, 2018. \n9 S. Nos. 19 and 20 omitted by the Finance Act, 2021. Earlier this amendment was made through \nTax Laws (Second  Amendment) Ordinance, 2021. The omitted S. Nos read as follows: \n  \n19 \nWhere any manufacturer of a motor vehicle accepts \nor processes any application for booking or purchase \nof a locally manufactured motor vehicle in violation of \nthe provisions of clause (a) of section 227C    \nSuch person shall pay a \npenalty of 5 percent of the \nvalue of the motor vehicle \n227C \n20 \n(i) Where any registering authority of Excise and \nTaxation Department accepts, processes or registers \nany application for registration of a locally \nmanufactured motor vehicle or for the first \nregistration of an imported vehicle in violation of the \nprovisions of clause (a) of section 227C. \n(ii) Where any authority responsible for registering, \nrecording or attesting the transfer of immovable \nproperty accepts or processes the registration or \nattestation of such property in violation of the \nprovisions of clause (b) of section 227C. \nSuch person shall pay a \npenalty of 3 percent of the \nvalue of motor vehicle or \nimmovable property. \n227C”   \n \n\n\f\nChapter X – Procedure__________________________________ \n \n390 \n \n \n \n \n]    ] \n1[21 \nAny \nperson \nwho \npurchases immovable \nproperty having fair \nmarket value greater \nthan \nrupees \nfive \nmillion through cash \nor bearer cheque.  \nSuch person shall pay a penalty of five percent of \nthe value of property determined by the Board \nunder sub-section (4) of section 68 or by the \nprovincial authority for the purpose of stamp duty, \nwhichever is higher. \n75A \n22 \nWhere an offshore tax \nevader is involved in \noffshore tax evasion \nin the course of any \nproceedings \nunder \nthis Ordinance before \nany \nIncome \nTax \nauthority \nor \nthe \nappellate tribunal.  \nSuch person shall pay a penalty of one hundred \nthousand rupees or an amount equal to two \nhundred per cent of the tax which the person sought \nto evade, whichever is higher. \nGeneral \n23 \nWhere in the course \nof any translation or \ndeclaration made by a \nperson \nan \nenabler \nhas enable, guided, \nadvised or managed \nany person to design, \narrange or manage \nthat \ntransaction \nor \ndeclaration in such a \nmanner \nwhich \nhas \nresulted or may result \nin \noffshore \ntax \nevasion in the course \nof any proceedings \nunder this Ordinance. \nSuch person shall pay a penalty of three hundred \nthousand rupees or an amount equal to two \nhundred per cent of the tax which was sought to be \nevaded, whichever is higher. \nGeneral  \n24 \nAny person who is \ninvolved \nin \nasset \nmove as defined in \nclause (5C) of section \n2 of the Ordinance \nfrom \nspecified \nterritory to an un-\nspecified territory. \nSuch person shall pay a penalty of one hundred \nthousand rupees or an amount equal to one \nhundred per cent of the tax whichever is higher. \nGeneral  \n                                            \n1New serial numbers (21 to 28) and corresponding entries added through Finance Act, 2019. \n\n\f\nChapter X – Procedure__________________________________ \n \n391 \n \n25 \nWhere a Reporting \nFinancial \nInstitution \nfails to comply with \nany \nprovisions \nof \nsection 165B of the \nOrdinance \nor \nCommon \nReporting \nStandard \nRules \nin \nChapter \nXIIA \nof \nIncome Tax Rules, \n2002. \nSuch Reporting Financial Institution shall pay a \npenalty of Rs.10,000 for each default and an \nadditional Rs. 10,000 each month until the default is \nredressed. \n \n26 \nWhere a Reporting \nFinancial \nInstitution \nfiles an incomplete or \ninaccurate \nreport \nunder provisions of \nsection 165B of the \nOrdinance \nand \nCommon \nReporting \nStandard \nRules \nin \nChapter \nXIIA \nof \nIncome Tax Rules, \n2002. \nSuch Reporting Financial Institution shall pay a \npenalty of Rs.10,000 for each default and an \nadditional Rs. 10,000 each month until the default is \nredressed. \n \n27 \nWhere a Reporting \nFinancial \nInstitution \nfails to obtain valid \nself-certification \nfor \nnew \naccounts \nor \nfurnishes false self-\ncertification for new \naccounts or furnishes \nfalse self-certification \nmade \nby \nthe \nReportable \nJurisdiction \nPerson \nunder \nCommon \nReporting \nStandard \nRules in Chapter XIIA \nof Income Tax Rules, \n2002.  \nSuch Reporting Financial Institution shall pay a \npenalty of Rs.10,000 for each default and an \nadditional Rs. 10,000 each month until the default is \nredressed. \n \n28 \nWhere a Reportable \nJurisdiction \nPerson \nfails to furnish valid \nself-certification \nor \nfurnishes false self-\ncertification \nunder \nCommon \nReporting \nStandard \nRules \nin \nChapter \nXIIA \nof \nIncome Tax Rules, \n2002. \nSuch Reporting Financial Institution shall pay a \npenalty of Rs.5,000 for each default and an \nadditional Rs. 5,000 each month until the default is \nredressed.] \n \n\n\f\nChapter X – Procedure__________________________________ \n \n392 \n \n1[29 \nWhere any person \nfails \nto \ndeclare \nbusiness \nbank \naccount(s), \nin \nhis \nregistration \napplication or fails to \namend his registration \nprofile \nto \ndeclare \nexisting \nbusiness \nbank \naccount(s) \nwillfully. \nSuch person shall pay a penalty of Rs. 10,000 for \neach day of default since the date of submission of \napplication for registration or date of opening of \nundeclared business bank account whichever is \nlater:  \n   \n    Provided that if penalty worked out as aforesaid \nis less than Rs.100,000 for each undeclared bank \naccount, such person shall pay a penalty of \nRs.100,000 for each undeclared business bank \naccount: \n \n     Provided further that this provision shall be \napplicable from the first day of October, 2021 during \nwhich period the taxpayer may update their \nregistration forms. \n181] \n2[30 \nAny \ncompany \nor \nAssociation \nof \nPersons \nwho \ncontravenes \nthe \nprovisions of Section \n181E. \n \nSuch company or Association of Persons shall pay \na penalty of Rs. 1,000,000/- for each default. \n181E \n31 \nAny person who fails \nto integrate or perform \nroles and functions as \nspecified, after being \nduly notified by the \nBoard \nas \nSWAPS \nAgent. \nSuch person shall pay a penalty of: \n \n(i) Rs.50,000 for first default of 07 days   \n(ii) Rs. 100,000 for second default of next 07 days \n(iii) Rs. 50,000 for each week after the second \nconsecutive week of default: \n \nProvided that no penalty shall be imposed for \nthe period for which extension from integration is \ngranted by the Commissioner subject to the \ncondition that, if the SWAPS Agent fails to integrate \nwithin such extended time, penalties shall be \nimposed as if no extension was granted. \n \n164A \n32 \nAny person, who is \nintegrated \nfor \nmonitoring, tracking, \nreporting or recording \nof sales, services and \nsimilar \nbusiness \ntransactions with the \nBoard \nor \nits \ncomputerized system, \nconducts \nsuch \ntransactions \nin \na \nmanner so as to avoid \nmonitoring, tracking, \nreporting or recording \nof such transactions, \nor issues an invoice \nSuch person shall pay a penalty of five hundred \nthousand rupees or two hundred per cent of the \namount of tax involved, whichever is higher.  \n237A \n                                            \n1 S. No. 29 added by the Finance Act, 2021. \n2 S. Nos. 30, 31, 32, 33 and 34 and entries relating thereto inserted by the Finance Act, 2022. \n\n\f\nChapter X – Procedure__________________________________ \n \n393 \n \nwhich does not carry \nthe prescribed invoice \nnumber or QR code or \nbears \nduplicate \ninvoice \nnumber \nor \ncounterfeit QR code, \nor \ndefaces \nthe \nprescribed \ninvoice \nnumber or QR code, \nor any person who \nabets commissioning \nof such offence.  \n \n33 \nAny person, who is \nrequired to integrate \nhis \nbusiness \nfor \nmonitoring, tracking, \nreporting or recording \nof sales, services and \nsimilar \nbusiness \ntransactions with the \nBoard \nor \nits \ncomputerized system, \nfails to get himself \nregistered under the \nOrdinance, \nand \nif \nregistered, \nfails \nto \nintegrate \nin \nthe \nmanner as required \nunder law.  \n \nSuch person shall be liable to pay a penalty up to \none million rupees, and if continues to commit the \nsame offence after a period of two months after \nimposition of penalty as aforesaid, his business \npremises shall be sealed till such time he integrates \nhis business in the manner as stipulated under sub-\nsection (3) of section 237A, as the case may be.  \n237A \n34 \nA person required to \nintegrate his business \nas stipulated under \nsub-section \n(3) \nof \nsection 237A, who \nfails to get himself \nregistered under the \nOrdinance, \nand \nif \nregistered, \nfails \nto \nintegrate \nin \nthe \nmanner as required \nunder the law and \nrules \nmade \nthereunder. \nSuch person shall be liable to pay- \ni) penalty of five hundred thousand rupees for first \ndefault;  \nii) penalty of one million rupees for second default \nafter fifteen days of order for first default;  \niii) penalty of two million rupees for third default after \nfifteen days of order for second default;  \niv)penalty of three million rupees for fourth default \nafter fifteen days of order for third default:  \n \nProvided that if such person fails to \nintegrate his business within fifteen days of \nimposition of penalty for fourth default, his business \npremises shall be sealed till such time he integrates \nhis business in the manner as stipulated under sub-\nsection (3) of section 237A:  \n \nProvided further that if the person integrates \nhis business with the Board's computerized system \nbefore imposition of penalty for second default, \npenalty for first default shall be waived by the \nCommissioner.] \n \n237A \n\n\f\nChapter X – Procedure__________________________________ \n \n394 \n \n1[35 \nAny company and an \nassociation \nof \npersons who –  \n \n(a) \nfails to fully \n \nstate all the \n \nrelevant \n \nparticulars or \n \ninformation as \n \nspecified \nin \n \nthe  \nform \n \nof \nreturn, \n \nincluding \na \n \ndeclaration of \n \nthe \nrecords \n \nkept by the \n \ntaxpayer;  \n \n(b)  \nfurnishes any \n \nannexure, \n \nstatement or \n \ndocument \n \nspecified \nin \n \nthe  \nreturn \n \nof \n \nincome \nas \n \nblank or with \n \nincomplete or \n \nirrelevant \n \nparticulars; or  \n \n(c)  \nattaches \n \nblank  or \n \nincomplete \n \nannexures, \n \nstatements or \n \ndocuments \n \nwhere \nsuch \n \nannexures, \n \nstatements or \n \nrecords were \n \nrequired to be \n \nfiled. \nSuch company, including a banking company and \nan association of persons shall pay a penalty of \nRs.500,000 or 10% of the tax chargeable on the \ntaxable income, whichever is higher.” \n114(2)] \n \n(2) \nThe penalties specified under sub-section (1) shall be applied in a \nconsistent manner and no penalty shall be payable unless an order in writing is \npassed by the Commissioner, Commissioner (Appeals) or the Appellate Tribunal \nafter providing an opportunity of being heard to the person concerned 2[:] \n \n                                            \n1 Inserted by the Finance Act, 2024. \n2 Full stop substituted by the Finance Act, 2012. \n\n\f\nChapter X – Procedure__________________________________ \n \n395 \n \n1[Provided that where the taxpayer admits his default he may \nvoluntarily pay the amount of penalty due under this section.] \n \n2[Explanation.—For the removal of doubt, it is clarified that establishing \nmens rea is not necessary for levying of penalty under this section.]  \n \n(3) \nWhere a Commissioner (Appeals) or the Appellate Tribunal makes an \norder under sub-section (2), the Commissioner (Appeals) or the Appellate Tribunal, \nas the case may be, shall immediately serve a copy of the order on the \nCommissioner and thereupon all the provision of this Ordinance relating to the \nrecovery of penalty shall apply as if the order was made by the Commissioner. \n \n(4) \nWhere in consequence of any order under this Ordinance, the amount \nof tax in respect of which any penalty payable under sub-section (1) is reduced, \nthe amount of penalty shall be reduced accordingly.] \n \n3[182A. Return not filed within due date. — (1) Notwithstanding anything \ncontained in this Ordinance, where a person fails to file a return of income under \nsection 114 by the due date as specified in section 118 or by the date as extended \nby the Board under section 214A or extended by the Commissioner under section \n119, as the case may be, such person shall— \n \n(a) not be included in the active taxpayers' list for the year for which return \nwas not filed within the due date 4[:] \n \n \n  \n5[Provided that without prejudice to any other liability under this \nOrdinance, the person shall be included in the active taxpayer ‘ list on \nfiling return after the due date, if the person pays surcharge at Rupees- \n \n(i) twenty thousand in case of a company; \n \n(ii)   ten thousand in case of an association of persons; \n \n(iii)  one thousand  in case of an individual.]  \n \n“Explanation.—For the removal of doubt it is clarified that the provisions of \nthis section shall apply from tax year 2018 and onwards for which the first \nActive Taxpayers List is to be issued on first day of March, 2019 under \nIncome Tax Rules, 2002.; and \n \n                                            \n1 Added by the Finance Act, 2011. \n2 Added by the Finance Act, 2021. \n3Inserted by the Finance Act, 2018. \n4Word “;and” substituted by colon through Finance Act, 2019. \n5New proviso inserted through Finance Act, 2019.  \n\n\f\nChapter X – Procedure__________________________________ \n \n396 \n \n(b) not be allowed, for that tax year, to carry forward any loss under Part \nVIII of Chapter IV 1[ ; ] \n \n2[(c) not be issued refund during the period the person is not included in the \nactive taxpayers’ list; and \n \n(d) not be entitled to additional payment for delayed refund under section \n171 and the period the person is not included in the active taxpayers’ \nlist, shall not be counted for computation of additional payment for \ndelayed refund.] \n \n3[   ] \n4[    ] \n5[183. Exemption from penalty and default surcharge.— The Federal \nGovernment may, by notification in the official Gazette, or the Board by an order \npublished in the official Gazette for reasons to be recorded in writing, exempt any \nperson or class of persons from payment of the whole or part of the penalty and \ndefault surcharge payable under this Ordinance subject to such conditions and \nlimitations as may be specified in such notification or, as the  case may be, order.] \n \n                                            \n1Full stop substituted by semicolon through Finance Act, 2019.  \n2 New clauses (c) & (d) added through Finance Act, 2019.   \n3New sub-section (2) added through Finance Act, 2020 dated 30th June, 2020.  \n4 Sub-section (2) omitted by the Finance Act, 2021. The omitted sub-section read as follows: \n“(2) \nWhere a person fails to furnish or update a taxpayer’s profile within the due date or time \nperiod specified in sub-section (3) of section 114A or within the date as extended by the Board under \nsection 214A, such person shall not be included in the active taxpayers’ list for the latest tax year ending \nprior to the aforesaid due date or extended date: \n \nProvided that without prejudice to any other liability under this Ordinance, such person shall be \nincluded in the active taxpayers’ list upon filing the taxpayer’s profile after the due date or extended \ndate, if the person pays surcharge at Rupees— \n(a) twenty thousand in case of a company; \n(b) ten thousand in case of an association of persons; and \n(c) one thousand in case of an individual.” \n5Section 183 substituted by the Finance Act, 2010. The substituted section 183 read as follows: \n“183.  Penalty for non-payment of tax.- (1)  A taxpayer who fails to pay any tax (other than penalty imposed \nunder this section) due under this Ordinance by the due date shall be liable for a penalty equal to – \n(a) \nin the case of the first default, five per cent of the amount of tax in default; \n(b) \nin the case of a second default, an additional penalty of twenty per cent of the amount of tax \nin default; \n(c) \nin the case of a third default, an additional penalty of twenty-five per cent of the amount of tax \nin default; and \n(d) \nin the case of a fourth and subsequent default, an additional penalty of up to fifty per cent of \nthe amount of tax in default as determined by the Commissioner, but the total penalty in \nrespect of the amount of tax in default shall not exceed one hundred per cent of such amount \nof tax. \n \n \n(2) \nWhere, in consequence of any order under this Ordinance, the amount of tax in respect of which \nany penalty imposed under sub-section (1) is reduced, the amount of the penalty shall be reduced \naccordingly.” \n\n\f\nChapter X – Procedure__________________________________ \n \n397 \n \n1[  ] \n2[  ] \n3[  ] \n \n4[  ] \n                                            \n1Section 184 omitted by the Finance Act, 2010. The omitted section 184 read as follows: \n“184.  Penalty for concealment of income.- (1)  Where, in the course of any proceedings under this \nOrdinance, the Commissioner, Commissioner (Appeals), or the Appellate Tribunal is satisfied that any \nperson has either in the said proceedings or in any earlier proceedings relating to an assessment in respect \nof the same tax year concealed income or furnished inaccurate particulars of such income, the \nCommissioner, Commissioner (Appeals), or the Appellate Tribunal, as the case may be, may, by an order \nin writing, impose upon the person a penalty equal to the amount of tax which the person sought to evade \nby concealment of income or the furnishing of inaccurate particulars of such income. \n \n(2) \nFor the purposes of sub-section (1), concealment of income or the furnishing of inaccurate \nparticulars of income shall include – \n(a) \nthe suppression of any income or amount chargeable to tax; \n(b) \nthe claiming of any deduction for any expenditure not actually incurred; or \n(c) \nany act referred to in sub-section (1) of section 111. \n  \n(3) \nWhere any income or amount declared by a taxpayer is claimed by the taxpayer to be exempt \nfrom tax or any expenditure declared by a taxpayer is claimed by the taxpayer to be deductible, the mere \ndisallowance of such claim shall not constitute concealment of income or the furnishing of inaccurate \nparticulars of income, unless it is proved that the taxpayer made the claim knowing it to be wrong. \n  \n(4) \nWhere a Commissioner (Appeals) or the Appellate Tribunal makes an order under sub-section \n(1), the Commissioner (Appeals) or the Appellate Tribunal, as the case may be, shall immediately serve a \ncopy of the order on the Commissioner and thereupon all the provisions of this Ordinance relating to the \nrecovery of penalty shall apply as if the order were made by the Commissioner.  \n(5)  \nWhere, in \nconsequence of any order under this Ordinance, the amount of tax in respect of which any penalty imposed \nunder sub-section (1) is reduced, the amount of the penalty shall be reduced accordingly.” \n2 Section 185 omitted by the Finance Act, 2010. The omitted section 185 read as follows: \n“185.  Penalty for failure to maintain records.- A person who, without reasonable excuse, fails to \nmaintain records as required under this Ordinance shall be liable for a penalty equal to – \n(a) \nin the case of the first failure, two thousand rupees; \n(b) \nin the case of a second failure, five thousand rupees; and \n(c) \nin the case of a third and subsequent failure, ten thousand rupees.” \n3 Section 186 omitted by the Finance Act, 2010. The omitted section 186 read as follows: \n“186.  Penalty for non-compliance with notice.- (1)  A person who, without reasonable excuse, \nfails to comply with any notice served on the person under section 116 or 176 shall be liable for a \npenalty equal to – \n(a) \nin the case of the first failure, two thousand rupees; \n(b) \nin the case of a second failure, five thousand rupees; or \n(c) \nin the case of a third and subsequent failure, ten thousand rupees. \n \n \n(2) \nWhere a person liable for a penalty under sub-section (1) has an assessed tax liability \nfor the tax year in which the failure occurred of less than twenty thousand rupees, the amount of the \npenalty imposed under sub-section (1) shall be reduced by seventy-five per cent.“ \n4 Section 187 omitted by the Finance Act, 2010. The omitted section 187 read as follows: \n“187. Penalty for making false or misleading statements.- (1)  Where a person – \n(a) \nmakes a statement to an income tax authority that is false or misleading in a \nmaterial particular or omits from a statement made to an income tax authority \nany matter or thing without which the statement is false or misleading in a \nmaterial particular; and \n(b) \nthe tax liability (including the liability for advance tax under section 147) of the \nperson computed on the basis of the statement is less than it would have been \nif the statement had not been false or misleading (the difference hereinafter \nreferred to as the “tax shortfall”), \n\n\f\nChapter X – Procedure__________________________________ \n \n398 \n \n1[  ] \n2[  ] \n3[  ] \nPART XI \nOFFENCES AND PROSECUTIONS \n \n191. Prosecution for non-compliance with certain statutory obligations. —\n(1)  Any person who, without reasonable excuse, fails to — \n                                            \nthe person shall be liable for a penalty equal to – \n (i) \nwhere the statement or omission was made knowingly or recklessly, two \nhundred per cent of the tax shortfall; or \n(ii) \nin any other case (other than where sub-section (2) applies), twenty-five \nper cent of the tax shortfall. \n \n(2) \nIn the case of an assessment order under section 120, no penalty shall be imposed \nunder sub-section (1) to the extent to which the tax shortfall arose as a result of the taxpayer taking \na reasonably arguable position on the application of this Ordinance to the taxpayer’s position. \n \n(3) \nA reference in this section to a statement made to an income tax authority is a reference \nto a statement made in writing or orally to that authority acting in the performance of the authority’s \nduties under this Ordinance, and shall include a statement made - \n(a) \nin an application, certificate, declaration, notification, return, objection or other \ndocument made, prepared, given, filed or furnished under this Ordinance;  \n(b) \nin information required to be furnished under this Ordinance;  \n(c) \nin a document furnished to an income tax authority otherwise than pursuant to \nthis Ordinance;  \n(d) \nin answer to a question asked of a person by an income tax authority; or \n(e) to another person with the knowledge or reasonable expectation that the statement \nwould be conveyed to an income tax authority.” \n1Section 188 omitted by the Finance Act, 2010. The omitted section 188 read as follows: \n“188.  Penalty for failure to give notice.- (1)  Where a person fails to give notice of the \ndiscontinuance of the person’s business as required under section 117, the Commissioner may \nimpose a penalty on the person not exceeding the amount of tax payable by the person for the tax \nyear in which the business was discontinued.  \n \n \n(2) \nWhere a person fails to give notice of the person’s appointment as liquidator as required \nunder section 141, the Commissioner may impose a penalty on the person not exceeding ten \nthousand rupees.” \n2Section 189 omitted by the Finance Act, 2010. The omitted section 189 read as follows: \n“189.  Penalty for obstruction.- Where any person obstructs the Commissioner or a taxation officer \nin discharge of the Commissioner or officer’s functions under this Ordinance, the Commissioner may \nimpose a penalty on the person not exceeding ten thousand rupees.” \n3Section 190 omitted by the Finance Act, 2010. The omitted section 190 read as follows: \n“190.  Imposition of penalty.- (1)  No penalty may be imposed under this Part on any person unless \nthe person is given a reasonable opportunity of being heard. \n \n(2) \nSubject to sub-section (3), the imposition of a penalty under this Part shall be without \nprejudice to any other liability incurred by the person under this Ordinance. \n \n(3) \nThe imposition of a penalty in relation to an act or omission shall be an alternative to \nprosecution under Part XI of this Chapter. \n \n(4) \nIf a penalty has been paid under this Part and the Commissioner institutes a prosecution \nproceeding under Part XI of this Chapter in respect of the same act or omission, the Commissioner \nshall refund the amount of penalty paid, and the penalty shall not be payable unless the prosecution \nis withdrawn.  \n \n(5) A penalty under sections 182, 183, 185, 186 and 187 shall be imposed by the Commissioner. \n \n(6) \nThe provisions of Parts III and IV of this Chapter shall apply to an assessment of penalty \nas if it were an assessment of tax.” \n\n\f\nChapter X – Procedure__________________________________ \n \n399 \n \n \n1[(a)  \ncomply with a notice under sub-section (3)2[and sub-section (4)] of \nsection 114 3[, sub-section (3) of section 117] or sub-section (1) of section \n116;] \n \n(b) \npay advance tax as required under section 147; \n \n(c) \ncomply with the obligation under Part V of this Chapter4[or chapter XII] \nto collect or deduct tax and pay the tax to the Commissioner; \n \n5[(ca) furnish particulars or complete or accurate particulars of persons \nmentioned in sub-section (1) of section 165;] \n \n(d) \ncomply with a notice served under section 140 or 176;  \n \n(e) \ncomply with the requirements of 6[sub-section (3) or sub-section (4) of] \nsection 141; 7[   ] \n \n(f ) \nprovide reasonable facilities and assistance as required under sub-\nsection (3) of section 175 8[; 9[    ]  \n \n(g)   declare business bank account(s) in the registration form or  updated \nregistration form or return of income or wealth statement] 10[; \n  \n(h) \nintegrate his business with Board’s computerized system; or \n \n(i) \ngenerate tax invoice verifiable by the Board’s system;”;  \nshall commit an offence punishable on conviction with a fine or imprisonment for a \nterm not exceeding one year, or both. \n \n \n(2) \nIf a person convicted of an offence under clause (a) of sub-section (1) \nfails, without reasonable excuse, to furnish the return of income or wealth \nstatement to which the offence relates within the period specified by the Court, the \nperson shall commit a further offence punishable on conviction with a fine 11[not \nexceeding fifty thousand rupees] or imprisonment for a term not exceeding two \nyears, or both. \n \n                                            \n1 Substituted by the Finance Act, 2003. The substituted clause (a) read as follows: \n“(a)  \nfurnish a return of income as required under section 114 or a wealth statement as required \nunder section 116;” \n2Inserted by the Finance Act, 2017 \n3 Inserted by the Finance Act, 2024. \n4Inserted by the Finance Act, 2017 \n5New clause (ca) inserted through Finance Act, 2019. \n6 Inserted by the Finance Act, 2003. \n7 The word “or” omitted by the Finance Act, 2021. \n8 Comma substituted, the word “and” inserted and clause (g) added by the Finance Act, 2021.  \n9 The word “and” omitted by the Finance Act, 2022.  \n10 Comma substituted and clauses (h) and (i) added by the Finance Act, 2022.  \n11Inserted by the Finance Act, 2009. \n\n\f\nChapter X – Procedure__________________________________ \n \n400 \n \n1[191A. Prosecution for failure to furnish information in return of income. – \nAny company including a banking company and an association of persons who –  \n \n(a) \nfails to fully state all the relevant particulars or information as specified in the \nform of return, including a declaration of the records kept by the taxpayer; \n \n(b) \nfurnishes blank or incomplete particulars or information as specified in the \nreturn of income; or  \n \n(c) \nattaches blank or incomplete annexures, statements or documents where \nsuch annexures, statements or records were required to be filed, shall \ncommit an offence punishable on conviction with a fine or imprisonment for \na term not exceeding one year or both.] \n \n191B. Prosecution for non-registration. – Any person specified in section 99B \nwho is required to apply for registration but fails to do so shall commit an offence \npunishable on conviction with imprisonment for a term not exceeding six months \nor fine or both.] \n \n192.  Prosecution for false statement in verification. — Any person who \nmakes a statement in any verification in any return or other document furnished \nunder this Ordinance which is false and which the person knows or believes to be \nfalse, or does not believe to be true, the person shall commit an offence punishable \non conviction with a fine 2[upto hundred thousand rupees] or imprisonment for a \nterm not exceeding three years, or both. \n \n3[192A. Prosecution for concealment of income.— (1) Where, in the course of \nany proceedings under this Ordinance, any person has either in the said \nproceedings or in any earlier proceedings concealed income or furnished \ninaccurate particulars of such income and revenue impact of such concealment or \nfurnishing of inaccurate particulars of such income is five hundred thousand rupees \nor more shall commit an offence punishable on conviction with imprisonment upto \ntwo years or with fine or both. \n \n \n(2)  \nFor the purposes of sub-section (1), concealment of income or the \nfurnishing of inaccurate particulars of income shall include– \n \n \n \n(a)  \nthe suppression of any income or amount chargeable to tax; \n \n(b) \nthe claiming of any deduction for any expenditure not actually \nincurred; or \n \n \n \n(c)  \nany act referred to in sub-section (1) of section 111.]   \n \n                                            \n1 Inserted by the Finance Act, 2024. \n2 Inserted by the Finance Act, 2009. \n3 Inserted by the Finance Act, 2009. \n\n\f\nChapter X – Procedure__________________________________ \n \n401 \n \n1[192B. Prosecution for concealment of an offshore asset.- (1) Any person who \nfails to declare an offshore asset to the Commissioner or furnished inaccurate \nparticulars of an offshore asset and revenue impact of such concealment or \nfurnishing of inaccurate particulars is ten million rupees or more shall commit an \noffence punishable on conviction with imprisonment up to three years or with a fine \nup to five hundred thousand Rupees or both.] \n  \n193.  Prosecution for failure to maintain records.—A person who fails to \nmaintain records as required under this Ordinance shall commit an offence \npunishable on conviction with – \n(a) \nwhere the failure was deliberate, a fine2[not exceeding fifty \nthousand rupees] or imprisonment for a term not exceeding \ntwo years, or both; or \n \n(b) \nin any other case, a fine3[not exceeding fifty thousand rupees]. \n \n194.  Prosecution for improper use of National Tax Number 4[Certificate].— \nA person who knowingly or recklessly uses a false National Tax Number \n5[Certificate] including the National Tax Number 6[Certificate] of another person on \na return or other document prescribed or used for the purposes of this Ordinance \nshall commit an offence punishable with a fine 7[not exceeding fifty thousand \nrupees] or imprisonment for a term not exceeding two years, or both. \n \n195.  Prosecution for making false or misleading statements. — (1) A person \nwho – \n \n(a) \nmakes a statement to 8[an income tax authority] that is false or \nmisleading in a material particular; or \n \n(b) \nomits from a statement made to 9[an income tax authority] any matter \nor thing without which the statement is misleading in a material \nparticular, \n \nshall commit an offence punishable on conviction – \n \n                                            \n1New sub section 192B inserted through Finance Act, 2019. \n2 Inserted by the Finance Act, 2009. \n3Inserted by the Finance Act, 2008. \n4 The word “Card” substituted by the Finance Act, 2005. \n5 The word “Card” substituted by the Finance Act, 2005. \n6The word “Card” substituted by the Finance Act, 2005. \n7Inserted by the Finance Act, 2009. \n8 The words “a taxation officer” substituted by the Finance Act, 2002. \n9The words “a taxation officer” substituted by the Finance Act, 2002. \n\n\f\nChapter X – Procedure__________________________________ \n \n402 \n \n (i) \nwhere the statement or omission was made knowingly or \nrecklessly, with a fine or imprisonment for a term not exceeding \ntwo years, or both; or \n \n(ii) \nin any other case, with a fine. \n \n \n(2) \nA person shall not commit an offence under sub-section (1) if the \nperson did not know and could not reasonably be expected to have known that the \nstatement to which the prosecution relates was false or misleading. \n \n \n(3) \n1[“Entry against S.No 10 in column (2) of the Table in sub-section (1) \nof section 182”] shall apply in determining whether a person has made a statement \nto 2[an income tax authority]. \n \n3[195A. Prosecution for non-compliance with notice under section 116A.— \nAny person who, without reasonable excuse, fails to comply with a notice under \nsub-section (2) of section 116A; shall commit an offence punishable on conviction \nwith imprisonment up to one year or with a fine up to fifty thousand Rupees or both. \n \n195B. Prosecution for enabling offshore tax evasion.– Any enabler who \nenables, guides or advises any person to design, arrange or manage a transaction \nor declaration in such a manner which results in offshore tax evasion, shall commit \nan offence punishable on conviction with imprisonment for a term not exceeding \nseven years or with a fine up to five million Rupees or both.] \n   \n196.  Prosecution for obstructing 4[an income tax authority. —] A person who \nobstructs 5[an income tax authority]in discharge of functions under this Ordinance \nshall commit an offence punishable on conviction with a fine or imprisonment for a \nterm not exceeding one year, or both. \n \n197.  Prosecution for disposal of property to prevent attachment. — Where \nthe owner of any property, or a person acting on the owner’s behalf or claiming \nunder the owner, sells, mortgages, charges, leases or otherwise deals with the \nproperty after the receipt of a notice from the Commissioner with a view to \npreventing the Commissioner from attaching it, shall commit an offence punishable \non conviction with a fine 6[upto hundred thousand rupees] or imprisonment for a \nterm not exceeding three years, or both. \n \n                                            \n1 Substituted “Sub-section (3) of section 187” by the Finance Act, 2015. \n2 The words “a taxation officer” substituted by the Finance Act, 2002. \n3New sub-sections (195A) & (195B) inserted through Finance Act, 2019. \n4The words “a taxation officer” substituted by the Finance Act, 2002. \n5The words “a taxation officer” substituted by the Finance Act, 2002. \n6Inserted by the Finance Act, 2009. \n\n\f\nChapter X – Procedure__________________________________ \n \n403 \n \n198.  Prosecution for unauthorised disclosure of information by a public \nservant.— A person who discloses any particulars in contravention of          1[sub-\nsection 1B of section 107 or] section 216 shall commit an offence punishable on \nconviction with a fine 2[of not less than five hundred thousand rupees] or \nimprisonment for a term not exceeding 3[one year], or both. \n \n199.  Prosecution for abetment. — Where a person 4[knowingly and wilfully] \naids, abets, assists, incites or induces another person to commit an offence under \nthis Ordinance, the first-mentioned person shall commit an offence punishable on \nconviction with a fine or imprisonment for a term not exceeding three years, or \nboth. \n \n200.  Offences by companies and associations of persons. — (1) Where an \noffence under this Part is committed by a company, every person who, at the time \nthe offence was committed, was – \n(a) \nthe principal officer, a director, general manager, company secretary \nor other similar officer of the company; o \n(b) \nacting or purporting to act in that capacity,  \nshall be, notwithstanding anything contained in any other law, guilty of the offence \nand all the provisions of this Ordinance shall apply accordingly. \n \n \n(2) \nWhere an offence under this Part is committed by an association of \npersons, every person who, at the time the offence was committed, was a member \nof the association shall be, notwithstanding anything contained in any other law, \nguilty of the offence and all the provisions of this Ordinance shall apply accordingly. \n \n \n(3) \nSub-sections (1) and (2) shall not apply to a person where – \n \n(a) \nthe offence was committed without the person’s consent or \nknowledge; and \n \n(b) \nthe person has exercised all diligence to prevent the \ncommission of the offence as ought to have been exercised \nhaving regard to the nature of the person’s functions and all the \ncircumstances. \n \n201. Institution of prosecution proceedings without prejudice to other action.—\nNotwithstanding anything contained in any law for the time being in force, a prosecution \nfor an offence against this Ordinance may be instituted without prejudice to any other \nliability incurred by any person under this Ordinance. \n                                            \n1Inserted by the Finance Act, 2016. \n2Inserted by the Finance Act, 2013. \n3 The words “six months” substituted by the Finance Act, 2013. \n4Inserted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n404 \n \n \n1[202. Power to compound offences.—Notwithstanding any provisions of this \nOrdinance, where any person has committed any offence, the \n2[Chief \nCommissioner] may, with the prior approval of the Board, either before or after the \ninstitution of proceedings, compound such offence subject to payment of tax due \nalong with 3[default surcharge]and penalty as is determined under the provisions \nof this Ordinance.] \n \n203. Trial by Special Judge.—4[(1) The Federal Government may, by \nnotification in the official Gazette, appoint as many Special Judges as it may \nconsider necessary, and where it appoints more than one Special Judge, it shall \nspecify in the notification the territorial limits within which each of them shall \nexercise jurisdiction 5[: \n \nProvided that the Federal Government may, by notification in official \nGazette, declare that a special judge appointed under section 185 of the Customs \nAct 1969 (IV of 1969) shall have jurisdiction to try offences under this Ordinance.] \n \n6[(1A) A Special Judge shall be a person who is or has been a Sessions Judge \nand shall, on appointment, have the jurisdiction to try exclusively an offence punishable \nunder this Part other than an offence referred to in section 198.] \n \n7[(1B) The provisions of the Code of Criminal Procedure, 1898 (Act V of \n1898), except those of Chapter XXXVIII, thereof shall apply to the proceedings of \nthe court of a Special Judge and, for the purposes of the said provisions, the court \nof Special Judge shall be deemed to be a Court of Sessions trying cases, and a \nperson conducting prosecution before the court of a Special Judge shall be \ndeemed to be a Public Prosecutor.] \n \n \n(2) \nA Special Judge shall take cognisance of, and have jurisdiction to try, \nan offence triable under sub-section (1) only upon a complaint in writing made by \nthe Commissioner 8[: \n                                            \n1Section 202 substituted by the Finance Act, 2009. The substituted sub-section “202” read as follows:  \n“202.  Power to compound offences.- Where any person has committed any offence under this \nPart, the Commissioner may either before or after the institution of proceedings, compound such \noffence and order that such person pay the amount for which the offence may be compounded.” \n2The words “Director General” substituted by Finance Act, 2012. \n3The words “additional tax” substituted by Finance Act, 2010. \n4Sub-section (1) substituted by Finance Act, 2010. The substituted sub-section (1) read as follows: \n“(1)  \nThe Federal Government” may, by notification in the official Gazette, appoint as many \nspecial judges as it may consider necessary, and where it appoints more than one Special Judge, \nshall specify in the notification the territorial limits within which each of them shall exercise \njurisdiction.” \n5 Full stop substituted by a colon and a proviso added by the Finance Act, 2014. \n6Inserted by Finance Act, 2010. \n7Inserted by Finance Act, 2010. \n8 Full stop substituted and proviso added by the Finance Act, 2021. \n\n\f\nChapter X – Procedure__________________________________ \n \n405 \n \n \nProvided that where the offence of concealment of income which has \nresulted in non-payment of tax of rupees one hundred and above in case of a filer \nand rupees twenty five million or above in case of non-filer, the procedure provided \nin section 203B shall be applicable.] \n \n1[(3) The Federal Government may, by order in writing, direct the transfer, at \nany stage of the trial, of any case from the court of one Special Judge to the court \nof another Special Judge for disposal, whenever it appears to the Federal \nGovernment that such transfer shall promote the ends of justice or tend to the \ngeneral convenience of parties or witnesses.] \n \n2[(4) In respect of a case transferred to a Special Judge by virtue of sub-section \n(1) or under sub-section (3), such Judge shall not, by reason of the said transfer, be \nbound to recall and record again any witness who has given evidence in the case before \nthe transfer and may act on the evidence already recorded by or produced before the \ncourt which tried the case before the transfer.] \n \n3[203A. Appeal against the order of a Special Judge.— An appeal against the \norder of a Special Judge shall lie to the respective High Court of a Province within \nthirty days of the passing of the order and it shall be heard as an appeal under the \nCode of Criminal Procedure 1898 (Act V of 1898) by a single Judge of the High \nCourt.] \n \n4[203B. Power to arrest and prosecute.—(1) Where on the basis of material \nevidence brought on record, as a result of audit conducted by the auditors in terms \nof sub-section (8) of section 177 read with section 214C of this Ordinance, an \nassessment is made or amended under section 121 or 122 of this Ordinance, as \nthe case may be, and the assessing officer records a finding that the taxpayer has \ncommitted the offence of concealment of income which has resulted in non-\npayment of tax of Rupees one hundred million and above in case of a filer and \nrupees twenty five million or above in case of non-filer, the taxpayer may be \narrested after obtaining written approval of the committee specified under sub-\nsection (2).  \n  \n(2) The committee under sub-section (1) shall comprise the Minister for \nFinance and Revenue, the Chairman of the Board and the senior most member of \nthe Board.  \n  \n(3) All arrests made under this Ordinance shall be carried out in accordance \nwith the relevant provisions of the Code of Criminal Procedure, 1898 (Act V of \n1898).  \n   \n                                            \n1Inserted by Finance Act, 2010. \n2Inserted by Finance Act, 2010. \n3Inserted by Finance Act, 2010. \n4 Sections 203B to 203I added by the Finance Act, 2021. \n\n\f\nChapter X – Procedure__________________________________ \n \n406 \n \n(4) Notwithstanding anything contained in sub-sections (1) and (2) or any \nother provision of this Ordinance, where any person has committed offence of \nconcealment of income or any offence warranting prosecution under this \nOrdinance, the Chief Commissioner with the prior approval of the Board may, \neither before or after the institution of any proceedings for recovery of tax, \ncompound the offence if such person pays the amount of tax due along with such \ndefault surcharge and penalty as is determined under the provisions of this \nOrdinance.  \n  \n(5)  Where the person suspected of offence of concealment of income or \nany offence warranting prosecution under this Ordinance is a company, every \ndirector or officer of that company whom the authorised officer has reason to \nbelieve is personally responsible for actions of the company contributing to offence \nof concealment of income or any offence warranting prosecution under this \nOrdinance shall be liable to arrest:  \n  \n    \nProvided that any arrest under this sub-section shall not absolve the \ncompany from the liabilities of payment of tax, default surcharge and penalty \nimposed under this Ordinance. \n \n203C. Procedure to be followed on arrest of a person.— (1) When an officer of \nInland Revenue authorized under sub-section (1) of section 203B in this behalf \narrests a person under section 203B, he shall immediately intimate the fact of the \narrest of that person to the Special Judge who may direct such officer to produce \nthat person at such time and place and on such date as the Special Judge \nconsiders expedient and such Officer shall act accordingly.  \n  \n(2) Notwithstanding anything contained in the sub-section (1), any person \narrested under this Ordinance shall be produced before the Special Judge or, if \nthere is no Special Judge within a reasonable distance, to the nearest Judicial \nMagistrate, within twenty-four hours of such arrest, excluding the time necessary \nfor the journey from the place of arrest to the Court of the Special Judge or, as the \ncase may be, of such Magistrate.  \n  \n(3) When any person is produced under sub-section (2) before the Special \nJudge, he may, on the request of such person, after perusing the record, if any \nand after giving the prosecution an opportunity of being heard, admit him to bail on \nhis executing a bond, with or without sureties, or refuse to admit him to bail and \ndirect his detention at such place as he deems fit:  \n  \n    \nProvided that nothing herein contained shall preclude the Special Judge \nfrom cancelling the bail of any such person at a subsequent stage if, for any \nreason, he considers such cancellation necessary, but before passing such order \nhe shall afford such person an opportunity of being heard, unless for reasons to \nbe recorded he considers that the affording of such opportunity shall defeat the \npurposes of this Ordinance.  \n\n\f\nChapter X – Procedure__________________________________ \n \n407 \n \n \n          (4) When such person is produced under sub-section (2) before a Judicial \nMagistrate, such Magistrate may, after authorising his detention in such custody \nat such place and for such period as he considers necessary or proper for \nfacilitating his earliest production before the Special Judge, direct his production \nbefore the Special Judge on a date and time to be fixed by him or direct such \nperson to be forthwith taken to, and produced before, the Special Judge and he \nshall be so taken.  \n  \n(5) Nothing in sub-section (3) or sub-section (4) shall preclude the Special \nJudge or the Judicial Magistrate from remanding any such person to the custody \nof an officer of Inland Revenue holding inquiry against that person if such officer \nmakes a request in writing to that effect, and the Special Judge or the Judicial \nMagistrate, after perusing the record, if any, and hearing such person, is of the \nopinion that for the completion of inquiry or investigation it is necessary to make \nsuch order:  \n  \n    \nProvided that the period of such custody shall not exceed more than fourteen \ndays.  \n  \n(6) When any person is arrested under this Ordinance, an officer of Inland \nRevenue shall record the fact of arrest and other relevant particulars in the register \nspecified in sub-section (10) and shall immediately proceed to inquire into the \ncharge against such person and if he completes the inquiry within twenty four \nhours of his arrest, excluding the time necessary for journey as aforesaid, he may, \nafter producing such person before the Special Judge or the nearest Judicial \nMagistrate, make a request for his further detention in his custody.  \n  \n(7) While holding an inquiry under sub-section (6), an officer of Inland \nRevenue shall exercise the same powers as are exercisable by an officer in charge \nof a police station under the Code of Criminal Procedure, 1898 (Act V of 1898), but \nsuch officer shall exercise such powers subject to the foregoing provisions of this \nsection while holding an inquiry under this Ordinance.  \n  \n(8) If an officer of Inland Revenue, after holding an inquiry as aforesaid, is of \nthe opinion that there is no sufficient evidence or reasonable ground for suspicion \nagainst such person, he shall release him on his executing a bond, with or without \nsureties, and shall direct such person to appear, as and when required, before the \nSpecial Judge, and make a report to the Special Judge for the discharge of such \nperson and shall make a full report of the case to his immediate superior.  \n  \n(9) The Special Judge to whom a report has been made under sub-section, \n(8) may, after the perusal of record of the inquiry, and hearing the prosecution, \nagree with such report and discharge the accused or, if he is of the opinion that \nthere is sufficient ground for proceedings against such person, proceed with his \ntrial and direct the prosecution to produce evidence.  \n\n\f\nChapter X – Procedure__________________________________ \n \n408 \n \n  \n(10) An officer of Inland Revenue empowered to hold inquiry under this \nsection shall maintain a register to be called “Register of Arrests and Detentions” \nin the prescribed form in which he shall enter the name and other particulars of \nevery person arrested under this Ordinance, together with the time and date of \narrest, the details of the information received, the details of things, goods or \ndocuments, recovered from his custody, the name of the witnesses and the \nexplanation, if any, given by him and the manner in which the inquiry has been \nconducted from day to day and, such register or authenticated copies of its \naforesaid entries shall be produced before the Special Judge, whenever such \nOfficer is so directed by him.  \n  \n(11) After completing the inquiry, an officer of Inland Revenue shall, as early \nas possible, submit to Special Judge a complaint in the same form and manner in \nwhich the officer in-charge of a police station submits a report, before a court.  \n   \n(12) Magistrate of the first class may record any statement or confession \nduring inquiry under this Ordinance, in accordance with the provisions of section \n164 of the Code of Criminal Procedure, 1898 (Act V of 1898).  \n  \n(13) Without prejudice to the foregoing provisions of this section, Board, with \nthe approval of the Federal Minister-in-charge, may, by notification in the official \nGazette, authorize any other officer working under the Board to exercise the \npowers and perform the functions of an officer of Inland Revenue under this \nsection, subject to such conditions, if any, that it may deem fit to impose.  \n  \n203D. Special Judges.— (1) The Federal Government shall by notification in the \nofficial Gazette, appoint as many Special Judges as it considers necessary and, \nwhere it appoints more than one Special Judge, it shall specify in the notification \nthe headquarter of each Special Judge and the territorial limits within which he \nshall exercise jurisdiction under this Ordinance.  \n  \n(2) No person shall be appointed as a Special Judge unless he is or has \nbeen a Sessions Judge.   \n  \n203E. Cognizance of offences by Special Judges.— (1) Notwithstanding \nanything contained in this Ordinance or any other law for the time being in force, a \nSpecial Judge may, within the limits of his jurisdiction, take cognizance of any \noffence punishable under this Ordinance upon—  \n  \n(a) a report in writing made by an officer of Inland Revenue or by any other \nofficer especially authorized in this behalf by the Federal Government; \nor  \n  \n(b)  receiving a complaint or information of facts constituting such offence \nmade or communicated by any person; or  \n  \n\n\f\nChapter X – Procedure__________________________________ \n \n409 \n \n(c) his own knowledge acquired during any proceeding before him under \nthis Ordinance or under any other law for the time being in force.  \n  \n(2) Upon the receipt of report under clause (a) of sub-section (1), the Special \nJudge shall proceed with the trial of the accused.  \n(3) Upon the receipt of a complaint or information under clause (b), or \nacquired in the manner referred to in clause (c) of subsection (1), the Special Judge \nmay, before issuing a summon or warrant for appearance of the person \ncomplained against, hold a preliminary inquiry for the purpose of ascertaining the \ntruth or falsehood of the complaint, or direct any magistrate or any officer of Inland \nRevenue or any police officer to hold such inquiry and submit a report, and such \nMagistrate or officer shall conduct such inquiry and make report accordingly.  \n  \n(4) If, after conducting such inquiry or after considering the report of such \nMagistrate or officer, the Special Judge is of the opinion that there is—  \n  \n(a)  no sufficient ground for proceeding, he may dismiss the complaint, or  \n  \n(b)  sufficient ground for proceeding, he may proceed against the person \ncomplained against in accordance with law.  \n  \n(5) A special Judge or a Magistrate or an officer holding inquiry under sub-\nsection (3) may hold such inquiry, as early as possible, in accordance with the \nprovision of section 202 of the Code of Criminal Procedure, 1898 (Act V of 1898).  \n  \n203F. Special Judge, etc. to have exclusive jurisdiction.— Notwithstanding \nanything contained in this Ordinance or in any other law for the time being in force \nno,–  \n  \n(a)   court other than the Special Judge having jurisdiction, shall try an  \noffence punishable under this Ordinance;  \n  \n(b) \nother court or officer, except in the manner and to the extent \nspecifically provided for in this Ordinance, shall exercise any power, \nor perform any function under this Ordinance;  \n  \n(c) \ncourt, other than the High Court, shall entertain, hear or decide any \napplication, petition or appeal under chapters XXXI and XXXII of the \nCode of Criminal Procedure, 1898 (Act V of 1898), against or in \nrespect of any order or direction made under this Ordinance; and  \n  \n(d) \nno court, other than the Special Judge or the High Court, shall \nentertain any application or petition or pass any order or give any \ndirection under chapters XXXVII, XXXIX, XLIV or XLV of the aforesaid \nCode.  \n\n\f\nChapter X – Procedure__________________________________ \n \n410 \n \n203G. Provisions of Code of Criminal Procedure, 1898, to apply.— (1) The \nprovision of the Code of Criminal procedure, 1898 (Act V of 1898), so far as they \nare not inconsistent with the provisions of this Ordinance, shall apply to the \nproceedings of the court of a Special Judge and such court shall be deemed to be \na court of Sessions for the purpose of the said Code and the provisions of Chapter \nXXIIA of the foresaid Code, so far as applicable and with the necessary \nmodifications, shall apply to the trial of cases by the Special Judge under this \nOrdinance.  \n  \n(2) For the purposes of sub-section (1), the Code of Criminal Procedure, \n1898 (Act V of 1898), shall have effect as if an offence punishable under this \nOrdinance were one of the offences referred to in sub-section (1) of section 337 of \nthe said Code.  \n  \n203H. Transfer of cases.—(1) Where more than one Special Judge are appointed \nwithin the territorial jurisdiction of a High Court, the High Court, and where not more \nthan one Special Judge is so appointed, the Federal Government, may by order in \nwriting direct the transfer, at any stage of the trial, of any case from the court of \none Special Judge to the Court of another Special Judge for disposal, whenever it \nappears to the High Court or, as the case may be, the Federal Government, that \nsuch transfer may promote the ends of justice or tend to the general convenience \nof the parties or witnesses.  \n  \n(2) In respect of a case transferred to a Special Judge under subsection (1), \nsuch Special Judge shall not by reason of the said transfer, be bound to recall and \nrehear any witness whose evidence has been recorded in the case before the \ntransfer and may act upon the evidence already recorded or produced before the \ncourt which tried the case before the transfer.  \n  \n203I. Place of sittings.—A Special Judge shall ordinarily hold sittings at his \nheadquarters but, keeping in view the general convenience of the parties or the \nwitnesses, he may hold sittings at any other place.] \n \n204.  Power to tender immunity from prosecution.— (1) The 1[Board with the \napproval of the Minister-in-charge] may, for the purpose of obtaining the evidence \nof any person appearing to have been directly or indirectly concerned in, or privy \nto the concealment of income or to the evasion of tax, tender to such person \nimmunity from prosecution for any offence under this Ordinance or under the \nPakistan Penal Code (Act XLV of 1860), or under any other Federal Law on \ncondition of the person making full and true disclosure of the whole circumstances \nrelating to the concealment of income or evasion of tax. \n \n                                            \n1 The words “Federal Government” substituted by the Finance Act, 2021. \n\n\f\nChapter X – Procedure__________________________________ \n \n411 \n \n \n(2) \nA tender of immunity made to, and accepted by, the person concerned \nshall render the person immune from prosecution for any offence in respect of \nwhich the tender was made and to the extent specified in the immunity. \n \n \n(3) \nIf it appears to the 1[Board with the approval of the  Minister-in-charge] \nthat any person to whom immunity has been tendered under this section has not \ncomplied with the conditions on which the tender was made or is concealing \nanything or giving false evidence, the 2[Board with the approval of the  Minister-in-\ncharge] may withdraw the immunity, and any such person may be tried for the \noffence in respect of which the tender of immunity was made or for any other \noffence of which the person appears to have been guilty in connection with the \nsame matter. \nPART XII \n3[DEFAULT SURCHARGE] \n \n205. 4[Default surcharge]. — (1)  A person who fails to pay – \n \n5[(a)  \nany tax, excluding the advance tax under section 147 and \n6[default surcharge]under this section;] \n \n(b) \nany penalty; or \n \n(c) \nany amount referred to in section 140 or 141,  \n \n                                            \n1 The words “Federal Government” substituted by the Finance Act, 2021. \n2 The words “Federal Government” substituted by the Finance Act, 2021. \n3 The words “ADDITIONAL TAX” substituted by the Finance Act, 2010. The substituted provision has \nbeen made effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier \nthe substitution was made through Finance (Amendment) Ordinance, 2009 which was re-\npromulgated as Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n4 The words “Additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n5 Substituted by the Finance Act, 2003. The substituted clause (a) read as follows:  \n“(a)  \nany tax, including any advance payment of tax under section 147;” \n6 The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n\n\f\nChapter X – Procedure__________________________________ \n \n412 \n \non or before the due date for payment shall be liable for 1[default surcharge] at a \nrate equal to 2[  ] 3[  ] 4[twelve percent or KIBOR plus three percent per annum, \nwhichever is higher] on the tax, penalty or other amount unpaid computed for the \nperiod commencing on the date on which the tax, penalty or other amount was due \nand ending on the date on which it was paid [:] \n \n5[Provided that if the person opts to pay the tax due on the basis of an \norder under section 129 on or before the due date given in the notice under sub-\nsection (2) of section 137 issued in consequence of the said order, and does not \nfile an appeal under section 131, he shall not be liable to pay default surcharge \nfor the period beginning from the due date of payment in consequence of an \norder appealed against to the date of payment in consequence of notice under \nsub-section (2) of section 137.] \n \n6[(1A) A person who fails to pay advance tax under section 147 shall be liable \nfor 7[default surcharge] at a rate equal to 8[ ] 9[  ]  10[twelve percent or KIBOR plus \nthree percent per annum, whichever is higher] on the amount of tax unpaid \ncomputed for the period commencing on the date on which it was due and ending \non the date on which it was paid or date on which the return of income for the \nrelevant tax year was due, whichever is earlier.] \n \n11[(1B) Where, in respect of any tax year, any taxpayer fails to pay tax under \nsub-section 12[(4A), or] (6) of section 147 or the tax so paid is less than 13[ninety] \nper cent of the tax chargeable for the relevant tax year, he shall be liable to pay \n                                            \n1 The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n2 The words “KIBOR plus three per cent per quarter” substituted by the Finance Act, 2012. \n3 The figure “18” substituted by Finance Act, 2015. \n4 The expression “12 per cent per annum” substituted by Finance Act, 2024. \n5 Added by the Finance Act, 2012. \n6 Inserted by the Finance Act, 2003. \n7The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n8The words “KIBOR plus three per cent per quarter” substituted by the Finance Act, 2012. \n9 The figure “18” substituted by Finance Act, 2015 \n10 The expression “12 per cent per annum” substituted by Finance Act, 2024. \n11Inserted by the Finance Act, 2004. \n12 Inserted by the Finance Act, 2006. \n13 The word “eighty” substituted by the Finance Act, 2006. \n\n\f\nChapter X – Procedure__________________________________ \n \n413 \n \n1[default surcharge]at the rate of 2[  ] 3[ ] 4[twelve percent or KIBOR plus three \npercent per annum, whichever is higher] on the amount of tax so chargeable or the \namount by which the tax paid by him falls short of the 5[ninety] per cent, as the \ncase may be; and such 6[default surcharge] shall be calculated from the first day \nof April in that year to the date on which assessment is made or the thirtieth day of \nJune of the financial year next following, whichever is the earlier 7[:] \n \n8[“Provided that in the case of person having a special tax year, the \ndefault surcharge shall be calculated on and from the first day of the fourth \nquarter of the special tax year till the date on which assessment is made or \nthe last day of special tax year, whichever is earlier.”;] \n \n \n(2) \nAny 9[default surcharge] paid by a person under sub-section (1) shall \nbe refunded to the extent that the tax, penalty or other amount to which it relates \nis held not to be payable. \n \n \n(3) \nA person who fails to 10[collect tax, as required under Division II of Part \nV of this Chapter or Chapter XII or deduct tax as required under Division III of Part \nV of this Chapter or Chapter XII or fails to] pay an amount of tax collected or \ndeducted as required under section 160 on or before the due date for payment \n                                            \n1The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n2The words “KIBOR plus three per cent per quarter” substituted by the Finance Act, 2012. \n3 The figure “18” substituted by Finance Act, 2015 \n4 The expression “12 per cent per annum” substituted by Finance Act, 2024. \n5 The word “eighty” substituted by the Finance Act, 2006. \n6The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n7Full stop substituted by the Finance Act, 2017 \n8Added by the Finance Act, 2017 \n9The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n10Inserted by the Finance Act, 2003. \n\n\f\nChapter X – Procedure__________________________________ \n \n414 \n \nshall be liable for 1[default surcharge] at a rate equal to 2[ ] 3[  ] 4[twelve percent or \nKIBOR plus three percent per annum, whichever is higher] on the amount unpaid \ncomputed for the period commencing on the date the amount was required to be \ncollected or deducted and ending on the date on which it was paid to the \nCommissioner 5[:] \n \n6[Provided that if the person opts to pay the tax due on the  basis of \nan order under section 129 on or before the due date given in the notice \nunder sub-section (2) of section 137 issued in consequence of the said order \nand does not file an appeal under section 131, he shall not be liable to pay \ndefault surcharge for the period beginning from the date of order under \nsection 161 to the date of payment.] \n \n7[   ] \n \n \n(5) \nThe Commissioner shall make an assessment of any 8[default \nsurcharge]imposed under this Part in accordance with the provisions of Part II of \nthis Chapter as if the 9[default surcharge] were tax. \n \n \n(6) \nThe provisions of Parts III and IV apply to an assessment of 10[default \nsurcharge]as if it were an assessment of tax. \n \n                                            \n1The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier \nthe substitution was made through Finance (Amendment) Ordinance, 2009 which was re-\npromulgated as Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n2 The words “KIBOR plus three per cent per quarter” substituted by the Finance Act, 2012. \n3 The figure “18” substituted by Finance Act, 2015 \n4 The expression “12 per cent per annum” substituted by Finance Act, 2024. \n5 Full stop substituted by the Finance Act, 2012. \n6Added by the Finance Act, 2012. \n7Sub-section (4) omitted by the Finance Act, 2003. The omitted sub-section (4) read as follows:  \n”(4) \nAdditional tax imposed under sub-section (3) shall be borne personally by the person \nobliged to collect or deduct the tax, and no part shall be recoverable from the taxpayer.” \n8The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n9The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n10 The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n\n\f\nChapter X – Procedure__________________________________ \n \n415 \n \n1[(7) \nWhere a person is liable for default surcharge under this Part, the \nCommissioner may, at his discretion, make assessment of default surcharge for \nthe period of default or part thereof, notwithstanding that the tax due has not \nactually been paid.]  \n \n2[205A. Reduction in 3[default surcharge], consequential to reduction in tax \nor penalty.— Where, in consequence of any order made under this Ordinance, \nthe amount of tax or penalty in respect of which 4[default surcharge] is chargeable \nunder section 205 is reduced, the 5[default surcharge], if any, levied under the \naforesaid section shall be reduced accordingly.] \nPART XIII \nCIRCULARS \n \n206.  Circulars. —(1) To achieve consistency in the administration of this \nOrdinance and to provide guidance to taxpayers and officers of the 6[Board], the \n7[Board] may issue Circulars setting out the Board’s interpretation of this \nOrdinance. \n \n \n8[(2) A circular issued by the 9[Board] shall be binding on all Income Tax \nAuthorities and other persons employed in the execution of the Ordinance, under \nthe control of the said Board other than Commissioners of Income Tax (Appeals).] \n \n \n(3) \nA Circular shall not 10[be] binding on a taxpayer. \n \n                                            \n1 New sub-section (7) added through Finance Act, 2020 dated 30th June, 2020. \n2 Added by the Finance Act, 2003. \n3The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n4The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n5 The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n6 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n7The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n8Sub-section (2) substituted by the Finance Act, 2006. The substituted sub-section (2) read as follows:  \n“(2) A Circular shall be binding on the Central Board of Revenue, other than the Commissioner \n(Appeals).” \n9 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n10Inserted by the Finance Act, 2002. \n\n\f\nChapter X – Procedure__________________________________ \n \n416 \n \n1[206A. Advance ruling.— (1) The 2[Board] may, on application in writing by a \nnon-resident taxpayer, issue to the taxpayer an advance ruling setting out the \nCommissioner’s position regarding the application of this Ordinance to a \ntransaction proposed or entered into by the taxpayer. \n \n(2)  \nWhere the taxpayer has made a full and true disclosure of the nature \nof all aspects of the transaction relevant to the ruling and the transaction has \nproceeded in all material respects as described in the taxpayer’s application for \nthe ruling, the ruling is 3[binding] on the Commissioner with respect to the \napplication to the transaction of the law as it stood at the time the ruling was issued. \n \n \n(3)  \nWhere there is any inconsistency between a circular and an advance \nruling, priority shall be given to the terms of the advance ruling 4[ 5[.]  ]  ] \n \n6[7[ ]  ] \n                                            \n1 Added by the Finance Act, 2003. \n2 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n3 The word “blinding” substituted by the Finance Act, 2005. \n4Full stop substituted by the Finance Act, 2011. \n5The colon substituted by the Finance Act, 2017. \n6Inserted by the Finance Act, 2011. \n7The proviso omitted by the Finance Act, 2017. The omitted proviso read as follows: \n“Provided that this section shall not apply to a non-resident taxpayer having a permanent \nestablishment in Pakistan.” \n \n\n\f\nChapter XI – Administration______________________________ \n \n417 \nCHAPTER XI \nADMINISTRATION \n \nPART I \nGENERAL \n \n1[207. Income tax authorities. — (1) There shall be the following Income Tax \nauthorities for the purposes of this Ordinance and rules made thereunder, \nnamely:— \n \n                                            \n1 Section 207 substituted by the Finance Act, 2010.  The substituted provision has been made effective \nfrom 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \nmade through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. The substituted section 207 \nread as follows: \n“207. Income tax authorities.- (1) There shall be the following income tax authorities for the purposes \nof this Ordinance and rules made thereunder,  namely:- \n(a)  \nBoard; \n(b)  \nChief Commissioner Inland Revenue; \n(c)  \nCommissioner Inland Revenue; \n(d)  \nCommissioner Inland Revenue (Appeals);  \n(e)  \nAdditional Commissioner Inland Revenue; \n(f)  \nDeputy Commissioner Inland Revenue; \n(g) \nAssistant Commissioner Inland Revenue; \n(h)  \nOfficer of Inland Revenue; \n(i)  \nSpecial Officer Inland Revenue; and \n(j)  \nInspector Inland Revenue.  \n \n(2)  \nThe Board shall examine, supervise and oversee the general administration of this \nOrdinance. \n \n \n(3)  \nThe Chief Commissioners Inland Revenue and Commissioners Inland Revenue \n(Appeals) shall be subordinate to the Board and Commissioners Inland Revenue, shall be \nsubordinate to the Chief Commissioner Inland Revenue. \n \n \n(4)  \nSubject to sub-section (5), Additional Commissioners Inland Revenue, Deputy \nCommissioners Inland Revenue, Assistant Commissioners Inland Revenue, Officer of Inland \nRevenue, Special Officers Inland Revenue and Inspectors Inland Revenue shall be subordinate to \nthe Commissioners Inland Revenue. \n \n \n(5)  \nAn officer vested with the powers and functions of the Commissioner, shall be \nsubordinate to the Chief Commissioner Inland Revenue.” \n\n\f\nChapter XI – Administration______________________________ \n \n418 \n \n(a) \n(b) \n(c) \n(d) \n(e) \n(f) \n(g) \n1[(ga) \n(h) \n(i) \n2[(ia) \n(ib) \n(j) \n(k) \n(l) \n(m) \nBoard: \nChief Commissioner Inland Revenue; \nCommissioner Inland Revenue; \nCommissioner Inland Revenue (Appeals); \nAdditional Commissioner Inland Revenue; \nDeputy Commissioner Inland Revenue; \nAssistant Commissioner Inland Revenue; \nSpecial audit panel;”] \nInland Revenue Officer; \nInland Revenue Audit Officer; \nDistrict Taxation Officer Inland Revenue; \nAssistant Director Audit.] \nSuperintendent Inland Revenue; \nInspector Inland Revenue; 3[  ] \nAuditor Inland Revenue; 4[and \nauditor appointed under section 222.] \n \n(2) \nThe Board shall examine, supervise and oversee the general \nadministration of this Ordinance. \n \n \n5[(3) The income tax authorities specified in sub-section (1) except in \nclause (a) shall be subordinate to the Board.] \n \n \n6[(3A) Commissioners Inland Revenue, Additional Commissioners Inland \nRevenue, Deputy Commissioners Inland Revenue, Assistant Commissioners \n                                            \n1 Inserted by Finance Act, 2015. \n2Inserted by Finance Act, 2017. \n3 The word “and” omitted by the Finance Act, 2025. \n4 The word “and” omitted by the Finance Act, 2025. \n5 Sub-section (3) substituted by the Finance Act, 2012. The substituted sub-section (3) read as \nfollows: \n \n \n“(3)  \nThe Chief Commissioners Inland Revenue and Commissioners Inland Revenue \n(Appeals) shall be subordinate to the Board and Commissioners Inland Revenue, shall be \nsubordinate to the Chief Commissioner Inland Revenue.” \n6 Inserted by the Finance Act, 2012. \n\n\f\nChapter XI – Administration______________________________ \n \n419 \n \nInland Revenue, Inland Revenue Officers, Inland Revenue Audit 1[Officers]        2[, \nDistrict \nTaxation \nOfficer \nInland \nRevenue, \nAssistant \nDirector \nAudit], \nSuperintendents Inland Revenue, Auditors Inland Revenue and Inspectors Inland \nRevenue, shall be subordinate to the Chief Commissioners Inland Revenue.] \n \n \n(4)  \nSubject to sub-section (5), Additional Commissioners Inland Revenue, \nDeputy Commissioner Inland Revenue, Assistant Commissioners Inland Revenue, \nInland Revenue Officers, Inland Revenue Audit Officers           3[, District Taxation \nOfficer Inland Revenue, Assistant Director Audit], Superintendents Inland \nRevenue, Auditors Inland Revenue and Inspectors Inland Revenue shall be \nsubordinate to the Commissioners Inland Revenue. \n \n(4A) Deputy Commissioners Inland Revenue, Assistant Commissioners \nInland Revenue, Inland Revenue Officers, Inland Revenue Audit Officers 4[, District \nTaxation Officer Inland Revenue, Assistant Director Audit], Superintendents Inland \nRevenue, Auditors Inland Revenue and Inspectors Inland Revenue shall be \nsubordinate to the Additional Commissioners Inland Revenue. \n \n \n(5) \nAn officer vested with the powers and functions of Commissioner shall \nbe subordinate to the Chief Commissioner Inland Revenue.] \n \n5[208.  Appointment of income tax authorities.— 6[(1) The Board may appoint as \nmany Chief Commissioners Inland Revenue, Commissioners Inland Revenue, \nCommissioners Inland Revenue (Appeals), Additional Commissioners Inland Revenue, \nDeputy Commissioners Inland Revenue, Assistant Commissioners Inland Revenue, \nInland Revenue Officers, Inland Revenue Audit Officers 7[, District Taxation Officer \nInland Revenue, Assistant Director Audit],Superintendents Inland Revenue, Inspectors \nInland Revenue, Auditors Inland Revenue and such other executive or ministerial \nofficers and staff as may be necessary.]   \n \n                                            \n1The word “officer” substituted by finance act 2017. \n2Inserted by Finance Act, 2017. \n3Inserted by Finance Act, 2017. \n4Inserted by Finance Act, 2017. \n5Section 208 substituted by the Finance Act, 2002. The substituted section 208 read as follows: \n“208. Central Board of Revenue.- The Central Board of Revenue shall exercise the general administration \nof this Ordinance.” \n6Sub-section (1) substituted by the Finance Act, 2010.  The substituted provision has been made effective from \n05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was made through \nFinance (Amendment) Ordinance, 2009 which was re-promulgated as Finance (Amendment) Ordinance, \n2010 and remained effective till 05.06.2010. The substituted sub-section (1) read as follows: \n“(1) The Central Board of Revenue may appoint as many Regional Commissioners of Income Tax, \nCommissioners of Income Tax, Commissioners of Income Tax (Appeals), taxation officers and such other \nexecutive or ministerial officers and staff as may be necessary.” \n7Inserted by Finance Act 2017. \n\n\f\nChapter XI – Administration______________________________ \n \n420 \n \n \n(2)  \nSubject to such orders or directions as may be issued by the 1[Board], \nany income tax authority may appoint any income tax authority subordinate to it \nand such other executive or ministerial officers and staff as may be necessary. \n \n \n(3)  \nAll appointments, other than of valuers, chartered accountants or \nexperts, made under this Ordinance, shall be subject to rules and orders of the \nFederal Government regulating the terms and conditions of persons in public \nservices and posts.] \n \n2[209. Jurisdiction of income tax authorities. — 3[(1) Subject to this Ordinance, \nthe 4[Chief Commissioners], the Commissioners and the Commissioners (Appeals) \nshall perform all or such functions and exercise all or such powers under this \nOrdinance as may be assigned to them in respect of such persons or classes of \npersons or such areas as the 5[Board] may direct 6[:]  ] \n \n7[Provided that the Board or the Chief Commissioner, as the case may \nbe, may transfer jurisdiction in respect of cases or persons from one \nCommissioner to another.] \n \n \n                                            \n1 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2 Section 209 substituted by the Finance Act, 2002. The substituted section 209 read as follows: \n“209. Appointment of Regional Commissioners of Income Tax and Commissioners of Income Tax.- \n(1)  The Central Board of Revenue may appoint as many Regional Commissioners of Income Tax and \nCommissioners of Income Tax as may be necessary. \n(2) \nSubject to such orders or directions as may be issued by the Central Board of Revenue, any \nRegional Commissioner of Income Tax may appoint any subordinate income tax authority subordinate and \nsuch other executive or ministerial officers and staff as may be necessary. \n(3) \nSubject to such orders or directions as may be issued by the Central Board of Revenue, any \nCommissioner of Income Tax may appoint such executive or ministerial officers and staff as may be \nnecessary. \n(4) \nAll appointments under this Ordinance shall be subject to the rules and orders of the \nFederal Government regulating the terms and conditions of service of persons in public services and \nposts.” \n3Substituted by the Finance Act, 2003. The substituted sub-section (1) read as follows:  \n“(1)  \nSubject to this Ordinance, the Regional Commissioners, the Commissioners and the \nCommissioners (Appeals) shall perform all or such functions and exercise all or such powers, under \nthis Ordinance, in respect of such persons or classes of persons or such areas, as may be assigned \nto them by orders or directions issued by the Central Board of Revenue.” \n4The words “Regional Commissioners” substituted by the Finance Act, 2010. \n5The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n6Full stop substituted by the Finance Act, 2011. \n7 Inserted by the Finance Act, 2011. \n\n\f\nChapter XI – Administration______________________________ \n \n421 \n \n \n(2)  \nThe 1[Board] or the 2[Chief Commissioner] may, by an order, confer \nupon or assign to any 3[officer of Inland Revenue] all or any of the powers and \nfunctions conferred upon or assigned to the Commissioner, under this Ordinance, \nin respect of any person or persons or classes of persons or areas 4[as may be \nspecified in the order] 5[; \n \n \nProvided that the Board may also confer upon or assign to any Officer of \nInland Revenue the aforesaid powers and functions through Automated Case \nSelection System: \n \n \nProvided further that the Board may make rules for conferment or \nassignment of such powers and functions through Automated Case Selection \nSystem.] \n \n6[Explanation.--- For the purpose of this sub-section, the expression “Automated \nCase Selection System” means an algorithm for randomized allocation of cases \nby using suitable technological modes.] \n \n \n(3)  \nAn order under sub-section (2) by the 7[Chief Commissioner] shall be \nmade only with the approval of the 8[Board]. \n \n \n \n(4)  \nThe 9[Officer of Inland Revenue] referred to in sub-section (2) shall, \nfor the purposes of this Ordinance, be treated to be the Commissioner. \n \n \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2The words “Regional Commissioner” substituted by the Finance Act, 2010. The substituted provision \nhas been made effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. \nEarlier the substitution was made through Finance (Amendment) Ordinance, 2009 which was re-\npromulgated as Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n3The words “taxation officer” substituted by Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n4 Inserted by the Finance Act, 2003. \n5 In sub-section (2) for the full stop at the end, a colon shall be substituted and thereafter provisos \nadded through Finance Act, 2020 dated 30th June, 2020. \n6Explanation added through Finance act, 2020 dated 30th June, 2020 \n7The words “Regional Commissioner” substituted by the Finance Act, 2010. The substituted provision \nhas been made effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. \nEarlier the substitution was made through Finance (Amendment) Ordinance, 2009 which was re-\npromulgated as Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n8 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n9The words “taxation officer” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n\n\f\nChapter XI – Administration______________________________ \n \n422 \n \n \n(5)  \nWithin the area assigned to him, the Commissioner shall have \njurisdiction, — \n \n(a) \nin respect of any person carrying on business, if the person’s \nplace of business is within such area, or where the business is \ncarried on in more than one place, the person’s principal place \nof business is within such area; or  \n \n(b) \nin respect of any other person, if the person resides in such \narea: \n \n(6)  \nWhere a question arises as to whether a Commissioner has \njurisdiction over a person, the question shall be decided by the 1[Chief \nCommissioner] or 2[Chief Commissioners] concerned and, if they are not in \nagreement, by the 3[Board]. \n \n \n(7)  \nNo person shall call into question the jurisdiction of a Commissioner \nafter that person has furnished a return of income to the Commissioner or, where \nthe person has not furnished a return of income, after the time allowed by any \nnotice served on the person for furnishing such return has expired. \n \n \n(8)  \nNotwithstanding \nanything \ncontained \nin \nthis \nsection, \nevery \nCommissioner shall have all the powers conferred by, or under, this Ordinance on \nhim in respect of any income arising within the area assigned to him. \n \n4[(8A) The power to confer jurisdiction under this section shall include the \npower to transfer jurisdiction from one income tax authority to another.] \n \n \n \n(9)  \nWhere, in respect of any proceedings under this Ordinance, an \nincome tax authority is succeeded by another, the succeeding authority may \ncontinue the proceedings from the stage it was left by that authority’s predecessor.] \n \n5[209A. Uniform.- The Board may by notification in the official gazette, prescribe \nrules for wearing of uniform by officers and staff of Inland Revenue Service of \nPakistan.] \n \n                                            \n1The words “Regional Commissioner” substituted by the Finance Act, 2010. The substituted provision \nhas been made effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. \nEarlier the substitution was made through Finance (Amendment) Ordinance, 2009 which was re-\npromulgated as Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n2The words “Regional Commissioners” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution \nwas made through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance (Amendment) \nOrdinance, 2010 and remained effective till 05.06.2010. \n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n4 Inserted by the Finance Act, 2003. \n5 Inserted by the Finance Act, 2022. \n\n\f\nChapter XI – Administration______________________________ \n \n423 \n \n1[210. Delegation. —(1) The Commissioner 2[subject to sub-section (1A),] may, \nby an order in writing, delegate to any 3[Officer of Inland Revenue, subordinate to \nthe Commissioner] all or any of the powers or functions conferred upon or assigned \nto the Commissioner under this Ordinance, other than the power of delegation. \n \n4[(1A) The Commissioner shall not delegate the powers of amendment of \nassessment contained in sub-section (5A) of section 122 5[ and amendment of an \norder of recovery under sub-section (3) of section 161]   to 6[an officer of Inland \nRevenue below the rank of Additional Commissioner Inland Revenue.] \n \n7[(1B) The Commissioner may, by an order in writing, delegate to a special \naudit panel appointed under sub-section (11) of section 177, or to a firm of \nchartered accountants or a firm of cost and management accountants appointed \n                                            \n1Substituted by the Finance Act, 2002. The substituted section 210 read as follows: \n“210.  Jurisdiction of Regional Commissioners of Income Tax and Commissioners of Income Tax.- (1)  \nSubject to this Ordinance, the Regional Commissioners of Income Tax and the Commissioners of Income Tax shall \nperform such functions in respect of such persons or classes of person, or such areas, as may be assigned to them \nby directions issued by the Central Board of Revenue. \n(2)Where any directions issued under sub-section (1) have assigned to two or more income tax authorities \nthe same function in respect of the same persons or class of persons, or the same areas, they shall perform their \nfunctions in accordance with such orders as the Central Board of Revenue, or any other authority to whom they \nare subordinate, may make for the allocation of functions and the distribution of the work performed. \n(3)Within a Commissioner’s assigned area, the Commissioner shall have jurisdiction, - \n(a) \nin respect of any person carrying on business, if the person’s place of business is within \nsuch area, or where the business is carried on in more than one place, the person’s \nprincipal place of business is within such area; or \n(b) \nin respect of any other person, if the person resides within such area. \n(4)Where a question arises as to whether a Commissioner has jurisdiction over any person, the question \nshall be decided by the Regional Commissioner or Regional Commissioners concerned and, if they are not in \nagreement, by the Central Board of Revenue. \n(5)No person shall call into question the jurisdiction of a Commissioner after the person has furnished a return \nof income to the Commissioner or, where the person has not furnished a return, after the time allowed by any notice \nserved on the person for furnishing such return has expired. \n(6)Notwithstanding anything contained in this section, every Commissioner shall have all the powers \nconferred by, or under this Ordinance on a Commissioner in respect of any income arising within the \nCommissioner’s assigned area. \n(7)Where any application may be made by a person under this Ordinance, the application shall be made to \nthe Commissioner with jurisdiction over the person or to the taxation officer with delegated power in respect of the \napplication.” \n2Inserted by the Finance Act, 2004. \n3The words “taxation officer” substituted by Finance Act, 2010. The substituted provision has been made effective \nfrom 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was made \nthrough Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n4 Added by the Finance Act, 2004. \n5The expression inserted through Finance Act, 2020 dated 30th June, 2020 \n6The words “taxation officer below the rank of Additional Commissioner of Income Tax” substituted by \nthe  Finance Act, 2010. \n7Substituted by Finance Act, 2015. The substituted sub-section (1B) read as follows:- \n “(1B)  The Commissioner may delegate the powers to a firm of chartered accountants or a \nfirm of Cost and Management Accountants]appointed  by the Board or the Commissioner to \nconduct the audit of persons for audit under section 177.” \n \n\n\f\nChapter XI – Administration______________________________ \n \n424 \n \nby the Board or the Commissioner to conduct an audit of person under section \n177, all or any of the powers or functions to conduct an audit under this Ordinance.] \n \n \n(2)  \nAn order under sub-section (1) may be in respect of all or any of the \npersons, classes of persons or areas falling in the jurisdiction of the Commissioner. \n \n \n(3)  \nThe Commissioner shall have the power to cancel, modify, alter or \namend an order under sub-section (1). \n \n1[211. Power or function exercised. —(1) Where, by virtue of an order under \nsection 210, a 2[an officer of Inland Revenue 3[or by a special audit panel appointed \nunder sub-section (11) of section 177] ] exercises a power or performs a function \nof the Commissioner, such power or function shall be treated as having been \nexercised or performed by the Commissioner. \n \n \n(2)  \nThe exercise of a power, or the performance of a function, of the \nCommissioner by a 4[an officer of Inland Revenue] shall not prevent the exercise \nof the power, or the performance of the function, by the Commissioner.] \n \n \n5[(3) The Board or, with the approval of the Board, an authority appointed \nunder this Ordinance, shall be competent to exercise all powers conferred upon \nany authority subordinate to it.] \n \n6[212.  Authority of approval.— The 7[Board] may, by a general or special order, \nauthorise the 8[Chief Commissioner Inland Revenue] or the Commissioner to grant \napproval in any case where such approval is required from the 9[Board] under any \nprovision of this Ordinance.] \n \n                                            \n1Substituted by the Finance Act, 2002. The substituted section 211 read as follows: \n“211.  Delegation.- The Commissioner may delegate to any taxation officer any duty, power, or \nfunction conferred or imposed on the Commissioner under this Ordinance, other than the power of \ndelegation under this section.”  \n2The words “a taxation officer” substituted by Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n3 Inserted by the Finance Act, 2015. \n4The words “a taxation officer” substituted by Finance (amendment) ordinance, 2009. \n5 Added by the Finance Act, 2012. \n6 Substituted by the Finance Act, 2002. The substituted section 212 read as follows: \n“212.  Authority of approval.- The Central Board of Revenue may, by general or special order, in writing, \nauthorise the Regional Commissioner or the Commissioner to grant approval in any case where such \napproval is required from the Central Board of Revenue under any provision of this Ordinance.” \n7 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n8 The words “Regional Commissioner” substituted by the Finance Act, 2021. \n9The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nChapter XI – Administration______________________________ \n \n425 \n \n1[213. Guidance to income tax authorities.— In the course of any proceedings \nunder this Ordinance, the Commissioner or any taxation officer may be assisted, \nguided or instructed by any income tax authority to whom he is subordinate or any \nother person authorised in this behalf by the 2[Board].] \n \n3[214. Income tax authorities to follow orders of the 4[Board]. —(1) Subject to \nsub-section (2), all income tax authorities and other persons employed in the \nexecution of this Ordinance shall observe and follow the orders, instructions and \ndirections issued by the 5[Board]. \n \n(2)  \nNo orders, instructions or directions shall be given by the 6[Board] that \nwill interfere with the discretion of the Commissioner (Appeals) in the exercise of \nhis appellate function.] \n \n7[214A. Condonation of time limit.— Where any time or period has been \nspecified under any of the provisions of the Ordinance or rules made there-under \nwithin which any application is to be made or any act or thing is to be done, the \nBoard may, 8[at any time before or after the expiry of such time or period,] in any \ncase or class of cases, permit such application to be made or such act or thing to \nbe done within such time or period as it may consider appropriate 9[.] \n \n10[Explanation,— For the purpose of this section, the expression “any  act or \nthing is to be done” includes any act or thing to be done by the taxpayer or by the \nauthorities specified in section 207.] \n \nProvided that the Board may, by notification in the official Gazette, and \nsubject to such limitations or conditions as may be specified therein, empower \n                                            \n1 Substituted by the Finance Act, 2002. The substituted section 213 read as follows: \n“213.  Exercise of jurisdiction by successor.- Where, in respect of any proceedings under this \nOrdinance, an income tax authority is succeeded by another, the succeeding authority may continue \nthe proceedings from the stage at which it was left by that authority’s predecessor.” \n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n3 Section 214 substituted by the Finance Act, 2002. The substituted section 214 read as follows: \n“214. Guidance to Commissioner or taxation officer.- In the course of any proceedings under this \nOrdinance, the Commissioner or any taxation officer with delegated power under section 211 may \nbe assisted, guided or instructed by any income tax authority to whom he is subordinate or any other \nperson authorised in this behalf by the Central Board of Revenue.” \n4 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n5 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n6 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n7Inserted by the Finance Act, 2009. \n8 Expression inserted by the Finance Act, 2022. \n9 Colon substituted by the Finance Act, 2012. \n10 Inserted by the Finance Act, 2012. \n\n\f\nChapter XI – Administration______________________________ \n \n426 \n \nany Commissioner or 1[Chief Commissioner] under this Ordinance to exercise \nthe powers under this section in any case or class of cases] 2[: \n \nProvided further that regardless of anything stipulated in this section, or \nany provision of this Ordinance, or any other applicable law currently in force, \nand notwithstanding any decision, order or judgment issued by any forum, \nauthority or court, the maximum period of extension under this section by the \nBoard or the Commissioner, as the case may be, shall not exceed two years in \naggregate:  \n \nProvided also that where there are reasons to believe that significant \nloss to exchequer or the taxpayer has been caused by an act of omission or \ncommission by the person or by the Commissioner, a committee of members as \nnotified by the Board may further condone the limitation specified for a period as \nit may deem fit, after providing a reasonable opportunity of being heard to the \nperson concerned.] \n \n3[214B. Power of the Board to call for records.— (1) The Board may, of its own \nmotion, call for and examine the record of any departmental proceedings under \nthis Ordinance or the rules made there-under for the purpose of satisfying itself as \nto the legality or propriety of any decision or order passed therein and may pass \nsuch order as it may think fit: \n \nProvided that no order imposing or enhancing any tax or penalty than the \noriginally levied shall be passed unless the person affected by such order has \nbeen given an opportunity of showing cause and of being heard. \n \n \n(2)  \nNo proceedings under this section shall be initiated in a case where \nan appeal is pending. \n \n \n(3)  \nNo order shall be made under this section after the expiry of three \nyears from the date of original decision or order.] \n \n4[214C. Selection for audit by the Board.— (1) The Board may select persons \nor classes of persons for audit of Income Tax affairs through computer ballot which \nmay be random or parametric as the Board may deem fit. \n \n \n5[(1A) Notwithstanding anything contained in this Ordinance or any other \nlaw, for the time being in force, the Board shall keep the parameters confidential.] \n                                            \n1 The words “Director General” substituted by the Finance Act, 2012. \n2 Full stop substituted with a colon and thereafter two new provisos added by the Finance Act, 2025.   \n3 Inserted by the Finance Act, 2009. \n4 Added by the Finance Act, 2010.  \n5 Added by the Finance Act, 2013. \n\n\f\nChapter XI – Administration______________________________ \n \n427 \n \n \n \n(2)  \nAudit of Income Tax affairs of persons selected under sub-section (1) \nshall be conducted as per procedure given in section 177 and all the provisions of \nthe Ordinance, except the first proviso to sub-section (1) of section 177, shall apply \naccordingly. \n \n \n(3)  \nFor the removal of doubt it is hereby declared that Board shall be \ndeemed always to have had the power to select any persons or classes of persons \nfor audit of Income Tax affairs.] \n \n1[Explanation.— For the removal of doubt, it is declared that the \npowers of the Commissioner under section 177 are independent of \nthe powers of the Board under this section and nothing contained in \nthis section restricts the powers of the Commissioner to call for the \nrecord or documents including books of accounts of a taxpayer for \naudit and to conduct audit under section 177.] \n \n2[ ] 3[ ] \n4[214E. Closure of audit.─ 5[(1)] Notwithstanding the omission of section 214D, \naudit of income tax affairs of a taxpayer under sub-section (2) of section 214D \nshall be deemed to have been concluded, if ─ \n(i) \ntaxpayer has been selected for audit under sub-section (1) of the \nomitted section 214D; \n(ii) \nnotice under section 122 has not been issued; \n                                            \n1 Added by the Finance Act, 2013. \n2 Section 214D Inserted by the Finance Act, 2015. \n3Section 214D omitted by the Finance Act, 2018. The omitted section 214D is read as follows:“214D. Automatic \nselection for audit.—(1) A person shall be automatically selected for audit of its income tax affairs for a tax year, if— \nthe return is not filed within the date it is required to be filed as specified in section 118, or, as the case may be, not filed within \nthe time extended by the Board under section 214A or further extended for a period not exceeding thirty days by the Commissioner under \nsection 119; or the tax payable under sub-section (1) of section 137has not been paid. \n(2) Audit of income tax affairs of persons automatically selected under sub-section (1) shall be conducted as per procedure \ngiven in section 177 and all the provisions of this Ordinance shall apply accordingly: \nProvided that audit proceedings shall only be initiated after the expiry of ninety days from the date as mentioned in sub-section \n(1). \n(3) Subject to section 182, 205 and 214C, sub-section (1) shall not apply if the person files the return within ninety days from \nthe date as mentioned in sub-section (1) and— \ntwenty-five percent higher tax, than the tax paid during immediately preceding tax year, has been paid by a person on the basis \nof taxable income and had declared taxable income in the return for immediately preceding tax year; or \ntax at the rate of two percent of the turnover or the tax payable under Part I of the First Schedule, whichever is higher, has \nbeen paid by a person alongwith the return and in the immediately preceding tax year has either not filed a return or had declared income \nbelow taxable limit: \nProvided that where return has been filed for the immediately preceding tax year, turnover declared for the tax year is not less \nthan the turnover declared for the immediately preceding tax year. \n(4)  \nThe provisions of sub-section (1) and sections 177 and214C shall not apply, for a tax year, to a person registered \nas retailer under rule (4) of the Sales Tax Special Procedure Rules, 2007 subject to the condition that name of the person registered \nunder rule (4) of the Sales Tax Special Procedure Rules, 2007remained on the sales tax active taxpayers‘ list throughout the tax year. \n(5)  \nSub-section (4) shall have effect from the date as the Board may, by notification in the official Gazette, appoint. \n4 Inserted by the Finance Supplementary (Amendment) Act, 2018. \n5 Provision re-numbered through Tax Law (Second Amendment) 2019, dated 26th December, 2019   \n\n\f\nChapter XI – Administration______________________________ \n \n428 \n \n(iii) the taxpayer has revised return voluntarily, by thirty first day of \nDecember, 2018, alongwith payment of 25% higher tax than the tax \npaid with return on the basis of taxable income and where no tax is \npayable 2% of the turnover and where no turnover is declared penalty \nunder entry at Serial No. 1 of sub-section (1) of section 182 has been \npaid voluntarily: \nProvided  that the condition of revision, 25% higher tax or 2% \nof the turnover shall not apply, if the taxable income of the taxpayer \nincludes only salary income or income subject to final taxation under \nsub-section (1) of section 169 or subject to taxation under section 5, \n5AA, 6, 7, 7A or 7B. \nExplanation.— For the removal of doubt it is clarified that only \naudit initiated as a result of automatic selection under the omitted \nsection 214D shall stand abated under this section and audit initiated \nor to be initiated on the basis of definite information or otherwise as \nper provisions of section 177 or 214C shall be conducted \nindependently.”] \n \n \n1[(2) Notwithstanding anything contained in sub-section (1), the Board may \nprescribe procedure for conclusion of audit of income tax affairs of a person \nautomatically selected for audit under omitted section 214D. \n \n \n(3) \nThe prescribed procedure under sub-section (2) may include \nacceptance of declared income of a taxpayer for a tax year subject to conditions \nspecified therein.]   \n \n \n2[215.  Furnishing of returns, documents etc. —(1) Where, by virtue of an order under \nsection 210, the Commissioner has delegated to any 3[an officer of Inland Revenue]the \nfunction and power to receive, or to call for and receive, any returns of income, \n                                            \n1 Sub-sections (2) & (3) inserted through Tax Law (Second Amendment) 2019 dated 26th December, \n2019 \n2 Section 215 substituted by the Finance Act, 2002. The substituted section 215 read as follows: \n“215. Taxation officers to follow orders of Central Board of Revenue.- (1)  Subject to sub-section \n(2), all taxation officers and other persons employed in the execution of this Ordinance shall observe \nand follow the orders, instructions and directions of the Central Board of Revenue. \n \n(2) \nNo orders, instructions or directions shall be given by the Central Board of Revenue \nthat will interfere with the discretion of the Commissioner (Appeals) in the exercise the appellate \nfunction of the Commissioner (Appeals).” \n3The words “taxation officer” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n\n\f\nChapter XI – Administration______________________________ \n \n429 \n \ncertificates, documents, accounts and statements from any person 1[ ] the 2[person] shall \nfurnish such returns, certificates, documents, accounts and statements to that 3[officer of \nInland Revenue]and, when furnished, shall be treated as having been furnished to the \nCommissioner. \n \n \n(2)  \nwhere a person is allowed, under any provision of this Ordinance, to \nmake an application to the Commissioner and the Commissioner has delegated to \nany 4[officer of Inland Revenue]the function or power to receive the application, \nsuch application, when made, shall be treated as having been made to the \nCommissioner.] \n \n216.  Disclosure of information by a public servant.- (1)  All particulars \ncontained in – \n \n(a) \nany statement made, return furnished, or accounts or \ndocuments produced under the provisions of this Ordinance;  \n \n(b) \nany evidence given, or affidavit or deposition made, in the \ncourse of any proceedings under this Ordinance, other than \nproceedings under Part XI of Chapter X; or \n \n(c) \nany record of any assessment proceedings or any proceeding \nrelating to the recovery of a demand, \n \nshall be  confidential and no public servant save as provided in this Ordinance may \ndisclose any such particulars. \n \n \n5[(2) Notwithstanding anything contained in the Qanun-e-Shahadat, 1984 \n(P.O. No. 10 of 1984), the National Accountability Ordinance, 1999 (XVIII of 1999), \n                                            \n1The words “or persons or class of persons (hereinafter called ‘filer’),” omitted through Finance Act, 2019. \n2The word “filer” substituted by “person” through Finance Act, 2019.  \n3The words “taxation officer” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n4The words “taxation officer” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n5The Sub-section (2) substituted by the Finance Act, 2022. The substituted sub-section read as \nfollows: \n  “(2) Notwithstanding anything contained in the Qanun-e-5[Shahadat], 1984 (P.O. Order No. 10 of \n1984), or any other law for the time being in force, no court or other authority shall be, save as \nprovided in this Ordinance, entitled to require any public servant to produce before it any return, \naccounts, or documents contained in, or forming a part of the records relating to any proceedings \nunder this Ordinance, or any records of the Income Tax Department generally, or any part thereof, \nor to give evidence before it in respect thereof.”  \n\n\f\nChapter XI – Administration______________________________ \n \n430 \n \nthe Federal Investigation Agency Act, 1974 (VIII or 1975) and the Right of Access \nto Information Act, 2017 (XXXIV of 2017), or any other law for the time being in \nforce, no court or any other authority shall, save as provided in the Ordinance, \nrequire any public servant to produce before it any return, accounts, or documents \ncontained in, or forming a part of the records relating to any proceedings under the \nOrdinance, or declarations made under the Voluntary Declaration of Domestic \nAssets Act, 2018, the Foreign Assets (Declaration and Repatriation) Act, 2018 or \nthe Assets Declaration Act, 2019 or any records of the Income Tax Department \ngenerally, or any part thereof, or to give evidence before it in respect thereof;] \n \n \n \n(3) \nNothing contained in sub-section (1) shall preclude the disclosure of \nany such particulars  – \n \n(a) \nto any person acting in the execution of this Ordinance, where \nit is necessary to disclose the same to him for the purposes of \nthis Ordinance;  \n \n(b) \nto any person authorised by the Commissioner in this behalf, \nwhere it is necessary to disclose the same to such person for \nthe purposes of processing of data and preparation of computer \nprintouts relating to returns of income or calculation of tax;  \n \n1[(ba)  to an auditor appointed on contractual basis or engaged through \na third party including a payroll firm in the Federal Board of \nRevenue, after a non-disclosure agreement is made with such \nauditor as may be prescribed, to assist any authority mentioned \nin clauses (b) to (g) of sub-section (1) of section 207.] \n \n(c) \nwhere the disclosure is occasioned by the lawful employment \nunder this Ordinance of any process for the service of any notice \nor the recovery of any demand;  \n \n(d) \nto the Auditor-General of Pakistan for the purpose of enabling \nthe Auditor-General to discharge his functions under the \nConstitution;  \n(e) \nto any officer appointed by the Auditor-General of Pakistan or \nthe Commissioner to audit income tax receipts or refunds;  \n \n(f ) \nto any officer of the Federal Government or a Provincial \nGovernment authorised by such Government in this behalf as \nmay be necessary for the purpose of enabling that Government \nto levy or realise any tax imposed by it;  \n \n                                            \n1 Clause (ba) inserted by the Finance Act, 2025.  \n\n\f\nChapter XI – Administration______________________________ \n \n431 \n \n(g) \nto any authority exercising powers under 1[the 2[Federal Excise \nAct, 2005], ] the Sales Tax Act, 1990, the Wealth Tax Act, 1963 \n(XV of 1963), or the Customs Act, 1969 (IV of 1969), as may be \nnecessary for the purpose of enabling its duty to exercise such \npowers;  \n \n(h) \noccasioned by the lawful exercise by a public servant of powers \nunder the Stamp Act, 1899 (II of 1899) to impound an \ninsufficiently stamped document;  \n \n(i) \nto the State Bank of Pakistan to enable it to compile financial \nstatistics of international investment and balance of payment; \n \n(j) \nas may be required by any order made under sub-section (2) of \nsection 19 of the Foreign Exchange Regulation Act, 1947 (VII of \n1947), or for the purposes of any prosecution for an offence \nunder section 23 of that Act;  \n                             \n(k) \nto the Securities and Exchange Commission or the Monopolies \nControl Authority for the purposes of the Securities and \nExchange Ordinance, 1969 (XVII of 1969), the Monopolies and \nRestrictive Trade Practices (Control and Prevention) Ordinance, \n1970 (VI of 1970), the 3[Companies Act, 2017 (XIX of 2017)] or \nthe Securities and Exchange Commission of Pakistan Act, \n1997, as the case may be; \n \n4[(ka) \nEmployees Old Age Benefit Institution in respect of information \nregarding salaries in statements furnished under section 165;] \n \n5[   ] \n \n6[     ] \n  \n7[(kc)  \nto National Database and Registration Authority to process and \nanalyze such data for the purposes of broadening of tax base;] \n                                            \n1The words, commas, figures and brackets ” the Central Excises and Salt Act, 1944 (I of 1944), the \nEstate Duty Act, 1950 (X of 1950)” substituted by the Finance Act, 2002. \n2 The words, comma, figure and brackets “Central Excises Act, 1944 (I of 1944)” substituted by the \nFinance Act, 2005. \n3 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n4Inserted by the Finance Act, 2017 \n5 Inserted by the Finance Act, 2018 \n6 Clause (kb) omitted by the Finance Act, 2022. The omitted clause read as follows: \n   “(kb) to National Database and Registration Authority for the purpose of broadening of the tax base;”  \n7 Clause (kc) added by the Finance Act, 2024. \n\n\f\nChapter XI – Administration______________________________ \n \n432 \n \n \n1[(kd)  \nto the Tax Policy Office for the purpose of processing and \nanalyzing data for research and policy analysis; and  \n   \n  (ke)  \nto the recognized universities and international donor agencies \nsubject to the conditions that before sharing, the taxpayer‘s data \nshall be anonymized.] \n \n(l) \nrelevant to any inquiry into a charge of misconduct in connection \nwith income tax proceedings against a legal practitioner or an \naccountant;  \n \n(m) \nto a Civil Court in any suit or proceeding to which the Federal \nGovernment or any income tax authority is a party which relates \nto any matter arising out of any proceedings under this \nOrdinance;  \n \n(n) \nfor the purposes of a prosecution for any offence under the \nPakistan Penal Code, 1860 (XLVI of 1860), in respect of any \nsuch statement, returns, accounts, documents, evidence, \naffidavit or deposition, or for the purposes of a prosecution for \nany offence under this Ordinance;  \n \n(o) \nrelevant to any inquiry into the conduct of an official of the \nIncome Tax Department to any person or officer appointed to \nhold such inquiry, or to a Public Service Commission, \nestablished under the Federal Public Service Commission \nOrdinance, 1977 (XLV of 1977), when exercising its functions in \nrelation to any matter arising out of such inquiry;  \n \n(p) \nas may be required by any officer or department of the Federal \nGovernment or of a Provincial Government for the purpose of \ninvestigation into the conduct and affairs of any public servant, \nor to a Court in connection with any prosecution of the public \nservant arising out of any such investigation; \n \n(q) \nto an authorised officer of the government of any country outside \nPakistan with which the Government has entered into an \nagreement under section 107 for the avoidance of double \ntaxation and the prevention of fiscal evasion as may be required \nto be disclosed in pursuance of that agreement; or \n \n                                            \n1 Clauses (kd) and ((ke) inserted by the Finance Act, 2025.  \n\n\f\nChapter XI – Administration______________________________ \n \n433 \n \n(r) \nto the Federal Tax Ombudsman appointed under the \nEstablishment of the Office of Federal Tax Ombudsman \nOrdinance, 2000 (XXXV of 2000) 1[; or] \n \n2[(s) \nto the Financial Monitoring Unit (FMU) for the purpose of \nperforming functions as laid down in the Anti-Money Laundering \nAct, 2010 (VII of 2010)] 3[; or \n \n (t)     in respect of any high-level public officials and public servants \nin BPS-17 and above, their spouses, children or benamidars, or \nany person in relation to whom the afore-mentioned persons are \nbeneficial owner:  \n \nProvided that nothing in clause (t) shall apply to those \nwho are expressly excepted under clause (iv) of sub-section (m) \nof section 5 of the National Accountability Ordinance, 1999 \n(Ordinance No. XVIII of 1999).  \n \nExplanation.— \n\"High-level \npublic \nofficials\" \nmean \npolitically exposed persons as defined by a rule, regulation, \nexecutive order or instrument; or under any law for the time \nbeing in force.] \n  \n(4) \nNothing in this section shall apply to the production by a public servant \nbefore a Court of any document, declaration, or affidavit filed or the giving of \nevidence by a public servant in respect thereof. \n \n \n(5) \nNothing contained in sub-section (1) shall prevent the 4[Board] from \npublishing, with the prior approval of the Federal 5[ ] 6[Government], any such \nparticulars as are referred to in that sub-section. \n \n \n(6) \nNothing contained in sub-section (1) shall prevent the Federal \nGovernment from publishing particulars and the amount of tax paid by a holder of \na public office as defined in the 7[National Accountability Bureau Ordinance, 1999 \n(XVIII of 1999).] \n                                            \n1 Full stop substituted by semi colon and word “or” through Tax Law (Second Amendment) 2019 dated \n26th December, 2019. \n2 New clause (s) added through Tax Law(Second Amendment) 2019, dated 26th December, 2019. \n3 Full stop substituted by semi colon and word “or” and clause (t) added by the Finance \n(Supplementary) Act, 2022. \n4The word “Commissioner” substituted by the Finance Act, 2011. \n5The word “Government” substituted by the Finance Act, 2017. \n6The expression “Minister-in-charge” substituted by the Finance Act, 2018. \n7The words, figures brackets and comma “Ehtesab Act, 1997 (IX of 1997)” substituted by the Finance \nAct, 2002. \n\n\f\nChapter XI – Administration______________________________ \n \n434 \n \n1[(6A)  Nothing contained in sub-section (1) shall prevent the Board from \nproviding data to any person approved by the Federal Government  to \nprocess  \nand analyze such data for broadening of tax base or for checking evasion: \nProvided that such data shall be anonymized before transmission to the \nperson and identifying particulars of the taxpayers shall be kept \nconfidential.”] \n \n2[(6B) Nothing contained in sub-section (1) shall prevent the Board from \npublishing the names of offshore evaders, in the print and electronic media who \nhave evaded offshore tax equal to or exceeding rupees two and half million \nRupees. \n \n(6C) Nothing contained in sub-section (1) shall prevent the Board from \npublishing the names of offshore tax enablers, in the print and electronic media \nwho have enabled offshore tax evasion.]   \n \n(7) \nAny person to whom any information is communicated under this \nsection, and any person or employee under the first-mentioned person’s control, \nshall be, in respect of that information, subject to the same rights, privileges, \nobligations, and liabilities as if the person were a public servant and all the \nprovisions of this Ordinance, so far as may be, shall apply accordingly. \n \n \n(8) \nNo prosecution may be instituted under this section except with the  \nprevious sanction of the 3[Board]. \n \n4[  ]  \n \n5[  ]  \n \n                                            \n1 Inserted by the Finance Supplementary (Amendment) Act, 2018. \n2Sub-sections (6B) & (6C) inserted through Finance Act, 2019. \n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n4New section 216A inserted through Finance Act, 2019.  \n5 Section 216A omitted by Finance Act, 2022. The omitted section read as follows: \n216A. Proceeding against authority and persons.- (1) Subject to section 227, the Board shall \nprescribe rules for initiating criminal proceedings against any authority mentioned in section 207 and \nofficer of the Directorate General mentioned in Part II and Part III of Chapter XI including any person \nsubordinate to the aforesaid authorities or officers of the Directorates General who wilfully and \ndeliberately commits or omits an act which results in under benefit or advantage to the authority or \nthe officer or official or to any other person.   \n(2) Where proceedings under sub-section (1) have been initiated against the authority or officer or \nofficial, the Board shall simultaneously intimate the relevant Government agency to initiate criminal \nproceedings against the person referred to in sub-section (1).  \n(3) The proceedings under this section shall be without prejudice to any other liability that the \nauthority or officer or official or the person may incur under any other law for the time being in force.” \n\n\f\nChapter XI – Administration______________________________ \n \n435 \n \n217.  Forms and notices; authentication of documents.—(1) Forms, notices, \nreturns, statements, tables and other documents required under this Ordinance \nmay be in such form as determined by the 1[Board] for the efficient administration \nof this Ordinance and publication of such documents in the official Gazette shall \nnot be required. \n \n \n(2) \nThe Commissioner shall make the documents referred to in sub-\nsection (1) available to the public in the manner prescribed. \n \n \n(3) \nA notice or other document issued, served or given by the \nCommissioner under this Ordinance shall be sufficiently authenticated if the name \nor title of the Commissioner, or authorised 2[Officer of Inland Revenue], is printed, \nstamped or written on the notice or document3[or if it is computer generated and \nbears the authentication in the manner prescribed by the Board]. \n \n218.  Service of notices and other documents.— (1) Subject to this Ordinance, \nany notice, order or requisition required to be served on a resident individual (other \nthan in a representative capacity) for the purposes of this Ordinance shall be \ntreated as properly served on the individual if – \n(a) \npersonally served on the individual or, in the case of an \nindividual under a legal disability or a non-resident individual, \nthe representative of the individual; \n(b) \nsent by registered post or courier service to the place specified \nin clause (b) 4[of sub-section (2)] or to the individual’s usual or \nlast known address in Pakistan; 5[    ] \n(c) \nserved on the individual in the manner prescribed for service of a \nsummons under the Code of Civil Procedure, 1908 (V of 1908) \n 6[; or] \n7[(d) served on the individual electronically in the prescribed \nmanner.] \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2The words “taxation officer” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n3Added by the Finance Act, 2010. The substituted provision has been made effective from 05.06.2010 \nby sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was made through \nFinance (Amendment) Ordinance, 2009 which was re-promulgated as Finance (Amendment) \nOrdinance, 2010 and remained effective till 05.06.2010. \n4 Inserted by the Finance Act, 2003. \n5  The word “or” omitted by the Finance Act 2022. \n6 Full stop substituted by the Finance Act 2018 \n7Added by the Finance Act, 2018. \n\n\f\nChapter XI – Administration______________________________ \n \n436 \n \n(2) \nSubject to this Ordinance, any notice, order or requisition required to be \nserved on any person (other than a resident individual to whom sub-section (1) \napplies) for the purposes of this Ordinance shall be treated as properly served on \nthe person if – \n \n(a) \npersonally served on the representative of the person; \n \n(b) \nsent by registered post or courier service to the person’s \nregistered office or address for service of notices under this \nOrdinance in Pakistan, or where the person does not have such \noffice or address, the notice is sent by registered post to any \noffice or place of business of the person in Pakistan; 1[    ] \n \n(c) \nserved on the person in the manner prescribed for service of a \nsummons under the Code of Civil Procedure, 1908 (V of 1908) \n2[; or] \n \n3[(d) served on the 4[person] electronically in the prescribed manner.] \n \n \n(3) \nWhere an association of persons is dissolved, any notice, order or \nrequisition required to be served under this Ordinance on the association may be \nserved on any person who was 5[the principal officer or] a member of the \nassociation immediately before such dissolution. \n \n(4) \nWhere section 117 applies, any notice, order or requisition required to \nbe served under this Ordinance on the person discontinuing the business may be \nserved on the person personally or on any individual who was the person’s \nrepresentative at the time of discontinuance. \n \n \n(5) \nThe validity of any notice issued under this Ordinance or the validity \nof any service of a notice under this Ordinance shall not be called into question \nafter the return to which the notice relates has been furnished or the notice has \nbeen otherwise complied with. \n \n219. Tax or refund to be computed to the nearest Rupee.—In the determination \nof any amount of tax or refund payable under this Ordinance, fractions of a rupee less \nthan fifty paisa shall be disregarded and fractions of a rupee equal to or exceeding fifty \npaisa shall be treated as one rupee. \n \n220. Receipts for amounts paid.— The Commissioner shall give a receipt for \nany tax or other amount paid or recovered under this Ordinance. \n                                            \n1  The word “or” omitted by the Finance Act 2023. \n2 Full stop substituted by the Finance Act 2018. \n3Added by the Finance Act, 2018. \n4  The word “individual” substituted by the Finance Act 2025. \n5Inserted by the Finance Act, 2002. \n\n\f\nChapter XI – Administration______________________________ \n \n437 \n \n221. Rectification of mistakes.— (1) The Commissioner, the Commissioner \n(Appeals) or the Appellate Tribunal may, by an order in writing, amend any order \npassed by 1[him] to rectify any mistake apparent from the record on 2[his or its] own \nmotion or any mistake brought to 3[his or its] notice by a taxpayer or, in the case of the \nCommissioner (Appeals) or the Appellate Tribunal, the Commissioner. \n \n4[(1A) The Commissioner may, by an order in writing, amend any order \npassed under the repealed Ordinance by the Deputy Commissioner, or an Income \nTax Panel, as defined in section 2 of the repealed Ordinance to rectify any mistake \napparent from the record on his own motion or any mistake brought to his notice \nby a taxpayer and the provisions of sub-section (2), sub-section (3) and sub-\nsection (4) shall apply in like manner as these apply to an order under sub-section \n(1).] \n \n \n(2) \nNo order under sub-section (1) which has the effect of increasing an \nassessment, reducing a refund or otherwise applying adversely to the taxpayer \nshall be made unless the taxpayer has been given a reasonable opportunity of \nbeing heard.  \n \n(3) \nWhere a mistake apparent on the record is brought to the notice of the \nCommissioner 5[or] Commissioner (Appeals) 6[  ], as the case may be, and no order \nhas been made under sub-section (1) before the expiration of the financial year \nnext following the date on which the mistake was brought to their notice, the \nmistake shall be treated as rectified and all the provisions of this Ordinance shall \nhave effect accordingly. \n \n \n(4) \nNo order under sub-section (1) may be made after five years from the \ndate of the order sought to be rectified. \n \n222.  Appointment of expert. — 7[(1)] The Commissioner may appoint any \nexpert as the Commissioner considers necessary for the purposes of this \nOrdinance, including for the purposes of audit or valuation. \n \n                                            \n1 The word “them” substituted by the Finance Act, 2003. \n2The word “their” substituted by the Finance Act, 2003. \n3The word “their” substituted by the Finance Act, 2003. \n4Inserted by the Finance Act, 2003. Earlier sub-section (1A) was inserted by S.R.O. 633(I)/2002, dated \n14.09.2002 which stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from \n01.07.2003. The said sub-section (1A) read as follows:  \n“(1A) \nThe Commissioner may, by an order in writing, amend any order passed under the \nrepealed Ordinance by the Deputy Commissioner, or an Income Tax Panel, as defined in section 2 \nof the repealed Ordinance.” \n5Comma substituted by the Finance Act, 2003. \n6The words “or the Appellate Tribunal” omitted by the Finance Act, 2003. \n7  The existing provision re-numbered as sub-section (1) thereof, by the Finance Act 2025. \n\n\f\nChapter XI – Administration______________________________ \n \n438 \n \n \n1[(2) The Board may also appoint as many auditors on contractual basis or \nthrough a third-party arrangement, as the case may be, as it deems fit for carrying \nout the purposes of this Ordinance:  \n \nProvided that the total number of auditors appointed under this section shall \nnot be more than two thousand.] \n \n2[222A. Fee and service charges.- 3[(1)] The 4[Board with the approval of Federal \nMinister-in-charge] may, be notification in the official Gazette, and subject to such \nconditions, limitations or restrictions as it may deem fit to impose, levy fee and \nservices charges for valuation or in respect of any other service or control \nmechanism provided by any formation under the control of the Board, including \nventures of public-private partnership at such rates as may be specified in the \nnotification.] \n \n5[(2) The Board may authorize and prescribe the manner in which fee and \nservice charges collected including by ventures of public-private partnership under \nthis section are expended.]  \n \n223.  Appearance by authorised representative. — (1)  Any taxpayer who is \nentitled or required to attend before the Commissioner, the Commissioner \n(Appeals) or the Appellate Tribunal in connection with any proceeding under this \nOrdinance may, except when required under section 176 to attend personally, \nattend by an authorised representative. \n \n \n(2) \nFor the purposes of this section and subject to sub-section (3), an \nauthorised representative of a taxpayer shall be a person who is a representative \nof the person under section 172 and any of the following persons, namely:– \n \n(a) \nA relative of the taxpayer; \n \n(b) \na current full-time employee of the taxpayer; \n(c) \nany officer of a scheduled bank with which the taxpayer \nmaintains a current account or has other regular dealings; \n \n(d) \nany legal practitioner entitled to practice in any Civil Court in \nPakistan; \n \n(e) \nany accountant; or \n \n                                            \n1  Sub-section (2) added by the Finance Act 2025. \n2 New section 222A added through Finance Act, 2019. \n3 Re-numbered as sub-section (1) of section 222A by the by the Finance Act, 2021. \n4 The words “Federal Government” substituted through Tax Laws (Second Amendment), 2019 dated \n26th December, 2019.   \n5 Sub-section (2) added by the Finance Act, 2021. \n\n\f\nChapter XI – Administration______________________________ \n \n439 \n \n(f) \nany income tax practitioner. \n \n \n(3) \nFor the purposes of this section — \n \n(a) \nno person who has been dismissed or removed from service in \nthe Income Tax Department shall be entitled to represent a \ntaxpayer under sub-section (1); \n \n(b) \nno  person having resigned from service after having been \nemployed in the Income Tax Department for not less than two \nyears shall be entitled to represent a taxpayer under sub-section \n(1) for a period of two years from the date of resignation;  \n \n(c) \nno person having retired from service in the Income Tax \nDepartment shall be entitled to represent a taxpayer under sub-\nsection (1) for a period of one year from the date of retirement in \nany case in which the person had made or approved, as the case \nmay be, any order of assessment, refund or appeal within one year \nbefore the date of retirement; or \n \n(d) \nno person who has become insolvent shall be entitled to \nrepresent a taxpayer under sub-section (1) for so long as the \ninsolvency continues; \n \n(e) \nno person who has been convicted of an offence in relation to any \nincome tax proceedings under this Ordinance shall be entitled to \nrepresent a taxpayer under sub-section (1) for such period as the \nCommissioner may, by order in writing, determine. \n \n(4) \nWhere any legal practitioner or accountant is found guilty of \nmisconduct in a professional capacity by any authority entitled to take disciplinary \naction against the legal practitioner or accountant, an order passed by that \nauthority shall have effect in relation to any right to represent a taxpayer under \nsub-section (1) as it has in relation to the person’s right to practice as a legal \npractitioner or accountant. \n \n \n(5) \nWhere any person (other than a person to whom sub-section (4) \napplies) is found guilty of misconduct in relation to any income tax proceeding, the \nCommissioner may, by an order in writing, direct that the person cease to \nrepresent a taxpayer under sub-section (1) before the Commissioner, \nCommissioner (Appeals) or Appellate Tribunal.  \n \n \n(6) \nThe Commissioner shall not make an order under clause (e) of sub-\nsection (3) or sub-section (5) in respect of any person, unless the Commissioner \nhas given the person a reasonable opportunity to be heard.  \n \n\n\f\nChapter XI – Administration______________________________ \n \n440 \n \n \n(7) \nAny person against whom an order under clause (e) of sub-section (3) or \nsub-section (5) has been made may, within thirty days of service of notice of the \norder, appeal to the 1[Board] to have the order cancelled. \n \n \n(8) \nThe 2[Board] may admit an appeal after the expiration of the period \nspecified in sub-section (7) if satisfied that the appellant was prevented by \nsufficient cause from lodging the appeal within the period. \n \n \n(9) \nNo order made under clause (e) of sub-section (3) or sub-section (5) \nshall take effect until thirty days after notice of the order is served on the person \nor, where an appeal has been lodged under sub-section (7), until the disposal of \nthe appeal. \n \n \n(10)  The 3[Board] may make rules under section 4[237]for the registration \nof income tax practitioners and related matters, including establishing a code of \nconduct for such practitioners. \n \n \n(11)  In this section – \n \n“accountant” means – \n \n(a) \na chartered accountant within the meaning of the Chartered \nAccountants Ordinance, 1961 (X of 1961);  \n(b) \na cost and management accountant within the meaning of the Cost \nand Management Accountants Act, 1966 (XIV of 1966); or \n(c) \na member of any association of accountants recognised for the \npurposes of this section by the 5[Board]; and \n \n“income tax practitioner” means a person who is registered as such by \nthe 6[Board], being a person who possesses such qualifications as \nmay be prescribed for the purposes of this section or who has retired \nafter putting in satisfactory service in the Income Tax Department for \na period of not less than ten years in a post or posts not below that of \nIncome Tax Officer. \n \n224.  Proceedings under the Ordinance to be judicial proceedings. —Any \nproceedings under this Ordinance before the Commissioner, Commissioner \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n4 The figure “232” substituted by the Finance Act, 2002. \n5The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n6 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nChapter XI – Administration______________________________ \n \n441 \n \n(Appeals) or Appellate Tribunal shall be treated as judicial proceedings within the \nmeaning of sections 193 and 228 of the Pakistan Penal Code, 1860 (Act XLV of \n1860), and for the purposes of section 196 of the Pakistan Penal Code, 1860 (Act \nXLV of 1860). \n \n225.  Proceedings against companies under liquidation. —Notwithstanding \nanything contained in 1[section 310 of the Companies Act, 2017 (XIX of 2017)], \nleave of the Court shall not be required for continuing with or commencing any \nproceeding under this Ordinance against a company in respect of which a winding \nup order has been made or Provisional Liquidator appointed. \n \n226.  Computation of limitation period.—In computing the period of limitation, \nthere shall be excluded – \n \n(a) \nin the case of an appeal or an application under this Ordinance, the \nday on which the order complained of was served and, if the taxpayer \nwas not furnished with a copy of the order when the notice of the order \nwas served on the taxpayer, the time requisite for obtaining a copy of \nsuch order; and \n \n2[(b)  in the case of an assessment or other proceeding under this \nOrdinance,— \n \n(i)  \nthe period, if any, for which such proceedings were stayed by \nany Court, Appellate Tribunal or any other authority; or \n \n(ii)  \nthe period, if any, for which any proceeding for the tax year \nremained pending before any Court, Appellate Tribunal 3[, \nAlternate Dispute Resolution Committee (ADRC)] or any other \nauthority.] \n \n227.  Bar of suits in Civil Courts.— 4[(1)] No suit or other legal proceeding shall \nbe brought in any Civil Court against any order made 5[or any notice issued] under \nthis Ordinance, and no prosecution, suit or other proceedings shall be made \n                                            \n1 The expression “section 316 of the Companies Ordinance, 1984 (XLVII of 1984)” substituted by the \nFinance Act, 2021. \n2Clause (b) substituted by the Finance Act, 2010. The substituted clause (b) read as follows: \n“(b) in the case of an assessment or other proceeding under this Ordinance, the period, if any, \nfor which such proceedings were stayed by any Court, Appellate Tribunal or any other \nauthority.” \n3 Expression inserted by the Finance Act 2025. \n4 Re-numbered as sub-section (1) by the Finance Act, 2010. \n5 Inserted by the Finance Act, 2018. \n\n\f\nChapter XI – Administration______________________________ \n \n442 \n \nagainst any person for anything which is in good faith done or intended to be done \nunder this Ordinance or any rules or orders made 1[or notices issued] thereunder. \n \n2[“Explanation.—For the removal of doubt, it is clarified that Civil Court \nincludes any court exercising power of the civil court.”] \n \n \n3[(2)  Notwithstanding anything contained in any other law for the time being \nin force, no investigation or inquiry shall be undertaken or initiated by any \ngovernmental agency against any officer or official for anything done in his official \ncapacity under this Ordinance, rules, instructions or direction made or issued \nthere-under without the prior approval of the Board.] \n \n4[227A. Reward to officers and officials of Inland Revenue.— (1) In cases 5[(i)] \ninvolving concealment or evasion of income tax and other taxes, cash reward shall, \nonly after realization of part or whole of the taxes involved in such cases, be \nsanctioned to the officers and officials of Inland Revenue for their meritorious \nconduct in such cases 6[and (ii) for other meritorious services] and to the informer \nproviding credible information leading to such detection. \n \n \n(2) \nThe Board may, by notification in the official Gazette, prescribe the \nprocedure in this behalf and also specify the apportionment of reward sanctioned \nunder this section for individual performance or to collective welfare of the officers \nand officials of Inland Revenue.] \n \n7[227B. Reward to whistleblowers.—(1) The Board may sanction reward to \nwhistleblowers in cases of concealment or evasion of income tax, fraud, corruption or \nmisconduct providing credible information leading to such detection of tax. \n \n(2) The Board may, by notification in the official Gazette, prescribe the \nprocedure in this behalf and also specify the apportionment of reward sanctioned \nunder this section for whistleblowers. \n \n(3) The claim for reward by the whistleblower shall be rejected, if— \n \n(a) the information provided is of no value; \n \n8[(aa) the information is not supported by any evidence;] \n                                            \n1 Inserted by the Finance Act, 2018. \n2 Added by the Finance Act, 2018. \n3 Added by the Finance Act, 2010. \n4 Added by the Finance Act, 2013. \n5 Inserted by the Finance Act, 2017. \n6 Inserted by the Finance Act, 2017 \n7 inserted by the Finance Act, 2015. \n8inserted by the Finance Act, 2017. \n\n\f\nChapter XI – Administration______________________________ \n \n443 \n \n \n(b) the Board already had the information; \n \n(c) the information was available in public records; or \n \n(d) no collection of taxes is made from the information provided \nfrom which the Board can pay the reward. \n \n(4) For the purpose of this section, “whistleblower” means a person who \nreports concealment or evasion of income tax leading to detection or collection of \ntaxes, fraud, corruption or misconduct, to the competent authority having power to \ntake action against the person or an income tax authority committing fraud, \ncorruption, misconduct, or involved in concealment or evasion of taxes.”] \n \n1[227BA. Reward and benefits for certain persons.— (1) The Board may \nsanction rewards to e-intermediaries for filing of returns of new taxpayers.   \n  \n(2) The Board with the approval of Federal Minister in-charge may announce \nbenefits, rebates, tax credits, allowances and any other incentive in cash or \notherwise for class or classes of persons.   \n  \n(3) The Board with the approval of the Federal Minister  in-charge may, by \nnotification in the official Gazette, prescribe the procedure in this behalf and also \nnotify the class or classes of persons eligible under this section. The provisions of \nthis section shall take effect from the date notified by the Board.] \n \n2[   ] \n                                            \n1 Section 227BA inserted by the Finance Act, 2021. \n2Section 227C omitted through Finance Act 2019, omitted section read as follows:- \n227C. Restriction on purchase of certain assets.─ Notwithstanding anything contained in any law, \nfor the time being in force,— \n(a) \nany application for booking, registration or purchase of a new locally manufactured motor \nvehicle or for first registration of an imported vehicle shall not be accepted or processed by any \nvehicle registering authority of Excise and Taxation Department or a manufacturer of a motor \nvehicle respectively, unless the person is a filer.; and \n \n(b) \nany application or request by a person to any authority responsible for registering, recording or \nattesting transfer of any immovable property, exceeding five million rupees, for registering or \nattesting the transfer shall not be accepted or processed by such authority, unless the person is a \nfiler2[:]” ] \n2[“Provided that the provisions of clause (a) shall not apply in respect of,─ \n2[(i) locally manufactured motor vehicle; or] \n(ii) \na person holding a Pakistan origin card or a national identity card for overseas \nPakistanis 2[or a non-resident Pakistani citizen holding international passport] who \nproduces a certificate from a scheduled bank of receipt of foreign exchange remitted \nfrom outside Pakistan through normal banking channels during a period of sixty \ndays prior to the date of booking, registration or purchase of motor vehicle: \nProvided further that the provisions of clause (b) shall not apply to,─ \n(i) a legal heir acquiring property in inheritance; or \n\n\f\nChapter XI – Administration______________________________ \n \n444 \n \n1[227D.- Automated impersonal tax regime.- (1) The Board may design an \nalternate impersonal taxation regime whereby personal interaction will be \nminimized. \n(2) \nThe Board may, by notification in the official Gazette, prescribe the \nprocedure in this behalf. \n(3) \nThis section shall be applicable only for low risk and compliant \ntaxpayers as may be prescribed.] \n2[227E. E-hearing.— (1) The Board may design and prescribe e-hearing module \nfor the purpose of conducting hearings, granting opportunity of being heard and \nelectronically receiving any information for the purpose of this Ordinance.  \n  \n(2) The recording of e-hearing proceedings shall be admissible as evidence \nbefore any forum or court of law for the purpose of this Ordinance.  \n  \n(3) The Board may make rules for the purpose of this section.] \nPART II \n \n3[DIRECTORATES-GENERAL] \n \n4[228. The Directorate General of 5[ ] Internal Audit. — (1) The Directorate \nGeneral of 6[  ]  Internal Audit shall consist of a Director-General and as many \nDirectors, Additional Directors, Deputy Directors and Assistant Directors and such \nother officers as the Board, may by notification in the official Gazette, appoint. \n \n                                            \n(ii) \na person holding a Pakistan origin card or a national identity card for overseas \nPakistanis 2[or a non-resident Pakistani citizen holding international passport] who \nproduces a certificate from a scheduled bank for receipt of foreign exchange \nremitted from outside Pakistan through normal banking channels during a period of \nsixty days prior to the date of registering, recording or attesting transfer. \n1New section 227D inserted through Finance Act, 2009. \n2 Section 227BA inserted by the Finance Act, 2021. \n3 The heading “DIRECTORATE-GENERAL OF INTERNAL AUDIT” substituted by the Finance Act, 2013. \n4Section 228 substituted by the Finance Act, 2005. The substituted section 228 read as follows: \n“228. Appointment of Directorate-General of Inspection.- (1) The Federal Government shall \nappoint a Directorate-General of Inspection to exercise the powers and discharge the functions \nconferred on it under this Part. \n \n \n(2)  The Directorate-General shall consist of a Director-General and as many Directors, \nAdditional Directors, Deputy Directors, Assistant Directors, Extra-Assistant Directors and Inspectors, \nas the Director-General may consider necessary to be appointed from among the officers of the \nIncome Tax Group.” \n5The words “Inspection and” omitted by the Finance Act, 2007. \n6The words “Inspection and” omitted by the Finance Act, 2007. \n\n\f\nChapter XI – Administration______________________________ \n \n445 \n \n \n(2)  \nThe Board may, by notification in the official Gazette, specify the \nfunctions, jurisdiction and powers of the Directorate General of 1[  ] Internal Audit.] \n \n2[229. 3[Inland Revenue Service Academy].— (1) The 4[Inland Revenue Service \nAcademy] shall consist of a Director-General, Additional Director-General and as \nmany Directors, Additional Directors, Deputy Directors, Assistant Directors and \nsuch officers as the Board, may, by notification in the official Gazette, appoint. \n \n \n(2)  \nThe Board may, by notification in the official Gazette, specify the \nfunctions, jurisdiction and powers of the 5[Inland Revenue Service Academy] and \nits officers.] \n \n6[230. Directorate General (Intelligence and Investigation), Inland Revenue.—(1) \nThe Directorate General (Intelligence and Investigation) Inland Revenue shall \nconsist of a Director General and as many Directors, Additional Directors, Deputy \nDirectors and Assistant Directors and such other officers as the Board, may by \nnotification in the official Gazette, appoint. \n \n \n(2) \nThe Board may, by notification in the official Gazette,— \n \n(a) \nspecify the functions and jurisdiction of the Directorate General \nand its officers; and \n \n(b) \nconfer the powers of authorities specified in section 207 upon \nthe Directorate General and its officers.] \n \n                                            \n1The words “Inspection and” omitted by the Finance Act, 2007. \n2 Added by the Finance Act, 2010.  Earlier  section 229 was omitted by the Finance Act, 2005. Which \nread as follows:-  \n“229. Inspection authorities.- (1) There shall be the following classes of inspection authorities for \nthe purposes of this Ordinance, namely:- \n \n \n(a) The Director-General of Inspection; and \n(b) Directors of Inspection. \n(2) The Directors of Inspection shall be subordinate to the Director-General of Inspection.” \n3 The words “Directorate General of Training and Research” substituted by the Finance Act, 2022. \n4 The words “Directorate General of Training and Research” substituted by the Finance Act, 2022. \n5 The words “Directorate General of Training and Research” substituted by the Finance Act, 2022. \n6Inserted by the Finance Act, 2012. Earlier it was omitted by the Finance Act, 2005, which read as \nfollows:-  \n“230. Jurisdiction of Inspection Authorities.- (1)  Subject to the provisions of this Chapter,  the \nDirectors of Inspection shall perform their functions in respect of such persons or classes of persons \nor such areas as may be assigned to them by the Director-General. \n(2) The Director-General or a Director of Inspection may assign any function in respect of any \narea, or office or offices located within an area, case, class of cases, person or classes of persons \nto any inspection officer working under his control. \n(3)  In this section, “inspection officer” means an Additional Director of Inspection, a Deputy \nDirector of Inspection, an Assistant Director and an Extra-Assistant Director.” \n\n\f\nChapter XI – Administration______________________________ \n \n446 \n \n1[PART III \n \n2[DIRECTORATES-GENERAL] \n230A. Directorate-General of Withholding Taxes.— (1) The Directorate-General of \nWithholding Taxes shall consist of a Director General and as many Directors, \nAdditional Directors, Deputy Directors and Assistant Directors and such other \nofficers as the Board, may by notification in the official Gazette, appoint. \n \n \n(2) \nThe Board may, by notification in the official Gazette, specify the \nfunctions, jurisdiction and powers of the Directorate-General of Withholding Taxes.] \n \n3[230B. Directorate-General of Law.— The Directorate-General of Law shall \nconsist of a Director General and as many Directors, Additional Directors, Deputy \nDirectors, Assistant Directors, Law Officers and such other officers as the Board \nmay, by notification in the official Gazette, appoint. \n \n \n(2)  \nThe Board may, by notification in the official Gazette, specify the \nfunctions, jurisdiction and powers of the Directorate-General of Law.] \n \n4[230C. Directorate-General of Research and Development.— (1) The \nDirectorate-General of Research and Development shall consist of a Director \nGeneral and as many Directors, Additional Directors, Deputy Directors, Assistant \nDirectors and such other officers as the Board may, by notification in the official \nGazette, appoint. \n \n \n(2)  \nThe Board may, by notification in the official Gazette, specify the \nfunctions, jurisdiction and powers of the Directorate-General of Research and \nDevelopment.] \n \n5[230D. Directorate-General of Broadening of Tax Base.— (1) The Directorate-\nGeneral of Broadening of Tax Base shall consist of a Director-General and as \nmany Directors, Additional Directors, Deputy Directors, Assistant Directors and \nsuch other officers as the Board may, by notification in the official Gazette, appoint. \n \n \n(2) \nThe Board may, by notification in the official Gazette, specify the \nfunctions, jurisdiction and powers of the Directorate-General of Broadening of Tax \nBase.] \n \n                                            \n1Added by the Finance Act, 2008. \n2The heading “DIRECTORATE-GENERAL OF WITHHOLDING TAXES” substituted by the Finance \nAct, 2013. \n3Added by the Finance Act, 2013. \n4 Added by the Finance Act, 2013. \n5Inserted by the Finance Act, 2017. \n\n\f\nChapter XI – Administration______________________________ \n \n447 \n \n1[230E Directorate General of International 2[Tax] Operations.—(l) The \nDirectorate General of international Tax Operations shall consist of a Director \nGeneral and as many Directors, Additional Directors, Deputy Directors, Assistant \nDirectors and such other officers as the Board may, by notification in the official \nGazette, appoint.  \n \n(2) \nThe Board may, by notification in the official Gazette,  \n \n(a) specify the functions and jurisdiction of the Directorate General \nand its officers; and  \n(b) confer the powers of authorities specified in section 207 upon the \nDirectorate General and its officers.  \n \n(3) The functions and powers of the Directorate General of International Tax \nOperations shall include but not limited to- \n \n(a)  receive and send information from other jurisdictions under \nspontaneous, automatic and on demand exchange of information \nunder exchange of information agreements;  \n \n(b)  levy and recover tax by passing an assessment order under \nsection I23(1A) in case of undeclared off-shore assets and \nincomes;  \n \n(c)  receive, transmit and exchange country reports to the jurisdictions \nthat are parties to international by country agreements with \nPakistan; and   \n \n(d)  conduct transfer pricing audit in cases selected for such audit by \nthe Director General of international Tax Operations.  \n \n(4) The Board may, by notification in the official Gazette, specify the criteria \nfor selection of the taxpayer for transfer pricing audit.  \n \n                                            \n1[230E. Directorate-General of Transfer Pricing.— (1) The Directorate-General of Transfer Pricing \nshall consist of a Director-General and as many Directors, Additional Directors, Deputy Directors, \nAssistant Directors and such other officers as the Board may, by notification in the official Gazette, \nappoint. \n \n(2) \nThe functions of the Directorate General of Transfer Pricing shall be to conduct transfer \npricing audit. \nExplanation: For the removal of doubt, it is clarified that transfer pricing audit refers to \nthe audit for determination of transfer price at arm's length in transactions between associates \nand is independent of audit under section 177, 214C or 214D which is audit of the income tax \naffairs of the taxpayer. \n \n(3) \nThe Board may, by notification in the official Gazette, specify the criteria for selection of \nthe taxpayer for transfer pricing audit and may further specify functions, jurisdiction and powers of the \nDirectorate-General of Transfer Pricing.] \n2 The word “Tar” substituted by the Finance Act, 2019. \n\n\f\nChapter XI – Administration______________________________ \n \n448 \n \nExplanation- For the removal of doubt, it is clarified that transfer pricing audit \nrefers to the audit for determination of transfer price at arm's length in \ntransactions between associates and is independent tax audit under section \n177 and 2l4C which is audit of the income tax affairs of the taxpayer. \n \n \n1[(5) \nTransfer pricing audit of cases selected under clause (d) of sub-\nsection (3) shall be conducted as per procedure given in section 177 and all the \nprovisions of the Ordinance, except the first proviso to sub-section (1), sub-section \n(6A), (10) and (14) of section 177, shall apply accordingly. \n \n \n (6) \nNothing contained in this section shall prevent the Commissioner from \ndetermination of transfer price at arm’s length in transactions between associates \nwhile conducting audit of income tax affairs of a taxpayer under section 177 or \n214C or during proceedings under section 122.]  \n \n2[230F. Directorate  General  of  Immovable  Property.—(1)  The Directorate-\nGeneral of Immovable Property, (hereinafter referred to as Directorate-General in \nthis section, shall consist of a Director General and as many Directors,  Additional \nDirectors, Deputy Directors and Assistant Directors and such other officers as the \nBoard may, by notification in the official Gazette, appoint. \n \n(2) \nThe Board may, by notification in the official Gazette, specify the \nfunctions and jurisdiction of the Directorate-General and its officers. \n \n(3) \nThe Directorate-General may, subject to the provisions and conditions \nas may be prescribed, initiate proceedings for the acquisition of property for the \nreasons and purposes specified in sub-section (4). \n \n(4) \nThe proceedings under sub-section (3) shall be initiated, where the \nDirectorate-General, on the basis of valuation made by it,   has reason to believe  \nthat any immovable property of a fair market value has been transferred by a  \nperson, hereinafter referred to as the transferor, to another person, hereinafter \nreferred to as the transferee, for a consideration which is less than the fair  market \nvalue of the immovable property and that the consideration for such transfer as \n                                            \n1 New sub-sections (5) & (6) inserted through Tax Law (Second Amendment) 2019, dated 26th \nDecember, 2019 \n2Inserted by the Finance Act, 2018. \n \n\n\f\nChapter XI – Administration______________________________ \n \n449 \n \nagreed to between the transferor and transferee has been  understated in  the  \ninstrument  of transfer for the purposes of ─ \n \n(a) \nthe avoidance or reduction of withholding tax obligations under \nthis Ordinance; \n \n(b) \nconcealment of unexplained amount referred to in sub- section   \n(1) of section 111 representing investment in immovable \nproperty; or \n \n(c) \navoidance or reduction of capital gains tax under section 37. \n \n(5) \nThe Directorate-General may appoint any valuer or expert as it \nconsiders necessary for the purposes of determination of valuation including fair \nmarket value of immovable property. \n \n(6) \nThe mode and manner of appointment of a valuer or expert shall be \nas may be prescribed. \n \n \n(7)  The valuation made under sub-section (4) and reasons that \nconsideration is less than the fair market value shall be recorded in writing. \n \n(8) \nNo proceedings shall be initiated in respect of any immovable property \nafter expiration of a period of six months from the end of the month in  which the \ninstrument of transfer in respect of such property is registered, recorded or \nattested. \n \n(9) \nThe mode and manner of initiation of proceedings and acquisition of  \nimmovable property under this section shall be as may be prescribed:  \n \nProvided that the proceedings shall not be initiated unless the  \ntransferee is provided with an opportunity of being heard and where the  \nobjection by the transferee, if any, is rejected by the Directorate-General,   it \nshall record in writing the reasons for rejection through an order. \n \n(10) If the Directorate-General is satisfied with the objections or reasons \nfurnished by the transferee or the transferor, it shall, by order in writing, declare \nthat the property shall not be acquired under this section. \n \n(11) If after hearing the objections, if any, and after taking into account all \nthe relevant material on record, the Directorate-General is satisfied that the fair \nmarket value of such property exceeds the consideration by more than fifty per  \ncent of such consideration and that transfer as agreed to between the transferor \nand the transferee has not been truly stated in the instrument of transfer it may, \n\n\f\nChapter XI – Administration______________________________ \n \n450 \n \nafter obtaining approval of the Board, make an order for acquisition of the \nimmovable property under this section. \n \n(12) The transferee may prefer express appeal to the Appellate Tribunal of \nImmovable Property against the order of acquisition of any immovable property \nunder sub-section (11) within sixty days of service of a copy of such order. \n \n(13) There shall be established an Appellate Tribunal of Immovable \nProperty to exercise the powers conferred on the Tribunal under this section. \n \n(14) The appointment of members of the Tribunal, powers, functions, \nconstitution of the Tribunal and mode and manner of disposal of appeals shall be \nas may be prescribed. \n \n(15) The Appellate Tribunal may, after giving the appellant and the \nDirectorate-General an opportunity of being heard, pass such order as it thinks fit. \n(16) The transferee or the Directorate-General aggrieved by any order of \nthe Tribunal may, within sixty days of the date on which the order under sub-section \n(15) is served, prefer an appeal against such order to the High Court. \n \n(17) As soon as may be after the order for acquisition of immovable \nproperty made under sub-section (11) becomes final, the Directorate-General \nmay, by notice in writing, order the transferee or any other person who  may  be  \nin  possession  of  the  immovable  property  to  surrender  or deliver possession \nthereof to the Directorate-General within thirty days of the date of the service of \nthe notice. \n \n(18) The order referred to in sub-section (11) becomes final if either no \nappeal has been there against filed or on appeal filed before the Tribunal, the order \nis confirmed and no appeal is filed before the High Court or on appeal filed before \nthe High Court the order is confirmed. \n \n(19) Notwithstanding anything contained in any law or any agreement for  \nthe time being in force, where order referred to in sub-section (11) becomes final, \nthe immovable property and all rights including ownership rights thereof shall be  \nvested in the Federal Government and shall be treated to be in the same position \nin relation to such rights as the person in whom such rights would have continued \nto vest if such order had not become final. \n \n(20) Where any immovable property is acquired under this section, the \nBoard shall make the payment of consideration for acquisition to the person or \n\n\f\nChapter XI – Administration______________________________ \n \n451 \n \npersons entitled thereto, as soon as may be, after the property becomes vested in \nthe Federal Government. \n \n(21) Notwithstanding the provisions of section 68, for the purpose of this \nsection,— \n \n(a) \n“consideration for acquisition” means a sum equal to the aggregate of \nthe amount of the consideration for the transfer of immovable   \nproperty and hundred per cent of such consideration; \n \n(b) \n“fair market value” in relation to an immovable property means the \nprice that the immovable property would ordinarily fetch on sale in  the \nopen market on the date of execution of the instrument of transfer of \nsuch property; \n \n(c) \n\"immovable property\" means any land with or without a superstructure \nor any building or part of a building or any rights therein and includes, \nwhere any land or any building or part of a  building is transferred  \nalong  with  any  machinery, plant, equipment, furniture and fittings; \nand \n \n(d) \n\"transfer\" in relation to any immovable property means transfer of  \nsuch property by way of sale or exchange or lease for a term of not \nless than ten years. \n \n(22) The provisions of this section shall come into force on such date as \nthe Federal Government may, by notification in official Gazette, appoint. \n \n1[  ]  \n \n2[230G. Directorate General of Special Initiative.- (1) The Directorate General \nof Special Initiative shall consist of a Director General and as many Directors, \nAdditional Directors, Deputy Directors, Assistant Directors and such other officers \nas the Board may, by notification in the official Gazette, appoint. \n \n(2) The Board may, by notification in the official Gazette,-  \n \n                                            \n1In section 230F, sub-section (23) omitted through Finance Act 2019, omitted sub-section read as \nfollows: \n(23) \nFrom  the  date  of  appointment  as  mentioned  in  sub-section  (22), rates mentioned in column \n(3) of the Table in Division XVIII shall be 1% and  provisions  of  clause  (c)  of  sub-section  (4)  of  \nsection  111,  section 236C, section 236W and Division X of Part IV of the First Schedule shall not \napply. \n \n2New section (230G) & (230H) inserted through Finance Act, 2019.   \n\n\f\nChapter XI – Administration______________________________ \n \n452 \n \n(a) specify the functions, jurisdiction and powers of the Directorate General \nof Special Initiative and its officers; and  \n(b) confer the powers of authorities specified in section 207 upon the \nDirectorate General and its officers.   \n   \n230H. Directorate General of Valuation.- (1) The Directorate General of \nValuation shall consist of a Director General and as many Directors, Additional \nDirectors, Deputy Directors, Assistant Directors and such other officers as the \nBoard may, by notification in the official Gazette, appoint. \n \n(2) The Board may, by notification in the official Gazette,-  \n \n(a) specify the functions, jurisdiction and powers of the Directorate General \nof Valuation and its officers; and  \n \n(b) confer the powers authorities specified in section 207 upon the \nDirectorate General and its officers.] \n \n1[230I. Directorate General of Compliance Risk Management.— (1) The \nDirectorate General of Compliance Risk Management shall consist of a Director \nGeneral and as many Directors, Additional Directors, Deputy Directors, Assistant \nDirectors and such other officers as the Board may, by notification in the official \nGazette, appoint.   \n  \n(2)  \nThe Board may, by notification in the official Gazette —  \n  \n(a) specify the functions, jurisdiction and powers of the Directorate General \nof Compliance Risk Management and its officers; and   \n  \n(b) confer the powers of authorities specified in section 207 upon the \nDirectorate General and its officers.] \n \n2[230J. International Centre of Tax Excellence. – (1) There shall be established \nan Institute to be known as International Centre of Tax Excellence.  \n \n(2) \nThe functions of the Institute shall be to help contribute to the \ndevelopment of tax policy, prepare model national tax policy, deliver inter-\ndisciplinary research in tax administration and policy, international tax cooperation, \nrevenue forecasting, conduct international seminars, workshops and conferences \non the current issues faced by tax authorities in the field of international taxation, \ncapacity building of Inland Revenue Officers, tax analysis, improve the design and \ndelivery of tax administration for maximising revenue within existing provisions to \n                                            \n1 Section 230I inserted by the Finance Act, 2021. \n2  Section 230J inserted by the Finance Act 2023. \n\n\f\nChapter XI – Administration______________________________ \n \n453 \n \nclose the tax gap or any other function as directed by the Board or the Federal \nGovernment.  \n \n(3)  \nThere shall be a Nominating Committee comprising the Minister-in-\nCharge, Secretary Revenue Division and Secretary Finance which shall be \nresponsible for recommending a panel to the Federal Government for the \nappointment of an Executive Director and independent members of the Executive \nCommittee.  \n \n(4)  \nThere shall an Executive Committee comprising Chairman, Federal \nBoard of Revenue, Member (IR-Policy), Member (IR-Operations) and two \nindependent members to be appointed by the Federal Government. Executive \nDirector shall act as Secretary of the Executive Committee.  \n \n(5)  \nThe Nominating Committee shall apply the prescribed criteria for \nmaking recommendations of the panel for Executive Director and independent \nmembers of the Executive Committee.  \n \n(6)  \nExecutive Director and independent members of the Executive \nCommittee shall be appointed by the Federal Government.  \n \n(7)  \nExecutive Director shall also be the Chief Executive of the Institute \nand shall work to ensure efficient functioning and day to day administrative \nfunctions of the Institute and shall be independent in the discharge of its functions \nspecified under sub-section (8).  \n \n(8)  \nExecutive Committee, for every fiscal year, shall assign the \nrequirements of the Board to be undertaken by the Institute, during the year.  \n \n(9)  \nThe Executive Committee shall prescribe rules for recruitment of the \nemployees of the Institute and Executive Director shall act in accordance with the \nrules. At least fifty per cent of the employees shall be serving Inland Revenue \nofficers having at least 5 years of experience of tax policy or tax administration.  \n \n(10)  The remuneration and term of employment of the employees of the \nInstitute shall be as prescribed by the Federal Government.  \n \n(11)  The Board may establish a committee to monitor the establishment of \nthe Institute including appointment of the Project Director for the purpose.  \n \n(12)  The Board may, provide such data to the Institute as is necessary for \nprocessing and analysis and for discharging its obligations under sub-section (8):  \n \nProvided that such data shall be anonymized before transmission to \nthe Institute and identifying particulars of the taxpayers shall be kept \n\n\f\nChapter XI – Administration______________________________ \n \n454 \n \nconfidential and provisions of sub-section (7) of section 216 shall apply \naccordingly.  \n \n(13) The Executive Committee may by notification in the official gazette \nmake rules for carrying out the purposes of this section.] \n \n1[230K. Tax Fraud Investigation Wing Inland Revenue. – (1) There shall be \nestablished a wing to be known as Tax Fraud Investigation Wing Inland Revenue.  \n \n(2) \nThe functions of the Tax Fraud Investigation Wing Inland Revenue \nshall be to detect, analyze, investigate, combat and prevent tax evasion and fraud.  \n \n(3) \nThe Tax Fraud Investigation Wing Inland Revenue shall comprise \nFraud Intelligence and Analysis Unit, Fraud Investigation Unit, Legal Unit, \nAccountants Unit, Digital Forensic and Scene of Crime Unit, Administrative Unit or \nany other Unit as may be approved by the Board or the Federal Government.  \n \n(4) \nThe Tax Fraud Investigation Wing Inland Revenue shall consist of a \nChief Investigator and as many following officers, as may be notified by the Board \n–  \n \n(a) \nSenior Investigators, Investigators, Junior Investigators or any \nother officer of Inland Revenue with any other designation;  \n \n(b) \na Senior Forensic Analyst and as many Forensic Analysts and \nJunior Forensic Analysts; and  \n \n(c) \na Senior Data Analyst and as many Data Analysts and Junior \nData Analysts.  \n(5) \nThe Board may, by notification in the official Gazette, -  \n \n(a) \n specify the functions and jurisdiction of the Tax Fraud \nInvestigation Wing Inland Revenue and its officers; and  \n \n(b) \nconfer the powers of authorities specified in section 207 upon \nthe Tax Fraud Investigation Wing Inland Revenue and its \nofficers in clause (a) of sub-section 4. \n  \n(6) \nNothing contained in this section shall prevent the authorities \nappointed under sections 207 and 208 or any other authority or officer conferred \nwith the power of authorities under sections 207 and 208 from conducting \nprosecution Part XI of Chapter X of the Ordinance.] \n                                            \n1  Section 230K inserted by the Finance Act 2024. \n\n\f\nChapter XI – Administration______________________________ \n \n455 \n \n1[  ] \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n                                            \n1 Section 231 omitted by the Finance Act, 2005. The omitted section 231 read as follows: \n“231. Functions and Powers of Directorate.- (1)  The functions of the Directorate-General of \nInspection shall be, namely:- \n(a) To carry out inspections of income tax cases and offices; \n(b) to investigate or cause investigation to be carried out in respect of – \n(i) cases involving leakage of revenue or evasion of taxes; and \n(ii) Regional Commissioners of Income Tax, Commissioners of Income Tax, taxation \nofficers and any other staff of income tax offices allegedly involved in corruption and \nmalpractice, and recommend to the competent authority appropriate disciplinary action; \n(c) to carry out audit of cases or offices involving income tax revenues; \n(d) to recommend to the Central Board of Revenue in matters of tax policy, tax administration \nand tax operations; \n(e) to furnish an annual report about the workings of Income Tax Offices to the Central Board \nof Revenue by the thirty-first day of December, following the end of the financial year to \nwhich it relates; and \n(f) \nto carry out any other work or function that may be assigned to it by the Federal \nGovernment. \n (2) \nIn discharge of its functions under sub-section (1), the Directorate-General shall have \nthe powers specified in section 176.” \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n456 \nCHAPTER XII \n \nTRANSITIONAL ADVANCE TAX PROVISIONS \n \n1[  ] \n2[  ]  \n3[   ]  \n4[   ]  \n5[   ]  \n6[   ] \n \n7[231AB. Advance tax on cash withdrawal. — (1) Every banking company shall \ndeduct advance adjustable tax at the rate of 8[0.8%] of the cash withdrawal from a \n                                            \n1Inserted by the Finance Act, 2005. \n2 Section 231A omitted by the Finance Act, 2021. The omitted section read as follows: \n“231A. Cash withdrawal from a bank.—2[(1) Every banking company shall deduct tax at the rate \nspecified in Division VI of Part IV of the First Schedule, if the payment for cash withdrawal, or the \nsum total of the payments for cash withdrawal in a day, exceeds 2[fifty] thousand rupees.]  \n2[“Explanation.- For removal of doubt, it is clarified that the said fifty thousand rupees \nshall be aggregate withdrawals from all the bank accounts in a single day.” \n3 Sub-section (2) omitted by Finance Act, 2015. The omitted sub-section (2) read as follows:-  \n“(2)  \nAdvance tax under this section shall not be collected in the case of withdrawals made by,-  \n \n \n(a)  \nthe Federal Government or a Provincial Government; \n \n \n(b)  \na foreign diplomat or a diplomatic mission in Pakistan; or \n(c)  \na person who produces a certificate from the Commissioner that his income \nduring the tax year is exempt.” \n4Added by the Finance Act, 2010. \n5 Section 231AA omitted by the Finance Act, 2021. The omitted section read as follows: \n“231AA. Advance tax on transactions in bank.— (1) Every banking company, non-banking financial \ninstitution, exchange company or any authorized dealer of foreign exchange shall collect advance tax \nat the time of sale against cash of any instrument, including Demand Draft, Pay Order, CDR, STDR, \nSDR, RTC, or any other instrument of bearer nature or on receipt of cash on cancellation of any of \nthese instruments5[“.”]  \n5[    ] \n(2) \nEvery banking company, non-banking financial institution, exchange company or any \nauthorized dealer of foreign exchange shall collect advance tax at the time of transfer of any sum \nagainst cash through online transfer, telegraphic transfer, mail transfer or any other mode of electronic \ntransfer. \n(3) \nThe advance tax under this section shall be collected at the rate specified in Division \nVIA of Part IV of the First Schedule, where the sum total of payments for transactions mentioned in \nsub-section (1) or sub-section (2) as the case may be, exceed twenty-five thousand rupees in a day. \n6 Sub-section (4) omitted by Finance Act, 2015.  Omitted sub-section (4) read as follows:-     \n“(4) \nAdvance tax under this section shall not be collected in the case of transactions made by,— \n \n(a) \nthe Federal Government or a Provincial Government; \n \n(b) \na foreign diplomat or a diplomatic mission in Pakistan; or  \n \n(c) \na person who produces a certificate from the Commissioner that its income during the \ntax year is exempt.] \n7 Section 231AB inserted by the Finance Act, 2023. \n8 The expression “0.6%” substituted by the Finance Act 2025. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n457 \n \nperson whose name is not appearing in the active taxpayers’ list on the sum total \nof the payments for cash withdrawal in a day, exceeding fifty thousand rupees.  \n \nExplanation. – For removal of doubt, it is clarified that the said fifty thousand \nrupees shall be aggregate cash withdrawals in a single day.] \n \n1[231B. Advance tax on 2[   ] motor vehicles.— (1) Every motor vehicle \nregistering authority of Excise and Taxation Department shall collect advance tax \nat the time of registration of a motor vehicle, at the rates specified in Division VII \nof Part IV of the First Schedule 3[:] \n \n4[Provided that no collection of advance tax under this sub-\nsection shall be made after five years from the date of first registration \nas specified in clauses (a), (b) and (c) of sub-section (6).] \n \n5[6[(1A) Every leasing company or a scheduled bank or a non-banking financial \ninstitution or an investment bank or a modaraba or a development finance institution, \nwhether shariah compliant or under conventional mode, at the time of leasing of a \nmotor vehicle to a 7[“person whose name is not appearing in the active taxpayers’ list”], \neither through ijara or otherwise, shall collect advance tax at the rate of four per cent \nof the value of the motor vehicle. ]  \n \n(2) \nEvery motor vehicle registering authority of Excise and Taxation \nDepartment shall collect advance tax at the time of transfer of registration or \nownership of a 8[   ] motor vehicle, at the rates specified in Division VII of Part IV \nof the First Schedule:  \n \n                                            \n1 Section 231B substituted by the Finance Act, 2014. The substituted section 231B read as follows: \n \n1[231B. Advance tax on private motor vehicles.— Every motor vehicle registering authority of Excise \nand Taxation Department shall collect advance tax at the time of registration of a new locally manufactured motor \nvehicle, at the rates specified in Division VII of Part IV of the First Schedule: \nProvided that the provisions of this section shall not be applicable in the case of –  \n \n \n(a)  \nthe Federal Government; \n \n \n(b)  \nthe Provincial Government; \n \n \n(c)  \nthe Local Government; \n \n \n(d)  \na foreign diplomat; or \n \n \n(e)  \na diplomatic mission in Pakistan.” \n2 The word “private” omitted by the Finance Act, 2022. \n3 Full-stop substituted by the Finance Act 2016. \n4 Added by the Finance Act, 2016. \n5Added by the Finance Act, 2016. \n6Sub-section (1A) substituted by the Finance Act, 2017. The substituted sub-section (1A) read as \nfollows: \n“ (1A)  Every leasing company or a scheduled bank or an investment bank or a development \nfinance institution or a modaraba shall, at the time of leasing of a motor vehicle to a non-filer, collect \nadvance tax at the rate of three per cent of the value of the motor vehicle.” \n7  The word “non-filer” substituted though Finance Act, 2019.  \n8The word “private” omitted by the Finance Act, 2022. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n458 \n \nProvided that no collection of advance tax under this sub-\nsection shall be made on transfer of vehicle after five year from the \ndate of first registration in Pakistan.  \n \n1[(2A) Every motor vehicle registration authority of Excise and Taxation \nDepartment shall, at the time of registration, collect tax at the rates specified in \nDivision VII of Part IV of the First Schedule, if the locally manufactured motor \nvehicle has been sold prior to registration by the person who originally purchased \nit from the local manufacturer.] \n \n(3) \nEvery manufacturer of a motor 2[“vehicle”]shall collect, at the time of \nsale of a motor car or jeep, advance tax at the rate specified in Division VII of Part \nIV of the First Schedule from the person to whom such sale is made. \n \n(4) \nSub-section (1) shall not apply if a person produces evidence that tax \nunder sub-section (3) in case of a locally manufactured vehicle or tax under section \n148 in the case of imported vehicle was collected from the same person in respect \nof the same vehicle. \n(5)  \nThe advance tax collected under this section shall be adjustable: \n \nProvided that the provisions of this section shall not be applicable in \nthe case of –  \n \n(a) \nthe Federal Government;  \n(b) \na Provincial Government;  \n(c) \na Local Government;  \n(d) \na foreign diplomat; or  \n(e) \na diplomatic mission in Pakistan.] \n \n3[(6) For the purposes of this section the expression “date of first registration” \nmeans— \n \n(a) the date of issuance of broad arrow number in case a vehicle is \nacquired from the Armed Forces of Pakistan; \n \n(b) the date of registration by the Ministry of Foreign Affairs in case the \nvehicle is acquired from a foreign diplomat or a diplomatic mission in \nPakistan; \n \n(c) \nthe last day of the year of manufacture in case of acquisition of an \nunregistered vehicle from the Federal or a Provincial Government; \nand  \n \n                                            \n1  Sub-section (2A) inserted by the Finance Act, 2021. Earlier sub-section (2A) was inserted through \nTax Laws (Amendment) Ordinance, 2021. \n2  The word “car or jeep” substituted by the Finance Act, 2015. \n3 Added by the Finance Act, 2015. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n459 \n \n(d) in all other cases the date of first registration by the Excise and \nTaxation Department. \n \n1[(7) For the purpose of this section, motor vehicle includes car, caravan \nautomobiles, jeep, limousine, pickup, sports utility vehicle, trucks, vans, wagon and \nany other automobile excluding– \n \n(i) \na motor vehicle used for public transportation, carriage of goods and \nagriculture machinery; \n \n(ii) \na rickshaw or a motorcycle rickshaw and  \n \n(iii) any other motor vehicle having engine capacity upto 200cc.] \n \n2[231C. Advance tax on foreign domestic workers. – (1) Any authority issuing \nor renewing domestic aide visa to any foreign national as a domestic worker at the \ntime of issuing or renewing such visa shall collect from the agency, sponsor or the \nperson as the case may be, employing the services of such foreign national a tax \nof two hundred thousand rupees.  \n \n(2)  \nThe tax collected or collectible under this section shall be adjustable \nadvance tax for the tax year to which it relates on the income of such agency, \nsponsor or a person, as the case may be, employing the services of such foreign \nnational.] \n \n3[   ] \n                                            \n1 Sub-section (7) substituted by the Finance Act, 2022. The substituted sub-section read as follows: \n“(7) For the purpose of this section “motor vehicle” includes car, jeep, van, sports utility \nvehicle, pick-up trucks for private use, caravan automobile, limousine, wagon and any other \nautomobile used for private purpose. \n1[Explanation.--- For the removal of doubt, it is clarified that a motor vehicle does not include \na rickshaw, motorcycle-rickshaw and any other motor vehicle having engine capacity upto \n200cc.”  \n2 Section 231C inserted by the Finance Act, 2023. \n3 Omitted by the Finance Act, 2002. The omitted section 232 read as follows: \n“232. Transfer of funds. - (1) Advance tax at the rate specified in Part-IV of the First Schedule shall \nbe collected by a person — \n(a) \nclearing an outstation cheque of an amount excluding twenty-five thousand rupees; \n(b)  \nissuing a demand draft, pay order, special deposit receipts, cash deposit receipt or rupee \ntraveller’s cheque; and \n(c)  \neffecting a telegraphic or electronic transfer of funds, from the drawer of such cheque, \ndraft, pay order, receipt or person ordering transfer of funds. \n  \n(2) \nAdvance tax under sub-section (1) shall not be collected in the case of payments made \nby — \n(a) \n    Federal Government, Provincial Governments, statutory bodies and universities; \n(b)  \n    a non-profit organization within the meaning of clause (37) of section 2; \n(c)      an industrial undertaking or institution exempt from tax under the Second Schedule; \n(d)      a public company whose shares are traded on a registered stock exchange in Pakistan; \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n460 \n \n1[233. Brokerage and commission. — (1) Where any payment on account of \nbrokerage or commission is made by the Federal Government, a Provincial \nGovernment, a 2[Local Government], a company or an 3[association of person or \nindividual having turnover of hundred million rupees or more] (hereinafter called \nthe “principal”) to a 4[ ] person (hereinafter called the “agent”), the principal shall \ndeduct advance tax at the rate specified in 5[Division II of] Part IV of the First \nSchedule from such payment. \n \n \n(2)  \nIf the agent retains Commission or brokerage from any amount \nremitted by him to the principal, he shall be deemed to have been paid the \ncommission or brokerage by the principal and the principal shall collect advance \ntax from the agent. \n \n6[(2A) Notwithstanding the provisions of sub-section (1), where the principal \nis making payment on account of commission to an advertising agent, directly or \nthrough electronic or print media, the principal shall deduct tax (in addition to tax \nrequired to be deducted under clause (b) of sub-section (1) of section 153 on \nadvertising services excluding commission), at the rate specified in Division II of \nPart IV of the First Schedule on the amount equal to-   \n \nA x 15 \n85 \n \n                                            \n(e)     a foreign diplomat or a foreign diplomatic mission in Pakistan; \n(f)      a branch or office of a company to another branch or office of such company; \n(g)     a person who holds National Tax Number and furnishes a statement to that bank in the \nprescribed form and manner.” \n1 Section 233 substituted by the Finance Act, 2005. The substituted section 233 read as follows:  \n“233. Brokerage and Commission.- (1) Where any payment on account of brokerage or \ncommission is made by the Federal Government, a Provincial Government, a local authority, a \ncompany or an association of persons constituted by, or under, any law (hereinafter called the \n“principal”) to any person B[other than travel agents and insurance agents] (hereinafter called the \n“agent”), the principal shall deduct advance tax at the rate specified in Part IV of the First Schedule \nfrom such payment. \n(2) \nIf the agent retains commission or brokerage from any amount remitted by him to the \nprincipal, he shall be deemed to have been paid the commission or brokerage by the principal and \nthe principal shall collect advance tax from the agent. \n (3)  \nWhere any payment on account of brokerage or commission is made by the principal \nto a travel agent or an insurance agent, the principal shall deduct advance tax at the rate specified \nin Part IV of the First Schedule from such payment. \n (4)  Where any tax is collected from a person under sub-section (1) or sub-section (3), the tax so \ncollected shall be the final tax on the income of such persons.” \n2The words “local authority” substituted by the Finance Act, 2008. \n3 The expression “association of persons constituted by, or under any law” substituted by the Finance \nAct, 2021. \n4The word “resident” omitted by the Finance Act, 2006. \n5Inserted by the Finance Act, 2010. \n6Inserted by the Finance Act, 2017. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n461 \n \nWhere A = amount paid or to be paid to electronic or print media for \nadvertising services (excluding commission) on which tax is \ndeductible under clause (b) of sub-section (I) of section 153. \n \n(2B) Tax deducted under sub-section (2A) shall be 1[minimum] tax on the \nincome of the advertising agent.] \n \n \n(3)  \nWhere any tax is 2[required to be] collected from a person under sub-\nsection (1), 3[such tax] shall be the 4[minimum] tax on the income of such persons.] \n \n5[Explanation.— For the removal of doubt, it is explained that the income of \nperson referred to in sub-sections (2B) and (3) means the amount on which \ntax is deductible under sub-sections (1) or (2A) of this section.] \n \n6[   ]  \n \n7[     ] \n \n8[     ]  \n \n 9[     ] \n                                            \n1The word “final” substituted through Finance Act, 2019. \n2Inserted by the Finance Act, 2012. \n3The words “the tax so collected” substituted by the Finance Act, 2012. \n4The word “final” substituted through Finance Act, 2019. \n5 Explanation added by the Finance (Supplementary) Act, 2022 \n6Inserted by the Finance Act, 2004. \n7 Section 233A omitted by the Finance Act, 2021. The omitted section read as follows: \n“233A. Collection of tax by a stock exchange registered in Pakistan.— (1) A stock exchange \nregistered in Pakistan shall collect advance tax,— \n(a)  \nat the rates specified in Division IIA of Part IV of First Schedule from its Members \non purchase of shares in lieu of 7[tax on]  the commission earned by such \nMembers; 7[and] \n(b) \nat the rates specified in Division IIA of Part IV of First 7[Schedule] from its \nMembers on sale of shares in lieu of 7[tax on] the commission earned by such \nMembers7[.] \n7[  ] \n7[  ] \n7[7[(2) The tax collected under sub-section (1) shall be 7[adjustable].] \n7[(3) This section shall not apply from the first day of March. 2019.” \n \n8 Inserted by the Finance Act, 2012. \n9 Section 233AA omitted by the Finance Act, 2021. The omitted section read as follows: \n“233AA. Collection of tax by NCCPL.—NCCPL shall collect advance tax from the members of \nStock Exchange registered in Pakistan 9[, margin financiers, trading financiers and lenders],in \nrespect of margin financing in share business 9[or providing of any margin financing, margin trading \nor securities lending under Securities (Leveraged Markets and Pledging) Rules, 2011 in share \nbusiness] at the rate specified in Division 9[IIB] of Part IV of First Schedule9[:] ] \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n462 \n \n234. 1[Tax on motor vehicles].— (1) Any person 2[at the time of] collecting motor \nvehicle tax shall also collect advance tax at the rates specified in 3[Division III of] \nPart IV of the First Schedule.  \n \n \n(2) \nIf the motor vehicle tax is collected in instalments4[or lump sum] the \nadvance tax may also be collected in instalments 5[or lump sum] in like manner. \n \n \n6[(2A) \nIn respect of motor cars used for more than ten years in Pakistan, no \nadvance tax shall be collected after a period of ten years.] \n \n \n(3) \nIn respect of a passenger transport vehicle with registered seating \ncapacity of ten or more persons, advance tax shall not be collected after a period \nof ten years from the first day of July of the year of make of the vehicle. \n \n \n(4) \nIn respect of a goods transport vehicle with registered laden weight of \n7[  ] less than 8120 kilograms, advance tax shall not be collected after a period of \nten years from the date of first registration of vehicle in Pakistan. \n \n \n8[(5)  Advance tax collected under this section shall be adjustable.] \n9[“(6) For the purpose of sub-sections (1) and (2) “motor vehicle” shall \ninclude the vehicles specified in sub-section (7) of section 231B.”] \n \n \n10[   ] \n \n11[    ] \n                                            \n \n9[Provided that the provisions of this section shall not apply to any Mutual Fund \nspecified in sub-clause (2) of clause (57) of Part I of the Second Schedule.” \n1The words “Transport business” substituted by the Finance Act, 2008. \n2 Inserted by the Finance Act, 2002. \n3 Inserted by the Finance Act, 2013. \n4Comma substituted by the Finance Act, 2013. \n5 Inserted by the Finance Act, 2013. \n6 Inserted by the Finance Act, 2002. \n7 The words “2030 kilogram or more but” omitted by the Finance Act, 2003. \n8 Sub-section (5) substituted by the Finance Act, 2013. The substituted sub-section  (5) read as \nfollows: \n  \n“(5) \nWhere tax is collected from any person being the owner of goods transport vehicle, the \ntax so collected shall be the final tax on the income of such person from plying, or hiring out, of \nsuch vehicle.” \n9 Added by the Finance Act, 2015. \n10 Inserted by the Finance Act, 2007. \n11 Section 234A omitted by the Finance Act, 2021. The omitted section read as follows: \n   “234A CNG Stations.—(1) There shall be collected advance tax at the rate specified in Division VIB  \nof Part III of the First Schedule on the amount of gas bill of a Compressed Natural Gas station. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n463 \n \n1[ ] \n \n235. Electricity consumption.-  (1) There shall be collected advance tax at the \nrates specified in 2[Division IV of] Part-IV of the First Schedule on the amount of \nelectricity bill of a commercial or industrial 3[or domestic] consumer 4[: \n \n \nProvided that the provisions of sub-section (1) shall not apply to a domestic \nconsumer of electricity if his name appears on the Active Taxpayers’ List.] \n \n 5[  ] \n \n6[    ] \n \n(2) \nThe person preparing electricity consumption bill shall charge \nadvance tax under sub-section (1) in the manner electricity consumption charges \nare charged. \n \n7[Explanation.— For removal of doubt, it is clarified that for the purposes \nof this section electricity consumption bill referred to in sub-section (2) means \nelectricity bill inclusive of sales tax and all incidental charges.] \n \n \n(3) \nAdvance tax under this section shall not be collected from a person \nwho produces a certificate from the Commissioner that his income during tax year \n                                            \n(2) The person preparing gas consumption bill shall charge advance tax under sub-section  (1) \nin the manner gas consumption charges are charged. \n \n \n(3) The tax collected under this section11[and under section 235] shall be a 11[minimum] tax on \nthe income of a CNG station arising from the consumption of the gas referred to in sub-section (1). \n11[Explanation.— For removal of doubt, it is clarified that for the purposes of this section tax on \nincome arising from consumption of gas referred to in sub-section (3) means the tax collected under \nsub-section (1) which is inclusive of sales tax and all incidental charges.] \n1Sub-section (4) omitted by the Finance Act, 2017. The  omitted sub-section (4) is read as follows: \n “(4) \nThe taxpayers shall not be entitled to claim any adjustment of withholding tax collected \nor deducted under any other head, during the tax year.” \n2 Expression inserted through Finance Act, 2020 dated 30th June, 2020 \n3 Inserted by the Finance Act, 2021. \n4 Full stop substituted and proviso added by the Finance Act, 2021. \n5 Sub-section (1A) added by the Finance Act, 2022. \n6 Sub-section (1A) omitted and deemed to have been so omitted from the 1st day of July, 2022 by the \nTax Laws (Amendment) Act, 2023 (XVI of 2023) dated 20.04.2023. Earlier this sub-section was \nomitted through Tax Laws (Second Amendment) Ordinance, 2022 (VI of 2022) dated 22.08.2022. \nOmitted sub-section (1A) read as follows: \n“(1A) In addition to tax collectible under sub-section (1), there shall be collected tax at the rates given \nin the Division IV of Part IV of First Schedule from retailers and service providers as provided under \nsection 99A of the Ordinance: \nProvided that the tax shall not be collectible under this sub-section if the tax has been collected \nfrom the person under sub-section (9) of section 3 of the Sales Tax Act, 1990 as provided in the \ngeneral order issued under section 99A of the Ordinance.” \n7 Added by Finance Act 2017. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n464 \n \nis exempt from tax 1[or that he has discharged advance tax liability 2[under section \n147 or whose entire income is subject to final tax regime or minimum tax regime \nunder any provisions of this Ordinance other than this section]. ] \n \n3[(4) Under this section, — \n(a)  in the case of a taxpayer other than a company, tax collected upto \nbill amount of 4[three hundred and sixty thousand Rupees per \nannum]shall be treated as minimum tax on the income of such \npersons and no refund shall be allowed;  \n \n(b)  in the case of a taxpayer other than a company, tax collected on \nmonthly bill over and above thirty thousand rupees per month shall \nbe adjustable; and  \n \n5[(c)]  in the case of a company, tax collected shall be adjustable against \ntax liability.] \n \n6[   ]  \n7[   ] \n8[   ] \n                                            \n1Expression inserted through Finance Act, 2020 dated 30th June, 2020 \n2 The words “for the tax year” substituted by the Finance Act, 2021. \n3Sub-section (4) substituted by the Finance Act, 2009. The substituted sub-section (4) read as follows: \n“(4) The tax collected under this section up to bill amount of twenty thousand rupees per month \nshall be minimum tax on the income of a person (other than a company). There shall be no refund \nof the tax collected under this section, unless the tax so collected is in excess of the amount for \nwhich the taxpayer is chargeable under this Ordinance in the case of a company.” \n4The word “thirty thousand rupees per month” substituted by the Finance Act 2017. \n5Clause (d) re-numbered by the Finance Act 2017. \n6Sections 235A and 235B inserted by the Finance Act, 2014. \n7 Section 235A omitted by the Finance Act, 2021. The omitted section read as follows: \n“235A. Domestic electricity consumption.- (1) There shall be collected advance tax at the rates \nspecified in Division XIX of Part IV of the First Schedule on the amount of electricity bill of a domestic \nconsumer. \n7[Explanation.— For removal of doubt, it is clarified that for the purposes of this section, \nelectricity consumption bill referred to in sub-section (2) means electricity bill inclusive of sales tax and \nall incidental charges.] \n(2) \nThe person preparing electricity consumption bill shall charge advance tax under sub-\nsection (1) in the manner electricity consumption charges are charged. \n(3)  \nTax collected under this section shall be adjustable against tax liability. \n8Section 235B omitted through Finance Act, 2020 dated 30th June, 2020 the omitted section read as \nfollows: 235B. Tax on steel melters 8[and composite units].- (1) There shall be collected tax from \nevery steel melter, 8[and] composite steel units, registered for the purpose of Chapter XI of Sales Tax \nSpecial Procedure  Rules, 2007 at the rate of one rupee per unit of electricity consumed for the \nproduction of steel billets, ingots and mild steel (MS products) excluding stainless steel .  \n(2) \nThe person preparing electricity consumption bill shall charge and collect the tax under \nsub-section (1) in the manner electricity consumption charges are charged and collected. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n465 \n \n 236. Telephone 1[and internet] users.- (1) Advance tax at the rates specified in \n2[Division V] Part IV of the First Schedule shall be collected on the amount of – \n \n \n \n(a) \ntelephone bill of a subscriber; 3[ ]  \n \n \n(b)  \nprepaid cards for 4[  ] telephones 5[; 6[ ] ] \n \n(c) \nsale of units through any electronic medium or whatever form \n7[; and] \n \n8[“(d) \ninternet bill of a subscriber; and  \n \n(e) \nprepaid cards for internet.”] \n \n \n(2) \nThe person preparing the telephone9[or internet] bill shall charge \nadvance tax under sub-section (1) in the manner telephone10[or internet] charges \nare charged. \n \n \n(3)  \nThe person issuing or selling prepaid cards for 11[  ] telephones 12[or \ninternet] shall 13[collect] advance tax under sub-section (1) from the purchasers at \nthe time of issuance or sale of cards. \n \n \n14[(3A) The person issuing or selling units through any electronic medium or \nwhatever form shall collect advance tax under sub-section (1) from the purchaser \nat the time of issuance of sale of units.] \n \n                                            \n(3) \nThe tax collected under sub- section (1) shall be deemed to be the tax required to be \ndeducted under sub-section (1) of section 153, on the payment for local purchase of scrap. \n(4) \nTax collected under sub-section (1) shall be non-adjustable and credit of the same shall \nnot be allowed to any person.] \n \n1Inserted by the Finance Act, 2015. \n2 Inserted by the Finance Act, 2021. \n3The word “and” omitted by the Finance Act, 2010. \n4 The word “mobile“ omitted by the Finance Act, 2002. \n5Full stop substituted by the Finance Act, 2010. \n6The word “and” omitted by Finance Act, 2015. \n7 Substituted by the Finance Act, 2015 \n8Added by the Finance Act, 2015. \n9Inserted by the Finance Act, 2015. \n10Inserted by the Finance Act, 2015. \n11 The word “mobile” omitted by the Finance Act, 2002. \n12 Inserted by the Finance Act, 2015. \n13The word “called” substituted by the Finance Act, 2003. \n14Added by the Finance Act, 2010. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n466 \n \n \n(4) \nAdvance tax under this section shall not be collected from \nGovernment, a foreign diplomat, a diplomatic mission in Pakistan, or a person who \nproduces a certificate from the Commissioner that his income during the tax year \nis exempt from tax. \n \n1[236A.  Advance tax at the time of sale by auction.— (1) Any person making \nsale by public auction2[or auction by a tender], of any property or goods 3[(including \nproperty or goods confiscated or attached)] either belonging to or not belonging to \nthe Government, local Government, any authority, a company, a foreign \nassociation declared to be a company under sub-clause (vi) of clause (b) of sub-\nsection (2) of section 80, or a foreign contractor or a consultant or a consortium or \nCollector of Customs or Commissioner of 4[Inland Revenue] or any other authority, \nshall collect advance tax, computed on the basis of sale price of such property and \nat the rate specified in Division VIII of Part IV of the First Schedule, from the person \nto whom such property or goods are being sold. \n \n5[Explanation.--- For the removal of doubt it is clarified for the purpose of this \nsection that--- \n \n(a) the expression “sale by public auction or auction by a tender” \nincludes renewal of a license previously sold by public auction or \nauction by a tender; and  \n \n(b) where payment is received in instalments, advance tax is to be \ncollected with each instalment.] \n \n \n(2)  \nThe credit for the tax collected under sub-section (1) in that tax year \nshall, subject to the provisions of section 147, be given in computing the tax \npayable by the person purchasing such property in the relevant tax year or in the \ncase of a taxpayer to whom section 98B or section 145 applies, the tax year, in \nwhich the “said date” as referred to in that section, falls or whichever is later. \n \nExplanation.- For the purposes of this section, sale of any property includes \nthe awarding of any lease to any person, including a lease of the right to \ncollect tolls, fees or other levies, by whatever name called.] \n \n \n6[(3) Notwithstanding the provisions of sub-section (2), tax collected on a \nlease of the right to collect tolls shall be final tax.] \n \n                                            \n1 Added by the Finance Act, 2009. \n2Inserted by the Finance Act, 2011. \n3The words “confiscated or attached” substituted by the Finance Act, 2010. \n4 The words “Income Tax” substituted by the Finance Act, 2011. \n5Explanation added through Finance Act, 2020 dated 30th June, 2020. \n6 Added by the Finance Act, 2016. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n467 \n \n1[  ] 2[     ]   \n3[    ]  \n \n4[236C. Advance Tax on sale or transfer of immovable Property. — (1) \n5[Subject to sub-section (2A), any person] responsible for registering 6[, recording] \nor attesting transfer of any immovable property shall at the time of registering \n7[,recording] or attesting the transfer shall collect from the seller or transferor \nadvance tax at the rate specified in Division X of Part IV of the First Schedule 8[:] \n \n9[Explanation,—For removal of doubt, it is clarified that the person \nresponsible for registering, recording or attesting transfer includes person \nresponsible for registering, recording or attesting transfer for local authority, \nhousing authority, housing society, co-operative society 10[, public and \nprivate real estate projects registered/governed under any law, joint \nventures, private commercial concerns] and registrar of properties.] \n \n11[Provided that this sub-section shall not apply to a seller, being the dependant \nof a Shaheed belonging to Pakistan Armed Forces or a person who dies while in the \nservice of the Pakistan Armed Forces or the service of Federal or Provincial Government \n12[or a war wounded person while in service of Pakistan Armed Forces or Federal \nor Provincial Government or an ex-serviceman and serving personnel of armed \n                                            \n1 Section 236B added by the Finance Act, 2010. \n2 Sub-section (4) omitted by the Finance Act, 2015. The omitted sub-section (4) read as follows:- \n[(4) The advance tax under this section shall not be collected in the case of— \n(a) \nthe Federal Government or a Provincial Government; or  \n \n(b)  \na person who produces a certificate from the Commissioner Inland Revenue that \nincome of such person during the tax year is exempt.] \n3 Section 236B omitted by the Finance Act, 2021. The omitted section read as follows: \n“236B. Advance tax on purchase of air ticket.— (1) There shall be collected advance tax at the \nrate specified in Division IX of Part IV of the First Schedule, on the purchase of gross amount of \ndomestic air ticket3[“:”] \n3[“Provided that this section shall not apply to routes of Baluchistan coastal belt, Azad Jammu \nand Kashmir, Federally Administered Tribal Areas, Gilgit-Baltistan and Chitral.”] \n \n(2) \nThe 3[airline issuing] air ticket shall charge advance tax under sub-section (1) in the \nmanner air ticket charges are charged.] \n3[(2A) The mode, manner and time of collection shall be as may be prescribed.] \n \n3[(3)  \nThe advance tax collected under sub-section (1) shall be adjustable.]” \n4 Inserted by the Finance Act, 2012. \n5 The words “Any person” substituted by the Finance Act, 2023. \n6 Inserted by the Finance Act, 2017. \n7Inserted by the Finance Act, 2017. \n8Full stop substituted by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016. \n9Added by the Finance Act, 2017. \n10 Inserted by the Finance Act, 2021. \n11 Added by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016. \n12 Expression inserted by the Finance Act, 2024. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n468 \n \nforces or ex-employees or serving personnel of Federal and Provincial \nGovernment], in respect of first sale of immovable property acquired from or allotted by \nthe Federal Government or Provincial Government or any authority duly certified by the \nofficial allotment authority, and the property acquired or allotted is in recognition of or for \nservices rendered by the Shaheed or the person who dies in service 1[or a war \nwounded person while in service of Pakistan Armed Forces or Federal or \nProvincial Government or an ex-serviceman and serving personnel of armed \nforces or ex-employees or serving personnel of Federal and Provincial \nGovernment] ] 2[: \n \n[Provided further that if the seller or transferor is a non-resident individual holding \nPakistan Origin Card (POC) or National ID Card for Overseas Pakistanis (NICOP) or \nComputerized National ID Card (CNIC) who had acquired the said immovable property \nthrough a Foreign Currency Value Account (FCVA) or NRP Rupee Value Account \n(NRVA) maintained with authorized banks in Pakistan under the foreign exchange \nregulations issued by the State Bank of Pakistan, the tax collected under this section \nfrom such persons shall be final discharge of tax liability in lieu of capital gains taxable \nunder section 37 earned by the seller or transferor from the property so disposed of.] \n \n \n(2)  \nThe Advance tax collected under sub-section (1) shall be adjustable \n \n3[:] \n \n4[Provided that where immovable property referred to in sub-\nsection (1) is acquired and disposed of within the same tax year, the \ntax collected under this section shall be minimum tax.] \n \n5[(2A) Notwithstanding anything contained in any other law, for the time \nbeing in force, any person responsible for registering, recording or attesting \ntransfer of any immovable property shall not register, record or attest transfer \nunless the seller or transferor has discharged its tax liability under section 7E and \nevidence to this effect has been furnished to the said person in the prescribed \nmode, form and manner.”; ] \n \n \n6[   ]  \n \n                                            \n1 Expression inserted by the Finance Act, 2024. \n2 Full stop substituted and proviso added by the Finance Act, 2021. Earlier this substitution and addition \nwere made through Tax Laws (Amendment) Ordinance, 2021. \n3Full stop substituted by the Finance Act, 2017 \n4inserted by the Finance Act, 2017 \n5 Sub-section (2A) inserted by the Finance Act, 2023. \n6 Sub-section (3) omitted by the Finance Act 2015. The omitted sub-section read as follows: \n \n“(3)  \nThe advance tax under this section shall not be collected in the case of Federal \n \nGovernment, Provincial Government or a Local Government.” \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n469 \n \n1[  ] \n \n2[  ] \n \n3[  ] \n4[(4) \nSub-section (1) shall not apply to:— \n \n(a) \na seller, if the seller is dependent of: \n(i) \na seller, if the seller is dependent of:  \na Shaheed belonging to Pakistan Armed Forces; or \n \n(ii) \na person who dies while in the service of the Pakistan \nArmed \nForces \nor \nthe \nFederal \nand \nProvincial \nGovernments; and \n \n(b) to the first sale of immovable property which has been acquired \nor allotted as an original allottee, duly certified by the official \nallotment authority.] \n \n5[236CA. Advance tax on TV plays and advertisements.- (1) Any licensing \nauthority certifying any foreign TV drama serial or a play dubbed in Urdu or any \nother language, for screening and viewing on any landing rights channel, shall \ncollect advance tax at the rates specified in Division XA of Part IV of the First \nSchedule. \n  \n(2) \nAny licensing authority certifying any commercial for advertisement \nstarring foreign actor, for screening and viewing on any landing rights channel shall \ncollect advance tax at the rates specified in Division XA of Part IV of the First \nSchedule.  \n \n                                            \n1 Added by the Finance Act, 2016. \n2 Sub-section (3) omitted by the Finance Act, 2022. The omitted sub-section read as follows: \n  “(3) Advance tax under sub-section (1) shall not be collected if the immovable property is held for a    \nperiod exceeding 2[four] years.” \n3 Sub-section (4) omitted by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016. The omitted \nsub-section read as follows:- \n “(4) Sub-section (1) shall not apply to:— \n(a) a seller, if the seller is dependent of: \n(i) \na Shaheed belonging to Pakistan Armed Forces; or \n(ii) \na person who dies while in the service of the Pakistan Armed Forces or the Federal and \nProvincial Governments; and \n(b) to the first sale of immovable property which has been acquired or allotted as an original \nallottee, duly certified by the official allotment authority.\"] \n4 Sub-section (4) added by the Income Tax (Fourth Amendment) Act, 2016 dated 02.12.2016. \n5 Section 236CA inserted by the Finance (Supplementary) Act, 2022. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n470 \n \n(3) \nThe tax required to be collected under this section shall be minimum \ntax in respect of income arising from such drama serial or play or advertisement \nreferred to in sub-section (1) or (2) of this section.] \n \n \n1[236CB. Advance tax on functions and gatherings. – (1) Every prescribed \nperson shall collect advance tax at the rate specified in Division Xl of Part IV of the \nFirst Schedule on the total amount of the bill from a person arranging or holding a \nfunction in a marriage hall, marquee, hotel, restaurant, commercial lawn, club, a \ncommunity place or any other place used for such purpose, subject to such \nconditions or limitations as may be prescribed.  \n \n(2)  \nWhere the food, service or any other facility is provided by any other \nperson, the prescribed person shall also collect advance tax on the payment for \nsuch food, service or facility at the rate specified in Division Xl of Part IV of the First \nSchedule from the person arranging or holding the function.  \n \n(3)  \nThe advance tax collected under sub-section (1) and subsection (2) \nshall be adjustable.  \n \n(4)  \nln this section –  \n \n(a)  \"function\" includes any wedding related event, a seminar, a \nworkshop, a session, an exhibition, a concert, a show, a party or \nany other gathering held for such purpose; and \n \n  \n(b)  \"prescribed person\" includes the owner, a lease-holder, an \noperator or a manager of a marriage hall, marquee, hotel, \nrestaurant, commercial lawn, club, a community place or any \nother place used for such purpose.] \n \n2[  ] \n                                            \n1 Section 236CB inserted by the Finance (Supplementary) Act, 2023 (X of 2023) dated 23.02.2023. \n2Section 236D and 236F omitted through Finance Act, 2020 dated 30th June, 2020 the omitted sections \nread as follows: 236D. Advance tax on functions and gatherings.— (1) Every prescribed person \nshall collect advance tax at the rate specified in Division XI of Part IV of the First Schedule on the total \namount of the bill from a person arranging or holding a function in a marriage hall, marquee, hotel, \nrestaurant, commercial lawn, club, a community place or any other place used for such purpose. \n(2)  \nWhere the food, service or any other facility is provided by any other person, the prescribed \nperson shall also collect advance tax on the payment for such food, service or facility at the rate \nspecified in Division XI of Part IV of the First Schedule from the person arranging or holding the function. \n(3)  \nThe advance tax collected under sub-section (1) and sub-section (2) shall be adjustable.  \n(4)   \nIn this section,— \n    (a)  “function” includes any wedding related event, a seminar, a workshop, a session, an exhibition, \na concert, a show, a party or any other gathering held for such purpose; and  \n(b)  “prescribed person” includes the owner, a lease-holder, an operator or a manager of a marriage \nhall, marquee, hotel, restaurant, commercial lawn, club, a community place or any other place \nused for such purpose.] \n \n2[ 2[   ]  ]  \n2[236F. Advance tax on cable operators and other electronic media.— (1) Pakistan Electronic \nMedia Regulatory Authority, at the time of issuance of licence for distribution services or renewal of the \nlicence to a licencee, shall collect advance tax at the rates specified in Division XIII of Part IV of the \nFirst Schedule.  \n(2) The tax collected under sub-section (1) shall be adjustable. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n471 \n \n1[236G. Advance tax on sales to distributors, dealers and wholesalers.— (1) \nEvery manufacturer or commercial importer 2[ ] at the time of sale to distributors, \ndealers and wholesalers, shall collect advance tax at the rate specified in Division \nXIV of Part IV of the First Schedule, from the aforesaid person to whom such sales \nhave been made. \n \n \n(2)  \nCredit for tax collected under sub-section (1) shall be allowed in \ncomputing the tax due by the distributor, dealer or wholesaler on the taxable \nincome for the tax year in which the tax was collected.] \n \n3[236H. Advance tax on sales to retailers.— (1) Every manufacturer, distributor, \ndealer, wholesaler or commercial importer 4[ ] at the time of sale to retailers5[“, and \nevery distributor or dealer to another wholesaler in respect of the said sectors”], \nshall collect advance tax at the rate specified in Division XV of Part IV of the First \nSchedule, from the aforesaid person to whom such sales have been made.  \n \n \n(2)  \nCredit for the tax collected under sub-section (1) shall be allowed in \ncomputing the tax due by the retailer on the taxable income for the tax year in \nwhich the tax was collected.] \n \n6[   ] \n \n7[   ] \n \n                                            \n(3) For the purpose of this section, “cable television operator” “DTH”, “Distribution Service”, “electronic \nmedia”, “IPTV”, “loop holder”, “MMDS”, “mobile TV”, shall have the same meanings as defined in \nPakistan Electronic Media Regulatory Authority Ordinance, 2002 (XIII of 2002) and rules made \nthereunder \n1Added by the Finance Act, 2013. \n2 The expression “of 2[pharmaceuticals, poultry and animal feed, edible oil and ghee, auto-parts, tyres, \nvarnishes, chemicals, cosmetics, IT equipment,] electronics, sugar, cement, iron and steel products, \nfertilizer, motorcycles, pesticides, cigarettes, glass, textile, beverages, paint or foam sector,” Added \nby the Finance Act, 2013.” omitted by the Finance Act, 2024. \n3Added by the Finance Act, 2013. \n4 The expression “of 4[pharmaceuticals, poultry and animal feed, edible oil and ghee, auto-parts, tyres, \nvarnishes, chemicals, cosmetics, IT equipment,] electronics, sugar, cement, iron and steel products, \n4[  ]motorcycles, pesticides, cigarettes, glass, textile, beverages, paint or foam sector,” omitted by \nthe Finance Act, 2024. \n5 Inserted by the Finance Act, 2015. \n6Inserted by the Finance Act, 2018 \n7 Section 236HA omitted by the Finance Act, 2021. The omitted section read as follows: \n“236HA. Tax on sale of certain petroleum products.— (1) Every person selling petroleum \nproducts to a petrol pump operator or distributer, where such operator or distributer is not allowed a \ncommission or discount, shall collect advance tax on ex-depot sale price of such products at the rate \nspecified in Division XVA of Part IV of the First schedule. \n(2) The tax deductible under sub-section (1) shall be a final tax on the income arising from the sale \nof petroleum products to which sub-section (1) applies.]” \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n472 \n \n1[   ] \n \n2[   ] \n3[  ] \n \n4[236K. Advance tax on purchase or transfer of immovable property.—(1) Any \nperson responsible for registering 5[,recording] or attesting transfer of any \nimmovable property shall at the time of registering 6[,recording] or attesting the \ntransfer shall collect from the purchaser or transferee advance tax at the rate \nspecified in Division XVIII of Part IV of the First Schedule. \n \n7[Explanation,—For removal of doubt, it is clarified that the person \nresponsible for registering, recording or attesting transfer includes person \nresponsible for registering, recording or attesting transfer for local authority, \n                                            \n1 Added by the Finance Act, 2013. \n2 Section 236I omitted by the Finance Act, 2022. The omitted section read as follows: \n“236I. Collection of advance tax by educational institutions.— (1) There shall be collected \nadvance tax 2[from a person not appearing on the active taxpayers’ list]  at the rate specified in \nDivision XVI of Part-IV of the First Schedule on the amount of fee paid to an educational institution. \n(2)  \nThe person preparing fee voucher or challan shall charge advance tax under sub-\nsection (1) in the manner the fee is charged. \n(3)  \nAdvance tax under this section shall not be collected from a person 2[on an amount \nwhich is paid by way of scholarship or] where annual fee does not exceed two hundred thousand \nrupees. \n \n(4)  \nThe term “fee” includes, tuition fee and all charges received by the educational \ninstitution, by whatever name called, excluding the amount which is refundable. \n(4) \nTax collected under this section shall be adjustable against the tax liability of either of \nthe parents or guardian making payment of the fee.] \n \n2[“(6)  Advance tax under this section shall not be collected from a person who is a non-\nresident and,— \n(i) \nfurnishes copy of passport as an evidence to the educational institution that during previous \ntax year, his stay in Pakistan was less than one hundred eighty-three days; \n(ii) \nfurnishes a certificate that he has no Pakistan-source income; and \n(iii) the fee is remitted directly from abroad through normal banking channels to the bank \naccount of the educational institution.” \n3The section 236J omitted through Finance Act, 2020 dated 30th June, 2020 the omitted section read \nas follows:  \n“236J. Advance tax on dealers, commission agents and arhatis etc.— (1) Every market committee \nshall collect advance tax from dealers, commission agents or arhatis, etc. at the rates specified in \nDivision XVII of Part-IV of the First Schedule at the time of issuance or renewal of licences. \n \n(2)  \nThe advance tax collected under sub-section (1) shall be adjustable. \n(4) \nIn this section “market committee” includes any committee or body formed under any \nprovincial or local law made for the purposes of establishing, regulating or organizing \nagricultural, livestock and other commodity markets.” \n4Sections 236K, 236L, 236M and 236N inserted by the Finance Act, 2014. \n5Inserted by the Finance Act, 2017. \n6Inserted by the Finance Act, 2017. \n7Added by the Finance Act, 2017 \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n473 \n \nhousing authority, housing society, co-operative society 1[, public and private \nreal estate projects registered/governed under any law, joint ventures, \nprivate commercial concerns] and registrar of properties.] \n \n(2) \nThe advance tax collected under sub-section (1) shall be adjustable \n2[: \n \nProvided that if the buyer or transferee is a non-resident individual \nholding a Pakistan Origin Card (POC) or National ID Card for Overseas \nPakistanis (NICOP) or Computerized National ID Card (CNIC) who has \nacquired the said immovable property through a Foreign Currency Value \nAccount (FCVA) or NRP Rupee Value Account (NRVA) maintained with \nauthorized banks in Pakistan under the foreign exchange regulations issued \nby the State Bank of Pakistan, the tax collected under this section from such \npersons shall be final discharge of tax liability for such buyer or transferee.]  \n \n \n3[     ] \n \n4[(3) Any person responsible for collecting payments in installments for  \npurchase or allotment of any immovable property where the transfer is to be  \neffected after making payment of all installments, shall at the time of  collecting \ninstallments collect from the allotee or transferee advance tax at the rate  specified \nin Division XVIII of Part IV of the First Schedule] 5[: \nProvided that where tax has been collected along with installments, \nno further tax under this section shall be collected at the time of transfer of \nproperty in the name of buyer from whom tax has been collected in \ninstallments which is equal to the amount payable in this section.] \n \n(4) \nNothing contained in this section shall apply to a scheme introduced \nby the Federal Government, or Provincial Government or an Authority established \nunder a Federal or Provincial law for expatriate Pakistanis6[:] \n \n                                            \n1 Inserted by the Finance Act, 2021. \n2 Full stop substituted and proviso added by the Finance Act, 2021. Earlier this substitution and \naddition were made through Tax Laws (Amendment) Ordinance, 2021. \n3 Sub-section (3) omitted by the Finance Act, 2015. The omitted sub-section (3) read as follows:- \n“(3) \nThe advance tax under this section shall not be collected in the case of the Federal \nGovernment, a Provincial Government, a Local Government or a foreign diplomatic \nmission in Pakistan.” \n4Sub-section (3) inserted by the Finance Act, 2018. \n5 Full stop substituted and proviso added by the Finance Act, 2021. \n6Full stop substituted by the finance Act, 2015. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n474 \n \n1[“Provided that the mode of payment by the expatriate Pakistanis in \nthe said scheme or schemes shall be in the foreign exchange remitted from \noutside Pakistan through normal banking channels.”] \n \n2[    ] \n \n3[   ] \n4[   ] \n                                            \n1Added by the Finance Act, 2015. \n2 Section 236L omitted by the Finance Act, 2021. The omitted section read as follows: \n   236L. Advance tax on purchase of international air ticket.— (1) Every airline, issuing ticket for  \njourney originating from Pakistan, shall collect advance tax at the rates specified in Division XX of \nPart IV of the First Schedule, on the gross amount of international air tickets issued to passengers \nbooking one-way or return, from Pakistan. \n(2) \nThe airline issuing air ticket shall collect or charge advance tax under sub-section (1) in \nthe manner air ticket charges are collected or charged, either manually or electronically. \n(3) \nThe mode, manner and time of collection under sub-section (1) and time of collection \nshall be as may be prescribed. \n(4)  \nThe advance tax collected under sub-section (1) shall be adjustable.” \n3 Section 236M omitted by the Finance Act, 2018. The omitted section 236M read as follows: \n“236M.  Bonus shares issued by companies quoted on stock exchange .- (1) Notwithstanding \nanything contained in any law for the time being in force, every company, quoted on stock exchange, \nissuing bonus shares to the shareholders of the company, shall withhold five percent of the bonus \nshares to be issued.  \n(2) Bonus shares withheld under sub-section (1) shall only be issued to a shareholder, if the \ncompany collects from the shareholder, tax equal to five percent of the value of the bonus \nshares issued to the shareholder including bonus share withheld, determined on the basis of \nday-end price on the first day of closure of books.    \n(3) Tax under sub-section (2), shall be collected by the company, within fifteen days of the first \nday of closure of books.  \n(4) If the shareholder fails to make the payment of tax under sub-section (2) within fifteen days \nor the company fails to collect the said tax within fifteen days, the company shall deposit the \nbonus share withheld under sub-section (1) in the Central Depository Company of Pakistan \nLimited or any other entity as may be prescribed. \n(5) Bonus share deposited in the Central Depository Company of Pakistan Limited or the entity \nprescribed under sub-section (4) shall be disposed of in the mode and manner as may be \nprescribed and the proceeds thereof shall be paid to the Commissioner, by way of credit to \nthe Federal Government.  \n(6) Issuance of bonus shares shall be deemed to be the income of the shareholder and the tax \ncollected by a company under sub-section (2) or proceeds of the bonus shares disposed of \nand  paid under sub-section (5) shall be treated to have been paid on behalf of shareholder. \n(7) Tax paid under this section shall be final tax on the income of the shareholder of the company \narising from issuing of bonus shares.” \n4Section 236N omitted by the Finance Act, 2018. The omitted section 236N read as follows: \n“236N. Bonus shares issued by companies not quoted on stock exchange .- (1) Notwithstanding \nanything contained in any law for the time being in force, every company, not quoted on stock \nexchange, issuing bonus shares to the shareholders of the company, shall deposit tax, within \nfifteen days of the closure of books, at the rate of five percent of the value of the bonus shares \non the first day of closure of books, whether or not tax has been collected by the company \nunder sub-section (3). \n(2) Issuance of bonus shares shall be deemed to be the income of the shareholder and tax \ndeposited under sub-section (1) shall be treated to have been deposited on behalf of the \nshareholder. \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n475 \n \n1[236O. Advance tax under this chapter.—The advance tax under this chapter \nshall not be collected 2[“or deducted from”] — \n \n(a) \nthe Federal Government or a Provincial Government; \n \n(b) \na foreign diplomat or a diplomatic mission in Pakistan; or \n(c)  \na person who produces a certificate from the Commissioner that \nhis income during the tax year is exempt.”] \n3[    ] \n \n 4[   ] \n5[   ] \n \n6[    ] \n                                            \n(3) A company liable to deposit tax under sub-section (1), shall be entitled to collect and recover \nthe tax deposited under sub-section (1),from the shareholder, on whose behalf the tax has \nbeen deposited, before the issuance of bonus shares.  \n(4) If a shareholder neither makes payment of tax to the company nor collects its bonus shares, \nwithin three months of the date of issuance of bonus shares, the company may proceed to \ndispose of its bonus shares to the extent it has paid tax on its behalf under sub-section (1). \n(5) Tax paid under this section shall be a final tax on the income of the shareholder of the \ncompany arising from issuance of bonus shares. \n(6)  The Board may prescribe rules for determination of value of shares under sub-section (1).]” \n1 Section “236O” inserted by the Finance Act, 2015. \n2 The words “in the case of withdrawals made by” substituted by the Finance Act, 2016. \n3 Section “236P” inserted by the Finance Act, 2015. \n4 Section 236P omitted by the Finance Act, 2021. The omitted section read as follows: \n“236P. Advance tax on banking transactions otherwise than through cash.— (1) Every banking \ncompany shall collect advance adjustable tax from a 4[person whose name is not appearing in the \nactive taxpayers’ list] at the time of sale of any instrument, including demand draft, pay order, special \ndeposit receipt, cash deposit receipt, short term deposit receipt, call deposit receipt, rupee traveller‘s \ncheque or any other instrument of such nature. \n \n(2) Every banking company shall collect advance adjustable tax from a 4[ person whose name \nis not appearing in the active taxpayers’ list] at the time of transfer of any sum through cheque or \nclearing, interbank or intra bank transfers through cheques, online transfer, telegraphic transfer, mail \ntransfer, direct debit, payments through internet, payments through mobile phones, account to account \nfunds transfer, third party account to account funds transfers, real time account to account funds \ntransfer, real time third party account to account fund transfer, automated teller machine (ATM) \ntransfers, or any other mode of electronic or paper based funds transfer. \n(3) The advance tax under this section shall be collected at the rate specified in Division XXI of \nPart IV of the First Schedule, where the sum total of payments for all transactions mentioned in sub-\nsection (1) or subsection (2), as the case may be, exceed fifty thousand rupees in a day. \n4[“Explanation.- For removal of doubt, it is clarified that the said fifty thousand rupees shall be \naggregate transfers from all the bank accounts in a single day.”] \n(4) Advance tax under this section shall not be collected in the case of 4[   ] payments made for \nFederal, Provincial or local Government taxes.”]” \n5 Section “236Q” inserted by the Finance Act, 2015. \n6 Section “236Q” omitted by the Finance Act, 2022. The omitted section read as follows: \n   “236Q. Payment to residents for use of machinery and equipment.—(1) Every prescribed \nperson making a payment in full or in part including a payment by way of advance to a resident person \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n476 \n \n \n1[    ] \n2[    ] \n \n3[    ]  \n4[ 5[  ]  ]  \n \n                                            \nfor use or right to use industrial, commercial and scientific equipment shall deduct tax from the gross \namount at the rate specified in Division XXIII of Part IV of the First Schedule. \n(2) Every prescribed person making a payment in full or in part including a payment by way of \nadvance to a resident person on account of rent of machinery shall deduct tax from the gross amount \nat the rate specified in Division XXIII of Part IV of the First Schedule. \n(3) The tax deductible under sub-sections (1) and (2) shall be 6[minimum] tax on the income \nof such resident person. \n[Explanation.— For the removal of doubt, it is explained that the income of person referred to \nin sub-section (3) means the amount on which tax is deductible under sub-section (1) or (2) of this \nsection.] \n(4) In this section ―prescribed person‖ means a prescribed person as defined in sub-section \n(7) of section 153. \n(5) The provisions of sub-section (1) and (2) shall not apply to— \n(a) \nagricultural machinery; and \n(b)   machinery leased by a leasing company, an investment bank or a modaraba or a \nscheduled bank or a development finance institution in respect of assets owned by the \nleasing company or an investment bank or a modaraba or a scheduled bank or a \ndevelopment finance institution.” \n1 Section “236R” omitted through Finance Act, 2020 dated 30th June, 2020 the omitted section read as \nfollows: “236R. Collection of advance tax on education related expenses remitted abroad.―(1) \nThere shall be collected advance tax at the rate specified in Division XXIIV of Part-IV of the First \nSchedule on the amount of education related expenses remitted abroad. \n(2) Banks, financial institutions, foreign exchange companies or any other person responsible \nfor remitting foreign currency abroad shall collect advance tax from the payer of education related \nexpenses. \n(3) Tax collected under this section shall be adjustable against the income of the person \nremitting payment of education related expenses. \n(4) For the purpose of this section, “education related expenses” includes tuition fee, boarding \nand lodging expenses, any payment for distant learning to any institution or university in a foreign \ncountry and any other expense related or attributable to foreign education.” \n2 Section “236S” inserted by the Finance Act, 2015. \n3 Section 236S omitted by the Finance Act, 2021. The omitted section read as follows: \n   “236S. Dividend in specie.—Every person making payment of dividend-in-specie shall collect tax \nfrom the gross amount of the dividend in specie paid at the rate specified in Division I of Part III of the \nFirst Schedule.”] \n4 Section “236T” inserted by the Finance Act, 2015. \n5Section “236T” omitted by the Finance Act, 2016. Omitted section read as follows:- \n“236T. Collection of tax by Pakistan Mercantile Exchange Limited (PMEX).—(1) Pakistan \nMercantile Exchange Limited (PMEX) shall collect advance tax— \n(a) at the rates specified in Division XXII of Part IV of First Schedule from its members on \npurchase of futures commodity contracts; \n(b) at the rates specified in Division XXII of Part IV of First Schedule from its members on sale \nof futures commodity contracts; and \n(2) The tax collected under clauses (a) and (b) of sub-section (1) shall be an adjustable \ntax.”] \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n477 \n \n1[    ] \n \n2[   ] \n \n3[   ] \n \n4[  ] \n5[  ] \n \n6[  ] \n \n7[   ] \n                                            \n1Section 236U omitted through Finance Act, 2020 dated 30th June, 2020 the omitted section read as \nfollows: “236U. Advance tax on insurance premium.- (1) Every insurance company shall collect \nadvance tax at the time of collection of insurance premium from 1[person whose name is not appearing \nin the active taxpayers’ list] in respect of general insurance premium and life insurance premium, at the \nrates specified in Division XXV of Part IV of the First Schedule. \n(2)  Insurance premium collected through agents of the insurance company shall be treated to have \nbeen collected by the insurance company. \n(3)  Advance tax collected under this section shall be adjustable.” \n2Inserted by the Finance Act, 2016. \n3 Section 236V omitted by the Finance Act, 2021. The omitted section read as follows: \n    “236V. Advance tax on extraction of minerals.- (1) There shall be collected advance tax at the \nrate specified in Division XXVI of Part-IV of the First Schedule on the value of minerals extracted, \nproduced, despatched and carried away from the licensed  or leased areas of the mines. \n(2) \nAdvance tax under sub-section (1) shall be collected by the provincial authority \ncollecting royalty per metric ton from the lease-holder of mines or any person extracting minerals.  \n(3) \nAdvance tax collected under this section shall be adjustable. \n(4) \nThe value of the minerals for the purpose of this section shall be as specified by the \nBoard.”]” \n4Section 236W omitted through Finance Act, 2019, omitted section read as follow: \n236W. Tax on purchase or transfer of immovable property.—(1) Every person responsible for \nregistering4[,recording] or attesting transfer of any immovable property shall at the time of registering \n4[,recording] or attesting the transfer shall collect from the purchaser or transferee advance tax at the \nrate of three per cent of the amount computed  under clause (c) of sub-section (4) of section 111. \n4[Explanation,—For removal of doubt, it is clarified that the person responsible for \nregistering, recording or attesting transfer includes person responsible for registering, recording \nor attesting transfer for local authority, housing authority, housing society, co-operative society \nand registrar of properties.] \n2. Tax collected under sub-section (1) shall not be adjustable. \n \n5Section 236X omitted through Finance Act, 2020 dated 30th June, 2020 omitted section read as \nfollows: “236X. Advance tax on tobacco.— (1)Pakistan Tobacco Board or its contractors, at the time \nof collecting cess on tobacco, directly or indirectly, shall collect advance tax at the rate of five percent \nof the purchase value of tobacco from every person purchasing tobacco including manufacturers of \ncigarettes.  \n(2) Tax collected under this section shall be adjustable.” \n6Inserted by the Finance Act, 2018. \n7 Section 236Y omitted by the Finance Act, 2021. The omitted section read as follows: \n236Y.  Advance tax on persons remitting amounts abroad through credit  or debit or prepaid \ncards.—(1)  Every banking company shall collect advance tax, at the time of transfer of any sum \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n478 \n \n1[236Y.  Advance tax on persons remitting amounts abroad through credit  \nor debit or prepaid cards.— (1)  Every banking company shall collect advance \ntax, at the time of transfer of any sum remitted outside Pakistan, on behalf of any \nperson who has completed a credit card or debit card or prepaid  card  transaction  \nwith  a  person  outside  Pakistan  at  the rate specified in Division XXVII of Part IV \nof the First Schedule. \n \n(2) \nThe advance tax collected under this section shall be adjustable.] \n \n2[236Z. Bonus shares issued by companies. – (1) Notwithstanding anything \ncontained in any law for the time being in force, every company, issuing bonus \nshares to the shareholders of the company, shall withhold ten percent of the bonus \nshares to be issued.  \n \n(2)  \nBonus shares withheld under sub-section (1) shall only be issued to a \nshareholder, if the company collects from the shareholder, tax equal to ten percent \nof the value of the bonus shares issued to the shareholder including bonus share \nwithheld, determined on the basis of day-end price on the first day of closure of \nbooks in the case of listed company and the value as prescribed in case of other \ncompanies.  \n \n(3)  \nTax under sub-section (2), shall be deposited by the company, within \nfifteen days of closure of books, whether or not tax has been collected by the \ncompany under subsection (2).  \n \n(4)  \nA company liable to deposit tax under this section shall be entitled to \ncollect and recover the tax deposited from the shareholder, on whose behalf the \ntax has been deposited, before the issuance of bonus shares.  \n \n(5)  \nIf a shareholder neither makes payment of tax to the company nor \ncollects its bonus shares, within fifteen days of the date of issuance of bonus \nshares, the company may proceed to dispose of its bonus shares to the extent it \nhas paid tax on its behalf under this section.  \n \n(6)  \nIssuance of bonus shares shall be deemed to be the income of the \nshareholder and the tax collected by a company under this section or proceeds of \nthe bonus shares disposed of and paid under this section shall be treated to have \nbeen paid on behalf of the shareholder.  \n \n                                            \nremitted outside Pakistan, on behalf of any person who has completed a credit card transaction, a debit \ncard transaction, or a  prepaid  card  transaction  with  a  person  outside  Pakistan  at  the rate specified \nin Division XXVII of Part IV of the First Schedule. \n(2)  The advance tax collected under this section shall be adjustable.\"]” \n1 Section 236Y inserted by the Finance Act, 2022.  \n2 Section 236Z inserted by the Finance Act, 2023.  \n\n\f\nChapter XII – Transitional Advance Tax Provisions__________ \n \n479 \n \n(7)  \nTax paid under this section shall be final tax on the income of the \nshareholder of the company arising from issuing of bonus shares.] \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n\n\f\nChapter XIII – Miscellaneous_____________________________ \n \n480 \nCHAPTER XIII \nMISCELLANEOUS \n \n237.  Power to make rules.—(1)  The 1[Board] may, by notification in the official \nGazette, make rules for carrying out 2[  ] the purposes of this Ordinance. \n \n \n(2) \nIn particular, and without prejudice to the generality of the foregoing \npower, such rules may provide for all or any of the following matters, namely:– \n \n(a) \nthe manner in, and procedure by, which the income, profits and \ngains chargeable to tax and the tax payable thereon under this \nOrdinance shall be determined in the case of – \n \n (i) \nincome derived partly from agriculture and partly from \nother business; or  \n \n(ii) \nnon-resident persons; \n \n3[(ab) \nascertainment or determination of any income or class of \nincome to be included in the total income of a taxpayer and any \ndeduction from such income;] \n \n(b) \nfees and other charges to be paid in respect of any matter \nreferred to in this Ordinance; \n \n(c) \nanything which is to be or may be prescribed under this \nOrdinance;  \n \n(d) \nthe procedure for furnishing returns and other documents as \nrequired under this Ordinance, including on computer media or \nthrough electronic medium or for issuance of orders or notices, \nor levy of 4[default surcharge]or penalty through electronic \nmedium; \n \n \n5[(da) the procedure for approval of a non-profit organization;] \n \n(e) \ncontain provisions of a saving or transitional nature consequent \nupon the making of this Ordinance; and  \n \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2 The word “of” omitted by the Finance Act, 2005. \n3Inserted by the Finance Act, 2003. \n4The words “additional tax ” substituted by the Finance Act, 2010. \n5 Inserted by the Finance Act, 2003. \n\n\f\nChapter XIII – Miscellaneous_____________________________ \n \n481 \n \n(f) \npenalties for the contravention of the rules made under this \nOrdinance. \n \n(3) \nThe power to make rules conferred by this section shall be, except on \nthe first occasion of the exercise thereof, subject to the condition of previous \npublication. \n \n \n(4) \nWhere rules made under this section – \n \n(a) \nadversely affect a person;  \n \n(b) \n are of a transitional nature; and \n \n(c) \nare made within twelve months after commencement of this \nOrdinance, \n \nthese may provide that they shall take effect from the date on which this Ordinance \ncomes into force or a later date. \n \n1[237A. Electronic record. —  (1) The Board may require any person to use its \ninformation system and electronic resource, in order to replace or supplement, its \nmanual business processes by automated business processes and substitute its \npaper based records by electronic record. \n \n(2)  Electronic record generated, maintained, issued, served, received, filed \nor requisitioned through the electronic resource of the Board shall by itself \nsufficiently and conclusively prove its validity, authenticity and integrity and shall \nbe treated to have been done so according to the provisions of this Ordinance.] \n \n2[(3) In case of an integrated enterprise, no sale shall be made or service \nshall be rendered, as the case may be, without generating fiscal invoices as \nprescribed.] \n \n3[237B. Prize schemes to promote tax culture.- (1) The Board may prescribe \nprize schemes to encourage the general public to make purchases, or avail \nservices only from integrated enterprises issuing tax invoices.  \n \n(2) \nThe Board may prescribe procedure for mystery shopping in respect \nof invoices issued by integrated enterprises randomly and in case of any \ndiscrepancy, all the relevant provisions of the Ordinance shall apply accordingly.] \n \n238.  Repeal. — The Income Tax Ordinance, 1979 (XXXI of 1979), shall stand \nrepealed on the date this Ordinance comes into force in pursuance of sub-section \n(3) of section 1. \n                                            \n1Added by the Finance Act, 2008. \n2 Sub-section (3) added by the Finance Act, 2022.  \n3 Section 237B added by the Finance Act, 2022.  \n\n\f\nChapter XIII – Miscellaneous_____________________________ \n \n482 \n \n239.  Savings. —1[(1) Subject to sub-section (2), in making any assessment in \nrespect of any income year ending on or before the 30th day of June, 2002, the \nprovisions of the repealed Ordinance in so far as these relate to computation of \ntotal income and tax payable thereon shall apply as if this Ordinance had not come \ninto force.] \n \n2[(2)  The assessment, referred to in sub-section (1), shall be made by an \nincome tax authority which is competent under this Ordinance to make an \nassessment in respect of a tax year ending on any date after the 30th day of June, \n2002, and in accordance with the procedure specified in section 59 or 59A 3[or 61] \nor 62 or 63, as the case may be, of the repealed Ordinance.] \n \n4[(3)   The provisions of 5[sub-sections] (1) and (2) shall apply, in like manner, \nto the imposition or charge of any penalty, 6[default surcharge]or any other amount, \nunder the repealed Ordinance, as these apply to the assessment, so however that \nprocedure for such imposition or charge shall be in accordance with the \ncorresponding provisions of this Ordinance.] \n \n \n(4) \nAny proceeding under the repealed Ordinance pending on the \ncommencement of this Ordinance before any income tax authority, the Appellate \nTribunal or any Court by way of appeal, reference, revision or prosecution shall be \ncontinued and disposed of as if this Ordinance has not come into force. \n \n(5) \nWhere the period prescribed for any application, appeal, reference or \nrevision under the repealed Ordinance had expired on or before the \ncommencement of this Ordinance, nothing in this Ordinance shall be construed as \nenabling such application, appeal, reference or revision to be made under this \nOrdinance by reason only of the fact that a longer period is specified or provision \nfor an extension of time in suitable cases by the appropriate authority. \n \n                                            \n1Sub-section (1) substituted by the Finance Act, 2002. The substituted sub-section (1) read as follows: \n “(1)  \nThe repealed Ordinance shall continue to apply to the assessment year ending on the \n30th day of June 2003. “ \n2Sub-section (2) substituted by the Finance Act, 2002. The substituted sub-section (2) read as follows: \n “(2) \nIn making any assessment in respect of any income year ending on or before the 30th \nday of June 2002, the provisions of the repealed Ordinance relating to the computation of total \nincome and the tax payable thereon shall apply as if this Ordinance has not come into force.” \n3Inserted by the Finance Act, 2003. Earlier this was inserted by S.R.O. 633(I)/2002, dated 14.09.2002 \nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. \n4Sub-section (3) substituted by the Finance Act, 2002. The substituted sub-section (3) read as follows:  \n“(3) \nWhere any return of income has been furnished by a person for any assessment year \nending on or before the 30th day of June 2003, proceedings for the assessment of the person for that \nyear shall be taken and continued as if this Ordinance has not come into force. “  \n5The word “sub-section” substituted by the Finance Act, 2005. \n6The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n\n\f\nChapter XIII – Miscellaneous_____________________________ \n \n483 \n \n \n(6) \nAny proceeding for 1[  ] prosecution in respect of an assessment for \nan income year ending on or before the 30th day of June 2002 shall be taken and \ncontinued as if this Ordinance has not come into force. \n \n(7) \nAny income tax, super tax, surcharge, penalty, 2[default surcharge], or \nother amount payable under the repealed Ordinance may be recovered under this \nOrdinance, but without prejudice to any action already taken for the recovery of the \namount under the repealed Ordinance. \n \n \n(8) \nAny election or declaration made or option exercised by any person \nunder any provision of the repealed Ordinance and in force immediately before the \ncommencement of this Ordinance shall be treated as an election or declaration \nmade, or option exercised under the corresponding provisions, if any, of this \nOrdinance. \n \n \n(9) \nAnything done or action taken under the repealed Ordinance in so far \nas it is not inconsistent with the 3[provisions] of this Ordinance shall, without \nprejudice to anything already done or any action already taken, be treated as \nhaving been done or taken under this Ordinance. \n \n \n(10)  Any agreement entered into, appointment made, approval given, \nrecognition granted, direction, instruction, notification, notice, order or rule issued \nor made under any provision of the repealed Ordinance and in force or valid at the \ncommencement of this Ordinance shall, so far as it is not inconsistent with the \ncorresponding provision of this Ordinance or any agreement, appointment entered \ninto, approval given, recognition granted, direction, instruction, notification, notice, \norder or rule issued or made under this Ordinance, be treated as entered into, \nmade, given, granted or issued, as the case may be, under that corresponding \nprovision and shall unless revoked, cancelled or repealed by, or under, this \nOrdinance, continue in force accordingly. \n \n \n(11)  Any appointment, act of authority or other thing made or done by any \nauthority or person and subsisting or in force at the commencement of this \nOrdinance which would have been made or done under any substantially \ncorresponding provision of this Ordinance by any authority or person other than \nthe one specified in the repealed Ordinance, or in any manner other than as \nspecified in the repealed Ordinance shall continue in force and have effect as if it \nhas been made or done under the corresponding provision of this Ordinance by \n                                            \n1 The words “the imposition of penalty or” omitted by the Finance Act, 2002. \n2The words “additional tax” substituted by the Finance Act, 2010. The substituted provision has been \nmade effective from 05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the \nsubstitution was made through Finance (Amendment) Ordinance, 2009 which was re-promulgated \nas Finance (Amendment) Ordinance, 2010 and remained effective till 05.06.2010. \n3 The word “provision” substituted by the Finance Act, 2005. \n\n\f\nChapter XIII – Miscellaneous_____________________________ \n \n484 \n \nthe authority or person, or in the manner specified in the corresponding provision \nas if such provision had been in force when it was made or done. \n \n1[(12) Any notification issued under section 50 of the repealed Ordinance \nand in force on the commencement of this Ordinance shall continue to remain in \nforce, unless 2[amended, modified], cancelled or repealed by, or under, this \nOrdinance.] \n \n3[(13) The authority which issued any notification, notice, direction or \ninstruction, or made any rule, agreement or appointment, or granted any approval \nor recognition, referred to in sub-sections (10) and (12), shall have the power to 4[ \n] 5[amend, modify], cancel or repeal any such notification, notice, direction, \ninstruction, rule, agreement, appointment, approval or recognition.] \n \n6[(14)  Any yield from National Saving Schemes of Directorate of National \nSavings where investment was made on or before 30th June, 2001 and any income \nderived from Mahana Amdani Account where monthly instalment does not \n7[exceed] one thousand rupees shall continue to remain exempt and any person \npaying such yield or income shall not deduct tax under section 151 therefrom and \nthe recipient of such yield or income shall not be required to produce an exemption \ncertificate under section 159 in support of the said exemption.] \n \n \n(15)  Section 107AA of the repealed Ordinance shall continue to apply until \nthe 30th day of June, 2002. \n \n                                            \n1Sub-section (12) substituted by the Finance Act, 2002. The substituted sub-section (12) read as \nfollows: \n“(12) \nClause 77C of Part I of the First Schedule of the repealed Ordinance shall continue to \napply to the yield on National Savings Deposit Certificates issued before 1st July, 2001 and a person \npaying yield on such a Certificate shall not deduct tax under section 151 from the payment.”  \n2 The word “revoked” substituted by the Finance Act, 2005. \n3Sub-section (13) substituted by the Finance Ordinance, 2002. The substituted sub-section (13) read \nas follows: \n“ (13) There is no requirement for the holder of  Certificate to which sub-section (14) applies \nto acquire an exemption certificate under section 159 to give effect to the exemption.“  \n4The word “revoke” substituted by the Finance Act, 2005. \n5 The words and comma “amended, modified” substituted by the words and comma “amend, modify” \nby the Finance Act, 2014. \n6Sub-section (14) substituted by the Finance Act, 2003. The substituted sub-section (14) read as \nfollows:  \n“ (14) Clause (77C) of Part I of the First Schedule of the repealed Ordinance shall continue to \napply to the yield on National Savings Deposit Certificates issued before 1st July, 2001, and a person \npaying yield on such a Certificate shall not deduct tax under section 151 from the payment, and the \nholder of such Certificate shall not be required to acquire an exemption certificate under section 159 \nto give effect to the said exemption. \n7 The word “exceeds” substituted by the Finance Act, 2005. \n\n\f\nChapter XIII – Miscellaneous_____________________________ \n \n485 \n \n \n(16)  The Income Tax Rules made under the repealed Ordinance, on the \nvaluation of perquisites shall continue to apply 1[in respect of any income year \nending on or before] the 30th day of June 2002. \n \n \n(17)  Item 8(5)(h) of the Third Schedule to the repealed Ordinance shall \ncontinue to apply to assets covered by the item. \n \n \n2[(18)The period of limitation provided in clause (d) of subsection (2) of \nsection 131 and sub-section (1) of section 133 shall continue to apply where any \ndecision of the Commissioner (Appeals) or the Appellate Tribunal is received prior \nto the date of commencement of the Tax Laws (Amendment) Act, 2024.] \n \n3[  ]  \n \n4[239A. Transition to Federal Board of Revenue.—Any reference to the Central \nBoard of Revenue, wherever occurring, in this Ordinance and the rules made \nthereunder and Notifications, Orders, or any other instrument issued thereunder \nshall be construed as a reference to the Federal Board of Revenue on the \ncommencement of the Federal Board of Revenue Act, 2007.] \n \n5[239B. Reference to authorities.— (1) Any reference to the Regional Commissioner \nof Income Tax, Commissioner of Income Tax, Commissioner of Income Tax (Appeals) \n                                            \n1The word “until” substituted by the Finance Act, 2002. \n2 Sub-section (18) added by the Finance Act, 2024. \n3Omitted by the Finance Act, 2003. Earlier this was omitted by S.R.O. 633(I)/2002, dated 14.09.2002 \nwhich stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with effect from 01.07.2003. The \nomitted sub-section (18) read as under:-  \n“(18)   In this section, ‘Income Tax authority’ means an Income Tax authority as specified in \nsection 3 of the repealed Ordinance.” \nEarlier this was substituted by Finance Act, 2002. The substituted sub-section (18) read as \nfollows: \n“(18) \nIn this section, - \n“assessment year” means assessment year as defined in the repealed Ordinance; \n“income tax authority” means income tax authority as defined in section 3 of the \nrepealed Ordinance; \n“income year” means income year as defined in the repealed Ordinance; and  \n“repealed Ordinance” means the Income Tax Ordinance, 1979 (XXXI of 1979).” \n4Inserted by the Finance Act, 2007. \n5 Substituted by the Finance Act, 2010. The substituted provision has been made effective from \n05.06.2010 by sub-clause (77) of clause 8 of the Finance Act, 2010. Earlier the substitution was \nmade through Finance (Amendment) Ordinance, 2009 which was re-promulgated as Finance \n(Amendment) Ordinance, 2010 and remained effective till 05.06.2010.Added by the Finance Act, \n2010. The substituted Section 239B read as follows: \n“239B. Reference to authorities.— (1) Any reference to the Regional Commissioner of Income Tax, \nCommissioner of Income Tax, Commissioner of Income Tax (Appeals) and Taxation Officer, \nwherever occurring, in this Ordinance and the rules made thereunder and notifications, orders, \ncirculars or clarifications or any instrument issued thereunder shall be construed as reference to the \nChief Commissioner Inland Revenue, Commissioner Inland Revenue, Commissioner Inland \nRevenue (Appeals) and officer of Inland Revenue, respectively.” \n\n\f\nChapter XIII – Miscellaneous_____________________________ \n \n486 \n \nand Taxation Officer, wherever occurring, in this Ordinance and the rules made \nthereunder 1[and in any other law in force at the time of promulgation of this Ordinance] \nand notifications, orders, circulars or clarifications or any instrument issued thereunder \nshall be construed as reference to the Chief Commissioner Inland Revenue, \nCommissioner Inland Revenue, Commissioner Inland Revenue (Appeals) and officer \nof Inland Revenue, respectively.] \n \n240.  Removal of difficulties.—(1)  Subject to sub-section (2), if any difficulty \narises in giving effect to any of the provisions of this Ordinance, the Federal \nGovernment may, by notification in the official Gazette, make such order, \n2[not]inconsistent with the provisions of this Ordinance, as may appear to it to be \nnecessary for the purpose of removing the difficulty. \n \n3[  ] \n \n4[241. Validation.—5[(1)] All notifications and orders issued and notified, in \nexercise of the powers conferred upon the Federal Government, before the \ncommencement of Finance Act, 2017 shall be deemed to have been validly issued \nand notified in exercise of those powers.] \n \n6[(2) Notwithstanding any omission, irregularity or deficiency in the  \nestablishment, or conferment of powers and functions, of the Directorate-General \n(Intelligence and Investigation), Inland Revenue and authorities specified in \nsection 230, all orders passed, notices issued and actions taken in exercise or \npurported exercise of the powers and functions of the Commissioner under  this \nOrdinance by the Directorate-General (Intelligence and Investigation), Inland \nRevenue or the authorities specified in section 230 shall be deemed to have  been \nvalidly passed, issued and taken under this Ordinance.] \n \n7[242. Benefits of repealed provisions.— The existing beneficiaries of \nexemptions or concessionary provisions of the Ordinance, already expired or \nexpiring, on thirtieth day of June, 2021 or repealed by Tax Laws (Second \n                                            \n1 Inserted  by the Finance Act, 2013. \n2 The word “no” substituted by the Finance Act, 2002. \n3Sub-section (2) omitted by the Finance Act, 2010. The omitted sub-section (2) read as follows: \n“(2) No such power shall be exercised under sub-section (1) after the 30th day of June 2004.” \n4Added by Finance Act 2017. \n5 Re-numbered by the Finance Act, 2018. \n6Added by the Finance Act, 2018. \n7 Section 242 added by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The amendment read as follows: \n  “The following provisions of the Income Tax Ordinance, 20021 (XLIX of 2001) already expired or \nexpiring on thirtieth day of June, 2021 are omitted, provided that the existing beneficiaries shall \ncontinue to enjoy benefits of the repealed provisions for the periods and subject to conditions and \nlimitations specified in theses repealed provisions, namely:-   \n1- \nSection 65D; \n2- \nFollowing clauses of Part-I of the Second Schedule :– (72), (126C), (126H), (126J), (126K), \n(126L) and (126N); and  \n3- \nClause (18A) of Part-II of the Second Schedule.”  \n\n\f\nChapter XIII – Miscellaneous_____________________________ \n \n487 \n \nAmendment) Ordinance, 2021 shall continue to enjoy benefits of the repealed \nprovisions for the periods prescribed therein and subject to conditions and \nlimitations specified therein.] \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n\n\f\nFirst Schedule – Part I __________________________________ \n \n488 \n   THE FIRST SCHEDULE \n \nPART I \nRATES OF TAX  \n(See Chapter II) \n \n1[ Division I \n                                            \n1 Division I substituted though Finance Act, 2019, substituted Division I read as follows: \nDivision I \n   Rates of Tax for Individuals \n1[(1) The rates of tax imposed on the taxable income of every individual, not being an individual to which paragraph \n(1A) of this Division applies, shall be as set out in the following table, namely:—  \nTABLE \n \nS. No. \nTaxable income \nRate of tax \n(1) \n(2) \n(3) \n1. \nWhere the taxable income does not exceed Rs. 400,000 \n0% \n2. \nWhere the taxable income exceeds Rs. 400,000 but does not \nexceed Rs. 800,000 \nRs. 1,000 \n3. \nWhere the taxable income exceeds Rs. 800,000 but does not \nexceed Rs.  1,200,000 \nRs. 2,000 \n4. \nWhere the taxable income exceeds Rs.1,200,000 but does \nnot exceed Rs. 2,400,000 \n5% of the amount exceeding Rs. \n1,200,000 \n5. \nWhere the taxable income exceeds Rs. 2,400,000 but does \nnot exceed Rs. 3,000,000 \n60,000 + 15% of the amount \nexceeding Rs. 2,400,000 \n6. \nWhere the taxable income exceeds Rs. 3,000,000 but does \nnot exceed Rs. 4,000,000 \n150,000 + 20% of the amount \nexceeding Rs. 3,000,000 \n7. \nWhere the taxable income exceeds Rs. 4,000,000 but does \nnot exceed Rs. 5,000,000 \n350,000 + 25% of the amount \nexceeding Rs. 4,000,000 \n8. \nWhere the taxable income exceeds Rs. 5,000,000 \n600,000 + 29% of the amount \nexceeding Rs. 5,000,000 \nProvided that where the taxable income exceeds eight hundred thousand rupees the minimum tax \npayable shall be two thousand rupees. \n                 (1A) Where the income of an individual chargeable under the head “salary” exceeds fifty per cent of his \ntaxable income, the rates of tax to be applied shall be as set out in the following table, namely:—  \n \nTABLE \n \nS. No. \nTaxable income \nRate of tax \n(1) \n(2) \n(3) \n1. \nWhere the taxable income does not exceed Rs. 400,000 \n0% \n2. \nWhere the taxable income exceeds Rs. 400,000 but does \nnot exceed Rs. 800,000 \nRs. 1,000 \n3. \nWhere the taxable income exceeds Rs. 800,000 but does \nnot exceed Rs.  1,200,000 \nRs. 2,000 \n4. \nWhere the taxable income exceeds Rs. 1,200,000 but does \nnot exceed Rs.  2,500,000 \n5% of the amount exceeding Rs. \n1,200,000 \n5. \nWhere the taxable income exceeds Rs.2,500,000 but does \nnot exceed Rs. 4,000,000 \n65,000 + 15% of the amount \nexceeding Rs. 2,500,000 \n6. \nWhere the taxable income exceeds Rs. 4,000,000 but does \nnot exceed Rs. 8,000,000 \n290,000 + 20% of the amount \nexceeding Rs. 4,000,000 \n7. \nWhere the taxable income exceeds Rs. 8,000,000 \n1,090,000 + 25% of the amount \nexceeding Rs. 8,000,000 \n\n\f\nFirst Schedule – Part I __________________________________ \n \n489 \n \n [Rates of Tax for Individuals and Association of Persons] \n \n(1) Subject to clause (2), the rates of tax imposed on income of every \nindividual and association of persons except a salaried individual shall be \nas set out in the following Table, namely:—  \n1[  ]  \n                                            \n \nProvided that where the taxable income exceeds eight hundred thousand rupees the minimum tax payable \nshall be two thousand rupees.”] \nRates of Tax for Association of Persons \n(2) The rates of tax imposed on the taxable income of every Association of Persons shall be as set out in the \nfollowing table, namely:— \nTABLE \nS. No. \nTaxable Income \nRate of Tax \n(1) \n(2) \n(3) \n1 \nWhere the tax able income does not exceed \nRs.400,000 \n0% \n2 \nWhere the tax able income exceeds  Rs.400,000  but \ndoes not exceed Rs.1,200,000 \n5% of the amount exceeding Rs.400,000 \n3 \nWhere the taxable income exceeds Rs.1,200,000 but \ndoes not exceed Rs.2,400,000 \nRs.40,000 + 10% of the amount exceeding \nRs.1,200,000 \n4 \nWhere the taxable income exceeds Rs 2,400,000 but \ndoes not exceed Rs.3,600,000 \nRs.160,000 + 15% of The amount exceeding \nRs.2,400,000 \n5 \nWhere the taxable income Exceeds Rs.3,600,000 but \ndoes not exceed Rs.4,800,000 \nRs.340,000 + 20% of the amount exceeding \nRs.3,600,000 \n6 \nWhere the taxable income exceeds Rs.4,800,000 but \ndoes not exceed Rs.6,000,000 \nRs.580,000+ 25% of The amount exceeding \nRs.4,800,000 \n7 \nWhere the tax able income exceeds Rs.6,000,000  \nRs.880,000+ 30% of the amount exceeding \nRs.6,000,000; \n \n1 Table substituted by the Finance Act, 2023. The substituted Table read as follows: \nTABLE \nS# \nTaxable Income \nRate of Tax \n(1) \n(2) \n(3) \n 1. \nWhere taxable income does not exceed Rs.600,000/-  \n0% \n2. \nWhere taxable income exceeds Rs. 600,000 but does \nnot exceed Rs. 800,000 \n5% of the amount exceeding Rs. \n600,000 \n3. \nWhere taxable income exceeds Rs. 800,000 but does \nnot exceed  Rs. 1,200,000 \nRs. 10,000 + 12.5% of the amount \nexceeding Rs.800,000 \n4. \nWhere taxable income exceeds Rs.1,200,000 but \ndoes not exceed  Rs. 2,400,000 \nRs.60,000 + 17.5% of the amount \nexceeding Rs.1,200,000 \n5. \nWhere taxable income exceeds Rs.2,400,000 but \ndoes not exceed Rs. 3,000,000 \nRs. 270,000 + 22.5% of the \namount exceeding Rs.2,400,000 \n6. \nWhere taxable income exceeds Rs.3,000,000 but \ndoes not exceed Rs. 4,000,000 \nRs.405,000 + 27.5% of the \namount exceeding Rs.3,000,000 \n7. \nWhere taxable income exceeds Rs.4,000,000 but \ndoes not exceed Rs. 6,000,000 \nRs. 680,000 + 32.5% of the \namount exceeding Rs.4,000,000 \n8. \nWhere taxable income exceeds Rs.6,000,000 \nRs. 1,330,000 + 35% of the \namount exceeding Rs.6,000,000. \n \n \n \n\n\f\nFirst Schedule – Part I __________________________________ \n \n490 \n \n1[TABLE \n \nS# \nTaxable Income \nRate of Tax \n(1) \n(2) \n(3) \n 1. \nWhere taxable income does not exceed \nRs. 600,000/- \n0% \n2. \nWhere taxable income exceeds Rs. \n600,000 but does not exceed Rs. \n1,200,000 \n15% \nof \nthe \namount \nexceeding Rs. 600,000 \n3. \nWhere taxable income exceeds Rs. \n1,200,000 but does not exceed Rs. \n1,600,000 \nRs. 90,000 + 20% of the \namount \nexceeding \nRs. \n1,200,000 \n4. \nWhere taxable income exceeds Rs. \n1,600,000 but does not exceed Rs. \n3,200,000 \nRs. 170,000 + 30% of the \namount \nexceeding \nRs. \n1,600,000 \n5. \nWhere taxable income exceeds Rs. \n3,200,000 but does not exceed Rs. \n5,600,000 \nRs. 650,000 + 40% of the \namount \nexceeding \nRs. \n3,200,000 \n6. \nWhere taxable income exceeds Rs. \n5,600,000 \nRs. 1,610,000 + 45% of the \namount \nexceeding \nRs. \n5,600,000: \n \n              Provided that in the case of an association of persons that is a \nprofessional firm prohibited from incorporating by any law or the rules of the \n                                            \n  \n1 Table substituted by the Finance Act, 2024. The substituted Table read as follows: \n“[ \nS# \nTaxable Income \nRate of Tax \n(1) \n(2) \n(3) \n 1. \nWhere taxable income does not exceed Rs. \n600,000/- \n0% \n2. \nWhere taxable income exceeds Rs. 600,000 but \ndoes not exceed Rs. 800,000 \n7.5% of the amount exceeding Rs. \n600,000 \n3. \nWhere taxable income exceeds Rs. 800,000 but \ndoes not exceed Rs. 1,200,000 \nRs. 15,000 + 15% of the amount \nexceeding Rs. 800,000 \n4. \nWhere taxable income exceeds Rs. 1,200,000 but \ndoes not exceed Rs. 2,400,000 \nRs. 75,000 + 20% of the amount \nexceeding Rs. 1,200,000 \n5. \nWhere taxable income exceeds Rs. 2,400,000 but \ndoes not exceed Rs. 3,000,000 \nRs. 315,000 + 25% of the amount \nexceeding Rs. 2,400,000 \n6. \nWhere taxable income exceeds Rs. 3,000,000 but \ndoes not exceed Rs. 4,000,000 \nRs. 465,000 + 30% of the amount \nexceeding Rs. 3,000,000 \n7. \nWhere taxable income exceeds Rs. 4,000,000 \nRs. 765,000 + 35% of the amount \nexceeding Rs. 4,000,000. \n ]” \n\n\f\nFirst Schedule – Part I __________________________________ \n \n491 \n \nbody regulating their profession, the 45% rate of tax mentioned against serial \nnumber 6 of the Table shall be 40%.] \n \n(2) \nWhere the income of an individual chargeable under the head \n“salary” exceeds seventy-five per cent of his taxable income, the rates of tax \nto be applied shall be as set out in the following table, namely:—  \n \n1[  ] \n \n2[  ]  \n                                            \n1 Table substituted by the Finance Act, 2023. The substituted Table read as follows: \nTABLE \nS# \nTaxable Income \nRate of Tax \n(1) \n(2) \n(3) \n1. \nWhere taxable income does not exceed Rs. \n600,000 \nRs. 0 \n2. \nWhere taxable income exceeds Rs.600,000 but \ndoes not exceed Rs.1,200,000 \n2.5% of the amount exceeding \nRs. 600,000 \n3. \nWhere taxable income exceeds Rs.1,200,000 \nbut does not exceed Rs.2,400,000 \nRs. 15,000 + 12.5% of the \namount exceeding Rs.1,200,000 \n4. \nWhere taxable income exceeds Rs.2,400,000 \nbut does not exceed Rs.3,600,000 \nRs. 165,000 + 20% of the \namount \nexceeding   \nRs. 2,400,000 \n5. \nWhere taxable income exceeds Rs.3,600,000 \nbut does not exceed Rs.6,000,000 \nRs. 405,000 + 25% of the \namount exceeding Rs.3,600,000 \n6. \nWhere taxable income exceeds Rs.6,000,000 \nbut does not exceed Rs.12,000,000 \nRs. 1,005,000 + 32.5% of the \namount exceeding Rs.6,000,000 \n7. \nWhere taxable income exceeds Rs.12,000,000 \nRs. 2,955,000 + 35% of the \namount \nexceeding  \nRs. 12,000,000 \n \n2 Table substituted by the Finance Act, 2024. The substituted Table read as follows: \n“[ \nS# \nTaxable Income \nRate of Tax \n(1) \n(2) \n(3) \n1. \nWhere taxable income does not exceed Rs. \n600,000/ \n0% \n2. \nWhere taxable income exceeds Rs. 600,000 \nbut does not exceed Rs. 1,200,000 \n2.5% of the amount exceeding \nRs. 600,000 \n3. \nWhere taxable income exceeds Rs. 1,200,000 \nbut does not exceed Rs. 2,400,000 \nRs. 15,000 + 12.5% of the \namount exceeding Rs. 1,200,000 \n4. \nWhere taxable income exceeds Rs. 2,400,000 \nbut does not exceed Rs. 3,600,000 \nRs. 165,000 + 22.5% of the \namount exceeding Rs. 2,400,000 \n5. \nWhere taxable income exceeds Rs. 3,600,000 \nbut does not exceed Rs. 6,000,000 \nRs. 435,000 + 27.5% of the \namount exceeding Rs. 3,600,000 \n6. \nWhere taxable income exceeds Rs. 6,000,000 \nRs. 1,095,000 + 35% of the \namount \nexceeding \nRs. \n6,000,000. \n\n\f\nFirst Schedule – Part I __________________________________ \n \n492 \n \n1[TABLE \n \nS# \nTaxable Income \nRate of Tax \n(1) \n(2) \n(3) \n1. \nWhere taxable income does not \nexceed Rs. 600,000/- \n0% \n2. \nWhere taxable income exceeds Rs. \n600,000 but does not exceed Rs. \n1,200,000/- \n1% of the amount exceeding \nRs. 600,000/- \n3. \nWhere taxable income exceeds Rs. \n1,200,000/- but does not exceed Rs. \n2,200,000/- \nRs. 6,000 + 11% of the amount \nexceeding Rs. 1,200,000/- \n4. \nWhere taxable income exceeds Rs. \n2,200,000/- but does not exceed Rs. \n3,200,000/- \nRs. 116,000 + 23% of the \namount \nexceeding \nRs. \n2,200,000/- \n5. \nWhere taxable income exceeds Rs. \n3,200,000/- but does not exceed Rs. \n4,100,000/- \nRs. 346,000 + 30% of the \namount \nexceeding \nRs. \n3,200,000/- \n6. \nWhere taxable income exceeds Rs. \n4,100,000/- \nRs. 616,000/- + 35% of the \namount \nexceeding \nRs. \n4,100,000/-: \n \n  \n \nProvided that pension received by an individual from a former \nemployer in a tax year, the rate of tax on such income shall be set out in the \nfollowing Table namely: — \n \n \n                                            \n \n1 Table substituted by the Finance Act, 2025. The substituted Table read as follows: \n    “ \nS# \nTaxable Income \nRate of Tax \n(1) \n(2) \n(3) \n1. \nWhere taxable income does not exceed Rs. \n600,000/- \n0% \n2. \nWhere taxable income exceeds Rs. 600,000 but \ndoes not exceed Rs. 1,200,000 \n5% of the amount exceeding Rs. \n600,000 \n3. \nWhere taxable income exceeds Rs. 1,200,000 \nbut does not exceed Rs. 2,200,000 \nRs. 30,000 + 15% of the amount \nexceeding Rs. 1,200,000 \n4. \nWhere taxable income exceeds Rs. 2,200,000 \nbut does not exceed Rs. 3,200,000 \nRs. 180,000 + 25% of the amount \nexceeding Rs. 2,200,000 \n5. \nWhere taxable income exceeds Rs. 3,200,000 \nbut does not exceed Rs. 4,100,000 \nRs. 430,000 + 30% of the amount \nexceeding Rs. 3,200,000 \n6. \nWhere taxable income exceeds Rs. 4,100,000 \nRs. 700,000 + 35% of the amount \nexceeding Rs. 4,100,000] \n” \n\n\f\nFirst Schedule – Part I __________________________________ \n \n493 \n \nS. No. \nDescription \nRate of Tax \n(1) \n(2) \n(3) \n1. \nWhere the amount of pension \nreceived does not exceed rupees ten \nmillion \n0% of the amount \n2. \nWhere the amount of pension \nreceived exceeds rupees ten million \n5% of the amount exceeding \nrupees ten million] \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n \n                                            \n1Para 2 omitted by the Finance Act, 2014.  The omitted para (2)  read as follows: \n \n“(2) The rate of tax payable on bonus as IDPT as income tax shall be 30% for the tax year 2010.” \n2 Clause (2) omitted by the Finance Act, 2006. The omitted clause (2) read as follows:  \n“2. \nWhere, for a tax year, an individual or association of persons to which subsection (1) of \nsection 92 applies derives income from agriculture to which section 41 applies and the gross \namount of such income for the year exceeds Rs. 80,000, the rates of tax imposed on the \ntaxable income of the individual or association of persons for the year shall be as set out in \nthe following table, namely:– \n“TABLE \nS. No. \n(1) \nTaxable income \n(2) \nRate of tax. \n(3) \n1. \n \n \nWhere taxable income does not exceed \nRs.150,000 \n7.5% \n2. \n \nWhere taxable income exceeds \nRs.150,000 but does not exceed \nRs.300,000 \nRs.11,250 plus 12.5% of the amount \nexceeding Rs.150,000. \n3. \n \nWhere taxable income exceeds \nRs.300,000 but does not exceed \nRs.400,000 \nRs.30,000 plus 20% of the amount \nexceeding Rs.150,000. \n4. \n \nWhere taxable income exceeds \nRs.400,000 but does not exceed \nRs.700,000  \nRs.50,000 plus 25% of the amount \nexceeding Rs.400,000 \n5. \n \nWhere taxable income exceeds \nRs.700,000 \nRs.125,000 plus 35% of the amount \nexceeding Rs.700,000” \n \n3Clause 3 omitted by the Finance Act 2002. The omitted clause 3 read as follows: \n   “3. \nThe rates of tax applicable to a legal representative of a deceased individual liable for tax \nunder clause (b) of sub-section (1) of section 87 shall be – \n(a) \nin the tax year in which the deceased died and the following tax year, \nthe rates applicable under clause 1; or \n(b) \nin any subsequent year, 35%.” \n \n4 “Division IA” omitted by the Finance Act, 2013. The omitted “Division IA” read as follows: \n“Division IA \nRate of Tax on certain persons \n \n \nThe rate of tax to be paid under sub-section (1) of section 113A shall be one per cent \nof the turnover.” \n\n\f\nFirst Schedule – Part I __________________________________ \n \n494 \n \n1[  ] \n2[   ]  \n \n  \n3[Division II \nRates of Tax for Companies \n \nThe rate of tax imposed on the taxable income of a company \nshall be as set out in the following Table, namely:- \n \n \n                                            \n1 “Division IB” omitted by the Finance Act, 2012. The omitted “Division IB” read as follows:- \n“Division IB \nRates of Tax for Association of Persons \n \n \nThe rate of tax imposed on the taxable income of Association of Persons for the tax \nyear 2010 and onward shall be 25%.” \n2Division II substituted by the Finance Act, 2002. The substituted Division II read as follows: \n“Division II \nRates of Tax for Companies \n \nThe rates of tax imposed on the taxable income of a company shall be as set out in the following table, \nnamely:– \nTABLE \nBanking \ncompany \n(1) \nPublic company, other than a \nbanking company. \n(2) \nPrivate company, other than a banking \ncompany. \n \n(3) \n50% \n35% \n45%” \n \n3 Division II substituted by the Finance Act, 2022. The substituted Division read as follows: \n \nDivision II \nRates of Tax for Companies \n3[(i) \nThe rate of tax imposed on the taxable income of a company for the tax year 2007 and onward \nshall be 35% 3[:] ] \n3[Provided that the rate of tax imposed on the taxable income of a company other than a \nbanking company, shall be 34% for the tax year 20143[: \nProvided further that the rate of tax imposed on the taxable income of a company, other \nthan a banking company, shall be 33% for the tax year 2015 3[“:”] ] ] \n3[“Provided further that the rate of tax imposed on taxable income of a company, other \nthan banking company shall be 32% for the tax year 2016, 31% for tax year 2017 3[,] 30% for tax year \n2018 and 3[29% for tax year 2019 and onwards.] 3[  ] 3[  ] \n3[(iii)  \nwhere the taxpayer is a small company as defined in section 2, tax shall be payable at \nthe rate of  3[25]% 3[:] ] \n3[  ] \n3[Provided  that  for  tax  year  2019  and onwards  tax  rates  shall  be  as  set  out  in  the \nfollowing Table, namely:— \nTax year \nRate of Tax \n2019 \n24% \n2020 \n23% \n2021 \n22% \n2022 \n21% \n2023 and onwards \n20%”; \n \n\n\f\nFirst Schedule – Part I __________________________________ \n \n495 \n \n1[Type of \nCompany \n \nRate of Tax \n(1) \n \n(2) \nBanking \nCompany \nTax Year \n2025 \nTax Year 2026 \nTax Year 2027 and \nonwards \n44% \n43% \n42% \nSmall \nCompany \n20% \nAny \nother \ncompany \n29%] \n \n \n    \n    2[   ] 3[Division IIA \n \nRate of super tax \n \nTABLE \n \nS.No. \nPerson \nRate of super tax \nRate (percentage of income) \n \nTax Year \n2018 \nTax Year \n2019 \nTax Year \n2020 \n4[Tax \nYears \n2021 and\n2022] \n(1) \n(2) \n(3) \n(4) \n      (5) \n    (6) \n                                            \n1 Table substituted by The Income Tax (Amendment) Act, 2025 (Act No. XIII of 2025). The substituted \nTable read as follows: \n    “Type of Company \nRate of Tax \n(1) \n(2) \nSmall company \n20% \nBanking company \n39% \nAny other company \n29%.]” \n \n2 Inserted by the Finance Act, 2015. \n3The Division IIA substituted by the Finance Act, 2018, the substituted Division IIA is read as under. \nDivision IIA \nRates of Super Tax \nPerson  \nRate of super tax \n \nBanking Company   \n \n4% of the income \n \nPerson, other than a banking  \n3% of the income” \ncompany, having income equal to \nor exceeding Rs.500 million \n \n4 The expression “Tax Year 2021 4[and onwards]” substituted by the Finance Act, 2022.  \n\n\f\nFirst Schedule – Part I __________________________________ \n \n496 \n \n1. \nBanking company \n 1[4]% \n4% \n 2[4]% \n3 [4]% \n2. \nPerson other than a \nbanking \ncompany, \nhaving income equal \nto or exceeding Rs. \n500 million \n3% \n2% \n 4[0]% \n0% \n \n \nProvided that in case of a banking company, super tax for tax year \n2019 shall be payable, on estimate basis, by thirtieth day of June, 2018. ]] \n \n5[Division IIB \nSuper Tax on high earning persons \n \nThe rate of tax under section 4C shall be – \n \n6[  ]  \n7[TABLE \n                                            \n1 The figure “0” substituted by “4” through Finance Supplementary (Second Amendment) Act, 2019 \n2 The figure “3” substituted by “4” through Finance Supplementary (Second Amendment) Act, 2019 \n3 The figure “2” substituted by “4” through Finance Supplementary (Second Amendment) Act, 2019 \n4 The figure “1” substituted by “0” through Finance Supplementary (Second Amendment) Act, 2019 \n5 Division IIB inserted by the Finance Act, 2022. \n6 Table substituted by the Finance Act, 2023. The substituted Table read as follows: \n \nS.No \nIncome under section 4C \nRate of Tax \n(1) \n(2) \n(3) \n1. \nWhere income does not exceed Rs.150 million \n0% of the income  \n2. \nWhere income exceeds Rs. 150 million but does not exceed Rs. 200 million  1% of the income  \n3. \nWhere income exceeds Rs. 200 million but does not exceed Rs. 250 million \n2% of the income \n4. \nWhere income exceeds Rs. 250 million but does not exceed Rs. 300 million \n3% of the income  \n5. \nWhere income exceeds Rs. 300 million \n4% of the income: \n \n7 Table substituted by the Finance Act, 2025. The substituted Table read as follows: \n“Table \n \nS. No \nIncome under section 4C \nRate of Tax \nFor tax year 2022 \nFor tax year 2023 and \nonwards \n(1) \n(2) \n(3) \n(4) \n1. \nWhere income does not exceed Rs. \n150 million \n0% of the income \n0% of the income \n2. \nWhere income exceeds Rs. 150 million \nbut does not exceed          Rs. 200 million \n1% of the income \n1% of the income \n3. \nWhere income exceeds Rs. 200 million \nbut does not exceed        Rs. 250 million \n2% of the income  \n2% of the income  \n\n\f\nFirst Schedule – Part I __________________________________ \n \n497 \n \n \nS. No Income \nunder \nsection 4C \n \nRate of Tax \n \nFor tax year \n2022 \nFor tax year \n2023, 2024 \nand 2025 \nFor tax year \n2026 and \nonwards \n(1) \n(2) \n(3) \n(4) \n(5) \n1. \nWhere \nincome \ndoes not exceed \nRs. 150 million \n0% \nof \nthe \nincome \n0% \nof \nthe \nincome \n0% \nof \nthe \nincome \n2. \nWhere \nincome \nexceeds Rs. 150 \nmillion but does \nnot exceed Rs. \n200 million \n1% \nof \nthe \nincome \n1% \nof \nthe \nincome \n1% \nof \nthe \nincome \n3. \nWhere \nincome \nexceeds Rs. 200 \nmillion but does \nnot exceed Rs. \n250 million \n2% \nof \nthe \nincome  \n2% \nof \nthe \nincome  \n1.5% of the \nincome  \n4. \nWhere \nincome \nexceeds Rs. 250 \nmillion but does \nnot exceed Rs. \n300 million \n3% \nof \nthe \nincome \n3% \nof \nthe \nincome \n2.5% of the \nincome \n5. \nWhere \nincome \nexceeds Rs. 300 \nmillion but does \nnot exceed Rs. \n350 million \n \n \n \n \n4% \nof \nthe \nincome \n4% \nof \nthe \nincome \n3.5% of the \nincome \n6. \nWhere \nincome \nexceeds Rs. 350 \nmillion but does \nnot exceed Rs. \n400 million \n6% \nof \nthe \nincome \n5.5% of the \nincome \n7. \nWhere \nincome \nexceeds Rs. 400 \n8% \nof \nthe \nincome \n7.5% of the \nincome \n                                            \n4. \nWhere income exceeds Rs. 250 million \nbut does not exceed        Rs. 300 million \n3% of the income \n3% of the income \n5. \nWhere income exceeds Rs. 300 million \nbut does not exceed        Rs. 350 million \n \n \n \n \n4% of the income \n4% of the income \n6. \nWhere income exceeds Rs. 350 million \nbut does not exceed        Rs. 400 million \n6% of the income \n7. \nWhere income exceeds Rs. 400 million \nbut does not exceed        Rs. 500 million \n8% of the income \n8. \nWhere income exceeds Rs. 500 million \n10% of the income: \n” \n\n\f\nFirst Schedule – Part I __________________________________ \n \n498 \n \nmillion but does \nnot exceed Rs. \n500 million \n8. \nWhere \nincome \nexceeds Rs. 500 \nmillion \n10% \nof \nthe \nincome: \n10% \nof \nthe \nincome \n \nProvided that for tax year 2022 for persons engaged, whether partly or wholly, \nin the business of airlines, automobiles, beverages, cement, chemicals, cigarette and \ntobacco, fertilizer, iron and steel, LNG terminal, oil marketing, oil refining, petroleum \nand gas exploration and production, pharmaceuticals, sugar and textiles the rate of \ntax shall be 10% where the income exceeds Rs. 300 million: \n \nProvided further that in case of banking companies for tax year 2023, the rate \nof tax shall be 10% where the income exceeds Rs. 300 million.] \n \n1[Division III \nRate of Dividend Tax \n \n \nThe rate of tax imposed under section 5 on dividend received from a \ncompany shall be- \n \n(a) 7.5% in the case of dividends paid by Independent Power 2[Producers] \nwhere such dividend is a pass through item under an Implementation \nAgreement or Power Purchase Agreement or Energy Purchase \nAgreement and is required to be re-imbursed by Central Power \nPurchasing (CPPA-G) or its predecessor or successor entity. \n                                            \n1Division III substituted though Finance Act, 2019, substituted Division read as follows: \n“Rate of Dividend Tax \n \nThe rate of tax imposed under section 5 on dividend received from a company shall be- \n(a) \n7.5% in the case of dividends declared or distributed by purchaser of a power \nproject privatized by WAPDA or on shares of a company set up for power \ngeneration or on shares of a company, supplying coal exclusively to power \ngeneration projects; and  \n1[(b) 1[15]%, in cases other than mentioned in clauses (a) and (c); \n(c)   1[12.5]% in case of dividend received by a person from a mutual fund 1[if the amount \nof dividend is above 2.5 million and 10% if the amount of dividend is less than or \nequal to 2.5 million.] ] \nProvided that the dividend received by a person from a stock fund shall be taxed at the \nrate of 12.5% for tax year 2015 and onwards, if dividend receipts are less than capital gains:  \nProvided further that the dividend received by a company from a collective investment \nscheme 1[,REIT Scheme”] or a mutual fund, other than a stock fund, shall be taxed at the rate \nof 1[15] for tax year 2015 and onwards1[:] ] \n1[Provided also that if a Developmental REIT Scheme with the object of development and \nconstruction of residential buildings is set up by thirtieth day of June, 1[2020], tax imposed on dividend \nreceived by a person from such Developmental REIT Scheme shall be reduced by fifty percent for \nthree years from 1[the date of setting up of the said scheme”. \n2 The word “Purchasers” substituted through Tax Law (Second Amendment) 2019 dated 26th \nDecember, 2019 \n\n\f\nFirst Schedule – Part I __________________________________ \n \n499 \n \n \n1[   ] \n \n2[(b)   15% in the case of Real Estate Investment Trust and cases other than   \nthose mentioned in clauses (a), (ba), (c) and (d);] \n \n3[(ba)  25% and 15%, in case of mutual funds, contingent upon proportional  \nincome derived from average annual investments in debt securities and \nequities respectively:  \n \nProvided that where the corporate entity is recipient of the \ndividend, the component derived from the debt securities shall be taxed \nat the rate of twenty-nine percent.] \n \n4[(c)    0% in case of dividend received by a REIT scheme from Special  Purpose \nVehicle and 35% in case of dividend received by others from Special \nPurpose Vehicle as defined under the Real Estate Investment Trust \nRegulations, 2015.] \n \n(d)   25% in case of a person receiving dividend from a company where no \ntax payable by such company, due to exemption of income or carry \nforward of business losses under Part VIII of Chapter III or claim of tax \ncredits under Part X of Chapter III.]  \n \n \n5[  ]  \n \n \n \n \n \n                                            \n1 Clause (b) substituted by the Finance Act, 2024. The substituted clause read as follows: \n“[(b) 15% in mutual funds 1[, Real Estate Investment Trusts] and cases other than those mentioned \nin clauses (a) 1[, (c) and (d).]” \n2 The Clause (b) substituted by the Finance Act, 2025. The substituted clause read as follows: \n \n“(b)  15% in the case of mutual funds, Real Estate Investment Trusts and cases other than those \nmentioned in clauses (a), (c) and (d): \n \n \nProvided that the rate of tax on dividend received from mutual funds deriving fifty percent or \nmore income from profit on debt shall be 25%.” \n3 The existing clause (c) re-numbered as clause (d) and a new clause (c) inserted by the Finance \n(Supplementary) Act, 2022. \n4 The existing clause (c) re-numbered as clause (d) and a new clause (c) inserted by the Finance \n(Supplementary) Act, 2022. \n5 Added by the Finance Act, 2015. \n\n\f\nFirst Schedule – Part I __________________________________ \n \n500 \n \n1[Division IIIA \n \nRate for Profit on Debt \n \nThe rate of tax for profit on debt imposed under section 7B shall be –  \n \n(a) \n20% of the yield or profit paid by a banking company or financial \ninstitution on an account or deposit maintained with such \ncompany or institution;  \n \n(b) \n20% of the yield or profit on Government securities under clause \n(c) of sub-section (1) of section 151 paid to any person other \nthan an individual; and  \n \n(c)  \n15% of the yield or profit in cases other than those mentioned \nin clauses (a) and (b).] \n \n \n2[     ] \n \n \n \n \n3[       ] \n                                            \n1 Division IIIA substituted by the Finance Act, 2025. The substituted Division read as follows: \n“Division IIIA \nRate for Profit on Debt \nThe rate of tax for profit on debt imposed under section 7B shall be 1[15%]” \n2 Table substituted through Finance Act, 2019, substituted table read as follow:  \n \n \n \n \n \n \nTABLE \nS.NO \nProfit on Debt \nRate of tax \n(1) \n(2) \n(3) \n1. \nWhere profit on debt does not exceed Rs.5,000,000 \n10% \n2. \nWhere profit on debt exceeds Rs.5,000,000 but does not exceed Rs.25,000,000 \n12.5% \n3. \nWhere profit on debt exceeds Rs.25,000,000  \n15% \n \n3 TABLE omitted by the Finance Act, 2021. The TABLE read as follows: \n“TABLE \nS.NO \nProfit on Debt \nRate of tax \n(1) \n(2) \n(3) \n1. \nWhere profit on debt does not exceed Rs.5,000,000 \n15% \n2. \nWhere profit on debt exceeds Rs.5,000,000 but does not exceed \nRs.25,000,000 \n17.5% \n3. \nWhere profit on debt exceeds Rs.25,000,000 but does not exceed Rs. \n36,000,000 \n20%] \n \n\n\f\nFirst Schedule – Part I __________________________________ \n \n501 \n \n1[Division IIIB \nRate of Tax on Return on investment in sukuks received from a special \npurpose vehicle \n \n \nThe rate of tax imposed under section 5AA on return on investment in \nsukuks received from a special purpose vehicle shall be— \n \n(a) 25% in the case the sukuk-holder is a company;  \n \n(b) 12.5% in case the sukuk-holder is an individual or an association of \nperson, if the return on investment is more than one million; and \n \n(c) \n10% in case the sukuk-holder is an individual and an association of \nperson, if the return on investment is less than one million.”]  \n \n2[DIVISION IV \n \nRate of Tax on Certain Payments \n \n  \nThe rate of tax imposed under section 6 on payments shall be 15% of the \ngross amount of royalty or fee for technical services 3[or fee of offshore digital \nservices] and 10% in any other case.  \n4[Division IVA \n \nRate of Tax on Payments for Digital Transactions in  \nE-commerce Platforms \n \n                                            \n1 Inserted by the Presidential Order No.F.2(1)2016-Pub dated 31.08.2016. \n \n2 Division IV substituted by the Finance Act, 2022. The substituted Division read as follows: \n“Division IV \nRate of Tax on Certain Payments to Non-residents \n \nThe rate of tax imposed under section 6 on payments to non-residents shall be 15% of the \ngross amount of the royalty or fee for technical services 2[and 5% of the gross amount of the fee for \noffshore digital services”.” \n3 Words inserted by the Finance Act, 2025. \n4 Division IVA inserted by the Finance Act, 2025. \n\n\f\nFirst Schedule – Part I __________________________________ \n \n502 \n \nThe rate of tax imposed under section 6A on payment for digitally ordered \ngoods or digitally delivered services through e-commerce platforms including \nwebsites shall be in case of payment through –  \n \n(i) \nDigital Means or banking channels by payment intermediary at the \nrate of 1% of gross amount paid or payable; and  \n \n(ii) \nCash on Delivery by courier service at the rate of 2% of the gross \namount paid or payable.]    \n \nDivision V \nRate of Tax on Shipping or Air Transport Income  \nof a Non-resident Person \n \n \nThe rate of tax imposed under section 7 shall be – \n \n(a) \nin the case of shipping income, 8% of the gross amount \nreceived or receivable; or \n \n(b) \nin the case of air transport income, 3% of the gross amount \nreceived or receivable. \n1[  ] \n \n                                            \n1 “Division VI” omitted by the Finance Act, 2013. The omitted “Division VI” read as follows: \n“Division VI \nIncome from Property \n \n(a) \nThe rate of tax to be paid under section 15, in the case of individual and \nassociation of persons, shall be— \nS.No. \nGross amount of rent \nRate of tax \n(1) \nWhere the gross amount of rent \ndoes not exceed Rs.150,000. \nNil \n(2) \nWhere the gross amount of rent \nexceeds Rs.150,000 but does not \nexceed Rs.400,000. \n5 per cent of the gross amount \nexceeding Rs.150,000. \n(3) \nWhere the gross amount of rent \nexceeds Rs.400,000 but does not \nexceed Rs.1,000,000. \nRs.12,500 plus 7.5 per cent of \nthe gross amount exceeding \nRs.400,000. \n(4) \nWhere the gross amount of rent \nexceeds Rs.1,000,000. \nRs.57,500 plus 10 per cent of \nthe gross amount exceeding \nRs.1,000,000. \n (b) \nThe rate of tax to be paid under section 15, in the case of company, shall be— \nS.No. \nGross amount of rent \nRate of tax \n(1) \nWhere the gross amount of rent \ndoes not exceed Rs.400,000. \n5 per cent of the gross amount \nof rent. \n(2) \nWhere the gross amount of rent \nexceeds Rs.400,000 but does not \nexceed Rs.1,000,000. \nRs.20,000 plus 7.5 per cent of \nthe gross amount of rent \nexceeding Rs.400,000. \n\n\f\nFirst Schedule – Part I __________________________________ \n \n503 \n \n1[    ]  2[   ] \n                                            \n(3) \nWhere the gross amount of rent \nexceeds Rs.1,000,000. \nRs.65,000 plus 10 per cent of \nthe gross amount of rent \nexceeding Rs.1,000,000.” \n \n1 Inserted by the Finance Act, 2016. \n2 Division VIA omitted by the Finance Act, 2021. The omitted Division read as follows: \n“Division VIA \nINCOME FROM PROPERTY \nThe rate of tax to be paid under section 15, in the case of individual and association of persons, \nshall be as follows:- \nS.No. \nGross amount of rent \nRate of tax \n(1) \n(2) \n(3) \n1. \nWhere the gross amount of rent does not exceed \nRs.200,000. \nNil \n2. \nWhere the gross amount of rent exceeds Rs.200,000 but \ndoes not exceed Rs.600,000. \n5 per cent of the gross amount \nexceeding Rs.200,000. \n3. \nWhere the gross amount of rent exceeds Rs.600,000 \nbut does not exceed Rs.1,000,000. \n \nRs.20,000 plus 10 per cent of \nthe gross amount exceeding \nRs.600,000. \n4. \nWhere \nthe \ngross \namount \nof \nrent \nexceeds \nRs.1,000,000 but does not exceed Rs.2,000,000. \n \nRs.60,000 plus 15 per cent of \nthe gross amount exceeding \nRs.1,000,000. \n5. \n \n \n6. \n \n \n7. \n \n \n \n8. \nWhere \nthe \ngross \namount \nof \nrent \nexceeds \nRs.2,000,000 2[but does not exceed Rs. 4,000,000]. \n \n2[Where the gross amount of rent exceeds Rs. \n4,000,000 but does not exceed Rs. 6,000,000 \n \nWhere the gross amount of rent exceeds Rs. \n6000,000 but does not exceeds Rs. 8,000,000 \n \nWhere the gross amount of rent exceeds Rs. \n8,000,000 \nRs.210,000 plus 20 per cent of \nthe gross amount exceeding \nRs.2,000,000”] \n \nRs.610,000 plus 25 per cent of \nthe gross amount exceeding \nRs.4,000,000 \n \nRs.1,110,000 plus 30 per cent \nof the gross amount exceeding \nRs.6,000,000 \n \nRs.1,710,000 plus 35 percent \nof the gross amount exceeding \nRs.8,000,000] “ \n \n\n\f\nFirst Schedule – Part I __________________________________ \n \n504 \n \n1[   ] 2[  ]  \n \n                                            \n1Division VII substituted by the Finance Act, 2015. The substituted Division VII read as follows:- \n \n[Division VII \nCapital Gains on disposal of Securities \n \nThe rate of tax to be paid under section 37A shall be as follows \n \nS.No. \nPeriod. \nTax Year. \nRate of tax. \n1 \n2 \n3 \n4 \n1. \nWhere holding period of a security is less \nthan six months. \n \n2011 \n2012 \n2013 \n2014 \n10% \n10% \n10% \n10% \n2. \nWhere holding period of a security is [more \nthan six months] but less than twelve \nmonths. \n \nTax Year 2015 \n \n2011 \n2012 \n2013 \n2014 \n \n7.5% \n8% \n8% \n8% \n \n3. \n \nWhere holding period of a security is less \nthan twelve months. \n \n12.5% \n4. \n Where holding period of a security is \ntwelve months or more but less than \ntwenty-four months. \n \n10% \n \n \n5. \nWhere holding period of  \na security is twenty-four months or more.” \n \n0% \n \n \n \n \n \nProvided that the rate for companies shall be as specified in Division II of Part I of First \nSchedule, in respective of debt securities;] \n \n \n \nProvided that a mutual fund or a collective investment scheme shall deduct Capital \nGains Tax at the rates as specified above, on redemption of securities as Prescribed. \n \n2 Division VII substituted by the Finance Act, 2016. Substituted  Division read as follows:- \n[“Division VII \nCapital Gains on disposal of Securities \n \n \nThe rate of tax to be paid under section 37A shall be as follows— \nS.No. \nPeriod \nTax Year 2015 \nTax Year 2016 \n(1) \n(2) \n(3) \n(4) \n1. \nWhere holding period of a security is less \nthan twelve months. \n12.5% \n \n15% \n2. \nWhere holding period of a security is twelve \nmonths or more but less than twenty four \nmonths. \n10% \n12.5% \n3. \nWhere holding period of a security is twenty \nfour months or more but less than four years. \n0% \n7.5% \n\n\f\nFirst Schedule – Part I __________________________________ \n \n505 \n \n1[   ] \n2[   ] \n                                            \n4. \nWhere holding period of a security is more \nthan four years \n0% \n0% \n \n \n1Substituted by the Finance Act, 2016. \n2 Division VII substituted by the Finance Act, 2022. The substituted Division read as follows: \n  “Division VII \nCAPITAL GAINS ON DISPOSAL OF SECURITIES \nThe rate of tax to be paid under section 37A shall be as follows:— \n2[       ] \n2[TABLE \nS. \nNo. \nPeriod \nTax \nYear \n2015 \nTax \nYear \n2016 \nTax \nYear \n2017 \nTax Years 2018, 2019 , \n2020 and 2021] \n \nTax Year 2022 \nand onwards \nSecurities \nacquired \nbefore \n01.07.2016 \nSecurities \nacquired \nafter \n01.07.2016 \n(1) \n(2) \n(3) \n(4) \n(5) \n(6) \n(7) \n(8) \n1. \nWhere holding \nperiod \nof \na \nsecurity is less \nthan \ntwelve \nmonths \n12.5% \n15% \n15% \n15% \n \n \n \n \n \n15% \n \n \n \n \n \n \n12.5% \n2. \nWhere \nholding \nperiod \nof \na \nsecurity is twelve \nmonths or more \nbut \nless \nthan \ntwenty-four \nmonths \n10% \n12.5% \n12.5% \n12.5% \n3. \nWhere holding \nperiod \nof \na \nsecurity \nis \ntwenty \n- \nfour \nmonths or more \nbut the security \nwas acquired on \nor after 1st July, \n2013. \n0% \n7.5% \n7.5% \n7.5% \n4. \nWhere \nthe \nsecurity \nwas \nacquired before \n1st July, 2013 \n0% \n0% \n0% \n0% \n0% \n0% \n5. \nFuture \ncommodity \ncontracts \nentered into by \nmembers \nof \nPakistan \n0% \n0% \n5% \n5% \n5% \n5%” \n\n\f\nFirst Schedule – Part I __________________________________ \n \n506 \n \n1[DIVISION VII  \n                                            \nMercantile \nExchange \n2[Provided that the rate of tax on cash settled derivatives traded on the stock \nexchange shall be 5% for the tax years 2018 to 2020.] \nProvided that the rate for companies shall be as specified in Division II of Part I of \nFirst Schedule, in respective of debt securities; \nProvided further that a mutual fund or a collective investment scheme or a REIT \nscheme shall deduct Capital Gains Tax at the rates as specified below, on redemption of \nsecurities as prescribed, namely:— \nCategory \nRate \nIndividual and association of \npersons \n10% for stock funds \n10% for other funds \nCompany  \n \n10% for stock funds \n25% for other funds \nProvided further that in case of a stock fund if dividend receipts of the fund are less \nthan capital gains, the rate of tax deduction shall be 12.5%: \nProvided further that no capital gains tax shall be deducted, if the holding period of the \nsecurity is more than four years.”] \n2[Explanation.- For removal of doubt, it is clarified that, the provisions of this proviso \nshall be applicable only in case of a mutual fund or collective investment scheme or a REIT \nscheme.] \n1 Division VII substituted by the Finance Act, 2024. The substituted Division read as follows: \n“DIVISION VII \nCapital Gains on Disposal of Securities \nThe rate of tax to be paid under section 37A shall be as follows:— \n  TABLE \nS.No \nHolding Period \nRate of Tax for Tax \nyear 2023 and onwards \n(1) \n(2) \n(3) \n1. \nWhere the holding period does not exceed one \nyear  \n15% \n2. \nWhere the holding period exceeds one year but \ndoes not exceed two years  \n12.5% \n3. \nWhere the holding period exceeds two years but \ndoes not exceed three years \n10% \n4. \nWhere the holding period exceeds three years but \ndoes not exceed four years \n7.5% \n5. \nWhere the holding period exceeds four years but \ndoes not exceed five years \n \n 5% \n6. \nWhere the holding period exceeds five years but \ndoes not exceed six years \n2.5% \n7. \nWhere the holding period exceeds six years  \n0% \n8. \nFuture commodity contracts entered into by \nmembers of Pakistan Mercantile Exchange \n5%: \nProvided that for securities except at S. No. 8 of the table,- \n(i) \nthe reduced rates of tax on capital gain arising on disposal shall apply where the securities are \nacquired on or after the first day of July, 2022; and \n1[(ii)  \nthe rate of 12.5% tax shall be charged on capital gain arising on disposal where the securities \nare acquired on or after the first day of July, 2013 but on or before the 30th day of June, 2022; and \n(iii)  \nthe rate of 0% tax shall be charged on capital gain arising on disposal where the securities are \nacquired before the first day of July, 2013:] \nProvided further that the rate for companies in respect of debt securities shall be as specified in \nDivision II of Part I of the First Schedule:  \n\n\f\nFirst Schedule – Part I __________________________________ \n \n507 \n \nCapital Gains on Disposal of Securities  \n \nThe rate of tax to be paid under section 37A shall be as follows: — \n \nTABLE   \n \nS. No. \nHolding Period \nRate of Tax \non disposal \nof securities \nacquired \nbetween 1st \nday of July, \n2022 \nand \n30th \nJune, \n2024 (both \ndates \ninclusive) \nRate of Tax on disposal \nof securities acquired on \nor after 1st day of July, \n2024  \n(1) \n(2) \n(3) \n(4) \n1. \nWhere the holding \nperiod \ndoes \nnot \nexceed one year  \n15% \n15% \nfor \npersons \nappearing on the Active \nTaxpayers’ List on the \ndate of acquisition and \nthe date of disposal of \nsecurities and at the rate \nspecified in Division I for \nindividuals \nand \nassociation of persons \nand \nDivision \nII \nfor \ncompanies in respect of \npersons not appearing on \nthe Active Taxpayers’ \nList on the date of \n2. \nWhere the holding \nperiod exceeds one \nyear but does not \nexceed two years  \n12.5% \n3. \nWhere the holding \nperiod exceeds two \nyears but does not \nexceed three years \n10% \n4. \nWhere the holding \nperiod exceeds three \nyears but does not \nexceed four years \n7.5% \n                                            \nProvided further that a mutual fund or a collective investment scheme or a REIT scheme \nshall deduct Capital Gains Tax at the rates as specified below, on redemption of securities as \nprescribed namely:—  \nCategory \nRate \nIndividual and association of persons \n10% for stock funds  \n10% for other funds \nCompany \n10% for stock funds  \n25% for other funds  \nProvided further that in case of a stock fund if dividend receipts of the fund are less than \ncapital gains, the rate of tax deduction shall be 12.5%: \n Provided further that no capital gains tax shall be deducted, if the holding period of the \nsecurity is more than six years. \nExplanation.- For removal of doubt, it is clarified that, the provisions of this proviso shall be applicable \nonly in case of a mutual fund or collective investment scheme or a REIT scheme.]” \n\n\f\nFirst Schedule – Part I __________________________________ \n \n508 \n \n5. \nWhere the holding \nperiod exceeds four \nyears but does not \nexceed five years \n5% \nacquisition and date of \ndisposal of securities: \nProvided that the rate of \ntax for individuals and \nassociation of persons not \nappearing on the Active \nTaxpayers’ List, the rate \nof tax shall not be less \nthan 15% in any case. \n6. \nWhere the holding \nperiod exceeds five \nyears but does not \nexceed six years \n2.5% \n7. \nWhere the holding \nperiod exceeds six \nyears  \n0% \n8. \nFuture commodity \ncontracts \nentered \ninto by members of \nPakistan Mercantile \nExchange \n5% \n5%: \n \nProvided that for securities except at S. No. 8 of the Table –  \n \n(i) \nthe rate of 12.5% tax shall be charged on capital gain arising on \ndisposal where the securities are acquired on or after the first day \nof July, 2013 but on or before the 30th day of June, 2022; and \n \n(ii)  \nthe rate of 0% tax shall be charged on capital gain arising on \ndisposal where the securities are acquired before the first day of \nJuly, 2013:  \n \nProvided further that the rate for companies in respect of debt \nsecurities shall be as specified in Division II of Part I of the First \nSchedule:  \n \nProvided also that a mutual fund or a collective investment \nscheme or a REIT scheme shall deduct Capital Gains Tax at the \nrates as specified below, on redemption of securities as prescribed, \nnamely: — \n \nCategory \nRate \nIndividual and association of persons \n15% for stock funds  \n15% for other funds \nCompany \n15% for stock funds  \n25% for other funds  \n \nProvided also that in case of a stock fund if dividend receipts \nof the fund are less than capital gains, the rate of tax deduction \nshall be 15%:  \n \n\n\f\nFirst Schedule – Part I __________________________________ \n \n509 \n \nProvided also that no capital gain shall be deducted, if the \nholding period of the security acquired on or before 30th day of \nJune 2024 is more than six years.  \n \nExplanation.– For the removal of doubt, it is clarified that \nprovisions of this proviso shall be applicable only in case of mutual \nfund or collective investment scheme or a REIT scheme.] \n \n1[   ] \n2[  ] \n3[   ]  \n \n                                            \n1Division VIII substituted through Finance Act, 2019, substituted Division read as follows:  \n “Division VIII \nCapital Gains on disposal of Immovable Property  \n \nThe rate of tax to be paid under sub-section (1A) of section 37 shall be as follows:— \n3 Table substituted through Finance Act, 2020 dated 30th June, 2020 \nS.No. \nAmount of Gain \nRate of tax \n(1) \n(2) \n(3) \n1. \nWhere the gain does not exceed Rs. 5 million \n5% \n2. \nWhere the gain exceeds Rs. 5 million but does not exceed \nRs. 10 million  \n10% \n3. \nWhere the gain exceeds Rs. 10 million but does not exceed \nRs. 15 million  \n15% \n4. \nWhere the gain exceeds Rs. 15 million  \n20%] \n \nProvided that gain arising on the disposal of immovable property  by a person in a tax year to a Rental \nREIT Scheme  shall be taxed at the rate of five percent  upto thirtieth day of June, 2019, irrespective of the holding \nperiod.] \n \n1[Provided that rate of tax to be paid under sub-section (1A) of section 37 shall be reduced by fifty per cent \non the first sale of immovable property acquired or allotted to ex-servicemen and serving personnel of Armed Forces \nor ex-employees or serving personnel of Federal and Provincial Governments, being original allottees of the \nimmovable property, duly certified by the allotment authority.] \n2 Division VIII substituted by the Finance Act, 2021. The substituted Division read as follows: \n3 Division VIII substituted by the Finance Act, 2022. The Division read as follows: \n   “Division VIII \nTax on Capital Gains on disposal of Immovable Property   \nThe rate of tax to be paid under sub-section (1A) of section 37 shall be as follows:— \nTABLE \n S. No. \nAmount of Gain \nRate of tax \n(1) \n(2) \n(3) \n1. \nWhere the gain does not exceed Rs. 5 million \n3.5% \n2. \nWhere the gain exceeds Rs. 5 million but does not exceed \nRs. 10 million  \n7.5% \n3. \nWhere the gain exceeds Rs. 10 million but does not exceed \nRs. 15 million  \n10% \n4. \nWhere the gain exceeds Rs. 15 million  \n15%” \n \n\n\f\nFirst Schedule – Part I __________________________________ \n \n510 \n \n1[Division VIII \n  \nThe rate of tax to be paid shall under sub-section (1A) of section 37  \nshall be as follows: –    \nTABLE \nS. No. \nHolding Period \nRate of Tax on properties \nacquired on or before 30th \nday of June, 2024 \nRate of Tax on \nproperties \nacquired on or \nafter 1st day of \nJuly, 2024 \n \n \nOpen \nPlots  \nConstructed \nProperty \nFlats \n(1) \n(2) \n(3) \n(4) \n(5) \n(6) \n1. \nWhere \nthe \nholding \nperiod \ndoes not exceed \none year  \n15% \n15% \n15% \n15% for persons \nappearing \non \nthe \nActive \nTaxpayers’ List \non \ndate \nof \ndisposal \nof \nproperty and at \nthe \nrates \nspecified \nin \nDivision \nI \nfor \nindividuals and \nassociation \nof \npersons \nand \nDivision II for \n2. \nWhere \nthe \nholding \nperiod \nexceeds \none \nyear but does \nnot exceed two \nyears  \n12.5% \n10% \n7.5% \n3. \nWhere \nthe \nholding \nperiod \nexceeds \ntwo \nyears but does \n10% \n7.5% \n0 \n                                            \n1 Division VIII substituted by the Finance Act, 2024. The substituted Division read as follows: \n“Division VIII \nThe rate of tax to be paid shall under sub-section (1A) of section 37 shall be as follows:  \nS. No \nHolding Period \nRate of Tax \n \n \nOpen Plots  \nConstructed \nProperty \nFlats  \n(1) \n(2) \n(3) \n(4) \n(5) \n1. \nWhere the holding period does not exceed \none year  \n15% \n15% \n15% \n2. \nWhere the holding period exceeds one \nyear but does not exceed two years  \n12.5% \n10% \n7.5% \n3. \nWhere the holding period exceeds two \nyears but does not exceed three years \n10% \n7.5% \n0 \n4. \nWhere the holding period exceeds three \nyears but does not exceed four years \n7.5% \n5% \n- \n5. \nWhere the holding period exceeds four \nyears but does not exceed five years \n5% \n0 \n- \n6. \nWhere the holding period exceeds five \nyears but does not exceed six years \n2.5% \n- \n- \n7. \nWhere the holding period exceeds six \nyears  \n0% \n- \n-] \n        ]” \n\n\f\nFirst Schedule – Part I __________________________________ \n \n511 \n \nnot exceed three \nyears \ncompanies \nin \nrespect \nof \npersons \nnot \nappearing \non \nthe \nActive \nTaxpayers’ List \non the date of \ndisposal \nof \nproperty: \n \n \nProvided \nthat the rate of \ntax \nfor \nindividuals \nand \nassociation \nof \npersons \nnot \nappearing on the \nActive \nTaxpayers’ \nList \non the date of \ndisposal, the rate \nof tax shall not be \nless than 15% of \nthe gain. \n4. \nWhere \nthe \nholding \nperiod \nexceeds \nthree \nyears but does \nnot exceed four \nyears \n7.5% \n5% \n- \n5. \nWhere \nthe \nholding \nperiod \nexceeds \nfour \nyears but does \nnot exceed five \nyears \n5% \n0 \n- \n6. \nWhere \nthe \nholding \nperiod \nexceeds \nfive \nyears but does \nnot exceed six \nyears \n2.5% \n- \n- \n7. \nWhere \nthe \nholding \nperiod \nexceeds \nsix \nyears  \n0% \n- \n- \n] \n \n1[Division VIIIA \nTAX ON BUILDERS \n \nThe rate of tax under section 7C shall be as follows: \n \n(A) \nKarachi, \nLahore \nand Islamabad \n(B) \nHyderabad, \nSukkur, \nMultan, \nFaisalabad, \nRawalpindi, \nGujranwala, \nSahiwal, \nPeshawar, \nMardan, \nAbbottabad, \nQuetta \n(C) Urban Areas not \nspecified in A and B \nFor commercial buildings \nRs. 210/ Sq Ft \nRs. 210/ Sq Ft \nRs. 210/ Sq Ft \nFor residential buildings \n                                            \n1 Inserted by the Finance Act, 2016. \n\n\f\nFirst Schedule – Part I __________________________________ \n \n512 \n \nArea in Sq. \nft \nRate/ \nSq. Ft \nArea in Sq. \nFt \nRate/ Sq. Ft \nArea in \nSq. Ft \nRate/ Sq. \nFt \nUp to750 \nRs. 20 \nUp to750 \nRs. 15 \nUp to 750 \nRs. 10 \n751 \nto \n1500 \nRs. 40 \n751 \nto \n1500 \nRs. 35 \n751 \nto \n1500 \nRs. 25 \n1501 \n& \nmore \nRs. 70 \n1501 \nand \nmore \nRs. 55 \n1501 and \nmore \nRs. 35 \n \n1[Division VIIIB \nTAX ON DEVELOPERS \n \nThe rate of tax under section 7D shall be as follows: \n \n(A) Karachi, Lahore and \nIslamabad \n(B) \nHyderabad, \nSukkur, \nMultan, \nFaisalabad, \nRawalpindi, \nGujranwala, \nSahiwal, Peshawar, Mardan, \nAbbottabad, Quetta \n(C) \nUrban \nAreas \nnot \nspecified in A and B \nFor commercial Plots \nRs. 210/ Sq Yd \nRs. 210/ Sq Yd \nRs. 210/ Sq Yd \nFor residential Plots \nArea in Sq. \nYd \nRate/ \nSq. Yd \nArea in sq. \nYd \nRate/ Sq. \nYd \nArea in Sq. \nYd \nRate/ Sq. \nYd \nUp to 120  \nRs. 20  \nUp to 120  \nRs. 15  \nUp to 120  \nRs. 10  \n121 to 200  \nRs. 40  \n121 to 200  \nRs. 35  \n121 to 200  \nRs. 25  \n201 \nand \nmore  \nRs. 70  \n201 and  more  \nRs. 55  \n201 \nand \nmore  \nRs. 35”]  \n \n \n2[Division VIIIC \nTax on deemed income \n \nThe rate of tax under section 7E shall be 20%.] \n     \n3[Division IX \n                                            \n1 Inserted by the Finance Act, 2016.  \n2Division VIIIC added by the Finance Act, 2022. \n3Division IX added by the Finance Act, 2014. \n\n\f\nFirst Schedule – Part I __________________________________ \n \n513 \n \nMinimum tax under section 113] \n \n1[S. No. \nPerson(s) \nMinimum Tax \nas \npercentage of \nthe person’s \nturnover for the \nyear \n(1) \n(2) \n(3) \n1. \n(a) 2[  ] Sui Southern Gas Company Limited and Sui \nNorthern Gas Pipelines Limited (for the cases \nwhere annual turnover exceeds rupees one \nbillion.) \n(b) Pakistani International Airlines Corporation; and  \n(c) \nPoultry industry including poultry breeding, broiler \nproduction, egg production and poultry feed \nproduction; \n0.75%  \n                                            \n1 Table of Division IX substituted by the Finance Act, 2021. The substituted Table read as follows: \nS.No \nPerson(s) \nMinimum Tax as \npercentage of \nthe person’s \nturnover for the \nyear \n(1) \n(2) \n(3) \n1. \n(a) Oil marketing companies, Oil refineries, Sui Southern Gas \nCompany Limited and Sui Northern Gas Pipelines Limited \n(for the cases where annual turnover exceeds rupees one \nbillion.) \n(b) \nPakistani Airlines; and  \n(c) \nPoultry industry including poultry breeding, broiler production, egg \nproduction and poultry feed production. \n1[(d)  Dealers or distributors of fertilizer 1[; and] \n1[(e)   person running an online    marketplace as defined in clause \n(38B) of section 2.] \n1[0.75%  \n 2. \n(a) \nDistributors of pharmaceutical products, \n1[ ] fast moving \nconsumer goods 1[ ] and cigarettes;  \n(b) \nPetroleum agents and distributors who are registered under the \nSales Tax Act, 1990;  \n(c) Rice mills and dealers; and \n(d)  Flour mills.  \n0.25%  \n3. \nMotorcycle dealers registered under the Sales Tax Act, 1990.  \n0.3%  \n4. \nIn all other cases. \n1.5%] \n \n2 The expression “Oil marketing companies,” omitted by the Finance Act, 2022. \n\n\f\nFirst Schedule – Part II________ __________________________ \n \n514 \n 2. \n(a) Oil refineries \n(b) Motorcycle dealers registered under the Sales Tax \nAct, 1990 \n1[(c)   Oil marketing companies] \n \n0.5%  \n3. \n(a)   Distributors of pharmaceutical products, fast     \nmoving consumer goods  and cigarettes; \n (b)   Petroleum agents and distributors who are  \nregistered under the Sales Tax Act, 1990;   \n(c)   Rice mills and dealers;  \n(d)  Tier-1 retailers of fast moving consumer goods who \nare integrated with Board or its computerized \nsystem for real time reporting of sales and receipts;  \n(e) Person’s turnover from supplies through  e-\ncommerce including from running an online \nmarketplace as defined in clause (38B) of section 2.  \n(f)  Persons engaged in the sale and purchase of used \nvehicles; and  \n(g)    Flour mills \n0.25%  \n4. \nIn all other cases. \n1.25%] \n \n2[PART II \nRATES OF ADVANCE TAX \n[See Division II of Part V of Chapter X] \n \n                                            \n1 The paragraph (c) added by the Finance Act, 2022. \n2 Table substituted thought Finance Act, 2020 dated 30th June, 2020, substituted table read as follows: \n“PART II \nRATES OF ADVANCE TAX \n[See Division II of Part V of Chapter X] \nThe rate of advance tax to be collected by the Collector of Customs under section 148 shall be- \nS.No. \nPersons \nRate \n(1) \n(2) \n(3) \n1. \n(i) \nIndustrial undertaking importing remeltable steel \n(PCT Heading 72.04) and directly reduced iron for \nits own use;  \n(ii) \nPersons importing potassic fertilizers in \npursuance \nof \nEconomic \nCoordination \nCommittee of the cabinet’s decision No.ECC-\n155/12/2004 dated the 9th  December, 2004;  \n(iii) \nPersons importing urea;   \n(iv) \nManufacturers covered under Notification No. \nS.R.O. 1125(I)/2011 dated the 31st December, \n2011 and importing items covered under S.R.O. \n1125(I)/2011 dated the 31st December, 2011; \n(v) \nPersons importing Gold; \n(vi) \nPersons importing Cotton; and  \n(vii) \n2[Persons importing LNG] \n1% of the import \nvalue as increased by \ncustoms-duty, sales \ntax and federal excise \nduty \n\n\f\nFirst Schedule – Part II________ __________________________ \n515 \n \nThe rate of advance tax to be collected by the Collector of Customs under section \n148 shall be- \n  \nS.No \nPersons \nRate \n(1) \n(2) \n(3) \n1. \nPersons importing goods classified in Part I of the \nTwelfth Schedule \n1% of the import \nvalue as increased \nby \ncustoms-duty, \nsales \ntax \nand \nfederal excise duty \n2. \nPersons importing goods classified in Part II of the \nTwelfth Schedule  \n2% of the import \nvalue as increased \nby \ncustoms-duty, \nsales \ntax \nand \nfederal excise duty \n1[and 3.5% of the \n                                            \n2. \nPersons importing pulses \n2% of the import \nvalue as increased by \ncustoms-duty, sales \ntax and federal excise \nduty \n3. \nCommercial importers covered under Notification \nNo. S.R.O. 1125(I)/2011 dated the 31st December, \n2011 and importing items covered under S.R.O. \n1125(I)/2011 dated the 31st December, 2011.  \n3% of the import \nvalue as increased by \ncustoms-duty, sales \ntax and federal excise \nduty \n2[3A \nPersons importing coal \n4% \n4. \nShip breakers on import of ships \n4.5%  \n5. \nIndustrial undertakings not covered under S. Nos. 1 to 4 \n5.5% \n6. \nCompanies not covered under S. Nos. 1 to 5 \n5.5% \n7. \nPersons not covered under S. Nos. 1 to 6 \n6%] \n \nProvided that the rate specified in column (3),—  \n(a) \nin the case of industrial undertaking, 2[ ] importing plastic raw material falling under PCT \nHeading 39.01 to 39.12 for its own use shall be 1.75% of the import value as increased by \ncustoms duty, sales tax and Federal excise duty; and \n(b) \nin the case of a commercial importer, 2[ ] importing   plastic raw material falling under PCT \nHeading 39.01 to 39.12  shall be 4.5 % of the import value as increased by customs duty, \nsales tax and Federal excise duty] 2[:]  \n2[Provided further that the rate of tax on value of import of mobile phone by any person \nshall be as set out in the following Table, namely:- \nTable \nS.No. \nC & F Value of mobile phone (in US Dollar) \nTax  \n(in Rs.) \n(1) \n(2) \n(3) \n1 \nUp to 30 \n70 \n2 \nExceeding 30 and up to 100  \n2[100] \n3 \nExceeding 100 and up to 200 \n930 \n4 \nExceeding 200 and up to 350 \n970 \n5 \nExceeding 350 and up to 500 \n3,000 \n6 \nExceeding 500 \n5,200] \n \n1 The expression added by the Finance Act, 2022. \n\n\f\nFirst Schedule – Part II________ __________________________ \n516 \n \nimport value as \nincreased \nby \ncustoms \nduty, \nsales \ntax \nand \nfederal excise duty \nin \ncase \nof \ncommercial \nimporter] \n3. \nPersons importing goods classified in Part III of \nthe Twelfth Schedule  \n5.5% of the import \nvalue as increased \nby \ncustoms-duty, \nsales \ntax \nand \nfederal excise duty \n1[and 6% of the \nimport value as \nincreased \nby \ncustoms \nduty, \nsales \ntax \nand \nfederal excise duty \nin \ncase \nof \na \ncommercial \nimporter:] ’;] \n2[Provided that the rate specified in column (3),—  \n(a) in the case of manufacturers covered under rescinded Notification \nNo. S.R.O 1125(I)/2011 dated the 31st December, 2011 as it stood \non the 28th June, 2019 on import of items covered under the \naforementioned S.R.O shall be 1%; \n \n(b) in case of persons importing finished pharmaceutical products \nthat are not manufactured otherwise in Pakistan, as certified by \nthe Drug Regulatory Authority of Pakistan shall be 4% 3[: \n \n (c)   in case of importers of CKD kits of electric vehicles for small cars \nor SUVs with 50 kwh battery or below and LCVs with 150 kwh \nbattery or below shall be one percent:] \n  \nProvided further that the rate of tax on value of import of mobile phone by \nany person shall be as set out in the following table, namely:- \n \nTable \n \n                                            \n1 The expression added by the Finance Act, 2023. \n \n3 Colon substituted and new clause (c) added by the Finance Act, 2021. Earlier this substitution and \naddition were made through Tax Laws (Amendment) Ordinance, 2021. \n\n\f\nFirst Schedule – Part II________ __________________________ \n517 \n \nS. No. \n \nC & F Value of mobile phone \n(in US Dollar) \nTax (in Rs.) \nIn CBU \ncondition \nPCT \nHeading \n8517.1219 \nIN CKD/SKD \ncondition \nunder PCT \nHeading \n8517.1211 \n(1) \n(2) \n(3) \n(4) \n1 \nUp to 30 except smart phones  \n70 \n0 \n2 \nExceeding 30 and up to 100 \nand smart phones up to 100  \n100 \n0 \n3 \nExceeding 100 and up to 200 \n930 \n0 \n4 \nExceeding 200 and up to 350 \n970 \n0 \n1[5 \nExceeding 350 and up to 500 \n5000 \n3000 \n6 \nExceeding 500 \n11,500 \n5,200] \n \n \n2[     ] \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n                                            \n1 S. Nos 5 & 6 and entries relating thereto substituted by the Finance Act, 2022. The substituted S. \nNos read as follows:    \n5 \nExceeding 350 and up to 500 \n3,000 \n5,000 \n6 \nExceeding 500 \n5,200 \n11,500 \n \n2  Part IIA omitted by the Finance Act, 2014. The omitted part IIA read as follows: \n“PART IIA \nCOLLECTION OF TAX FROM DISTRIBUTORS, DEALERS \nAND WHOLESALERS \n(See section 153A) \nThe rate of tax to be collected under section 153A, shall be 0.5% of the gross amount of sales.” \n\n\f\nFirst Schedule – Part IIB______ __________________________ \n \n518 \n1[Part IIB  \nRates of Advance Tax  \n[see sub-section (5C) of section 147]  \nTABLE \n \n \nRate in respect of \n(1) \n(2) \n(3) \n(4) \n \n \nArea in \n \nKarachi, Lahore \nand Islamabad \nHyderabad, Sukkur, \nMultan, Faisalabad, \nRawalpindi, Gujranwala, \nSahiwal, Sialkot, \nBahawalpur, Peshawar, \nMardan, Abbottabad, \nQuetta \n \nUrban Areas not \nspecified in  \ncolumns (2) and (3) \n \nTAX ON PERSONS FALLING UNDER SECTION 147(5C)(i) FOR COMMERCIAL BUILDINGS \nSq. Ft. \n- \n- \n- \nAny size \nRs.250 per Sq. ft. \nRs.230 per Sq. ft. \nRs.210 per Sq. ft. \nTAX ON PERSONS FALLING UNDER SECTION 147(5C)(i) FOR RESIDENTIAL BUILDINGS \nSq. Ft. \n- \n- \n- \nupto 3000 \nRs.80 per Sq. ft. \nRs.65 per Sq. ft. \nRs.50 per Sq. ft. \n3000 and above \nRs.125 per Sq. ft. \nRs.110 per Sq. ft. \nRs.100 per Sq. ft. \nTAX ON PERSONS FALLING UNDER SECTION 147(5C)(ii) \nSq. Yds. \n- \n- \n- \nAny size \nRs.150 per Sq. yd \nRs.130 per Sq. yd \nRs.100 per Sq. yd \nTAX ON PERSONS FALLING UNDER SECTION 147(5C)(ii) FOR DEVELOPMENT OF \nINDUSTRIAL AREA \nSq. Yds. \n- \n- \n- \nAny size \nRs.20 per Sq. yd \nRs.20 per Sq. yd \nRs.10 per Sq. yd: \n \nProvided that in case of mixed use buildings having both commercial and \nresidential areas, respective rates mentioned above shall apply:  \n \nProvided further that in case of development of plots and constructing \nbuildings on the same plots as one project, both rates shall apply.] \n \n \n \n \n                                            \n1 Part IIB inserted by the Finance Act, 2023. \n\n\f\nFirst Schedule – Part III______ __________________________ \n \n519 \nPART III \nDEDUCTION OF TAX AT SOURCE \n(See Division III of Part V of Chapter X) \n \n1[Division I \nAdvance Tax on Dividend \n \nThe rate of tax to be deducted under section 150 2[  ] 3[  ] shall be-  \n \n4[(a)  7.5% in case of dividend paid by Independent Power 5[Producers] \nwhere such dividend is a pass through item under an Implementation \nAgreement or Power Purchase Agreement or Energy Purchase \nAgreement and is required to be re-imbursed by Central Power \nPurchasing Agency (CPPA-G) or its predecessor or successor entity.]     \n \n6[   ] \n \n    7[   ] \n  \n    8[(b) 15% in the case of Real Estate Investment Trust and cases other       \nthan   those mentioned in clauses (a), (ba), (c) and (d);] \n \n                                            \n1Division-I substituted by the Finance Act, 2014. The substituted Division-I read as follows:  \n“ [Division I \nProfit on Debt \n \nThe rate of tax to be deducted under section 151 shall be 10% of the yield or profit paid.” \n2Inserted by the Finance Act, 2015. \n3 The expression “and 236S” omitted by the Finance Act, 2021. \n4 Paragraph (a) substituted though Finance Act, 2019, substituted para read as follow: \n(a) \n“7.5% in the case of dividends declared or distributed by purchaser of a power project privatized by \nWAPDA or on shares of a company set up for power generation or on shares of a company, supplying \ncoal exclusively to power generation projects;” \n5 The word “Purchasers” substituted through Tax Laws (Second Amendment), 2019 dated 26th \nDecember, 2019. \n6 The clause (b) substituted and new clause (ba) added through Finance Act, 2020 dated 30th June \n2020  the substituted clause (b) read as follows: “6[ 6[15] % 6[   ] other than mentioned in (a) above;”    \n7 Clause (b) substituted by the Finance Act, 2024. The substituted clause read as follows: \n“[(b) 15% in mutual funds 7[, Real Estate Investment Trusts] and cases other than those mentioned \nin clauses (a) 7[, (c) and (d).]” \n8 The Clause (b) substituted by the Finance Act, 2025. The substituted clause read as follows: \n \n“(b)  15% in the case of mutual funds, Real Estate Investment Trusts and cases other than those \nmentioned in clauses (a), (c) and (d): \n \n \nProvided that the rate of tax on dividend received from mutual funds deriving fifty percent or \nmore income from profit on debt shall be 25%.” \n\n\f\nFirst Schedule – Part III_______ __________________________ \n520 \n \n1[(ba) 25% and 15%, in case of mutual funds, contingent upon proportional         \nincome derived from average annual investments in debt securities and \nequities respectively:  \n \nProvided that where the corporate entity is recipient of the dividend, \nthe component derived from the debt securities shall be taxed at the rate of \ntwenty-nine percent.] \n \n2[(c) 0% in case of dividend received by a REIT scheme from Special Purpose \nVehicle and 35% in case of dividend received by others from Special \nPurpose Vehicle as defined under the Real Estate Investment Trust \nRegulations, 2015; and] \n \n3[(d)]  25% in case of a person receiving dividend from a company where no tax is \npayable by such company, due to exemption of income or carry forward of \n                                            \n1 The existing clause (c) re-numbered as clause (d) and a new clause (c) inserted by the Finance \n(Supplementary) Act, 2022. \n2 Clause (c) inserted by the Finance (Supplementary) Act, 2022. \n3 Clause (ba) re-numbered as clause (d) by the Finance (Supplementary) Act, 2022. \n\n\f\nFirst Schedule – Part III_______ __________________________ \n521 \n \nbusiness losses under Part VIII Chapter III or claim of tax credits under Part \nX of Chapter III.] \n \n1[  ]  \n2[Division IA \nProfit on Debt \n \nThe rate of tax to be deducted under section 151 shall be –  \n \n(a) \n20% of the yield or profit paid by a banking company or financial \ninstitution on an account or deposit maintained with such company or \ninstitution;  \n \n(b) \n20% of the yield or profit on Government securities under clause (c) \nof sub-section (1) of section 151 paid to any person other than an \nindividual; and  \n \n(c)     15% of the yield or profit in cases other than those mentioned in clauses \n(a) and (b).] \n \n                                            \n1 Para (c) and provisos thereafter omitted through Finance Act, 2019, omitted para read as follows: \n   \n(c) 20% for non-filers other than mentioned in (a) above:  \nProvided that the rate of tax required to be deducted by a collective investment scheme 1[, REIT Scheme] or \na mutual fund shall be-  \n1[Person \nStock Fund \nMoney market fund, income fund or REIT scheme or any other fund \nFiler \nNon-Filer \n(1) \n(2) \n(3) \n(4) \nIndividual \n1[12.5]% \n1[12.5]% \n15% \nCompany \n1[12.5]% \n1[15%] \n25% \nAOP \n1[12.5]% \n1[12.5]% \n15%”] \nProvided further that in case of a stock fund if dividend receipts of the fund are less than capital gains, the \nrate of tax deduction shall be 12.5% 1[“:”] ] \n1[“Provided further that if a Developmental REIT Scheme with the object of development and construction of \nresidential buildings is setup by thirtieth day of June, 1[2020], rate of tax on dividend received by a person from such \nDevelopmental REIT Scheme shall be reduced by fifty percent for three years from 1[the date of setting up of the said \nscheme]1[:] \n1[Provided further that the rate of tax on dividend received by a person, other than a company, \nfrom a money market mutual fund shall be 10%, if the amount of dividend does not exceed two and a \nhalf million Rupees.1[;]] \n1[Provided also that the rate of tax on dividend received by an individual,  from a Rental REIT \nScheme shall be 7.5%.”;]” \n \n2 Division IA substituted by the Finance Act, 2025. The substituted Division read as follows: \n“Division IA \nProfit on Debt \n \nThe rate of tax to be deducted under section 151 shall be 2[15%] of the yield or profit 2[.]   2[  ]  \n \n2[   ]” \n \n \n\n\f\nFirst Schedule – Part III_______ __________________________ \n522 \n \n1[Division IB \nReturn on Investment in Sukuks \n \nThe rate of tax to be deducted 2[on return on investment in sukuks from a \nsukuk holder] shall be— \n \n(a) \n3[25]% in case the sukuk-holder is a company;   \n(b) \n12.5% in case the sukuk-holder is an individual or an \nassociation of person, if the return on investment is more than \none million;  \n(c) \n10% in case the sukuk-holder is an individual and an \nassociation of person, if the return on investment is less than \none million; and] \n4[  ]  \n \n5[Division II \nPayments to non-residents \n \n \n  (1) The rate of tax to be deducted from a payment referred to in sub-section \n(1A) of section 152 shall be 6[7% of the gross amount payable 7[  ] s]. \n \n \n8[(1A) The rate of tax to be deducted from payments referred to in sub-\nsection (1AA) of section 152, shall be 5% of the gross amount paid.] \n \n \n(2) The rate of tax to be deducted under sub-section (2) of section 152 shall \nbe 9[20]% of the gross amount paid.] \n \n \n10[(3) The rate of tax to be deducted under sub-section (1AAA) of \nsection152, shall be 10% of the gross amount paid.] \n                                            \n1 Inserted by the Presidential Order No.F.2(1)/2016-Pub dated 31.08.2016. \n2 The expression “under section 150A” substituted by the Finance Act, 2021. \n3The figure “15” substituted through Finance Act, 2020 dated 30th June 2020. \n4In Division IB, paragraph(d)omitted through Finance Act, omitted paragraph read as follow:  \n  “(d) 17.5% in case the sukuk-holder is a non-filer”    \n5 Division-II substituted by the Finance Act, 2006. The substituted “Division-II” read as follows: \n“Division II \nPayments to non-residents \n The rate of tax to be deducted under sub-section (2) of section 152 shall be 30% of the gross amount \npaid.” \n6The expression “6% of the gross amount payable” substituted by the Finance Act, 2016. \n7The words “in case a person is a filer 13% in case the person is a non-filer” omitted through Finance \nAct, 2019. \n8Inserted by the Finance Act, 2008. \n9The figure “30” substituted by the Finance Act, 2010. \n10Added by the Finance Act, 2012. \n\n\f\nFirst Schedule – Part III_______ __________________________ \n523 \n \n \n \n1[(3A) The rate of tax to be deducted under 2[sub-sections (1D) and (1DA)] \nof section 152 shall be 10% of the amount of capital gain.]  \n \n \n \n3[(4) The rate of tax to be deducted from a payment referred to in clause (a) \nof sub-section (2A) of section 152 shall be— \n \n \n(i) in case of a company, 4[5%] of the gross amount payable 5[  ] ; and \n \n(ii) in any other case, 6[5.5%] of the gross amount payable 7[ ] \n \n \n \n8[(5) The rate of tax to be deducted from a payment referred to in clause \n(b) of sub-section (2A) of section 152 shall be — \n \n9[(i) \n10[ ] 11[8%] of the gross amount payable, in the cases of \ntransport  services, freight forwarding services, air cargo \nservices, courier services, manpower outsourcing services, \nhotel services, security guard services, software development \nservices, IT services and IT enabled services as defined in \n12[section 2], tracking services, advertising services (other than \nby print or electronic media), share registrar services, \nengineering services, car rental services, building maintenance \nservices, services rendered of Pakistan Stock Exchange \nLimited and Pakistan Mercantile Exchange Limited inspection \n                                            \n1 New clause (3A) inserted through Tax Law (Second Amendment) Ordinance, 2019 dated 26th \nDecember, 2019 \n2 The expression “sub-section (1D)” substituted by the Finance Act, 2021. Earlier this substitution was \nmade through Tax Laws (Amendment) Ordinance, 2021. \n3 Paragraph (4) substituted by the Finance Act, 2015. The substituted paragraph read as follows:-  \n“(4) \nThe rate of tax to be deducted from a payment referred to in clause (a) of sub-section \n  \n(2A) of section 152 shall be 3.5% of the gross amount payable.” \n4 The expression “4%” substituted by Finance Act, 2023. \n5 The words “, if the company is a filer, 7% if the company is a non-filer” omitted through Finance Act, \n2019. \n6 The expression “4.5%” substituted by Finance Act, 2023. \n7 The words “, if the person is a filer and 7.75% if the person is a non-filer.” Omitted through Finance  \nAct, 2019 \n8 Added by the Finance Act, 2012. \n9 Sub para (i) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted para read \nas follows:  “(i) in the case of transport services, two per cent of the gross amount payable; or” \n10 The expression “3%” substituted by Finance Act, 2023. \n11 The expression “4%” substituted by Finance Act, 2025. \n12 The expression “clause(133) of Part I of the Second Schedule” substituted by the Finance Act, \n2021. \n\n\f\nFirst Schedule – Part III_______ __________________________ \n524 \n \nand certification, testing and training services 1[, oilfield \nservices] 2[: \n \n \n \nProvided that the rate of tax shall be 4% in case of IT \nservices and IT enabled services as defined in section 2.]   \n \n3[  ] \n4[(ii)  \nin case of rendering of or providing of services other than sub-\nparagraph (i) shall be 15% of the gross amount payable.] \n \n \n5[(6)  The rate of tax to be deducted from a payment referred to in clause \n(c) of sub-section (2A) of section 152 shall be,— \n \n(i) \n6[15%] of the gross amount payable in case of sportspersons; \n \n7[(ii) \n8[  ] 9[8%] of the gross amount payable 10[  ].]   \n \n \n11[    ] \nDivision III \nPayments for Goods or Services \n \n \n(1) \nThe rate of tax to be deducted from a payment referred to in clause \n(a) of sub-section (1) of section 153 shall be – \n \n                                            \n1 Inserted by the Finance Act, 2021. \n2 The expression “3%” substituted by Finance Act, 2023.  \n3 Sub-paragraph (ii) substituted by the Finance Act, 2015. Substituted sub-paragraph read as \nfollows:- “(ii)  in any other case, six per cent of the gross amount  payable.” \n4 Sub-paragraph (ii) substituted by the Finance Act, 2025. Substituted sub-paragraph read \nas follows:- (ii) in cases other than 4[sub-paragraph (i)],— \n(a) \nin case of a company, 4[9%] of the gross amount payable 4[   ]; and \n(b) in any other case, 4[11%] of the gross amount payable, 4[  ];] “ \n5paragraph (6) substituted by the Finance Act, 2015. Substituted paragraph read as follows:- \n“(6) \nThe rate of tax to be deducted from a payment referred to in clause (c) of sub-section \n \n(2A) of section 152 shall be six per cent of the gross amount payable.” \n6 The expression “10%” substituted by the Finance Act, 2025. \n7 Sub-paragraph (ii) substituted by the Finance Act, 2016. Substituted  sub-paragraph read as follows:- \n“(ii) in case of a company, 7% of the gross amount payable, if the company is a filer and 10% \nif the company is a non-filer;” \n8 The words “in case a person is a filer,” omitted through Finance Act, 2019. \n9 The expression “7%” substituted by Finance Act, 2023. \n10 The words “and 13 % if the person is a non-filer ,” omitted through Finance Act, 2019 \n11 Sub-paragraph (iii) omitted by the Finance Act, 2016. Omitted sub-paragraph read as follows:- \n(iii) in any other case, 7.5% of the gross amount payable, if the person is a filer and 10% if the \nperson is a non-filer.”] \n\n\f\nFirst Schedule – Part III_______ __________________________ \n525 \n \n(a) \nin the case of the sale of rice, 1[  ], cotton seed or edible oils, \n2[1.5]% of the gross amount payable; or 3[:] \n \n4[Explanation.— For removal of doubt, it is clarified that \n“cotton seed and edible oils” means cotton seed oil and edible \noils;] \n \n5[ 6[   ]  ] \n7[    ] \n   \n \n \n(b)  \nin the case of sale of goods 8[including toll manufacturing],— \n \n9[  ] \n \n10[(i) \nin case of a company, 9% of the gross amount payable \nfor toll manufacturing and 5% of the gross amount \npayable in case other than toll manufacturing; and  \n \n(ii) \nin case other than a company, 11% of the gross amount \npayable for toll manufacturing and 5.5% of the gross \namount payable in other than toll manufacturing.] \n \n                                            \n1 The word “cotton” omitted by the Finance Act, 2005. \n2 Substituted for the figure “1” by the Finance Act, 2003. Earlier this was substituted by S.R.O. \n586(I)/2002 dated 28.08.2002  which stands rescinded by SRO 608(I)/2003, dated 24.06.2003 with \neffect from 01.07.2003. \n3 Full stop substituted by finance act 2017. \n4 Added by the Finance Act, 2016. \n5 Inserted by the Finance Act, 2016. \n6 Sub-paragraph (ab) substituted by the Finance Act, 2017. The substituted sub-paragraph (ab) read  \nas follows: \n“(ab) in the case of the supplies made by the distributors of fast moving consumer goods, 3% of the \ngross amount payable, if the supplier is a company and 3.5% if the supplier is other than a \ncompany.” \n7 Sub-paragraph (ab) omitted by the Finance Act, 2021. The sub-paragraph read as follows: \n“(ab) \nin the case of supplies made by the distributer of fast moving consumer goods,─ \n(i) \nin case of a company, 2% of the gross amount payable; and \n(ii) \nin any other case, 2.5% of the gross amount payable.]”  \n8The expression inserted through Finance Act, 2020 dated 30th June, 2020 \n9 Clauses (i) and (ii) of sub-paragraph (b) of paragraph (1) substituted by the Finance Act, 2015. The \nsubstituted clauses read as follows:- \n“(i)   4% of the gross amount payable in the case of companies; and \n(ii)   4.5%of the gross amount payable in the case of other taxpayers.” \n10 Clause (i) and (ii) substituted by the Finance Act, 2024. The substituted clauses read as follows: \n“[(i) in case of a company, 10[5%] of the gross amount payable, 10[   ]; and \n(ii) \nin any other case, 10[5.5%] of the gross amount payable, 10[  ] ]]” \n\n\f\nFirst Schedule – Part III_______ __________________________ \n526 \n \n1[(2) The rate of tax to be deducted from a payment referred to in clause (b) \nof sub-section (1) of section 153 shall be — \n \n2[(i) 3[ ] 4[6%] of the gross amount payable, in the cases of transport \nservices, freight forwarding services, air cargo services, courier \nservices, manpower outsourcing services, hotel services, \nsecurity guard services, software development services, IT \nservices and IT enabled services as defined in section 2, \ntracking services, advertising services (other than by print or \nelectronic media), share registrar services, engineering \nservices including architectural services, warehousing services, \nservices rendered by asset management companies, data \nservices provided under license issued by the Pakistan \nTelecommunication Authority, telecommunication infrastructure \n(tower) services, car rental services, building maintenance \nservices, services rendered by Pakistan Stock Exchange \nLimited and Pakistan Mercantile Exchange Limited, inspection, \ncertification, testing and training services, oilfield services, \ntelecommunication services,  collateral management services, \n                                            \n1Substituted by the Finance Act, 2019. The substituted clause (2) read as follows:  \n“(i) \nin the case of transport services, two per cent of the gross  \namount payable; or \n \n \n \n(ii)  \nin the case of rendering of or providing of services, — \n \n \n \n \n1[(a) in case of a company, 8% of the gross amount payable, if the company is \na filer and 1[14.5]% if the company is a non-filer; and \n \n(b) in any other case, 10% of the gross amount payable, if the person is a \nfiler and 1[17.5]% if the person is a non-filer; \n \n(a) in respect of persons making payments to electronic and print media for \nadvertising services,— \n \n(i)  in case of a filer, 1[1.5%] of the gross amount payable; and \n \n(ii) \nin case of a non-filer, 12% of the gross amount payable, if the non-filer is a company and 15% \nif the non-filer is other than a company;” \n2 Sub-paragraph (i) substituted by the Finance Act, 2021. The substituted sub-paragraph read as \nfollows: “  \n(i) \n3% of the gross amount payable, in the cases of transport services, freight forwarding services, \nair cargo services, courier services, manpower outsourcing services, hotel services, security guard \nservices, software development services, IT services and IT enabled services as defined in clause \n(133) of Part I of the Second Schedule, tracking services, advertising services (other than by print or \nelectronic media), share registrar services, engineering services, 2[warehousing services, services \nrendered by asset management companies, data services provided under licence issued by the \nPakistan Telecommunication Authority, telecommunication infrastructure (tower) services,] car rental \nservices, building maintenance services, services rendered by Pakistan Stock Exchange Limited and \nPakistan Mercantile Exchange Limited inspection, certification, testing and training services;” \n3 The expression “3%” substituted by Finance Act, 2023. \n4 The expression “4%” substituted by Finance Act, 2025. \n\n\f\nFirst Schedule – Part III_______ __________________________ \n527 \n \ntravel and tour services 1[, REIT management services, \nservices rendered by National Clearing Company of Pakistan \nLimited] 2[: \n \n \n \nProvided that the rate of tax shall be 4% in case of IT \nservices and IT enabled services as defined in section 2.]   \n    \nExplanation:—The tax rate under this subparagraph shall be \napplicable only to a service provider whose services are subjected to \nwithholding tax on gross receipts and the service provider has not \nagitated taxation of gross receipts before any court of law;]  \n \n3[(ii)  \nin case of rendering of or providing of services other than sub-\nparagraph (i) shall be 15% of the gross amount payable:  \n \nProvided that in respect of persons making payments to \nelectronic and print media for advertising services the rate shall \nbe 1.5% of the gross amount payable.] \n \n \n(3) The rate of tax to be deducted from a payment referred to in clause (c) \nof sub-section (1) of section 153 shall be 4[ ] - ] \n \n \n \n5[(i)  6[15%] of the gross amount payable in case of sportspersons; \n \n(ii) in case of a company, 7[   ] 8[7.5%] of the gross amount payable 9[  \n] ; and \n \n                                            \n1 Expression added by the Finance Act, 2022. \n2 The expression “3%” substituted by Finance Act, 2023.  \n3 Sub-paragraph (ii) substituted by the Finance Act, 2025. Substituted sub-paragraph read as follows:- \n(ii) in case of rendering of or providing of services other than sub-clause (i),- \n(a) in case of a company, 3[9%] of the gross amount payable;  \n(b) in any other case, 3[11%] of the gross amount payable; and  \n(c) in respect of persons making payments to electronic and print media for \nadvertising services, 1.5% of the gross amount payable.] \n4The figure, words and full stop “6% of the gross amount payable.” Substituted by the Finance Act, \n2013. \n5Sub-paragraphs (i), (ii) and (iii) of paragraph (3) substituted by the Finance Act, 2015. The substituted \nsub-paragraphs read as follows:-  \n“(i)  \n 7%of the gross amount payable in the case of companies; and \n \n \n \n \n(ii)  \n 7.5% of the gross amount payable in the case of other taxpayers. \n  (iii)   \n10% of the gross amount payable in case of sportspersons.” \n6 The expression “10%” substituted by the Finance Act, 2025. \n7 The figure “7%” substituted by the Finance Act, 2021. \n8 The expression “6.5%” substituted by Finance Act, 2023. \n9The words “, if the company is a filer and 9[ ] 9[14]% if the company is a non-filer” omitted though \nFinance Act, 2019. \n\n\f\nFirst Schedule – Part III_______ __________________________ \n528 \n \n(iii) in any other case, 1[  ] 2[8%] of the gross amount payable 3[  ]] \n \n \n4[(3A) The rate of tax to be deducted from a payment referred to in sub-\nsection (2A) of section 153 for digitally ordered goods or digitally delivered services \nthrough e-commerce platforms including websites shall be in case of payment \nthrough –  \n \n(i)  Digital Means or banking channels by payment intermediary at the rate \nof  1% of gross amount paid or payable;  \n \n(ii)  Cash on Delivery by courier service at the rate of 2% of gross amount \npaid or payable:] \n \n \n5[  ] \n6[  ] \n7[Division IIIAA \nGain arising on disposal of certain debt securities \nThe rate of tax to be deducted under section 151A shall be 15% of \nthe gross amount of the capital gain.] \n                                            \n1 The figure “7.5%” substituted by the Finance Act, 2021. \n2 The expression “7%” substituted by Finance Act, 2023. \n3The words “, if the person is a filer and 3[ ] 3[15]% if the person is a non-filer” omitted through \nFinance Act, 2019. \n4 The figure “7.5%” substituted by the Finance Act, 2021. \n5 Clause (4) omitted by the Finance Act, 2006. The omitted clause (4) read as follows: \n“ (4) The rate of tax to be deducted from a payment referred to in sub-section (3) of section 153 shall \nbe 6% of the gross amount payable.” \n6“Division IIIA” omitted by the Finance Act, 2012. The omitted “Division IIIA” read as follows:- \n“Division IIIA \nPayments to non-resident media persons \n \nThe rate of tax to be deducted under section 153A, shall be 10% of the gross amount paid.” \n7 Division IIIAA inserted by the Finance Act, 2025.  \n\n\f\nFirst Schedule – Part III_______ __________________________ \n529 \n \n1[   ] \n2[   ]  \n \nDivision IV  \nExports \n \n3[(1) The rate of tax to be deducted under sub-sections (1), (3), (3A), (3B) \nor (3C) of section 154 shall be 1% of the proceeds of the export.] \n \n \n4[     ]  \n \n \n(3) \nThe rate of tax to be deducted under sub-section 5[(2)] of section 153 \nshall be 6[1] %.  \n \n7[  ] \n \n8[DIVISION IVA \nExport of Services \nThe rate of tax to be deducted under section 154A shall be:- \n \nS. No. \nTypes of Receipts \nRate of Tax \n(1) \n(2) \n(3) \n1. \nExport proceeds of Computer software or \nIT services or IT Enabled services by \npersons \nregistered \nwith \nPakistan \nSoftware Export Board \n0.25% of proceeds \n9[for \ntax \nyears \n2024 up to tax year \n2026] \n2. \nAny other case \n1% of proceeds] \n      \n                                            \n1 New Division IIIB inserted through Finance Act, 2019. \n2 Division IIIB omitted by the Finance Act, 2021. The omitted Division read as follows: \nDivision IIIB  \nRoyalty paid to resident persons \n  The rate of tax to be deducted under section 153B shall be 15% of the gross amount payable.] \n3 Clause (1) substituted by the Finance Act, 2009. The substituted clause (1) read as follows: - \n“(1) \nThe rate of tax to be deducted under sub-sections (1), (3), (3A) or (3B) of section 154 \nshall be 1% of the proceeds of the export.” \n4 Clause (2) omitted by the Finance Act, 2022. \n5 The figure, brackets and letter “(1A)” substituted by the Finance Act, 2011. \n6 Figure “0.5” substituted by the figure “1” by the Finance Act, 2014. \n7 Division IVA added by the Finance Act, 2021. \n8 Division IVA substituted by the Finance Act, 2022. The substituted Division read as follows: \n   “Division IVA   \nExports of Services  \nThe rate of tax to be deducted under section 154A shall be one percent of the proceeds of the export.” \n9 Expression added by the Finance Act, 2023. \n\n\f\nFirst Schedule – Part III_______ __________________________ \n530 \n \n1[Division V \nIncome from Property \n(a) The rate of tax to be deducted under section 155, in the case of individual \nand association of persons, shall be— \n2[TABLE \n                                            \n1 Division V substituted by the Finance Act, 2013. The substituted “Division V” read as follows: \n“Division V \nIncome from Property \n (a)  The rate of tax to be deducted under section 155, in the case of individual and \nassociation of persons, shall be— \nS.No. \nGross amount of rent \nRate of tax \n(1) \nWhere the gross amount of rent \ndoes not exceed Rs.150,000. \nNil \n(2) \nWhere the gross amount of rent \nexceeds Rs.150,000 but does \nnot exceed Rs.400,000. \n5 per cent of the gross amount exceeding \nRs.150,000. \n(3) \nWhere the gross amount of rent \nexceeds Rs.400,000 but does \nnot exceed Rs.1,000,000. \nRs.12,500 plus 7.5 per cent of the gross amount \nexceeding Rs.400,000. \n(4) \nWhere the gross amount of rent \nexceeds Rs.1,000,000. \nRs.57,500 plus 10 per cent of the gross amount \nexceeding Rs.1,000,000. \n(b) \nThe rate of tax to be deducted under section 155, in the case of  company, shall \nbe— \nS.No. \nGross amount of rent \nRate of tax \n(1) \nWhere the gross amount of rent \ndoes not exceed Rs.400,000. \n5 per cent of the gross amount of rent. \n(2) \nWhere the gross amount of rent \nexceeds Rs.400,000 but does \nnot exceed Rs.1,000,000. \nRs.20,000 plus 7.5 per cent of the gross \namount of rent exceeding Rs.400,000. \n(3) \nWhere the gross amount of rent \nexceeds Rs.1,000,000. \nRs.65,000 plus 10 per cent of the gross \namount of rent exceeding Rs.1,000,000.” \n \n2 The Table of Division V substituted by the Finance Act, 2021. The substituted Table read as \nfollows: \n2[ S.No. \nGross amount of rent \nRate of tax \n(1) \n(2) \n(3) \n\n\f\nFirst Schedule – Part III_______ __________________________ \n531 \n \nS. No. \nGross amount of rent \nRate of tax \n(1) \n(2) \n(3) \n1. \nWhere the gross amount of rent does not \nexceed Rs.300,000. \nNil \n2. \nWhere the gross amount of rent exceeds \nRs.300,000 \nbut \ndoes \nnot \nexceed \nRs.600,000. \n5 per cent of the gross \namount \nexceeding \nRs.300,000. \n3. \nWhere the gross amount of rent exceeds \nRs.600,000 \nbut \ndoes \nnot \nexceed \nRs.2,000,000. \nRs.15,000 plus 10 per \ncent of the gross amount \nexceeding Rs.600,000. \n4. \nWhere the gross amount of rent exceed \nRs.2,000,000. \nRs.155,000 plus 25 per \ncent of the gross amount \nexceeding Rs.2,000,000. \n \n \n \n(b)  The rate of tax to be deducted under section 155, in the case  of \ncompany shall be 15% of the gross amount of rent 1[   ] \n \nDivision VI \nPrizes and Winnings \n \n                                            \n1. \nWhere the gross amount of rent \ndoes not exceed Rs.200,000. \nNil \n2. \nWhere the gross amount of rent \nexceeds Rs.200,000 but does \nnot exceed Rs.600,000. \n5 per cent of the gross amount exceeding \nRs.200,000. \n3. \nWhere the gross amount of rent \nexceeds Rs.600,000 but does \nnot exceed Rs.1,000,000. \nRs.20,000 plus 10 per cent of the gross \namount exceeding Rs.600,000. \n4. \nWhere the gross amount of rent \nexceeds Rs.1,000,000 but does \nnot exceed Rs.2,000,000. \nRs.60,000 plus 15 per cent of the gross \namount exceeding Rs.1,000,000. \n5. \nWhere the gross amount of rent \nexceeds Rs.2,000,000 2[but not \nexceed Rs. 4000,000]. \nRs.210,000 plus 20 per cent of the gross \namount exceeding Rs.2,000,000”] \n2[6. \nWhere the gross amount of rent \nexceeds Rs.4,000,000 but does \nnot exceed Rs.6,000,000. \nRs.610,000 plus 25 per cent of the gross \namount exceeding Rs.4,000,000. \n7. \nWhere the gross amount of rent \nexceeds Rs.6,000,000 but does \nnot exceed Rs.8,000,000. \nRs.1,110,000 plus 30 per cent of the \ngross amount exceeding Rs.6,000,000. \n8. \nWhere the gross amount of rent \nexceeds Rs.8,000,000. \nRs.1,710,000 plus 35 per cent of the \ngross amount exceeding Rs.8,000,000.] \n \n1 The words “for filers and 17.5% of the gross amount of rent for non-filers” omitted through Finance \nAct, 2019 \n\n\f\nFirst Schedule – Part III_______ __________________________ \n532 \n \n(1)  \nThe rate of tax to be deducted under section 156 on a prize on prize \nbond or cross-word puzzle shall be 1[15]% of the gross amount paid 2[   \n]. \n \n(2)  \nThe rate of tax to be deducted under section 156 on winnings from a \nraffle, lottery, prize on winning a quiz, prize offered by a company for \npromotion of sale, shall be 20% of the gross amount paid.] \n \nDivision VIA \nPetroleum Products \n \n \nRate of collection of tax under section 156A shall be 3[12] of the amount of \npayment 4[    ]. \n \n5[  ] \n \n6[   ] \n \n7[  ] \n \n \n \n \n                                            \n1 The figure “10” substituted by the Finance Act, 2013. \n2 The words “for filers and 2[25]% of the gross amount paid for non-filers” omitted through Finance \nAct, 2019. \n3 Figure “10” substituted by the figure “12” by the Finance Act, 2014. \n4 The words “for filers and 4[17.5]% for non-filers” omitted through Finance Act, 2019. \n5 Added by the Finance Act, 2007. \n6 Division VIB Omitted by the Finance Act, 2021. The omitted Division read as follows: \nDivision VIB \nCNG STATIONS \n \n \nThe rate of tax to be collected under section 234A in the case of a Compressed Natural \nGas station shall be four per cent of the gas consumption charges 6[  ] . ]” \n7 Division VII omitted by the Finance Act, 2002. The omitted Division VII read as follows: \n“Division VII \nPetroleum Products \nThe Rate of tax to be deducted under section 157 shall be 10% of the commission or \ndiscount.” \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n533 \n \nPART IV \n(See Chapter XII) \nDEDUCTION OR COLLECTION OF ADVANCE TAX \n \n \n1[  ] \n \n2[Division II \nBROKERAGE AND COMMISSION \n \n \n \nThe rate of tax for deduction or collection under section 233 shall be \nas set out in the following Table, namely:- \n \nTABLE \n \nS. No. \nPerson \n \nRate of Tax \n(1) \n(2) \n(3) \n1. \nAdvertising Agents \n10% \n2. \nLife Insurance Agents where commission \nreceived is less than Rs.0.5 million per annum \n8% \n3. \nPersons not covered in 1 and 2 above \n12%] \n \n3[  4[    ]   ] \n                                            \n1 Division I omitted by the Finance Act, 2002. The omitted Division I read as follows: \n“Division I \nTransfer of Funds \nRate of tax for the purpose of collection of tax under section 232 is 0.30 per cent of the amount.” \n2 Rate of tax set out  through Finance Act, 2019. Pervious table read as under:  \nS.No. \nPerson \nRate applicable on the amount of \npayment. \nFiler \nNon-filer \n(1) \n(2) \n(3) \n(4) \n1. \nAdvertising Agents \n10% \n15% \n2. \nLife \nInsurance \nAgents \nwhere \ncommission received is less than \nRs.0.5 million per annum \n8% \n16% \n3. \nPersons not covered in 1 and 2 \nabove \n12% \n15%”] \n \n3Inserted by the Finance Act, 2004. \n4Division IIA substituted by the Finance Act, 2016. Substituted Division read as follows:- \n“Division IIA \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n534 \n \n1[    ] \n \n2[  ] \n3[   ]  \n \nDivision III \n4[Tax on Motor Vehicles] \n \n \nRates of collection of tax under section 234,— \n \n5[(1)   In case of goods transport vehicles, tax of two rupees and fifty paisa \nper kilogram of the laden weight shall be charged 6[  ] .] \n7[(1A)  In the case of goods transport vehicles with laden weight of 8120 \nkilograms or more, advance tax after a period of ten years from the date of first \nregistration of vehicle in Pakistan shall be collected at the rate of twelve hundred \nrupees per annum;] \n \n                                            \nRates for Collection of Tax by a Stock Exchange  \nRegistered in Pakistan \n(i) \nin case of purchase of shares as per clause (a) of \nsub-section (1) of section 233A. \n4[0.01%] of purchase \nvalue \n(ii) \nin case of sale of shares as per clause (b) of sub-\nsection (1) of section 233A. \n4[0.01%] of  \nsale value \n4[  ] \n \n \n \n4[  ]” \n \n \n \n1 Division IIA omitted by the Finance Act, 2021. The omitted Division read as follows: \n“Division IIA \nRATES FOR COLLECTION OF TAX BY A STOCK \nEXCHANGE REGISTERED IN PAKISTAN \n \nS.No. \nDescription \nRate \n(1) \n(2) \n(3) \n1. \nin case of purchase of shares as per clause \n(a) of sub-section (1) of section 233A. \n0.02% \nof \npurchase value \n2. \nin case of sale of shares as per clause (b) of \nsub-section (1) of section 233A. \n0.02% of sale \nvalue”;” \n \n2 Inserted by the Finance Act, 2013.  \n3 Division IIB omitted by the Finance Act, 2021. The omitted Division read as follows: \n“Division IIB \nRates for collection of tax by NCCPL \n \nThe rate of deduction under section 233AA shall be 10% of profit or  mark-up \nor \ninterest \nearned by the member, margin financier or securities lender.]” \n4 The heading “Transport Business” substituted by the Finance Act, 2008. \n5Paragraph (i) substituted by the Finance Act, 2015. The substituted paragraph (i) read as follows:-“(i)  \nin case of goods transport vehicles, tax of five rupees per kilogram of the laden weight shall be charged.” \n6The words “for filer and four rupees per kilogram of the laden weight for non-filer” omitted though \nFinance Act, 2019. \n7 Inserted by the Finance Act, 2003. \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n535 \n \n(2) \nIn the case of passenger transport vehicles plying for hire with \nregistered seating capacity of — \n \n1[S. No \nCapacity \nRs. per seat \nper annum \nNon Air \nConditioned \nRs. per seat per \nannum \nAir Conditioned \n(1) \n(2) \n(3) \n(4) \n1. \n4 or more persons but less \nthan 10 persons  \n200 \n375 \n2. \n10 or more persons but less \nthan 20 persons  \n500 \n750 \n3. \n20 persons or more  \n1000 \n1500] \n \n2[(3)  In case of other 3[   ] motor vehicles shall be as set out in the following \nTable, namely:- \n \n4[S. No. \nEngine capacity \nTax \n                                            \n1 The Table substituted by the Tax Laws (Amendment) Act, 2023 (XVI of 2023) dated 20.04.2023. \nEarlier this Table was substituted through Tax Laws (Second Amendment) Ordinance, 2022 (VI of \n2022) dated 22.08.2022. The substituted Table read as follows: \n“S. No \nCapacity \nRs. per seat per annum \nNon Air Conditioned \nRs. per seat per\nannum Air \nConditioned \n(1) \n(2) \n(3) \n(4) \n1. \n4 or more persons but less than 10 persons  \n500 \n1000 \n2. \n10 or more persons but less than 20 persons  \n1500 \n2000 \n3. \n20 persons or more  \n2500 \n4000” \n \n2Clause (3) substituted by Finance Act, 2014. The substituted clause (3) read as follows: \n“(3)  Other private motor cars with engine capacity of— \n(a) \nupto 1000cc \n \nRs. 750 \n(b) \n1001cc to 1199cc \nRs. 1250 \n(c) \n1200cc to 1299 cc \nRs.1750 \n(d) \n1300cc to 1599cc \nRs. 3000 \n(e) \n1600cc to 1999 cc \nRs. 4000 \n(f) \n2000cc and above  \nRs. 8000” \n \n3The word “private” omitted by the Finance Act, 2022. \n4 Clause (3) substituted through Finance Act, 2019. Substituted clause read as follows:   \n“(3)  In case of other private motor vehicles shall be as following,- \n“S. No. \nEngine capacity \nfor filers \nfor non-filer \n(1) \n(2) \n(3) \n(4) \n1. \nupto 1000cc \nRs. 800 \nRs. 1,200 \n2. \n1001cc to 1199cc \nRs. 1,500 \nRs. 4,000 \n3. \n1200cc to 1299cc \nRs. 1,750 \nRs. 5,000 \n4. \n1300cc to 1499cc \nRs. 2,500 \nRs. 7,500 \n5. \n1500cc to 1599cc \nRs. 3,750 \nRs. 12,000 \n6. \n1600cc to 1999cc \nRs. 4,500 \nRs. 15,000 \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n536 \n \n(1) \n(2) \n(3) \n1. \nupto 1000cc \nRs. 800 \n2. \n1001cc to 1199cc \nRs. 1,500 \n3. \n1200cc to 1299cc \nRs. 1,750 \n4. \n1300cc to 1499cc \nRs. 2,500 \n5. \n1500cc to 1599cc \nRs. 3,750 \n6. \n1600cc to 1999cc \nRs. 4,500 \n7. \n2000cc & above \nRs. 10,000] \n \n(4)  \nwhere the motor vehicle tax is collected in lump sum, \n \n1[S. \nNo. \nEngine capacity \nTax \n(1) \n(2) \n(3) \n1. \nupto 1000cc \nRs. 10,000 \n2. \n1001cc to 1199cc \nRs. 18,000 \n3. \n1200cc to 1299cc \nRs. 20,000 \n4. \n1300cc to 1499cc \nRs. 30,000 \n5. \n1500cc to 1599cc \nRs. 45,000 \n6. \n1600cc to 1999cc \nRs. 60,000 \n7. \n2000cc & above \nRs. 120,000] \n \n \n2[DIVISION IV  \n                                            \n7. \n2000cc & above \nRs. 10,000 \nRs. 30,000”] \n  \n1 Table substituted through Finance Act, 2019. Substituted table read as follows:   \nS. No. \nEngine capacity \nfor filers \nfor non-filer \n(1) \n(2) \n(3) \n(4) \n1. \nupto 1000cc \nRs. 10,000 \nRs. 10,000 \n2. \n1001cc to 1199cc \nRs. 18,000 \nRs. 36,000 \n3. \n1200cc to 1299cc \nRs. 20,000 \nRs. 40,000 \n4. \n1300cc to 1499cc \nRs. 30,000 \nRs. 60,000 \n5. \n1500cc to 1599cc \nRs. 45,000 \nRs. 90,000 \n6. \n1600cc to 1999cc \nRs. 60,000 \nRs. 120,000 \n7. \n2000cc & above \nRs. 120,000 \nRs. 240,000] \n \n2 Division IV omitted by the Finance Act, 2021. The omitted Division read as follows: \nDivision IV \nElectricity Consumption \n \nRate of collection of tax under section 235 2[where the 2[gross] amount of electricity bill,]- \n \n2[(a) \ndoes not exceed Rs. 400 \nRs.    2[0]  \n(b) \nexceeds Rs.    400 but does not exceed Rs.       600 \nRs.     80  \n(c) \nexceeds Rs.    600 but does not exceed Rs.       800 \nRs.   100  \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n537 \n \n  \nElectricity Consumption  \n  \n(1) The rate of collection of tax from commercial and industrial consumers \nfrom gross amount of bills shall be as set out in the following Table, namely:—  \n    \n TABLE  \n \nS. No \nGross amount of Bill \nTax \n1 \nupto Rs. 500 \nRs. 0 \n2 \nexceeds Rs. 500 but \ndoes not exceed Rs. \n20,000 \n10% of the amount   \n3 \nexceeds Rs.20,000 \nRs. 1950 plus 12% of the amount exceeding \nRs.20,000 for commercial consumers Rs. 1950 \nplus 5% of the amount exceeding Rs.20,000 for \nindustrial consumers   \n \n  \n(2)  The rate of tax to be collected on domestic electricity consumption shall \nbe—  \n  \n (i)   zero percent the amount of monthly bill is less than Rs.25,000; and   \n  \n (ii)   7.5% if the amount of monthly bill is Rs. 25,000 or more;]  \n1[   ]  \n                                            \n(d) \nexceeds Rs.    800 but does not exceed Rs.     1000 \nRs.   160  \n(e) \nexceeds Rs.  1000 but does not exceed Rs.     1500 \nRs.   300  \n(f) \nexceeds Rs.  1500 but does not exceed Rs.     3000 \nRs.   350  \n(g) \nexceeds Rs.  3000 but does not exceed Rs.     4500 \nRs.   450  \n(h) \nexceeds Rs.  4500 but does not exceed Rs.     6000 \nRs.   500  \n(i) \nexceeds Rs.  6000 but does not exceed Rs.   10000 \nRs.   650  \n(j) \nexceeds Rs. 10000 but does not exceed Rs. 15000 \nRs. 1000  \n(k) \nexceeds Rs. 15000 but does not exceed Rs. 20000 \nRs. 1500  \n(l) \nexceeds Rs. 20000. \n2[(i) at the rate  of \n2[12] per  cent \nfor commercial \nconsumers; \n \n(ii)  at \nthe \nrate \n of \n5 \nper \ncent \nfor \nindustrial \nconsumers.] ] \n \n \n1 Clause (3) inserted by the Finance Act, 2022. \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n538 \n \n1 [    ]  \n  \nDivision V \nTelephone users \n \nRates of collection of tax under section 236, — \n \n2[(a) \n \n \n \n \n3[(b) \nin the case of a telephone subscriber \n(other than mobile phone subscriber) \nwhere the amount of monthly bill \nexceeds Rs.1000. \n \n10% \nof \nthe \nexceeding \namount of bill.] \n \n \n                                            \n1 Clause (3) omitted by Tax Laws (Amendment) Act, 2023 (XVI of 2023) dated 20.04.2023. Earlier this \nclause was omitted through Tax Laws (Second Amendment) Ordinance, 2022 (VI of 2022) dated \n22.08.2022.The omitted clause (3) read as follows: \n“(3) \nthe rate of tax leviable under section (99A), and collectable under sub section (1A) of \nSection 235 shall be as set out in the TABLE under:- \nTABLE \nS. No \nGross amount of monthly bill \nTax \n(1) \n(2) \n(3) \n1. \nWhere the amount does not exceed Rs. 30,000 \nRs.3,000 \n2. \nWhere the amount exceeds Rs. 30,000 but does not exceed Rs. \n50,000  \nRs.5,000 \n3. \nWhere the amount exceeds Rs. 50,000 but does not exceed Rs. \n100,000 \nRs.10,000 \n4. \nRetailers and service providers as notified by the Board in the \nincome tax general order \nUp to Rs.200,000” \n \n2Paragraph (a) substituted by the Finance Act, 2008. The substituted paragraph (a) read as follows: \n“(a) \nIn the case of telephone subscriber (other than mobile phone subscriber) where \nthe monthly bill— \n(a) \nexceeds Rs. 1000 but does not exceed Rs. \n2000 \nRs.   50 \n(b) \nexceeds Rs. 2000 but does not exceed \nRs. 3000. \n \nRs. 100 \n(c) \nexceeds Rs. 3000 but does not exceed \nRs. 5000. \n \nRs. 200 \n(d) \nexceeds Rs. 5000. \n \nRs. 300” \n \n3Clause (b) of Division V substituted by the Finance Act, 2015. The substituted clause (b) read as \nfollows:- \n“(b)   \nin the case of subscriber of mobile   \n telephone and pre-paid telephone card \n14% of the amount of \nbill or sales price of \npre-paid \ntelephone \ncard 3[or sale of units \nthrough \n3[any \nelectronic medium] or \nwhatever form ] \n \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n539 \n \nin the case of subscriber of internet, \nmobile  telephone and pre-paid internet \nor telephone card \n \n \n1[ ]  2[ ] 3[15%] of \nthe amount of bill or \nsales \nprice \nof \ninternet \npre-paid \ncard \nor \nprepaid \ntelephone card or \nsale \nof \nunits \nthrough \nany \nelectronic \nmedium \nor \nwhatever form 4[: \n \n \nProvided \nthat in the case of \npersons \nmentioned \nin \nincome \ntax \ngeneral \norder \nissued \nunder \nsection 114B, the \nrate of collection \nof tax shall be \n75% \nof \nthe \namount of bill or \nsale \nprice \nof \ninternet pre-paid \ncard or prepaid \ntelephone card or \nsale of units to \nany \nelectronic \nmedium \nor \nwhatever form.] \n \n \n \n \n                                            \n1 The figure “14” substituted by Finance Act 2017. \n2 The expression “12.5%” substituted by the Finance Act, 2021. \n3  The expression “10% for tax year 2022 and 8% onwards” substituted by the Finance (Supplementary) \nAct, 2022. \n4 Colon inserted and Proviso added by the Finance Act 2024. \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n540 \n \n1[    ] \n \n2[DIVISION VII \nAdvance Tax on Purchase, Registration and Transfer of  \nMotor Vehicles \n \n3 [(1) The rate of tax under sub-sections (1) and (3) of section 231B shall be \nas set out in the following Table: – \n                                            \n1 Division VI and VIA omitted by the Finance Act, 2021. The omitted divisions read as follows: \nDivision VI \nCash withdrawal from a bank \nThe Rate of tax to be deducted under section 231A shall be 1[ ] 1[0.6] % of the cash amount withdrawn, \nfor 1[the person whose name is not appearing in the active taxpayers’ list]]. \n1[Division VIA \nAdvance tax on Transactions in Bank \nThe rate of tax to be deducted under section 231AA shall be at the rate of 4[0.6% of the \ntransactions for 1[the person whose name is not appearing in the active taxpayers’ list].]” \n1Division VII of Part IV substituted by the Finance Act, 2015. The substituted Division VII readas follows:- \n \n \n \n \n“DIVISION VII \nAdvance Tax on purchase of Motor Car and Jeep \nThe rate of tax under sub-sections (1), (2) and (3) of section 231B shall be as follows:– \nS. No. \nEngine capacity \nFor filers \nTax for non-filer \n(1) \n(2) \n(3) \n(4) \n1. \nupto 850cc \nRs. 10,000 \nRs. 10,000 \n2. \n851cc to 1000cc \nRs. 20,000 \nRs. 25,000 \n3. \n1001cc to 1300cc \nRs. 30,000 \nRs. 40,000 \n4. \n1301cc to 1600cc \nRs. 50,000 \nRs. 100,000 \n5. \n1601cc to 1800cc \nRs. 75,000 \nRs. 150,000 \n6. \n1801cc to 2000cc \nRs. 100,000 \nRs. 200,000 \n7. \n2001cc to 2500cc \nRs. 150,000 \nRs. 300,000 \n8. \n2501cc to 3000cc \nRs. 200,000 \nRs. 400,000 \n9. \nAbove 3000cc \nRs. 250,000 \nRs. 450,000” \nProvided that the rate of tax to be collected under sub-section (2) of section 231B, shall be reduced \nby 10% each year from the date of first registration in Pakistan.” \n3 Clause (1) substituted by the Finance Act, 2023. The substituted clause (1) read as follows: \n“(1) The rate of tax under sub-sections (1) and (3) of section 231B shall be as set out in the following \nTable:– \nTABLE \nS.No \nEngine Capacity \nTax \n(1) \n(2) \n(3) \n1. \nUpto 850 cc \nRs.10,000 \n2. \n851cc to 1000cc \nRs.20,000 \n3. \n1001cc to 1300cc \nRs.25,000 \n4. \n1301cc to 1600cc \nRs.50,000 \n5. \n1601cc to 1800cc \nRs.150,000 \n6. \n1801cc to 2000cc \nRs.200,000 \n7. \n2001cc to 2500cc \nRs.300,000 \n8. \n2501cc to 3000cc \nRs.400,000 \n9. \nAbove 3000cc \nRs.500,000 \n \nProvided that in cases where engine capacity is not applicable and the value of vehicle is \nRupees five million or more, the rate of tax collectible shall be 3% of the import value as increased \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n541 \n \n1[TABLE \n \nS. No. \nEngine capacity \nRate of Tax \n \n(1) \n(2) \n(3) \n1. \nUpto 850 cc \n0.5% of the value \n2. \n851cc to 1000cc \n1% of the value \n3. \n1001cc to 1300cc \n1.5% of the value \n4. \n1301cc to 1600cc \n2% of the value \n5. \n1601cc to 1800cc \n3% of the value \n6. \n1801cc to 2000cc \n5% of the value \n7. \n2001cc to 2500cc \n7% of the value \n8. \n2501cc to 3000cc \n9% of the value \n9. \nAbove 3000cc \n12% of the value:] \n    \nProvided that the value for the purpose of 2[ ] of the above Table shall be in \ncase of motor vehicle –  \n \n(i)  \nimported in Pakistan, the import value assessed by the Customs \nauthorities as increased by customs duty, federal excise duty and \nsales tax payable at import stage;  \n \n(ii)  \nmanufactured or assembled locally in Pakistan, the invoice value \ninclusive of all duties and taxes; or  \n \n(iii)  \nauctioned, the auction value inclusive of all duties and taxes:  \n \nProvided further that in cases where engine capacity is not applicable and \nthe value of vehicle is Rupees five million or more, the rate of tax collectible shall \nbe 3% of the import value as increased by customs duty, sales tax and federal \nexcise duty in case of imported vehicles or invoice value in case of locally \nmanufactured or assembled vehicles.] \n                                            \nby customs duty, sales tax and federal excise duty in case of imported vehicles or invoice value in \ncase of locally manufactured or assembled vehicles.] \n1 Table substituted by the Finance Act 2024. The substituted Table read as follows: \n“[TABLE \nS. No. \nEngine capacity \nTax \n(1) \n(2) \n(3) \n1. \nUpto 850 cc \nRs.10,000 \n2. \n851cc to 1000cc \nRs.20,000 \n3. \n1001cc to 1300cc \nRs.25,000 \n4. \n1301cc to 1600cc \nRs.50,000 \n5. \n1601cc to 1800cc \nRs.150,000 \n6. \n1801cc to 2000cc \nRs.200,000 \n \nRate of Tax \n7. \n2001cc to 2500cc \n6% of the value \n8. \n2501cc to 3000cc \n8% of the value \n9. \nAbove 3000cc \n10% of the value: \n]” \n2 Expression “S. Nos. 7 to 9” omitted by the Finance Act 2024. \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n542 \n \n \n1[(2) The rate of tax under sub-sections (2) of section 231B shall be as \nfollows:– \n \nS. No. \nEngine capacity \nTax \n(1) \n(2) \n(3) \n1. \nupto 850cc \n- \n2. \n851cc to 1000cc \n5,000 \n3. \n1001cc to 1300cc \n7,500 \n4. \n1301cc to 1600cc \n12,500 \n5. \n1601cc to 1800cc \n18,750 \n6. \n1801cc to 2000cc \n25,000 \n7. \n2001cc to 2500cc \n37,500 \n8. \n2501cc to 3000cc \n50,000 \n9. \nAbove 3000cc \n62,500] \n \n2[Provided that in cases where engine capacity is not \napplicable and the value of vehicle is Rupees five million or more, the \nrate of tax collectible shall be Rupees twenty thousand: \n \nProvided further that the rate of tax to be collected under this \nclause shall be reduced by ten percent each year from the date of first \nregistration in Pakistan.] \n \n \n3[(3) The rate of tax under sub-section (2A) of section 231B shall be as \nfollows:—  \n4[TABLE \n                                            \n1 Clause (2) substituted through Finance Act, 2019. Substituted clause read as follows:   \nS. No. \nEngine capacity \nFor filers \nTax for non-filer \n(1) \n(2) \n(3) \n(4) \n1. \nupto 850cc \n- \n5000 \n2. \n851cc to 1000cc \n5,000 \n15,000 \n3. \n1001cc to 1300cc \n7,500 \n25,000 \n4. \n1301cc to 1600cc \n12,500 \n65,000 \n5. \n1601cc to 1800cc \n18,750 \n100,000 \n6. \n1801cc to 2000cc \n25,000 \n135,000 \n7. \n2001cc to 2500cc \n37,500 \n200,000 \n8. \n2501cc to 3000cc \n50,000 \n270,000 \n9. \nAbove 3000cc \n62,500 \n300,000 \n \n2  Proviso substituted by the Finance Act, 2022. Substituted proviso read as follows: \n   “Provided that the rate of tax to be collected shall be reduced by 10% each year from the date    \nof first registration in Pakistan.” \n3 Clause (3) added by the Finance Act, 2021. Earlier this addition was made through Tax Laws \n(Amendment) Ordinance, 2021. \n4  TABLE substituted by the Finance (Supplementary) Act, 2022. Substituted TABLE read as follows: \n   “TABLE \nS. No. \nEngine capacity \nTax \n(1) \n(2) \n(3) \n1. \nUp to 1000cc \nRs. 50,000 \n2. \n1001cc to 2000cc \nRs.100,000 \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n543 \n \n \nS. No. \nEngine capacity \nTax \n(1) \n(2) \n(3) \n1. \nUp to 1000cc \nRs. 100,000 \n2. \n1001cc to 2000cc \nRs.200,000 \n3. \n2001cc and above \nRs.400,000] \n \n1[Division VIII \nAdvance tax at the time of sale by auction \n \n The rate of collection of tax under section 236A shall be 2[10]% of the gross \nsale price of any property or goods sold by auction 3[  ] 4[: \n \nProvided that in case of immovable property sold by auction 5[and sale by \nauction of train management services by Pakistan Railways], the rate of collection \nof tax under this section shall be 5% of the gross sale price.] \n \n6[    ] \n7[    ] \n8[  ] \n9[  ]   \n \n10[Division X  \n                                            \n3. \n2001cc and above \nRs.200,000” \n \n1 Added by the Finance Act,  2009. \n2 The figure “5” substituted by the Finance Act, 2013. \n3 The words “for filers and 15% of the gross sale price of any property or goods sold by auction for \nnon-filers” omitted through Finance Act, 2019. \n4 Proviso added through Finance Act, 2020. \n5 Words inserted by the Finance Act, 2023. \n6 Added by the Finance Act, 2010. \n7 Division IX omitted by the Finance Act, 2021. The omitted Division read as follows: \n“Division IX \nAdvance tax on Purchase of Air Ticket \nThe rate of tax to be deducted under section 236B shall be 5% of the gross amount of air ticket.” \n8 Division X added by the Finance Act, 2012. \n9 Division X substituted by the Finance Act 2024. The substituted Division read as follows: \n“[Division X \nAdvance tax on sale or transfer of \nImmovable property \n \n \nThe rate of tax to be collected under section 236C shall be 9[ ] 9[  ] 9[3%] of the gross \namount of the consideration received 9[ ] ]” \n   \n10 Division X substituted by the Finance Act 2024. The substituted Division read as follows: \n.   “Division X  \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n544 \n \n \nAdvance tax on sale or transfer of immovable property \n  \nThe rate of tax to be collected under section 236C shall be as set out in the \nfollowing table: –  \nTABLE \n \nS. No. \nAmount \nTax Rate \n(1) \n(2) \n(3) \n1 \nWhere the gross amount of the consideration \nreceived does not exceed Rs. 50 million  \n4.5% \n2 \nWhere the gross amount of the consideration \nreceived exceeds Rs. 50 million but does not \nexceed Rs 100 million \n5% \n3 \nWhere the gross amount of the consideration \nreceived exceeds Rs. 100 million \n5.5%] \n \n \n1[Division XA  \nAdvance Tax on TV plays and advertisements  \n \nThe rate of tax to be collected under section 236CA shall be, — \n \n2[S. No \nDescription \nRate of Tax \n(1) \n(2) \n(3) \n                                            \n \nAdvance tax on sale or transfer of immovable property  \nThe rate of tax to be collected under section 236C shall be as set out in the following table: –  \n \nS. No. \nAmount \nTax Rate \n(1) \n(2) \n(3) \n1 \nWhere the gross amount of the consideration received does \nnot exceed Rs. 50 million  \n3% \n2 \nWhere the gross amount of the consideration received \nexceeds Rs. 50 million but does not exceed Rs 100 million \n3.5% \n3 \nWhere the gross amount of the consideration received \nexceeds Rs. 100 million \n4%] \n” \n1 Division XA inserted by the Finance (Supplementary) Act, 2022. \n2 TABLE substituted by the Finance Act, 2022. The substituted TABLE read as follows: \n     \n[S.No \nDescription \nRate of Tax \n(1) \n(2) \n(3) \n1. \nForeign-produced TV drama serial or play \nRs.1,000,000 per episode \n2. \nForeign-produced TV play (single episode) \nRs.3,000,000 \n3. \nAdvertisement starring foreign actor                        Rs.100,000 per second.] \n \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n545 \n \n1. \nForeign-produced TV drama serial or play \nRs.1,000,000 per episode \n2. \nForeign-produced TV play (single episode) \nRs.3,000,000 \n3. \nAdvertisement starring foreign actor                Rs.100,000 per second.] \n \n1[Division XI  \nAdvance tax on functions and gatherings  \n \nThe rate of tax to be collected under section 236CB shall be 10%.] \n \n2[  ]  \n3[   ]  \n                                            \n1 Division XI added by the Finance (Supplementary) Act, 2023 (X of 2023) dated 23.02.2023. \n2Division XI  omitted through Finance Act, 2020 dated 30th June, 2020 the omitted Division read as \nfollows:  \n“Division XI \nAdvance tax on functions and gatherings \n \n \nThe rate of tax to be collected under each sub-sections (1) and (2) of section 236D shall \nbe 2[5] %]2[;] \n \n2[Provided that the rate for the function of marriage in a marriage hall, marquee, hotel, \nrestaurant, commercial lawn, club, a community place or any other place used for such purpose shall \nbe as set out in the Table below:─ \nTABLE \nS.No. \nRate of tax \n(1) \n(2) \n(3) \n1. \n5% of the bill ad valorem or Rs. \n20,000 per function, whichever is \nhigher \nFor \nIslamabad, \nLahore, \nMultan,Faisalabad, \nRawalpindi, Gujranwala, Bahawalpur, Sargodha, \nSahiwal, Shekhurpura, Dera Ghazi Khan, Karachi, \nHyderabad, Sukkur, Thatta, Larkana, Mirpur Khas, \nNawabshah, Peshawar, Mardan, Abbottabad, Kohat, \nDera Ismail Khan, Quetta, Sibi, Loralai, Khuzdar, Dera \nMurad Jamali and Turbat. \n2. \n5% of the bill ad valorem or Rs. \n10,000 per function, whichever is \nhigher \nFor cities other than those mentioned above. \n2[Provided further that the rate for the function of marriage in a marriage hall, marquee or a \ncommunity place with the total function area less than 500 square yards or, in case of a multi storied \npremises, with the largest total function area on one floor less than 500 square yards, shall be 5% of \nthe bill ad valorem or Rs. 5.000 per function whichever is higher.” \n \n3 Division XII omitted by the Finance Act, 2016. Omitted Division read as follows:- \n3[Division XII \nAdvance tax on foreign-produced films and TV plays \n \nRate of collection of tax under section 236E shall be as follows: — \n \n \n(a)  \nForeign-produced TV drama \n \nRs.100,000 per episode \n \n \n \nSerial \n \n \n(b)  \nForeign-produced TV play \n \nRs. 100,000] \n \n \n \n(single episode) \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n546 \n \n1[  ]  \n2[Division XIV \nAdvance tax on sale to distributors, dealers or wholesalers. \n \n \nThe rate of collection of tax under section 236G shall be as set out in the \nfollowing table namely:- \nTABLE \n \n                                            \n1Division XIII omitted through Finance Act, 2020 dated 30th June, 2020 the omitted Division is read as \nfollows: \n“Division XIII \n(1)  \nThe rate of tax to be collected under section 236F in the case of Cable Television Operator \nshall be as follows:— \nLicense Category as provided in \nPEMRA Rules \nTax on License Fee \nTax on Renewal \nH \nRs. 7,500 \nRs. 10,000 \nH-I \nRs. 10,000 \nRs. 15,000 \nH-II \nRs. 25,000 \nRs. 30,000 \nR \nRs. 5,000 \nRs. 1[12,000] \nB \nRs. 5,000 \nRs. 40,000 \nB-1 \nRs. 30,000 \nRs. 1[35,000] \nB-2 \nRs. 40,000 \nRs. 1[45,000] \nB-3 \nRs. 50,000 \nRs. 75,000 \nB-4 \nRs. 75,000 \nRs. 100,000 \nB-5 \nRs. 87,500 \nRs. 150,000 \nB-6 \nRs. 175,000 \nRs. 200,000 \nB-7 \nRs. 262,500 \nRs. 300,000 \nB-8 \nRs. 437,500 \nRs. 500,000 \nB-9 \nRs. 700,000 \nRs. 800,000 \nB-10 \nRs. 875,500 \nRs. 900,000 \n(2)  \nThe rate of tax to be collected by Pakistan Electronic Media Regulatory Authority under \nsection 236F in the case of IPTV, FM Radio, MMDS, Mobile TV, Mobile Audio, Satellite TV Channel \nand Landing Rights, shall be 20 per cent of the permission fee or renewal fee, as the case may be.] \n1[“(3) \nIn addition to tax collected under paragraph (2) Pakistan Electronic Media Regulatory \nAuthority shall collect tax at the rate of fifty per cent of the permission fee or renewal fee, as the case \nmay be, from every TV Channel on which foreign TV drama serial or a play in any language, other than \nEnglish, is screened or viewed.” \n \n2[ Division XIV substituted through finance Act, 2019. Substituted Division read as follows:-  \n \n \n \nDivision XIV \nAdvance tax on sale to distributors, dealers or wholesalers.  \nThe rate of collection of tax under section 236G shall be as follows:- \nCategory of Sale \nRate of Tax \nFiler \nNon-filer \nFertilizers \n0.7% \n1.4% \nOther than Fertilizers \n0.1% \n0.2% \n  \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n547 \n \nS.No. \nCategory of Sale \nRate of Tax \n(1) \n(2) \n(3) \n1. \nFertilizers \n0.7% \n2. \nOther than Fertilizers \n0.1%] \n \n1[Provided that the rate of advance tax on sale to distributors, dealers or \nwholesalers of fertilizer shall be 0.25%, if they are already appearing on both the \nActive Taxpayers’ Lists issued under the provisions of the Sales Tax Act, 1990 and \nthe Income Tax Ordinance, 2001 (XLIX of 2001).] \n \n2[ 3[   ]  ] \n \n4[DIVISION XV  \nAdvance tax on sale to retailers  \nThe rate of collection of tax under section 236H on the gross amount of sales \nshall be 0.5%.] \n5[   ] \n                                            \n1 Proviso added by the Finance Act, 2021. Earlier this addition was made through Tax Laws \n(Amendment) Ordinance, 2021. \n2 Added by the Finance Act, 2013. \n3 Division XV substituted through Finance Act, 2019. Substituted Division read as follows:- \n[Category of sale \nRate of tax \nFiler \nNon-filer \n(1) \n(2) \n(3) \nElectronics \n1% \n1%] \nOthers \n0.5% \n \n \n4Division XV substituted by the Finance Act, 2021. The substituted Division read as follows: \nDivision XV \nAdvance tax on sale to retailers \n4[The rate of collection of tax under section 236H on the gross amount of sales shall be as set \nout in the following table namely:- \n \nTABLE \nS.No \nCategory of sale \nRate of tax \n \n(1) \n(2) \n(3) \n \n1. \nElectronics \n1% \n \n2. \nOthers \n0.5%]  \n] \n \n5Inserted by the Finance Act, 2018 \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n548 \n \n1[  ] \n \n2[   ] \n \n3[   ] \n \n4[  ] 5[  ]  \n  \n6[  ] \n                                            \n1 Divisions XVA, omitted by the Finance Act, 2021. The Divisions read as follows: \nDivision XVA  \nAdvance tax on sale of certain petroleum products \n \nThe rate of collection of tax under section 236HA shall be 0.5% of ex-depot sale price \n1[  ]. ] \n2Added by the Finance Act, 2013. \n3 Division XVI omitted by the Finance Act, 2022. The omitted Division read as follows: \n     “Division XVI \nCollection of advance tax by educational institutions \n \nThe rate of collection of tax under section 236I shall be 5% of the amount of fee.” \n4Added by the Finance Act, 2013. \n5 Division XVII omitted through Finance Act, 2020 dated 30th June, 2020 the omitted Division read as \nfollows:    \n“Division XVII \nAdvance tax on dealers, commission agents and arhatis, etc. \n \nThe amount of collection of tax under section 236J shall be as set out in the following table:— \nTABLE \nGroup \nAmount of tax  \n(per annum) \n \nGroup or Class A: \nRs. 100,000 \n \nGroup or Class B: \nRs. 75,000 \n \nGroup or Class C: \nRs. 50,000 \n \nAny other category: \nRs. 50,000” \n \n \n6 Division XVIII substituted through Finance Act, 2019.Substituted Division read as follows: \nDivision XVIII \nAdvance tax on purchase of immovable property \n \nThe rate of tax to be collected under section 236K shall be 1% of the fair market value.”; \n \n \nS. No. \nPeriod \nRate of Tax \n(1) \n(2) \n(3) \n1. \nWhere value of Immovable property is up to 6[“4 \nmillion”]. \n0% \n2. \nFiler 6[2]% \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n549 \n \n \n1[Division XVIII  \n \nAdvance tax on purchase of immovable property \n \n  \nThe rate of tax to be collected under section 236K shall be as set out in the \nfollowing table: –  \n \n2[ TABLE \n \nS. No. \nAmount \nTax Rate \n(1) \n(2) \n(3) \n1 \nWhere the fair market value does not exceed \nRs. 50 million \n1.5% \n2 \nWhere the fair market value exceeds Rs. 50 \nmillion but does not exceed Rs 100 million \n2% \n3 \nWhere the fair market value exceeds Rs. 100 \nmillion \n2.5%] \n \n \n \n3[  ] \n \n                                            \nWhere the value of Immovable property is more than \n6[“4 million”]. \nNon-Filer 6[4]% \n \nProvided that the rate of tax for Non-Filter shall be 1% upto the date appointed by the Board \nthrough notification in official gazette 6[ * ].  \n1 Division XVIII substituted by the Finance Act 2024. The substituted Division read as follows: \n“[Division XVIII \nAdvance tax on purchase of immovable property \nThe rate of tax to be collected under section 236K shall be 1[   ] 1[3%] of the fair market value. ]” \n   \n2 Table substituted by the Finance Act 2025. The substituted Table read as follows: \n   “ \nS. No. \nAmount \nTax Rate \n(1) \n(2) \n(3) \n1 \nWhere the fair market value does not exceed Rs. 50 million \n3% \n2 \nWhere the fair market value exceeds Rs. 50 million but does \nnot exceed Rs 100 million \n3.5% \n3 \nWhere the fair market value exceeds Rs. 100 million \n4%” \n \n3 Added by the Finance Act, 2015. \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n550 \n \n1[ ] 2[ ] 3[:]”] \n \n4[ ] 5[ ] \n6[ * ] \n \n \n7[ ** ] \n \n \n8[ *** ] \n \n \n9[ **** ] \n \n \n10[ ***** ] \n                                            \n1 Inserted by the Presidential Order NoF.2(1)/2015-Pub dated 11.07.2015. \n2 The proviso omitted by the Finance Act 2018, the omitted provisos reads as follows:- \n“Provided that the rate specified in this Division 2[for the period it deems appropriate] shall be \n0.3 per cent for the period commencing from the 11th day of July, 2015 and ending on the \n30th day of September, 2015 (both days inclusive) or till the date as the 2[Board with the \napproval of Federal Minister-in-charge] may, by notification in the official Gazette on \nrecommendation of the Economic Coordination Committee of the Cabinet, extend \n3 Substituted by the National Assembly Secretariat’s O.M. No F.22(30)/2015-Legis dated 29.01.2016. \n4 Inserted by the National Assembly Secretariat O.M. No F.22(30)/2015-Legis dated 29.01.2016. \n5 The proviso omitted by the Finance Act 2018,the omitted provisos reads as follows:- \n“Provided that the 5[Board with the approval of Federal Minister-in-charge] may, by \nnotification in the official Gazette and on recommendation of the Economic Coordination \nCommittee of the Cabinet, amend the rate specified in this Division.” \n6 Inserted by the S.R.O. 964(I)/2015 dated 30.09.2015. \n “ *Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, on the recommendation of the Economic \nCoordination Committee of the Cabinet, is pleased to extend the time period for applicability of 0.3 per cent \nreduced rate under Division XXI of Part IV of the First Schedule read with section 236P of the said Ordinance, \nto thirty first day of October, 2015.”] \n7Inserted by the S.R.O.1056(I)/2015 dated 30.10.2015. \n “ **Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to extend the time period for \napplicability of 0.3 percent reduced rate under Division XXI of Part IV of the First Schedule read with section \n236P of the said Ordinance, to seventh day of November, 2015.”] \n8Inserted by the S.R.O.1092(I)/2015 dated 09.11.2015. \n “ ***Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to extendthe time period for \napplicability of 0.3 percent reduced rate under Division XXI of Part IV of the First Schedule read with section \n236P of the said Ordinance, from 8th day of November, 2015 to 15th day of November, 2015.”] \n9Inserted by the S.R.O.1135(I)/2015 dated 14.11.2015. \n “ *****Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.1092(I)/2015, dated the 9th November, 2015 the following amendment shall be made, namely:- \nIn the aforesaid Notification, for the figure “15th” the figure “30th” shall be substituted.”] \n10 Inserted by the S.R.O.1182(I)/2015 dated 01.12.2015. \n “ ******Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.1092(I)/2015, dated the 9th November, 2015 the following amendment shall be made, namely:- \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n551 \n \n \n \n1[ ****** ] \n2[ ******* ] \n \n3[ ******** ] \n \n4[ ********* ] \n \n5[ # ] \n6[ ## ] \n \n                                            \nIn the aforesaid Notification, for the expression “from 8th day of November, 2015 to 15th day of November, \n2015” the expression “from the 1st day of December, 2015 to the 31st day of December, 2015” shall be \nsubstituted.”] \n1Inserted by the S.R.O.1329(I)/2015 dated 31.12.2015. \n “ ******Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.1092(I)/2015, dated the 9th November, 2015 the following amendment shall be made, namely:- \nIn the aforesaid Notification, for the expression “from 8th day of November, 2015 to 15th day of November, \n2015” the expression “from the 1st day of January, 2016 to 31st day of January, 2016” shall be substituted.”] \n2 Inserted by the S.R.O.72(I)/2016 dated 01.02.2016. \n “ *******Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to amend the rate specified under \nDivision XXI of Part IV of the First Schedule to 0.3% w.e.f. first day of February, 2016 to twenty ninth day of \nFebruary, 2016.”] \n3Inserted by the S.R.O.169(I)/2016 dated 29.02.2016. \n [“ ********Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to amend the rate specified under \nDivision XXI of Part IV of the First Schedule to 0.4% w.e.f. first day of March, 2016 to fifteenth day of March, \n2016.”] \n4Inserted by the S.R.O.216(I)/2016 dated 15.03.2016. \n [“ ********Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.169(I)/2016 dated the 29th February, 2016 the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of March, of 2016 to fifteenth day of March, 2016” \nthe words “sixteenth day of March, 2016 to thirty first day of March 2016” shall be substituted.”] \n5Inserted by the S.R.O.286(I)/2016 dated 01.04.2016. \n [“ # Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.216(I)/2016 dated 15th March, 2016, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “sixteenth day of March, 2016 to thirty first day of March 2016” \nthe words “first day of April, 2016 to thirtieth day of April, 2016” shall be substituted.”] \n6 Inserted by the S.R.O.370(I)/2016 dated 30.04.2016. \n [“ ## Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.286(I)/2016 dated 1st April, 2016, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of April, 2016 to thirtieth day of April, 2016”, the words \n“first day of May, 2016 to thirty first day of May, 2016” shall be substituted.”] \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n552 \n \n1[ ### ] \n2[ #### ] \n \n3[ ##### ] \n \n4[ ###### ] \n \n5[ % ] \n6[ %% ] \n \n7[ %%% ] \n                                            \n1 Inserted by the S.R.O.472(I)/2016 dated 31.05.2016. \n [“ ### Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.370(I)/2016 dated 30th April, 2016, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of May, 2016 to thirty first day of May, 2016”, the \nwords “first day of June, 2016 to thirtieth day of June, 2016” shall be substituted.”] \n2 Inserted by the S.R.O.494(I)/2016 dated 30.06.2016. \n [“ #### Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.472(I)/2016 dated 31st May, 2016, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of June, 2016 to thirtieth day of June, 2016”, the \nwords “first day of July, 2016 to thirty first day of July, 2016” shall be substituted.”] \n3 Inserted by the S.R.O.720(I)/2016 dated 01.08.2016. \n [“ ##### Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.494(I)/2016 dated 30th June, 2016, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of July, 2016 to thirty first day of July, 2016”, the \nwords “first day of August, 2016 to thirty first day of August, 2016” shall be substituted.”] \n4 Inserted by the S.R.O.811(I)/2016 dated 31.08.2016. \n [“ ###### Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.720(I)/2016 dated 1st August, 2016, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of August, 2016 to thirty first day of August, 2016”, \nthe words “first day of September, 2016 to thirty first day of December, 2016” shall be substituted.”] \n5Inserted by the S.R.O.37(I)/2017 dated 23.01.2017. \n [“ % Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income \nTax Ordinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.811(I)/2016 dated 31st August, 2016, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of September, 2016 to thirty first day of December, \n2016”, the words “first day of January, 2017 to thirty first day of March, 2017” shall be substituted.”] \n6Inserted by the S.R.O.289(I)/2017 dated 27.04.2017. \n [“ %% Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income Tax \nOrdinance, 2001 (XLIX of 2001), the Federal Government, is pleased to direct that in its Notification \nNo.S.R.O.37(I)/2017 dated 23rd April, 2017, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of January, 2017 to thirty first day of March, 2017”, the words \n“first day of April, 2017 to thirtieth day of June, 2017” shall be substituted.”] \n7 Inserted by the S.R.O.602(I)/2017 dated 03.07.2017. \n [“ %%% Notification \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n553 \n \n \n1[ %%%% ] \n \n2[ %%% %%] \n3[  ] \n4[    ] \n                                            \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income Tax \nOrdinance, 2001 (XLIX of 2001), the Board with approval of Federal Minister-in-charge is pleased to direct that in its \nNotification No.S.R.O.289(I)/2017 dated 27th April, 2017, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of April, 2017 to thirtieth day of June, 2017”, the words “first \nday of July, 2017 to thirtieth day of September, 2017” shall be substituted.”] \n1 Inserted by the S.R.O.983(I)/2017 dated 29.09.2017. \n [“ %%% %Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income Tax \nOrdinance, 2001 (XLIX of 2001), the Board with approval of Federal Minister-in-charge is pleased to direct that in its \nNotification No.S.R.O.602(I)/2017 dated 29th September, 2017, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of July, 2017 to thirtieth day of September, 2017”, the words \n“first day of October, 2017 to thirty first day of December, 2017” shall be substituted.”] \n2 Inserted by the S.R.O.1330(I)/2017 dated 30.12.2017. \n [“ %%%%% Notification \nIn exercise of the powers conferred by proviso under Division XXI of Part IV of the First Schedule to the Income Tax \nOrdinance, 2001 (XLIX of 2001), the Board with approval of Federal Minister-in-charge is pleased to direct that in its \nNotification No.S.R.O.983(I)/2017 dated 29th September, 2017, the following amendments shall be made, namely:- \nIn the aforesaid Notification, for the words “first day of October, 2017 to thirty first day of December, 2017”, the \nwords “first day of January, 2018 to thirtieth day of June, 2018” shall be substituted.”] \n3 Divisions XIX, XX, XXI, XXVI and XXVII omitted by the Finance Act, 2021. The Divisions read as \nfollows: \n \nDivision XIX \nAdvance tax on Domestic Electricity Consumption \nThe rate of tax to be collected under section 235A shall be--- \n(i) \n7.5% if the amount of monthly bill is Rs. 3[“75,000”] or more; and \n(ii) \n0% the amount of monthly bill is less than Rs. 3[75,000]. \nDivision XX \nAdvance tax on international air ticket \nThe rate of tax to be collected under section 236L shall be:- \n \n3[“S. No. \nType of Ticket \nRate \n(1) \n(2) \n(3) \n1. \nFirst/Executive Class \nRs. 16,000 per person \n2. \nOthers excluding Economy \nRs. 12,000 per person \n3. \nEconomy \n0”] \n \nDivision XXI \nAdvance Tax on Banking Transactions Otherwise Than \nThrough Cash \nThe rate of tax to be collected under section 236P shall be 3[ ] 3[0.6]%  of the transaction \nfor 3[the person whose name is not appearing in the active taxpayers’ list]. \n \n4Division XXII omitted by the Finance Act, 2016. Omitted Division read as follows:- \n“Division XXII \nRate of Collection of Tax by Pakistan Mercantile Exchange Limited \nThe rate of tax to be collected under section 236T shall be as follows:– \nin case of sale or purchase of future commodity contract as per clause (a) and (b) of sub-\nsection (1) of section 236T shall be 0.05%.” \n\n\f\nFirst Schedule – Part IV_____ __________________________ \n554 \n \n \n1[     ] \n2[    ]  \n3[     ]  \n 4[     ] \n5[     ] \n6[DIVISION XXVII \nAdvance tax on amount remitted abroad through credit,  \ndebit or prepaid cards \n \nThe rate of tax to be deducted under section 236Y shall be 7[5%] of the gross amount \nremitted abroad.] \n                                            \n1 Division XXIII omitted by the Finance Act, 2022. The omitted Division read as follows: \n   “DIVISION XXIII \nPayment to a resident person for right to use  \nmachinery and equipment \nRate of collection of tax under section 236Q shall be 10 percent of the amount of payment.” \n2 Division XXIV omitted through Finance Act, 2020 dated 30th June, 2020 the omitted Division read \nas follows: \n“DIVISION XXIV \nCollection of advance tax on education related expenses remitted abroad \nRate of collection of tax under section 236R shall be 5percent of the amount of total education \nrelated expenses.” \n \n3Division XXV omitted through Finance Act, 2020 dated 30th June, 2020 the omitted Division read as \nfollows: \n“Division XXV \nADVANCE TAX ON INSURANCE PREMIUM \nThe rate of tax to be collected from 3[persons who are not appearing in the active taxpayers’ \nlist] under section 236U shall be as under:- \nS.No. \nType of Premium \nRate \n(1) \n(2) \n(3) \n1. \nGeneral insurance premium \n4% \n2. \nLife insurance premium if 3[exceeding Rs 0.3 \nmillion in aggregate] per annum \n1% \n3. \nOthers \n0%” \n \n4 Inserted by the Finance Act, 2016. \n5 Divisions XXVI and XXVII omitted by the Finance Act, 2021. The Divisions read as follows:  \nDivision XXVI \nADVANCE TAX ON EXTRACTION OF MINERALS \nThe rate of tax to be collected under section 236V shall be 5% of the value of the minerals  5[   \n].] \nDivision XXVII \nAdvance tax on amount remitted abroad through credit, debit or prepaid cards  \nThe rate of tax to be deducted under section 236Y shall be 1% of the gross amount remitted \nabroad 5[   ].] \n6 Inserted by the Finance Act, 2022. \n7 The expression “1%” substituted by the Finance Act, 2023. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n \n533 \nTHE SECOND SCHEDULE \nEXEMPTIONS AND TAX CONCESSIONS  \n[See section 53] \n \nPART I \nEXEMPTIONS FROM TOTAL INCOME \n \n \nIncomes, or classes of income, or persons or classes of persons, \nenumerated below, shall be exempt from tax, subject to the conditions and to the \nextent specified hereunder:  \n \n1[  ] \n \n2[  ] \n \n(3) \nAny income chargeable under the head \"Salary\" received by a person who, \nnot being a citizen of Pakistan, is engaged as an expert or technical, professional, \nscientific advisor or consultant or senior management staff by institutions of the \nAgha Khan Development Network, (Pakistan) listed in Schedule I of the Accord \nand Protocol dated, November 13, 1994 executed between the Government of the \nIslamic Republic of Pakistan and Agha Khan Development Network. \n \n3[   ] \n \n4[    ] \n \n5[(5A) Any allowance or perquisite paid or allowed as such outside Pakistan by the \nGovernment to a citizen of Pakistan for rendering service outside Pakistan.] \n                                            \n1Clause (1) omitted by the Finance Act, 2003. The omitted clause (1) read as follows:  \n“(1) Any income chargeable under the head \"Salary\" received by any person being an employee of \nthe International Irrigation Management Institute (IIMI) in Pakistan, who is neither a citizen of \nPakistan nor a resident individual in any of the four years immediately preceding the year in which \nhe arrived in Pakistan.” \n2Clause (2) omitted by the Finance Act, 2008. The omitted clause (2) read as follows: \n“(2) Any income chargeable under the head \"Salary\" received by, or due to, any person, not being \na citizen of Pakistan or a resident individual, as remuneration for services rendered by him as a \nhealth professional under the contract of service concluded with Shaukat Khanum Memorial Hospital \nand Research Center, Lahore, and approved by the Federal Government for the purposes of this \nclause.” \n3 Clause (4) omitted by the Finance Act, 2021. The omitted clause read as follows: \n    “(4) Any income chargeable under the head “Salary” received by- \n(a)  a Pakistani seafarer, working on Pakistan flag vessels for one hundred and eighty three days \nor more during a tax year; or  \n(b) a Pakistani seafarer working on a foreign vessel provided that such income is remitted to \nPakistan, not later than two months of the relevant 3[tax year], through normal banking \nchannels.” \n4Clause (5) omitted by the Finance Act, 2022. The omitted clause read as follows: \n“(5) \nAny allowance or perquisite paid or allowed as such outside Pakistan by the Government to a   \ncitizen of Pakistan for rendering service outside Pakistan.” \n5 Clause (5A) inserted and deemed to have been so inserted from the 1st day of July, 2022 by the Tax \nLaws (Amendment) Act, 2023 (XVI of 2023) dated 20.04.2023. Earlier this clause was inserted \nthrough Tax Laws (Second Amendment) Ordinance, 2022 (VI of 2022) dated 22.08.2022. \n     \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n556 \n \n1[  ] \n2[  ] \n \n3[    ]  \n \n4[(9) Any pension – \n \n5[  ]  \n \n(ii)   \ngranted under the relevant rules to the families and dependents of  \npublic servants or members of the Armed Forces of Pakistan who die \nduring service.] \n6[  ] \n7[  ] \n \n(12) Any payment in the nature of commutation of pension received from \nGovernment or under any pension scheme approved by the 8[Board] for the \npurpose of this clause. \n \n(13) Any income representing any payment received by way of gratuity or \ncommutation of pension by an employee on his retirement or, in the event of his \ndeath, by his heirs as does not exceed – \n                                            \n1  Clause (6) omitted by the Finance Act, 2008. The omitted clause (6) read as follows: \n“(6) Any income chargeable under the head “Salary” received by a person, not being a citizen of \nPakistan, by virtue of his employment with the British Council.” \n2  Clause (7) omitted by the Finance Act, 2002. The omitted clause (7) read as follows: \n“(7) Any income chargeable under the head \"Salary\" paid by Government to Khasadars, levies and \nBadraggas employed in the tribal territory on the North West Frontier and of all persons employed in \nthe tribal levy services in Baluchistan.” \n3  Clause (8) omitted by the Finance Act 2025. The omitted clause read as follows: \n   “(8) Any pension received by a citizen of Pakistan from a former employer, other than where the \nperson continues to work for the employer (or an associate of the employer). \nProvided that where the person receives more than one such pension, the exemption \napplies only to the higher of the pensions received.” \n4  Clause (9) substituted by the Finance Act, 2006. The substituted clause (9) read as follows: \n“(9) Any pension received in respect of any service rendered by a member of the Armed Forces of \nPakistan or as an employee of the Federal Government or a Provincial Government.“ \n5  Sub-clause (i) omitted by the Finance Act 2025. The omitted sub-clause read as follows: \n   “(i)  received in respect of services rendered by a member of the Armed Forces of Pakistan or \nFederal Government or a Provincial Government;” \n6  Clause (10) omitted by the Finance Act, 2006. The omitted clause (10) read as follows: \n“(10) Any pension granted to any public servant to whom clause (14) does not apply in respect of \ninjuries received in the performance of his duties.” \n7  Clause (11) omitted by the Finance Act, 2006. The omitted clause (11) read as follows: \n“(11) Any pension granted to any public servant to whom clause (15) does not apply who has been \ninvalidated from service on account of any bodily disability.” \n8  The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n557 \n \n \n(i) \nin the case of an employee of the Government, a 1[Local Government], \na statutory body or corporation established by any law for the time being \nin force, the amount receivable in accordance with the rules and \nconditions of the employee’s services; \n \n(ii) \nany amount receivable from any gratuity fund approved by the \nCommissioner in accordance with the rules in Part III of the Sixth \nSchedule; \n \n(iii) \nin the case of any other employee, the amount not exceeding 2[three] \nhundred thousand rupees receivable under any scheme applicable to \nall employees of the employer and approved by the 3[Board] for the \npurposes of this sub-clause; and \n \n(iv) \nin the case of any employee to whom sub-clause (i), (ii) and (iii) do not \napply, fifty per cent of the amount receivable or seventy-five thousand \nrupees, whichever is the less: \n \nProvided that nothing in this sub-clause shall apply – \n \n(a) \nto any payment which is not received in Pakistan; \n \n(b) \nto any payment received from a company by a director of such \ncompany who is not a regular employee of such company; \n \n(c) \nto any payment received by an employee who is not a resident \nindividual; and to any gratuity received by an employee who has \nalready received any gratuity from the same or any other \nemployer.  \n \n4[  ] \n \n5[  ] \n(16) Any income derived by the families and dependents of the \"Shaheeds\" \nbelonging to Pakistan Armed Forces from the special family pension, dependents \npension or children's allowance granted under the provisions of the Joint Services \nInstruction No. 5/66. \n                                            \n1  The words “local authority” substituted by the Finance Act, 2008. \n2The word “two” substituted by the Finance Act, 2016. \n3The words  “Central Board of Revenue” substituted by the Finance Act, 2007. \n4Clause (14) omitted by the Finance Act, 2006. The omitted clause (14) read as follows: \n“(14) Any pension granted to the personnel of Armed Forces of Pakistan (including personnel of the \nTerritorial Force and the National Service of Pakistan) in respect of injuries received in the \nperformance of their duties as such.” \n5Clause (15) omitted by the Finance Act, 2006. The omitted clause (15) read as follows:  \n“(15) Any pension granted to the personnel of the Armed Forces of Pakistan (including personnel of \nthe Territorial Force and the National Service of Pakistan) invalidated from service with such Forces \non account of bodily disability attributable to, or aggravated by, such service.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n558 \n \n \n(17) Any income derived by the families and dependents of the \"Shaheeds\" \nbelonging to the Civil Armed Forces of Pakistan to whom the provisions of the Joint \nServices Instruction No. 5/66 would have applied had they belonged to the \nPakistan Armed Forces from any like payment made to them. \n \n1[  ] \n \n(19) Any sum representing encashment of leave preparatory to retirement of a \nmember of the Armed Forces of Pakistan or an employee of the Federal \nGovernment or a Provincial Government. \n \n2[   ] \n \n3[  ] \n \n(22) Any payment from a provident fund to which the Provident Funds Act, 1925 \n(XIX of 1925) applies. \n \n(23) The accumulated balance due and becoming payable to an employee \nparticipating in a recognized provident fund.  \n \n4[(23A) the accumulated balance upto 5[50]% received from the voluntary pension \nsystem offered by a pension fund manager under the Voluntary Pension System \nRules, 2005 at the time of eligible person’s-  \n \n \n \n(a)  \nretirement; or \n \n \n \n(b)  \ndisability rendering him unable to work; or \n \n \n \n(c)  \ndeath by his nominated survivors6[:] \n \nProvided that, excluding the cases mentioned in sub-clauses (b) and (c), \nin case of withdrawal before retirement age or withdrawal at the time of or after \nretirement age in excess of fifty percent of the accumulated balance, tax shall be \n                                            \n1Clause (18) omitted by the Finance Act, 2006. The omitted clause (18) read as follows:  \n“(18) Any pensions granted under the relevant rules to the families and dependents of public servants \nor members of the Armed Forces of Pakistan who die during service.“ \n2Clause (20) omitted by the Finance Act, 2015. The omitted clause (20) read as follows:- \n“(20) Any income received by a person from an annuity issued under the Pakistan Postal Annuity \nCertificate Scheme on or after the 27th July, 1977, not exceeding ten thousand rupees per annum.” \n3Clause (21) omitted by the Finance Act, 2008. The omitted clause (21) read as follows: \n“(21) Any income received by a person from an annuity or annuities issued upto 30th June, 2005 by \nthe State Life Insurance Corporation of Pakistan or a life insurance company registered under section \n3 of the Insurance Ordinance, 2000 (XXXIX of 2000): \n \nProvided that this clause shall not apply to so much of the income received by a person from \nan annuity or annuities which, together with the income from any annuity or annuities referred to in \nclause (20), exceeds ten thousand rupees per annum.” \n4Inserted by the Finance Act, 2006. \n5The figure “25” substituted by the Finance Act, 2009. \n6The full stop substituted by colon and thereafter new proviso added through Finance Act, 2020 \ndated 30th June, 2020  \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n559 \n \ncharged at the rate specified in sub-section (6) of section 12 and the pension fund \nmanager shall at the time of making payment deduct tax at the said rate.] \n \n1[  ] \n \n2[  ] \n \n3[(23C) Any withdrawal of accumulated balance from approved pension fund that \nrepresent the transfer of balance of approved provident fund to the said approved \npension fund under the Voluntary Pension System Rules , 2005.] \n \n(24) \nAny benevolent grant paid from the Benevolent Fund to the employees or \nmembers of their families in accordance with the provisions of the Central \nEmployee Benevolent Fund and Group Insurance Act, 1969. \n \n(25) \nAny payment from an approved superannuation fund made on the death \nof a beneficiary or in lieu of or in commutation of any annuity, or by way of refund \nof contribution on the death of a beneficiary 4[.] \n \n5[  ] \n \n6[  ] \n \n7[  ] \n                                            \n1Inserted by the Finance Act, 2012. \n2Clause (23B) omitted by the Finance Act, 2022. The omitted clause read as follows: \n“(23B) \nThe amounts received as monthly installment from an income payment plan invested out \nof the accumulated balance of an individual pension accounts with a pension fund manager or an \napproved annuity plan or another individual pension account of eligible person or the survivors \npension account maintained with any other pension fund manager as specified in the Voluntary \nPension System Rules 2005 shall be exempt from tax provided accumulated balance is invested for \na period of ten years: \nProvided that where any amount is exempted under this clause and subsequently it is \ndiscovered, on the basis of documents or otherwise, by the Commissioner that any of the conditions \nspecified in this clause were not fulfilled, the exemption originally allowed shall be deemed to have \nbeen wrongly allowed and the Commissioner may, notwithstanding anything contained in this \nOrdinance, re-compute the tax payable by the taxpayer for the relevant years and the provisions of \nthis Ordinance shall, so far as may be, apply accordingly.” \n3 Inserted by the Finance Act, 2012. \n4Added by the Finance Act, 2008. \n5Sub-clause (i) omitted by the Finance Act, 2008. The omitted sub-clause (i) read as follows:  \n“ (i)  in the case of an employee of the Government or a local authority or  a statutory body or \ncorporation established by any law for the time being in force, the amount receivable in \naccordance with the  rules and conditions of his service;” \n6Sub-clause (ii) omitted by the Finance Act, 2008. The omitted sub-clause (ii) read as follows: \n“(ii)  \nany amount receivable from any gratuity fund approved by the Commissioner in accordance \nwith the rules contained in Part III of the Sixth Schedule; \n7 Sub-clause (iii) omitted by the Finance Act, 2008. The omitted sub-clause (iii) read as follows: \n“(iii)  in the case of any other employee, the amount not exceeding two hundred thousand rupees \nreceivable under any scheme applicable to all employees of the employer and approved by \nthe Central Board of Revenue for the purposes of this sub-clause; and \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n560 \n \n1[  ] \n \n(26) Any income of a person representing the sums received by him as a worker \nfrom out of the Workers Participation Fund established under the Companies \nProfits (Workers Participation) Act, 1968 (XII of 1968). \n \n2[  ] \n \n3[  ] \n \n4[  ] \n \n5[  ] \n \n6[  ] \n \n7[    ] \n                                            \n1 Sub-clause (iv) omitted by the Finance Act, 2008. The omitted sub-clause (iii) read as follows: \n“(iv)  in the case of any employee to whom sub-clauses (i), (ii) and (iii) do  not apply, fifty per cent \nof the amount receivable or seventy-five thousand rupees, whichever is the less: \n \nProvided that nothing in this sub-clause shall apply- \n(a) \nto any payment which is not received in Pakistan ; \n(b) \nto any payment received from a company by a director of such company who is \nnot regular employee of such company; \n(c)  \nto any payment received by an employee who is not a resident of Pakistan; and \n(d) \nto any gratuity received by an employee who has already received any gratuity \nfrom the same or any other employer.” \n2Clause (28) omitted by the Finance Act, 2002. The omitted clause (28) read as follows: \n“(28)  Any income of an officer representing the sum received by him as Entertainment Allowance \nadmissible to him under the Ministry of Finance (Finance Division) Office Memorandum No. F.1 (1)-\nImp/83, dated the 18th August, 1983.” \n3Clause (29) omitted by the Finance Act, 2002. The omitted clause (29) read as follows: \n“(29)  Any income of an officer of the Pakistan Armed Forces representing the sum received as \nEntertainment Allowance admissible to him under the Ministry of Defence Office Memorandum No. \n716(D)/(B)/77, dated the 29th April, 1977.” \n4Clause (30) omitted by the Finance Act, 2002. The omitted clause (30) read as follows: \n“(30)  Any income of an officer representing the sum received by him as Entertainment Allowance \nadmissible to him under the Cabinet Secretariat (Establishment Division) Office Memorandum No. \n18/2/78-CV, dated the 13th July, 1978.” \n5Clause (31) omitted by the Finance Act, 2002. The omitted clause (31) read as follows: \n“(31)  Any income of an officer representing the sum received by him as Senior Post Allowance \nadmissible to him under the Ministry of Finance, Planning and Development (Finance Division) Office \nMemorandum No. F.1(36) Gaz-IMP-I/73, dated the 18th August, 1973.” \n6Clause (32) omitted by the Finance Act, 2002. The omitted clause (32) read as follows: \n“(32)  Any income of an officer representing the sum received by him as Senior Post Allowance \nadmissible to him under the Ministry of Finance and Provincial Coordination (Finance Division) Office \nMemorandum No. F.1(1) Imp-I/77, dated the 28th April, 1977.” \n7Clause (33) omitted by the Finance At, 2003. The omitted clause (33) read as follows:  \n“(33)  Any income of any officer representing the sum received by him as Orderly Allowance \nadmissible to him under the Finance Division O.M. No. F.1(3)-IMP-II/85, dated the 24th October, \n1985.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n561 \n \n1[    ] \n \n2[    ] \n \n3[    ] \n \n4[    ] \n \n5[    ] \n \n6[    ] \n \n7[(39A) Any   amount   paid   as8[,internal security allowance, compensation in lieu \nof bearer allowance,]   kit   allowance,   ration allowance, special messing \nallowance, SSG allowance, Northern Areas compensatory allowance, special pay \nfor Northern  Areas  and  height  allowance  to  the  Armed Forces personnel.] \n \n(40) Any income of a newspaper employee representing Local Travelling \nAllowance paid in accordance with the decision of the Third Wage Board for \nNewspaper Employees constituted under the Newspaper Employees (Conditions \nof Service) Act, 1973, published in Part II of the Gazette of Pakistan, Extraordinary, \ndated the 28th June, 1980. \n \n9[  ] \n                                            \n1 Clause (34) omitted by the Finance At, 2003. The omitted clause (34) read as follows: \n“(34)  Any income of an employee of a recognized University in Pakistan representing the sums \nreceived by him as Orderly Allowance admissible under the terms and conditions of his service.” \n2Clause (35) omitted by the Finance Act, 2014. The omitted clause read as follows: \n \n“(35) \nAny income representing compensatory allowance payable to a citizen of Pakistan \nlocally recruited in Pakistan Mission abroad as does not exceed 75 per cent of his gross salary.” \n3Clause (36) omitted by the Finance At, 2003. The omitted clause (36) read as follows: \n“(36)  Any income of an officer representing the sum received by him as Personal Staff Subsidy \nadmissible to him under the Cabinet Secretariat (Establishment Division) Office Memorandum No. \n18/2/78-CV, dated the 13th July, 1978.” \n4Clause (37) omitted by the Finance Act, 2002. The omitted clause (37) read as follows: \n“(37) Any income representing cost of living allowance admissible to the Government employees at \nthe rate of 7%.” \n5 Clause (38) omitted by the Finance Act, 2006. The omitted clause (38) read as follows: \n“(38) Any sum paid, for purpose of meeting the charges for gas, water and electricity, or the value of \ngas, water and electricity provided free of charge to an employee up to ten per cent of the minimum \nof time scale, and where there is no time scale, up to ten per cent of the basic salary.” \n6 Clause (39) omitted by the Finance Act, 2021. The omitted clause read as follows: \n   “(39) Any special allowance or benefit (not being entertainment or conveyance allowance) or other   \nperquisite within the meaning of section 12 specially granted to meet expenses wholly and \nnecessarily incurred in the performance of the duties of an office or employment of profit.” \n7Inserted by the Finance Act, 2018. \n8Words “internal security allowance, compensation in lieu of bearer allowance,” inserted though \nFinance Act, 2019.  \n9Clause (41) omitted by the Finance Act, 2003. The omitted clause (41) read as follows: \n“(41)  Such portion of the income of a member of Pakistan Armed Forces as is compulsorily payable \nby him under any orders issued by Government to mess, entertainment or band fund.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n562 \n \n1[  ] \n \n2[  ] \n \n3[  ] \n \n4[  ] \n \n5[  ] \n \n6[  ] \n \n7[  ] \n \n8[  ] \n \n9[  ] \n \n(51) The perquisite represented by the right of the President of Pakistan 10[ ] the \nProvincial Governors and the Chiefs of Staff, Pakistan Armed Forces to occupy \nfree of rent as a place of residence any premises provided by the Government. \n \n(52) The perquisite represented by free conveyance provided and the sumptuary \n(entertainment) allowance granted by Government to 11[ ] the Chiefs of Staff, \nPakistan Armed Forces and the Corps Commanders. \n                                            \n1Clause (42) omitted by the Finance Act, 2006. The omitted clause (42) read as follows: \n“(42)  Any amount received as flying allowance by pilots, flight engineers and navigators employed \nby any Pakistani airline or by Civil Aviation Authority.” \n2Clause (43) omitted by the Finance Act, 2006. The omitted clause (43) read as follows: \n“(43)  Any amount notified as flying allowance payable to pilots, flight engineers and navigators of \nthe Pakistan Air Force.” \n3Clause (44) omitted by the Finance Act, 2006. The omitted clause (44) read as follows: \n“(44)  Any amount notified as flying allowance payable to pilots, flight engineers and navigators of \nthe Pakistan Army and the Pakistan Navy.“ \n4Clause (45) omitted by the Finance Act, 2006. The omitted clause (45) read as follows:  \n“(45)  Any amount received as flying allowance by junior commissioned officers or other ranks of \nPakistan Armed Forces.“ \n5Clause (46) omitted by the Finance Act, 2006. The omitted clause (46) read as follows: \n“(46) Any amount notified as submarine allowance payable to officers of the Pakistan Navy.” \n6Clause (47) omitted by the Finance Act, 2006. The omitted clause (47) read as follows: \n“(47)  The value of rations issued in kind, or cash allowance paid in lieu thereof, to members of \nPakistan Armed Forces or of Territorial Forces.” \n7Clause (48) omitted by the Finance Act, 2006. The omitted clause (48) read as follows:  \n“(48) The value of rent-free quarters occupied by, or cash allowance paid in lieu thereof, to members \nof the Pakistan Armed Forces, including Territorial Force.” \n8Clause (49) omitted by the Finance Act, 2006. The omitted clause (49) read as follows:  \n“(49) The conservancy allowance granted in lieu of free conservancy to personnel below \ncommissioned rank of Pakistan Armed Forces and Territorial Force.” \n9Clause (50) omitted by the Finance Act, 2003. The omitted clause (50) read as follows: \n“(50)  Deferred pay admissible to Armed Forces personnel under the new Pay Code.” \n10 The comma and words “,the Provincial Governors” omitted by the Finance Supplementary \n(Amendment) Act, 2018. \n11 The words and comma “the Provincial Governors,” omitted by the Finance Supplementary \n(Amendment) Act, 2018. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n563 \n \n \n1[  ] \n      \n2[(53A) The following perquisites received by an employee by virtue of his \nemployment, namely:-  \n \n3[  ] \n \n  (ii)  free or subsidized food provided by hotels and restaurants to its \nemployees during duty hours; \n(iii)  free or subsidized education provided by an educational institution to \nthe children of its employees; \n(iv)  free or subsidized medical treatment provided by a hospital or  a clinic \nto its employees; and  \n(v)  any other perquisite or benefit for which the employer does not  have \nto bear any marginal cost, as notified by the4[Board].] \n \n5[  ] \n \n(55) The perquisites represented by the right of a judge of the Supreme Court of \nPakistan or of a judge of High Court to occupy free of rent as a place of residence \nany premises provided by Federal or Provincial Government, as the case may be, \nor in case a judge chooses to reside in a house not provided by Government, so \nmuch of income which represents the sum paid to him as house rent allowance. \n \n(56) The following perquisites, benefits and allowances received by a Judge of \nSupreme Court of Pakistan and Judge of High Court, shall be exempt from tax. \n \n(1)      (a) \nPerquisites and benefits derived 6[from] use of official car \nmaintained at Government expenses. \n \n                                            \n1 Clause (53) omitted by the Finance Supplementary (Amendment) Act, 2018. The omitted clause (53) \nread as follows: \n“(53) The following perquisites and allowances provided or granted by Government to the Ministers \nof the Federal Government, namely:- \n(a) \nrent-free accommodation in so far as the value thereof exceeds ten per cent of the \nbasic salary of the Ministers concerned; \n(b) \nhouse-rent allowance paid by Government in lieu of rent-free accommodation in so far \nas it exceeds five hundred and fifty rupees per month; \n(c) \nfree conveyance; and \n(d)      sumptuary allowance \n2 Inserted by the Finance Act, 2005. \n3 Sub-clause (i) omitted by the Finance Act, 2013. The omitted sub-clause (i) read as follows: \n“(i)  free or concessional passage provided by transporters including airlines to its employees \n(including the members of their household and dependents);” \n4The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n5Clause (54) omitted by the Finance Act, 2002. The omitted clause (54) read as follows: \n“(54) Any sum paid, for purpose of meeting the charges for gas, water and electricity, or the value of \ngas, water and electricity provided free of charge to the Federal and Provincial Ministers.” \n6 The word “form” substituted by the Finance Act, 2005. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n564 \n \n(b) \nSuperior judicial allowance payable to a Judge of supreme \nCourt of Pakistan and Judge of a High Court. \n \n(c) \nTransfer allowance payable to a Judge of High Court. \n \n(2) \nThe following perquisites of the Judge of Supreme Court of Pakistan \nand Judge of High Court shall also be exempt from tax during service, and on or \nafter retirement. \n \n(a) \nThe services of a driver and an orderly. \n \n(b) \n1000 (one thousand) free local telephone calls per month. \n \n(c) \n1000 units of electricity as well as (25 hm3 of gas) per month \nand free supply of water; and \n \n(d) \n200 litres of petrol per month. \n \n \n(3) \nIf during service, a judge dies, exemption from tax in respect of \nbenefits and perquisites provided to widow as mentioned in sub-clause (2) shall \nalso be available to the widow. \n \n(57)   (1) \nAny income from voluntary contributions, house property and \ninvestments in securities of the Federal Government derived by the following, namely:-\n \n \n(i) \nNational Investment (Unit) Trust of Pakistan established by the National \nInvestment Trust Limited, if not less than ninety per cent of its Units at \nthe end of that year are held by the public and not less than ninety per \ncent of its come of the year is distributed among the Unit-holders; \n \n(ii) \nAny Mutual Fund approved by the 1[Securities and Exchanges commission \nof Pakistan] and set up by the Investment Corporation of Pakistan, if not less \nthan ninety per cent of its Certificates at the end of that year are held by the \npublic and not less than ninety per cent of its income of that year is distributed \namong the Certificate-holders; and \n \n2[   ]        \n(2)  \nAny income 3[other than capital gain on stock and shares of public \ncompany, PTC vouchers, modaraba certificates, or any instrument of redeemable \ncapital and derivative products held for less than 12 months] derived by any Mutual \n                                            \n1The words “Controller of Capital Issues” substituted by the Finance Ordinance, 2002 \n2 Paragraph (iii) of sub-clause (1) omitted by the Finance Act, 2021. Earlier this amendment was made \nthrough Tax Laws (Second  Amendment) Ordinance, 2021. The omitted paragraph read as follows: \n    “(iii) Sheikh Sultan Trust, Karachi” \n3Inserted by the Finance Act, 2010. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n565 \n \nFund, investment company, or a collective investment scheme 1[or a 2[REIT \nScheme] 3[or Private Equity and Venture Capital Fund]] 4[ ] or the National \nInvestment (Unit) Trust of Pakistan established by the National Investment Trust \nLimited from any instrument of redeemable capital as defined in the 5[Companies \nAct, 2017 (XIX of 2017), if not less than ninety per cent of its income of that year \nis distributed amongst the Unit- holders. \n \n(3) \nAny income of the following funds and institution, namely:- \n \n(i) \na provident fund to which the Provident Funds Act, 1925 (XIX of \n1925), applies; \n(ii) \ntrustees on behalf of a recognized provident fund or an approved \nsuperannuation fund or an approved gratuity fund; \n \n(iii) \na benevolent fund or group insurance scheme approved by the \n6[Board] for the purposes of this clause; \n \n(iv) \nService Fund; \n \n (v) \nEmployees Old Age Benefits Institution established under the \nEmployees Old Age Benefit Act, 1976 (XIV of 1976); \n \n (vi) \nany Unit, Station or Regimental Institute; and \n \n(vii) \nany recognized Regimental Thrift and Savings Fund, the assets of \nwhich consist solely of deposits made by members and profits \nearned by investment thereof; \n \n7[(viii)  a Pension Fund approved by the Securities and Exchange \nCommission of Pakistan under the Voluntary  Pension System \nRules, 2005;] \n \n8[(ix)  \nany profit or gain or benefit derived by a pension fund manager from \na pension Fund approved under the Voluntary Pension System \nRules, 2005, on redemption of the seed capital invested in pension \n                                            \n1Words inserted by the Finance Act, 2006. \n2The words “real estate investment trust” substituted by the Finance Act, 2008. \n3Inserted by the Finance Act, 2007. \n4The words “approved by the Securities and Exchange Commission of Pakistan” Omitted by the \nFinance Act, 2008. \n5 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \n6The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n7Added by the Finance Act, 2005. \n8Added by the Finance Act, 2005. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n566 \n \nfund as specified in the Voluntary Pension System Rules, 2005 1[;] ] \n \n2[  ] \n \n3[xi.  \nInternational Irrigation Management Institute.] \n \n4[xii. Punjab Pension Fund established under the Punjab Pension Fund \nAct, 2007 (I of 2007) and the trust established thereunder.] \n \n5[xiii.  Sindh Province Pension Fund established under the Sindh Province \nPension Fund Ordinance, 2002.] \n \n6[(xiv) Punjab General Provident Investment Fund established under the \nPunjab General Provident Investment Fund Act, 2009 (V of 2009) \nand the trust established thereunder.] \n \n Explanation.—For the purpose of this clause, \"Service Fund\" \nmeans a fund which is established under the authority, or with the \napproval of the Federal Government for the purpose of — \n \n(a) \nsecuring deferred annuities to the subscribers of payment to \nthem in the event of their leaving the service in which they are \nemployed; or \n \n(b) \nmaking provision for their wives or children after their death; or \n \n(c) \nmaking payment to their estate or their nominees upon their \ndeath. \n \n7[(xv) Khyber Pakhtunkhwa Retirement Benefits and Death Compensation \nFund. \n \n(xvi) \nKhyber Pakhtunkhwa General Provident Investment Fund. \n \n(xvii) Khyber Pakhtunkhwa Pension Fund.] \n \n                                            \n1 Full stop substituted by the Finance Act, 2006. \n2 Paragraph (x) omitted by the Finance Act, 2008. The omitted paragraph (x) read a follows: \n“(x)  the accumulated balance upto 25% received from the  voluntary pension system offered by a \npension fund manager under the Voluntary Pension System Rules, 2005 at the time of eligible \nperson’s: \n \n \n(a)  \nretirement; or \n \n \n(b)  \ndisability rendering him unable to work; or \n \n \n(c)  \ndeath by his nominated survivors.” \n3 Inserted by S.R.O. 1038(I)/2006, dated 09.10.2006. \n4 Added by the Finance Act, 2010. \n5 Clause (xiii) added by the Finance Act, 2014. \n6 Inserted by the Finance Act, 2015. \n7 Added by the Finance Act, 2018. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n567 \n \n1[(4) any income of the following funds, institutions, foundations and trusts, \nnamely:-  \n \nTABLE \n \nSr. No. \nName \n(1) \n(2) \ni. \nPension of a former President of Pakistan and his widow. \nii. \nState Bank of Pakistan and State Bank of Pakistan Banking Services \nCorporation. \niii. \nFederal Board of Revenue Foundation. \niv. \nPakistan Council of Scientific and Industrial Research. \nv. \nThe Pakistan Water and Power Development Authority established \nunder the Pakistan Water and Power Development Authority Act, 1958 \n(W. P. Act XXXI of 1958). \nvi. \nPakistan Agricultural Research Council. \nvii. \nThe corporatized entities of Pakistan Water and Power Development \nAuthority from the date of their creation upto the date of completion of \nthe process of corporatization i.e. till the tariff is notified. \nviii. \nThe Prime Minister’s Special Fund for victims of terrorism. \nix. \nChief Minister’s (Punjab) Relief Fund for Internally Displaced Persons \n(IDPs) of NWFP. \nx. \nSupreme Court of Pakistan – Diamer Bhasha & Mohmand Dams – \nFund. \nxi. \nNational Disaster Risk Management Fund. \nxii. \nThe Prime Minister’s COVID-19 Pandemic Relief Fund-2020. \nxiii. \nNational Endowment Scholarship for Talent (NEST). \nxiv. \nSecurities and Exchange Commission of Pakistan.  \nxv. \nPrivatisation Commission of Pakistan. \nxvi. \nFauji Foundation. \nxvii. \nAudit Oversight Board. \nxviii. \nSupreme Court Water Conservation Account. \nxix. \nBaluchistan Education Endowment Fund (BEEF). \nxx. \nArmy Welfare Trust. \nxxi. \nPublic Private Partnership Authority for tax year 2022 and subsequent \nfour tax years \nxxii. \nThe Prime Minister's Relief Fund for Flood, Earthquake and Other \nCalamities with effect on and from the 5th August, 2022. \nxxiii. \nExport-Import Bank of Pakistan \nxxiv. \nDeposit Protection Corporation established under sub-section (l) of \nsection 3 of Deposit Protection Corporation Act, 2016 (XXXVII of 2016). \nxxv. \nWAPDA First Sukuk Company Limited. \nxxvi. \nPakistan Domestic Sukuk Company Ltd. \n                                            \n1 Sub-clause (4) inserted by the Finance Act, 2025. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n568 \n \nxxvii. \nWAPDA on issuance of twenty billion rupees TFC’s/SUKUK certificates \nfor consideration of Diamer Bhasha Dam Projects. \nxxviii. \nWAPDA Second Sukuk Company Limited. \nxxix. \nPakistan International Sukuk Company Limited. \nxxx. \nSecond Pakistan International Sukuk Company Limited. \nxxxi. \nThird Pakistan International Sukuk Company Limited. \nxxxii. \nIslamic Naya Pakistan Certificates Company Limited (INPCCL). \nxxxiii. \nPakistan Mortgage Refinance Company Limited.; \nxxxiv. \nThe Pakistan Global Sukuk Programme Company Limited. \nxxxv. \nShaheed Mohtarma Benazir Bhutto Institute of Trauma, Karachi \nxxxvi. \nNational Memorial Bab-e-Pakistan Trust. \nxxxvii. \nPakistan Poverty Alleviation Fund. \nxxxviii. \nNational Rural Support Programme. \nxxxix. \n Karandaaz Pakistan from Tax Year 2015 onwards  \nxl. \nThe Institutions of the Agha Khan Development Network (Pakistan) as \ncontained in Schedule 1 of the Accord and Protocol, dated November \n13, 1994, executed between the Government of the Islamic Republic \nof Pakistan and the Agha Khan Development Network. \nxli. \nInternational Finance Corporation established under the International \nFinance Corporation Act, 1956 (XXVIII of 1956) and provided in \nsection 9 of Article VI of Articles of Agreement 1955 as amended \nthrough April 1993. \nxlii. \nAsian Infrastructure Investment Bank and persons as provided in \nArticle 51 of Chapter IX of the Articles of Agreement signed and ratified \nby Pakistan and entered into force on the 25th December, 2015. \nxliii. \nSAARC Energy Centre. \nxliv. \nThe Asian Development Bank established under the Asian \nDevelopment Bank Ordinance, 1971 (IX of 1971). \nxlv. \nInternational Islamic Trade Finance Corporation. \nxlvi. \nIslamic Corporation for Development of Private Sector. \nxlvii. \nECO Trade and Development Bank. \nxlviii. \nThe Islamic Chamber of Commerce and Industry under the \nOrganization of Islamic Conference (OIC). \nxlix. \nCommission on Science and Technology for Sustainable Development \nin the South (COMSATS) formed under International Agreement \nsigned on 5th October, 1994. \nl. \nSaarc Arbitration Council (SARCO). \nli. \nInternational Parliamentarians’ Congress. \nlii. \nArmy Officers Benevolent Fund/Benevolent Fund/Bereaved Family \nScheme. \n \n \n1[  ] \n                                            \n1 Clauses (58), (58A), (59) and (60) omitted by the Finance Act, 2014. The omitted clauses read as follows: \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n569 \n \n1[    ] \n                                            \n“(58) (1)  \nAny income of a trust or welfare institution or non-profit organization specified in sub-\nclauses (2) and (3) from donations, voluntary contributions, subscriptions, house property, investments \nin the securities of the Federal Government and so much of the income chargeable under the head \n\"Income from business\" as is expended in Pakistan for the purposes of carrying out welfare activities: \nProvided that in the case of income under the head \"Income from business\", the exemption in \nrespect of income under the said head shall not exceed an amount which bears to the income under \nthe said head the same proportion as the said amount bears to the aggregate of the incomes from the \naforesaid sources of income. \n(2) A trust administered under a scheme approved by the Federal Government in this behalf and \nestablished in Pakistan exclusively for the purposes of carrying out such activities as are for the benefit \nand welfare of— \n(i) \nex-servicemen and serving personnel, including civilian employees of the Armed Forces, \nand their dependents; or \n(ii)  ex-employees and serving personnel of the Federal Government or a Provincial \nGovernment and their dependents, where the said trust is administered by a committee \nnominated by the Federal Government or, as the case may be, a Provincial Government. \n(3) A trust or welfare institution or non-profit organization approved by Regional Commissioner of \nIncome Tax for the purposes of this sub-clause. \n(58A) Income of a university or other educational institution being run by a non-profit organization \nexisting solely for educational purposes and not for purposes of profit. \n \n(59) \nAny income which is derived from investments in securities of the Federal Government, profit \non debt from scheduled banks, grant received from Federal Government or Provincial Government or \nDistrict Government, foreign grants and house property held under trust or other legal obligations \nwholly, or in part only, for religious or charitable purposes and is actually applied or finally set apart for \napplication thereto: \nProvided that nothing in this clause shall apply to so much of the income as is not expended \nwithin Pakistan: \nProvided further that if any sum out of the amount so set apart is expended outside Pakistan, it \nshall be included in the total income of the tax year in which it is so expended or of the year in which \nit was set apart, whichever is the greater, and the provisions of section 122 shall not apply to any \nassessment made or to be made in pursuance of this proviso. \nExplanation.— Notwithstanding anything contained in the Mussalman Wakf Validating Act, 1913 (VI \nof 1913), or any other law for the time being in force or in the instrument relating to the trust or the \ninstitution, if any amount is set apart, expended or disbursed for the maintenance and support wholly \nor partially of the family, children or descendents of the author of the trust or the donor or, the maker \nof the institution or for his own maintenance and support during his life time or payment to himself or \nhis family, children, relations or descendents or for the payment of his or their debts out of the income \nfrom house property dedicated, or if any expenditure is made other than for charitable purposes, in \neach case such expenditure, provision, setting apart, payment or disbursement shall not be deemed, \nfor the purposes of this clause, to be for religious or charitable purposes. \n(60) \nAny income of a religious or charitable institution derived from voluntary contributions applicable \nsolely to religious or charitable purposes of the institution: \nProvided that nothing contained in clause (61) or this clause shall apply to the income \nof a private religious trust which does not ensure for the benefit of the public.” \n1  Clause (61) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n    “(61) \n1[Any] amount paid as donation to the following institution, foundations, societies, \nboards, trusts and funds, namely: — \n \n \n(i) \nany Sports Board or institution recognised by the Federal Government for the \npurposes of promoting, controlling or regulating any sport or game; \n \n1[(ia) \nThe Citizens Foundation;] \n \n1[  ] \n \n(iii) \nFund for Promotion of Science and Technology in Pakistan; \n \n(iv) \nFund for Retarded and Handicapped Children; \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n570 \n \n                                            \n \n(v) \nNational Trust Fund for the Disabled; \n \n1[  ] \n \n(vii) \nFund for Development of Mazaar of HazaratBurri Imam; \n \n(viii) \nRabita-e-Islami's Project for printing copies of the Holy Quran; \n \n(ix) \nFatimid Foundation, Karachi; \n \n(x) \n Al-Shifa Trust; \n \n1[  ] \n \n (xii) \nSociety for the Promotion of Engineering Sciences and Technology in Pakistan; \n \n1[  ] \n \n1[  ] \n \n1[  ] \n \n1[  ] \n \n1[  ] \n \n1[  ] \n \n1[  ] \n \n1[  ] \n \n1[   ] \n \n1[   ] \n \n(xxiii) \nCitizens-Police Liaison Committee, Central Reporting Cell, Sindh Governor House, \nKarachi; \n \n(xxiv) \nICIC Foundation; \n \n1[  ] \n \n(xxvi) \nNational Management Foundation; \n \n(xxvii) \nEndowment Fund of the institutions of the Agha Khan Development Network (Pakistan \nlisted in Schedule 1 of the Accord and Protocol, dated November 13, 1994, executed \nbetween the Government of the Islamic Republic of Pakistan and Agha Khan \nDevelopment Network; \n \n(xxviii)  \nShaheed Zulfiqar Ali Bhutto Memorial Awards Society; \n \n(xxix) \nIqbal Memorial Fund; \n \n(xxx) \nCancer Research Foundation of Pakistan, Lahore; \n \n(xxxi) \nShaukat Khanum Memorial Trust, Lahore;  \n \n(xxxii) \nChristian Memorial Hospital, Sialkot; \n \n(xxxiii) \nNational Museums, National Libraries and Monuments or institutions declared to be \nNational Heritage by the Federal Government; \n \n(xxxiv) \nMumtaz Bakhtawar Memorial Trust Hospital, Lahore; \n \n \n(xxxv) \nKashmir Fund for Rehabilitation of Kashmir Refugees and Freedom Fighters; \n \n(xxxvi) \nInstitutions of the Agha Khan Development Network (Pakistan) listed in Schedule 1 of \nthe Accord and Protocol, dated November 13, 1994, executed between the \nGovernment of the Islamic Republic of Pakistan and Agha Khan Development \nNetwork; \n \n(xxxvii) \nAzad Kashmir President's Mujahid Fund, 1972 ; National Institute of Cardiovascular \nDiseases, (Pakistan) Karachi; Businessmen Hospital Trust, Lahore; Premier Trust \nHospital, Mardan ; Faisal Shaheed Memorial Hospital Trust, Gujranwala; Khair-un-\nNisa Hospital Foundation, Lahore; Sind and Balochistan Advocates' Benevolent Fund; \nRashid Minhas Memorial Hospital Fund; \n \n(xxxviii) \nAny relief 1[or] welfare fund established by the Federal Government; \n \n (xxxix) \nMohatta Palace Gallery Trust; 1[  ]  \n \n1[(xl)] \nBagh-e-Quaid-e-Azam project, Karachi1[; 1[ ]  ]  \n \n1[(xli)  \nAny amount donated for Tameer-e-Karachi Fund1[:] ] \n \n1[(xlii) \nPakistan Red Crescent Society;] \n \n1[(xliii) \nBank of Commerce and Credit International Foundation for Advancement of Science \nand Technology;] \n \n1[(xliv) \nAny amount donated to Federal Board of Revenue Foundation.] \n \n1[“(xlv) \nThe Indus Hospital, Karachi.”] \n \n1[(xlvi) \nPakistan Sweet Homes Angels and Fairies Place.  \n \n    (xlvii)  \nAl-Shifa Trust Eye Hospital. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n571 \n \n \n1[  ] \n \n2[  ] \n \n3[  ] \n \n4[  ] \n \n5[     ] \n \n6[     ] \n \n                                            \n \n(xlviii) \nAziz Tabba Foundation \n \n1[(liv) \nSupreme Court of Pakistan – Diamer  Bhasha & Mohmand Dams – Fund.] \n \n1[(lv) \nLayton Rahmatullah Benevolent Trust  (LRBT). \n \n(lvi) \nAkhuwat.] \n \n1[(lvii) \nThe Prime Minister’s COVID-19 Pandemic Relief Fund-2020; \n \n(lviii) \nGhulam Ishaq Khan Institute of Engineering Sciences and Technology (GIKI); \n  \n(lvix) \nLahore University of Management Sciences; \n \n(lvx) \nDawat-e-Hadiya, Karachi; \n \n(lvxi) \nBaitussalam Welfare Trust; \n \n \n(lvxii) \nPatients’ Aid Foundation; \n \n(lvxiii) \nAlkhidmat Foundation; \n \n(lvxiv) \nAlamgir Welfare Trust International] 1[: \nProvided further that the amount so donated by an associate shall not exceed- \n(a) in the case of an individual or association of persons, fifteen percent of the taxable income \nof the person for the year; and \n(b) in the case of company, ten percent of taxable income of the person for the year: \nProvided also that the provisions of this clause shall apply only if donation is paid by a \ncrossed cheque drawn on a bank.] \n1 Clause (62) omitted by the Finance Act, 2008. The omitted clause (62) read as follows: \n“(62) Such portion of the total income of a taxpayer as is paid by him during the income year as \ndonation to the Liaquat National Hospital Association, Karachi: \n \n \nProvided that the amount so donated shall be included in computing the total income of the \ntaxpayer:  \nProvided further that the amount by which the taxable by a taxpayer is reduced on account of \nthe exemption under this clause shall be equal to the sum which bears the same proportion to the \nsum exempted from tax under this clause as the tax payable on the total income of the taxpayer \nbears to the said total income.” \n2Clause (63) omitted by the Finance Act, 2006. The omitted clause (63) read as follows: \n“ (63) Any amount paid as donation to the President’s Relief Fund for Tsunami Victims.” \n Earlier Clause (63) was omitted by the Finance Act, 2002. which read as follows: \n   “(63) Any amount paid as donation to the Prime Minister's Fund for National Debt Retirement: \nProvided that the exemption under this clause shall not apply in respect of any assessment year \ncommencing on, or after, the first day of July,2002. “ \n3 Clause (63A) omitted by the Finance Act, 2008. The omitted clause (63A) read as follows: \n“(63A) Any amount paid as donation to the President’s Relief Fund for Earthquake Victims 2005.” \n4Clause (63B) omitted by the Finance Act, 2008. The omitted clause (63B) read as follows: \n“(63B)  Any amount donated or paid, as sponsorship in connection with the holding of 2nd session \nof the World Islamic Economic Forum, 2006.” \n5Clause (64) omitted by the Finance Act, 2002. The omitted clause (64) read as follows: \n   “(64) Any amount paid as donation to the National Self Reliance Fund: \nProvided that the exemption under this clause shall not apply in respect of any assessment year \ncommencing on, or after, the first day of July,2002.” \n6Inserted by S.R.O. 389(I)/2009, dated 19.05.2009. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n572 \n \n1[     ] \n \n2[     ] \n \n3[     ] \n \n4[     ] \n \n5[     ] \n \n6[(65A) Income for any tax year commencing from the tax year 2003, derived from \nthe Welfare Fund created under rule-26 of the Emigration Rules, 1979 (made \nunder section 16 of the Emigration Ordinance, 1979 (XVIII of 1979), except the \nincome generated by the aforesaid Fund through commercial activities.] \n \n7[(65B) Any monetary award received from the Federal or Provincial Government \nor from a Public Office holder by a sportsperson winning a medal in international \nOlympic Games representing Pakistan:  \n \n \nProvided that this clause shall be applicable from tax year 2025.] \n \n8[   ] \n                                            \n1 Clause (64A) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n  “(64A)  Any amount donated to the Prime Minister’s Special Fund for victims of terrorism.]  \n2 Inserted by S.R.O. 576(I)/2009, dated 18.06.2009. \n3 Clause (64B) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n  “((64B) Any amount donated to the Chief Minister’s (Punjab) Relief Fund for Internally Displaced    \nPersons (IDPs) of NWFP.]”  \n4 Inserted by S.R.O. 755(I)/2010, dated 09.08.2011. \n5 Clauses (64C) and (65) omitted by the Finance Act, 2021. Earlier this amendment was made through \nTax Laws (Second  Amendment) Ordinance, 2021. The omitted clauses read as follows: \n  “(64C)   Prime Minister’s Flood Relief Fund 2010 and Provincial Chief Ministers’ Relief Funds, for \nvictims of flood 2010.] \n(65) Any income derived from donations made by non-official or private sector sources in Pakistan \nto the Waqf for Research on Islamic History, Art and Culture, Istanbul set up by the Research Centre \nfor Islamic History, Art and Culture (IRCICA).”  \n6 Serial No. (65A) inserted by S.R.O 819(I)/202, dated 04.07.2012. \n7 Clause (65B) inserted by the Finance Act 2025.  \n8 Clause (66) substituted by the Finance Act, 2020. The substituted clause (66) read as follows: \n  (66) Any income derived by— \ni.  \nAbdul SattarEdhi Foundation, Karachi; \nii.  \nAl-Shifa Trust, Rawalpindi. \niii.  \nBilquisEdhiFoundation, Karachi. \niv.  \nFatimid Foundation, Karachi. \n8[ ]  \nvi.  \nInternational Islamic Trade Finance Corporation”. \nvii.  \nIslamic Corporation for Development of Private Sector; \nviii.  \nNational Memorial Bab-e-Pakistan Trust for the assessment year commencing on or \nafter the 1st day of July, 1994. \n \nix.  \nPakistan Agricultural Research Council, Islamabad. \n \nx.  \nPakistan Engineering Council; \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n573 \n \n                                            \nxi.  \nThe corporatized entities of Pakistan Water and Power Development Authority from the \ndate of their creation upto the date of completion of the process of corporatization i.e. \ntill the tariff is notified. \n \nxii.  \nThe Institution of Engineers, Pakistan, Lahore. \n8[(xiia)  \nThe Prime Minister’s Special Fund for victims of terrorism.] \n8[(xiib) \nChief Minister’s (Punjab) Relief Fund for Internally Displaced Persons (IDPs) of \nNWFP.] \nxiii.  \nThe Institutions of the Agha Khan Development Network (Pakistan) as contained in \nSchedule 1 of the Accord and Protocol, dated November 13, 1994, executed between \nthe Government of the Islamic Republic of Pakistan and the Agha Khan Development \nNetwork. \nxiv.  \nThe Liaquat National Hospital Association, Karachi. \n \nxv.  \nThe Pakistan Council of Scientific and Industrial Research. \n \nxvi.  \nThe Pakistan Water and Power Development Authority established under the Pakistan \nWater and Power Development Authority Act, 1958 (W. P. Act XXXI of 1958).] \n8[xvii. \nWAPDA First Sukuk Company Limited.] \n8[8[   ] ]  \n8[(xix)  \nPension of a former President of Pakistan and his widow under the President Pension \nAct, 1974 (IX of 1975).] \n8[(xx)  \nState Bank of Pakistan and State Bank of Pakistan Banking Services Corporation.] \n8[(xxi)  \nInternational Finance Corporation established under the International Finance \nCorporation Act, 1956 (XXVIII of 1956) and provided in section 9 of Article VI of Articles \nof Agreement 1955 as amended through April 1993.] \n8[(xxii)  \nPakistan Domestic Sukuk Company Ltd.] \n8[(xxiii)  \nThe Asian Development Bank established under the Asian  \n \n \n \nDevelopment Bank Ordinance, 1971 (IX of 1971).] \n8[(xxiv) \nThe ECO Trade and Development Bank.] \n8[8[(xxv)] \nThe Islamic Chamber of Commerce and Industry under the Organization of Islamic \nConference (OIC).] \n8[8[(xxvi)] \n \nCommission on Science and Technology for Sustainable Development in the \nSouth (COMSATS) formed under International Agreement signed on 5th October, \n1994.] \n8[8[(xxvii)] WAPDA on issuance of twenty billion rupees TFC’s/SUKUK certificates for \nconsideration of DiamerBhasha Dam Projects.] \n8[8[(xxviii)] Federal Board of Revenue Foundation.] \n8[8[(xxix)] \nWAPDA Second Sukuk Company Limited.] \n8[8 [(xxx)] \nThe Citizens Foundation.] \n8[8[(xxxi)] \nSindh Institute of Urology and Transplantation, SIUT Trust and8[Society for the Welfare \nof SIUT.]] \n8[8[“(xxxii)” Greenstar Social Marketing Pakistan (Guarantee) Limited.]] \n8[“(xxxiii)  Pakistan International Sukuk Company Limited.”] \n8[“(xxxiii)  The Indus Hospital, Karachi.”] \n8[“(xxxiv)  Second Pakistan International Sukuk Company Limited.”] \n8[(xxxv)     Third Pakistan International Sukuk Company Limited.”;] \n8[(xxxv)  \nThird Pakistan International Sukuk Company Limited.] \n8[(xxxvi) \nAsian Infrastructure Investment Bank and persons as provided in Article 51 of Chapter IX of the \nArticles of Agreement signed and ratified by Pakistan and entered into force on the 25th \nDecember, 2015.  \n(xxxvii) \nGulab Devi Chest Hospital. \n(xxxviii) \nPakistan Poverty Alleviation Fund. \n(xxxix) \nNational Academy of Performing Arts. \n(xl) \nPakistan Sweet Homes Angels and Fairies Place. \n(xli) \nNational Rural Support Programme.] \n    8[(xlii) \n  SAARC Energy Centre.  \n(xliii) \n  Pakistan Bar Council. \n(xliv) \n  Pakistan Centre for Philanthropy. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n574 \n \n1[(66) Subject to the provisions of section 100C, any income, derived by the \n                                            \n(xlv) \n  Pakistan Mortgage Refinance Company Limited. \n(xlvi)  \nAziz Tabba Foundation. \n(l)      \nAl-Shifa Trust Eye Hospital. \n(li) \nSaylani Welfare International Trust. \n(lii) \nShaukat Khanum Memorial Trust. \n(liii) \nLayton Rahmatullah Benevolent Trust (LRBT).  \n(liv) \nThe Kidney Centre Post Graduate Training Institute. \n(lv) \nPakistan Disabled Foundation.  \n(lvi) \nForman Christian College.; \n(lvii)         Habib University Foundation. \n(lviii) \nBegum Akhtar Rukhsana Memorial Trust Hospital. \n \n(lix) \nAl-Khidmat Foundation.  \n(lx) \nDawat-e-Islami Trust \n(Ixi) \nSardar Trust Eye Hospital, Lahore.] \n8[(lxii)  \nSupreme Court of Pakistan – Diamer Bhasha & Mohmand Dams – Fund.”;] \n8[(lxiii)      National Disaster Risk Management Fund.  \n(lxiv)       Deposit Protection Corporation established under sub-section (l) of section 3 of Deposit \nProtection Corporation Act, 2016 (XXXVII of 2016). \n(lxv)        SARMAYA-E-PAKISTAN LIMITED] \n8[(lxvi)        Akhuwat \n(lxvii) \nAudit Oversight Board. \n(lxviii)        Patient’s Aid Foundation.”  \n \n1 Clause (66) substituted by the Finance Act, 2025. The substituted clause read as follows: \n   “(66) \n(1) \nAny income derived by the following institutions, foundations, societies, boards, trusts \nand funds, namely: — \nTable 1 \n \nSr. No. \nName \n(1) \n(2) \n(i) \nInternational Islamic Trade Finance Corporation. \n(ii) \nIslamic Corporation for Development of Private Sector. \n(iii) \nNational Memorial Bab-e-Pakistan Trust. \n(iv) \nPakistan Agricultural Research Council. \n(v) \nThe corporatized entities of Pakistan Water and Power Development Authority from the \ndate of \ntheir creation upto the date of completion of the process of corporatization i.e. till the \ntariff is notified. \n(vi) \nThe Prime Minister’s Special Fund for victims of terrorism. \n(vii) \nChief Minister’s (Punjab) Relief Fund for Internally Displaced Persons (IDPs) of \nNWFP. \n(viii) \nThe Institutions of the Agha Khan Development Network (Pakistan) as contained in \nSchedule 1 of the Accord and Protocol, dated November 13, 1994, executed between the \nGovernment of the Islamic Republic of Pakistan and the Agha Khan Development \nNetwork. \n(ix) \nPakistan Council of Scientific and Industrial Research. \n(x) \nThe Pakistan Water and Power Development Authority established under the \nPakistan Water and Power Development Authority Act, 1958 (W. P. Act XXXI of \n1958). \n(xi) \nWAPDA First Sukuk Company Limited. \n(xii) \nPension of a former President of Pakistan and his widow. \n(xiii) \nState Bank of Pakistan and State Bank of Pakistan Banking Services Corporation. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n575 \n \n                                            \n(xiv) \nInternational Finance Corporation established under the International Finance \nCorporation Act, 1956 (XXVIII of 1956) and provided in section 9 of Article VI of \nArticles of Agreement 1955 as amended through April 1993. \n(xv) \nPakistan Domestic Sukuk Company Ltd. \n(xvi) \nECO Trade and Development Bank. \n(xvii) \nThe Islamic Chamber of Commerce and Industry under the Organization of Islamic \nConference (OIC). \n(xviii) \nCommission on Science and Technology for Sustainable Development in the \nSouth (COMSATS) \nformed under International Agreement signed on 5th October, 1994. \n(xix) \nWAPDA on issuance of twenty billion rupees TFC’s/SUKUK certificates for \nconsideration of Diamer Bhasha Dam Projects. \n(xx) \nFederal Board of Revenue Foundation. \n(xxi) \nWAPDA Second Sukuk Company Limited. \n(xxii) \nPakistan International Sukuk Company Limited. \n(xxiii) \nSecond Pakistan International Sukuk Company Limited. \n(xxiv) \nThird Pakistan International Sukuk Company Limited. \n(xxv) \nAsian Infrastructure Investment Bank and persons as provided in Article 51 of \nChapter IX of the Articles of Agreement signed and ratified by Pakistan and \nentered into force on the 25th December, 2015. \n(xxvi) \nSupreme Court of Pakistan – Diamer Bhasha & Mohmand Dams – Fund. \n(xxvii) \nNational Disaster Risk Management Fund. \n(xxviii) \nDeposit Protection Corporation established under sub-section (l) of section 3 of \nDeposit Protection Corporation Act, 2016 (XXXVII of 2016). \n(xxix) \nSAARC Energy Centre. \n(xxx) \nThe Asian Development Bank established under the Asian Development Bank \nOrdinance, 1971 (IX of 1971). \n(xxxi) \nThe Prime Minister’s COVID-19 Pandemic Relief Fund-2020. \n(xxxii) \nSaarc Arbitration Council (SARCO). \n(xxxiii) \nInternational Parliamentarians’ Congress. \n(xxxiv) \nSindh Institute of Urology and Transplantation, SIUT Trust and Society for the \nWelfare of SIUT. \n(xxxv) \nShaukat Khanum Memorial Trust. \n(xxxvi) \nNational Endowment Scholarship for Talent (NEST). \n1[(xxxvii) \nIslamic Naya Pakistan Certificates Company Limited (INPCCL). \n(xxxviii) \nAbdul Sattar Edhi Foundation. \n(xxxix) \nPatient’s Aid Foundation. \n(xl) \nIndus Hospital and Health Network. \n(xli) \nSecurities and Exchange Commission of Pakistan.  \n(xlii) \nDawat-e-Hadiya, Karachi. \n(xliii) \nPrivatisation Commission of Pakistan. \n(xliv) \nThe Citizens Foundation. \n(xlv) \nSundus Foundation. \n(xlvi) \nAli Zaib Foundation  \n(xlvii) \nFauji Foundation. \n(xlviii) \nMake a Wish Foundation \n(xlix) \nAudit Oversight Board. \n1[(l) \nSupreme Court Water Conservation Account. \n(li) \nLayton Rahmatullah Benevolent Trust (LRBT). \n(lii) \nBaluchistan Education Endowment Fund(BEEF). \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n576 \n \n                                            \n(liii) \nSaylani Welfare International Trust. \n(liv) \nChiniot Anjuman Islamia. \n(lv)] \nArmy Welfare Trust.] \n[ [(lvi) \n Pakistan Mortgage Refinance Company Limited.; \n(lvii)  \n The Pakistan Global Sukuk Programme Company Limited.\" \n(lviii) \n Karandaaz Pakistan from tax year 2015 onwards \n(lix) \n Pakistan Sweet Homes Angels and Fairies Place. \n(lx) \n Public Private Partnership Authority for tax year 2022 and subsequent four \ntax years  \n(lxi) \n Dawat-e-Islami Trust \n(lxii)  \n Hamdard Laboratories (Waqf) Pakistan  \n1[(lxiii) \nThe Prime Minister's Relief Fund for Flood, Earthquake and Other \nCalamities with  effect on and from the 5th August, 2022. \n(lxiv) \n Film and Drama Finance Fund \n(lxv) \nExport-Import Bank of Pakistan \n(lxvi) \n Shaheed Mohtarma Benazir Bhutto Institute of Trauma, Karachi \n(lxvii) \nShaheed Zulfikar Ali Bhutto Institute of Science and Technology] \n(2) \nSubject to the provisions of section 100C, any income derived by the following \ninstitution, foundations, societies, boards, trusts and funds, namely: \nTable 2 \nSr. No. \nName \n(1) \n(2) \n1[  ]  \n \n(ii) \nAl-Shifa Trust. \n(iii) \nBilquis Edhi Foundation. \n(iv) \nFatimid Foundation. \n(v) \nPakistan Engineering Council. \n(vi) \nThe Institution of Engineers. \n(vii) \nLiaquat National Hospital Association. \n[   ] \n \n(ix) \nGreenstar Social Marketing Pakistan (Guarantee) Limited. \n[    ] \n \n(xi) \nGulab Devi Chest Hospital. \n(xii) \nPakistan Poverty Alleviation Fund. \n(xiii) \nNational Academy of Performing Arts. \n1[    ]  \n \n(xv) \nNational Rural Support Programme. \n(xvi) \nPakistan Bar Council. \n(xvii) \nPakistan Centre for Philanthropy. \n[    ]    \n \n(xix) \nAziz Tabba Foundation. \n[   ] \n \n(xxi) \nThe Kidney Centre Post Graduate Training Institute. \n(xxii) \nPakistan Disabled Foundation.. \n(xxiii) \nForman Christian College.. \n(xxiv) \nHabib University Foundation. \n(xxv) \nBegum AkhtarRukhsana Memorial Trust Hospital. \n(xxvi) \nAl-Khidmat Foundation. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n577 \n \nfollowing institutions, foundations, societies, boards, trust and funds, namely:- \n \nTABLE \n \nSr. No. \nName \n(1) \n \n \n \n(2) \n(i)  \nAl-Shifa Trust. \n(ii)  \nFatimid Foundation. \n(iii)  \nPakistan Engineering Council. \n(iv)  \nThe Institution of Engineers. \n(v)  \nLiaquat National Hospital Association. \n(vi)  \nGreenstar Social Marketing Pakistan (Guarantee) Limited. \n(vii)  \nGulab Devi Chest Hospital. \n(viii)  \nNational Academy of Performing Arts. \n(ix)  \nPakistan Bar Council. \n(x)  \nPakistan Centre for Philanthropy. \n(xi)  \nAziz Tabba Foundation. \n(xii)  \nThe Kidney Centre Post Graduate Training Institute. \n                                            \n    [      ] \n \n(xxviii) \nSardar Trust Eye Hospital, Lahore.. \n(xxix) \nAkhuwat. \n[    ] \n \n[   ] \n \n(xxxii) \nAl-Shifa Trust Eye Hospital. \n[   ] \n \n(xxxiv) \nSARMAYA-E-PAKISTAN LIMITED. \n(xxxv) \nLahore University of Management Sciences, Lahore. \n[   ] \n \n(xxxvii) \nGhulam Ishaq Khan Institute of Engineering Sciences and Technology. \n(xxxviii) \nSociety for the Promotion of Engineering Sciences and Technology in Pakistan \n(SOPREST). \n(xxxix) \nBusinessmen Hospital Trust. \n(xl) \nBaitussalam Welfare Trust. \n(xli) \nAlamgir Welfare Trust International. \n(xlii) \nFoundation University. \n1[(xliii) \nBurhani Qarzan Hasnan Trust \n(xliv) \nSaifee Hospital Karachi  \n(xlv) \nSaifiyah Girls Taalim Trust] \n1[(xlvi) \nBalochistan Bar Council \n(xlvii) \n Islamabad Bar Council \n(xlviii) \n  Khyber Pakhtunkhwa Bar Council \n(xlix) \n Punjab Bar Council \n(l) \nSindh Bar Council \n(li) \n  Shaheed Zulfikar Ali Bhutto Foundation (SZABF)] \nProvided that with effect from the 1st day of July, 2021, exemption under this sub- clause shall \nbe subject to fulfilling the conditions specified in section 100C.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n578 \n \n(xiii)  \nPakistan Disabled Foundation. \n(xiv)  \nForman Christian College. \n(xv)  \nHabib University Foundation. \n(xvi)  \nBegum AkhtarRukhsana Memorial Trust Hospital. \n(xvii)  \nAl-Khidmat Foundation. \n(xviii) \nSardar Trust Eye Hospital, Lahore. \n(xix)  \nAkhuwat. \n(xx)  \nAl-Shifa Trust Eye Hospital. \n(xxi)  \nSarmaya-E-Pakistan Limited. \n(xxii)  \nLahore University of Management Sciences, Lahore. \n(xxiii) \nGhulam Ishaq Khan Institute of Engineering Sciences and Technology. \n(xxiv) \nSociety for the Promotion of Engineering Sciences and Technology in \nPakistan (SOPREST). \n(xxv) \nBusinessmen Hospital Trust. \n(xxvi) \nBaitussalam Welfare Trust. \n(xxvii) \nAlamgir Welfare Trust International. \n(xxviii) \nFoundation University. \n(xxix) \nBurhani Qarzan Hasnan Trust \n(xxx) \nSaifee Hospital Karachi  \n(xxxi) \nSaifiyah Girls Taalim Trust] \n(xxxii) \nBalochistan Bar Council \n(xxxiii)   Islamabad Bar Council \n(xxxiv)   Khyber Pakhtunkhwa Bar Council \n(xxxv)   Punjab Bar Council \n(xxxvi)   Sindh Bar Council \n(xxxvii)   Shaheed Zulfikar Ali Bhutto Foundation (SZABF)] \n(xxxviii)  Pakistan Sweet Homes Angels and Fairies Place. \n(xxxix)   Sindh Institute of Urology and Transplantation, SIUT Trust and Society  for \nthe   Welfare of SIUT. \n(xl)  \n Shaukat Khanum Memorial Trust. \n(xli)  \n Abdul Sattar Edhi Foundation. \n(xlii)  \n Patient’s Aid Foundation. \n(xliii) \n Indus Hospital and Health Network. \n(xliv) \n Sundus Foundation. \n(xlv)  \n Ali Zaib Foundation  \n(xlvi) \n Layton Rahmatullah Benevolent Trust (LRBT). \n(xlvii) \n Dawat-e-Hadiya, Karachi. \n(xlviii) \n The Citizens Foundation. \n(xlix) \n Make a Wish Foundation \n(l)  \n Saylani Welfare International Trust. \n(li)  \n Dawat-e-Islami Trust \n(lii)  \n Chiniot Anjuman Islamia. \n(liii)  \n Hamdard Laboratories (Waqf) Pakistan \n(liv)  \n Film and Drama Finance Fund \n(lv)  \n Shaheed Zulfikar Ali Bhutto Institute of Science and Technology \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n579 \n \n(lvi)  \n Beaconhouse National University \n(lvii)  \n Federal Ziauddin University \n(lviii) \n Punjab Police Welfare Organization, Lahore. \n \n \n \n \n \n \n \n \n \n \n \n \n \n] \n1[   ] \n \n2[   ] \n \n3[   ] \n \n4[   ] \n \n5[   ] \n \n6[   ] \n7[   ] \n8[   ] \n                                            \n1Clause (67) omitted by the Finance Act, 2006. The omitted clause (67) read as follows: \n“(67) Any income of the Liaquat National Hospital Association, Karachi.” \n2Clause (68) omitted by the Finance Act, 2006. The omitted clause (68) read as follows: \n“(68) Any income derived by- \n \n(i) \nAbdul Sattar Edhi Foundation, Karachi; and \n(ii) \nBilquis Edhi Foundation, Karachi.” \n3Clause (69) omitted by the Finance Act, 2006. The omitted clause (69) read as follows: \n“(69) Any income derived by Al-Shifa Trust, Rawalpindi.” \n4 Clause (70) omitted by the Finance Act, 2006. The omitted clause (70) read as follows: \n“(70) Any income derived by Fatimid Foundation, Karachi.” \n5Clause (71) omitted by the Finance Act, 2006. The omitted clause (71) read as follows: \n“(71) Any income of Hamadard Laboratories (Waqf) Pakistan.” \n6Clause (71A) omitted by the Finance Act, 2006. The omitted clause (71A) read as follows: \n“(71A) Any income of National Memorial Bab-e-Pakistan Trust for the assessment year commencing \non or after the 1st day of July, 1994.” \n7Clause (72) substituted by the Finance Act, 2006. The substituted clause (72) read as follows:  \n“(72) Any profit on debt payable to a non-resident person in respect of such private loan to be utilised \non such project in Pakistan as may be approved by the Federal Government for the purposes of this \nclause, having regard to the rate of profit and the terms of re-payment of the loan and the nature of \nproject on which it is to be utilised.” \n8 Clauses (72) and (72A) omitted by the Finance Act, 2021. Earlier clause (72A) was omitted through \nTax Laws (Second  Amendment) Ordinance, 2021. The omitted clauses read as follows: \n    “(72) Any profit on debt payable to a non-resident person,- \n(i)  \nin respect of such private loan to be utilized on such project in  Pakistan as may be \napproved by the Federal Government for the purposes of this clause, having regard to \nthe rate of profit and the terms of repayment of the loan and the nature of project on \nwhich it is to be utilized; \n(ii)  \non a loan in foreign exchange against export letter of credit which is  used exclusively \nfor export of goods manufactured or processed for exports in Pakistan 8[.] \n8[(iii)  \nbeing a foreign individual, company, firm or association of persons in respect of a \nforeign loan as is utilized for industrial investment in Pakistan provided that the \nagreement for such loan is concluded on or after the first day of February, 1991, and is \nduly registered with the State Bank of Pakistan: \nProvided that this clause shall have retrospective effect of exemption to the agreements \nentered into in the past and shall not be applicable to new contracts after the 30th day of June, \n2010, prospectively.] \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n580 \n \n1[   ] \n \n2[   ] \n \n3[   ] \n4[   ] \n \n5[(75) Any profit on debt and capital gains derived by any agency of foreign \nGovernment or any non-resident person approved by the Federal Government for \nthe purpose of this clause from debt and debt instruments approved by the Federal \nGovernment.] \n \n \n6[  ] \n \n7[  ] \n \n \n(78) Any profit on debt derived from foreign currency accounts held with \nauthorised banks in Pakistan, 8[or certificate of investment issued by investment \nbanks] in accordance with Foreign Currency Accounts Scheme introduced by the \nState Bank of Pakistan, by 9[non-resident individuals, non-resident association of \n                                            \n  (72A) Any income derived by Sukuk holder in relation to Sukuk issued by “The Second Pakistan   \nInternational Sukuk Company Limited” 8[and the Third Pakistan International Sukuk Company \nLimited], including any gain on disposal of such Sukuk.”] \n1Inserted by S.R.O. 1029(I)/2014 dated 19.11.2014. \n2 Clause (73) omitted by the Finance Act, 2006. The omitted clause (73) read as follows: \n“(73) Any profit on debt payable to a non-resident person on a loan in foreign exchange against \nexport letter of credit which is used exclusively for export of goods manufactured or processed for \nexports in Pakistan.” \n3 Clause (74) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021.The omitted clause read as follows: \n    “(74) \nAny profit on debt derived by Hub Power Company Limited on or after the first day of July, \n1991, on its bank deposits or accounts with3[financial institutions] directly connected with \nfinancial transactions relating to the project operations.” \n4Clause (74A) omitted by the Finance Act, 2011. The omitted clause (74A) read as follows: \n“(74A) Any profit on debt, payable to National Bank of Pakistan, on foreign currency loan of US $ \n100 million, given to Pakistan State Oil Company Limited (PSO) under agreement executed at \nBahrain on the 29th May, 2001, approved by the Federal Government vide Finance Division’s letter \nNo.F.3(3)EF(B-III)/2001, dated the May 29, 2001. \n5 Clause (75) substituted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The substituted clause read as follows: \n“(75) \nAny income of an agency of a foreign Government, a foreign national (company, firm or \nassociation of persons), or any other non-resident person approved by the Federal Government for the \npurposes of this clause, from profit on moneys borrowed under a loan agreement or in respect of  \nforeign currency instrument approved by the Federal Government.” \n6Clause (76) omitted by the Finance Act, 2006. The omitted clause (76) read as follows: \n“(76) Any profit on debt payable to a non-resident person being a foreign individual, company, firm \nor association of persons in respect of a foreign loan as is utilised for industrial investment in \nPakistan provided that the agreement for such loan is concluded on or after the First day of February \n1991, and is duly registered with the State Bank of Pakistan.” \n7 Clause (77) omitted by the Finance Act, 2008. The omitted clause (77) read as follows: \n“(77) Any profit derived by a non-resident person (whether a citizen of Pakistan or otherwise) in \nrespect of the Islamic mode of financing, including istisna, morabaha, musharika.” \n8Inserted by the Finance Act, 2004. \n9 The expression “citizens of Pakistan and foreign nationals residing abroad, foreign association of \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n581 \n \npersons and non-resident companies].  \n \n(79) Any profit on debt derived from a rupee account held with a scheduled bank in \nPakistan by a 1[non-resident individual holding a Pakistan Origin Card (POC) or \nNational ID Card for Overseas Pakistanis (NICOP) or Computerized National ID \nCard (CNIC)], where the deposits in the said account are made exclusively from foreign \nexchange remitted into the said account. \n \n2[   ] \n \n3[   ] \n \n4[   ] \n \n5[   ] \n \n6[   ] \n \n \n7[  ] \n                                            \npersons, companies registered and operating abroad and foreign nationals residing in Pakistan” \nsubstituted by the Finance Act, 2021. Earlier this expression was made through Tax Laws \n(Amendment) Ordinance, 2021. \n1 The expression “citizen of Pakistan residing abroad” substituted by the Finance Act, 2021. Earlier this \nexpression was made through Tax Laws (Amendment) Ordinance, 2021. \n2 Clause (80) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(80) Any income derived from a private foreign currency account held with an authorised bank in \nPakistan, 2[or certificate of investment issued by investment banks] in accordance with the Foreign \nCurrency Accounts Scheme introduced by the State Bank of Pakistan, by a resident individual who \nis a citizen of Pakistan:  \nProvided that the exemption under this clause shall not be available in respect of any \nincremental deposits made in the said accounts on or after the 16th day of December, 1999, or in \nrespect of any accounts opened under the said scheme on or after the said date.” \n3Clause (81) omitted by the Finance Act, 2004. The omitted clause (81) read as follows:  \n“(81) The income of a person, other than a bank or a financial institution, by way of interest on \nForeign Currency Bearer Certificates issued under the Three-Years Foreign Currency Bearer \nCertificate Rules, 1997.” \n4Clause (81A) omitted by Finance Act, 2014. The omitted clause (81A) read as follows: \n“(81A) Notwithstanding omission of clause (81), the existing holders of Foreign Currency Bearer \nCertificate shall continue to have the benefit of exemption till such certificates are encashed.” \n5Clause (82) omitted by the Finance Act, 2008. The omitted clause (82) read as follows: \n“(82)  Any profit on Special US Dollar Bonds issued under the Special US Dollar Bonds Rules, 1998: \nProvided that the exemption under this clause shall not apply to profits on the said bonds \npurchased by a resident person out of any incremental deposits made in the foreign currency \naccounts on or after the 16th day of December, 1999, or out of new accounts opened on or after \nthe said date.” \n6Clause (83) omitted by the Finance Act, 2008. The omitted clause (83) read as follows: \n“(83) Any profit on debt derived from Pak rupees account or certificates of deposit which have been created \nby conversion of a foreign currency account or deposit held on the 28th day of May, 1998, with a bank \nauthorised under the Foreign Currency Accounts Scheme of State Bank of Pakistan: \nProvided that nothing contained in this clause shall apply to such Pak rupee account or certificates \nwhich are created out of foreign currency deposits which are not exempt under clause (78) and (80).” \n7 Clause (84) omitted by the Finance Act, 2004. The omitted clause (84) read as follows:  \n“(84)  Any profit on debt received from a Pakistani bank by a foreign bank, approved by the Federal \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n582 \n \n1[  ] \n \n2[  ] \n \n3[  ] \n \n4[  ] \n \n5[  ] \n6[  ] \n                                            \nGovernment for the purposes of this clause, for such period as may be determined by the Federal \nGovernment: \nProvided that- \n(i) \nthe profit is earned on deposits comprising of remittances from abroad held in a rupee account \nopened with a Pakistani bank with the prior approval of the State Bank of Pakistan; \n(ii) \nthe Pakistani bank maintaining the said rupee account holds 20 per cent or more of the equity \ncapital of the said foreign bank and the management of the latter vests in the Pakistani bank; \nand \n(iii) \nthe rate of profit chargeable on the said deposits does not exceed the rate of interest \nchargeable on the deposits in the foreign currency accounts allowed to be opened with banks \nin Pakistan by the State Bank of Pakistan.” \n1Clause (85) omitted by the Finance Act, 2002. The omitted clause (85) read as follows: \n“(85) Any income derived by any person, not being a bank, a banking company, financial institution, a \ndevelopment financing institution or a company engaged in the business of insurance, by way of return on \nbearer bonds issued by the Pakistan Water and Power Development Authority, established under the \nPakistan Water and Power Development Authority Act, 1958 (West Pakistan Act. No.( XXXI of 1958):  \nProvided that nothing contained in this clause shall apply in respect of return on bonds issued on or after \nthe first day of July, 1991.” \n2 Clause (86) omitted by the Finance Act, 2002. The omitted clause (86) read as follows: \n“(86) Any income derived by any person, being an individual, by way of return on bearer or registered bonds \n(Second issue, 1989), issued by the Pakistan Water and Power Development Authority, established under \nthe Pakistan Water and Power Authority Act, 1958 (West Pakistan Act, No. XXXI of 1958):  \nProvided that nothing contained in this clause shall apply in respect of return on bonds issued on or after \nthe first day of July, 1991.” \n3 Clause (87) omitted by the Finance Act, 2003. The omitted clause (87) read as follows:  \n“(87)  Any income derived by a non-resident person from foreign investment in 7th issue of Pak rupee \ndenominated WAPDA Energy Bonds issued under the WAPDA Energy Bonds (7th Issue) Regulations, 1997.” \n4 Clause (88) omitted by the Finance Act, 2004. The omitted clause (88) read as follows:  \n“(88)  Any income derived by a non-resident person(excluding local branches, subsidiaries or offices of  \nforeign banks, companies, associations of persons or any other person operating in Pakistan) from Federal \nGovernment securities and redeemable capital, as defined in the Companies Ordinance, 1984, (XLVII of \n1984) listed on a registered stock exchange, where the investments are made exclusively from foreign \nexchange remitted into Pakistan through a Special Convertible Rupee Account maintained with a bank in \nPakistan.” \n5Clause (88A) omitted by Finance Act, 2014. The omitted clause (88A) read as follows: \n \n“ (88A) Notwithstanding omission of clause (88), the existing holders of Federal Government \nSecurities and redeemable capital shall continue to have benefit of exemption till the maturity of the \nsecurities and redeemable capital.” \n6 Clause (89) omitted by the Finance Act, 2002. The omitted clause (89) read as follows: \n”(89) Any income derived by an individual or association of persons from rated and listed Term \nFinance Certificates being the instruments of redeemable capital under the Companies Ordinance \n1984, issued on or after the 14th day of September 1997: \nProvided that the exemption under this clause shall not apply in respect of any assessment \nyear commencing on, or after, the first day of July, 2002.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n583 \n \n1[   ] \n2[   ] \n \n3[   ] \n \n4[   ] \n \n5[   ]  \n \n6[   ] \n7[  ] \n                                            \n1 Clause (90) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n   “(90) Any profit on debt payable by an industrial undertaking in Pakistan — \n(i) \non moneys borrowed by it under a loan agreement entered into with any such financial \ninstitution in a foreign country as may be approved in this behalf by the Federal \nGovernment by a general or special order; and  \n \n(ii) \non moneys borrowed or debts incurred by it in a foreign country in respect of the purchase \noutside Pakistan of capital plant and machinery in any case where the loan or debt is approved \nby the Federal Government, having regard to its terms generally and in particular to the terms \nof its payment, from so much of the tax payable in respect thereof as exceeds the tax or taxes \non income paid on such interest in the foreign country from which the loan emanated or in \nwhich the debt was incurred (hereinafter referred to as the `said country'): \nProvided that, where the amount of such tax or taxes paid in the said country \nexceeds the amount of the tax payable in Pakistan, no refund of the amount paid in \nexcess shall be allowed: \nProvided further that, where the said country exempts such interest or allows credit \nagainst its own tax for the tax which would have been payable in Pakistan if the said interest \nwere liable to tax in Pakistan, no tax shall be payable in Pakistan in respect of such interest.” \n2Inserted by the Finance Act, 2018. \n3 Clauses (90A) and (91) omitted by the Finance Act, 2021. Earlier this amendment was made through \nTax Laws (Second  Amendment) Ordinance, 2021. The omitted clauses read as follows: \n   “(90A)    Any profit on debt derived by any person on bonds issued by Pakistan Mortgage Refinance \nCompany  to  refinance  the  residential  housing mortgage market, for a period of five years with \neffect from the 1st  day of July, 2018. \n     (91)  Any income of a text-book board of a Province established under any law for the time being in   \nforce, accruing or arising from the date of its establishment.” \n4 Clause (92) omitted by the Finance Act, 2013. The omitted clause (92) read as follows: \n“(92)  Any income of any university or other educational institution established solely for educational \npurposes and not for purposes of profit.” \n5Clause (92 A) omitted by Finance Act, 2014. The omitted clause (92A) read as follows: \n \n“(92A) Any income of any university or any other educational institution established in the most \naffected and moderately affected areas of Khyber Pakhtunkhwa, FATA and PATA, for a period of two \nyears ending on the 30th day of June, 2011.” \n6 Clause (93) omitted by the Finance Act, 2011. The omitted clause (93) read as follows: \n“(93)  Profits and gains derived by a taxpayer from the running of any computer training institution or \ncomputer training scheme, recognized by a Board of Education or a University or the University \nGrant Commission, as the case may be, set up between the first day of July, 1997, and the thirtieth \nday of June, 2005, both days inclusive, for a period of five years beginning with the month in which \nsuch institution is set up: \nProvided that a computer training institution or computer training scheme approved \nby the Central Board of  Revenue before the first day of July, 2000 shall continue to avail \nexemption under this clause till the expiry of the specified period.”  \n7Clause (93 A) omitted by Finance Act, 2014. The Omitted clause (93A) read as follows: \n \n“(93A) Profits and gains derived by a taxpayer from the running of any vocational institute or \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n584 \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n5[    ] \n6[  ] \n7[(98AA) Any income derived by ICC Business Corporation (IBC) or International \nCricket Council (ICC) or employees, officials, agents and representatives of IBC \nand ICC, officials from ICC members, players, coaches, medical doctors and \nofficials of member countries, IBC partners and media representatives, other than \npersons who are resident of Pakistan, from ICC champions Trophy, 2025 hosted \nin Pakistan.] \n                                            \ntechnical institute or poly-technical institute, recognized by a Board of Technical Education or a \nuniversity or any other authority appointed in this behalf by the Federal Government or a Provincial \nGovernment, as the case may be, set up between the first day of July, 2004, and the thirtieth day of \nJune, 2008, both days inclusive, for a period of five years beginning from the tax year in which such \ninstitution is recognized.” \n1 Clause (94) omitted by the Finance Act, 2002. The omitted clause (94) read as follows: \n“(94) Any amount paid by way of Federal Educational Fee or expended on setting up and managing \nor running of a middle, high or technical school in accordance with the conditions laid down in the \nFederal Education Fee Scheme.” \n2 Clause (95) omitted by the Finance Act, 2006. The omitted clause (95) read as follows: \n“(95) Any income derived by the Pakistan Council of Scientific and Industrial Research.” \n3 Omitted by the Finance Act, 2006. The omitted clause (96) read as follows: \n“(96) Any income derived by the Institution of Engineers, Pakistan, Lahore.” \n4 Clause (97) omitted by the Finance Act, 2006. The omitted clause (97) read as follows: \n“(97) Income of Pakistan Agricultural Research Council, Islamabad.” \n5 Clause (98) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(98) Any income derived by any Board or other organization established 5[by Government] 5[  ] in   \nPakistan for the purposes of controlling, regulating or encouraging major games and sports \nrecognised by Government 5[:] \n         5[Provided that the exemption of this clause shall not be applicable to the Pakistan Cricket Board.] \n6 Clause (98A) omitted by the Finance Act, 2013. The omitted clause (98A) read as follows: \n“(98A) \nAny income derived by International Cricket Council Development (International) \nLimited (IDI), International Cricket Council (ICC), employees, officials, agents and representatives \nof IDI and ICC officials from ICC members, players, coaches, medical doctors and officials of \nmember countries, IDI partners and media representatives, other than persons who are resident of \nPakistan, from ICC champions Trophy, 2001 hosted in Pakistan” \n7 Clause (98AA) added by the Finance Act 2025. Earlier this clause was inserted through \nS.R.O.579(I)/2025 dated 9th April, 2025.  \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n585 \n \n1[(99) Any income derived by a Collective Investment Scheme or a REIT Scheme \n2[including Special Purpose Vehicle], if not less than ninety per cent of its \naccounting income of that year, as reduced by 3[accumulated losses and] capital \ngains whether realized or unrealized, is distributed amongst the unit or certificate \nholders or shareholders as the case may be 4[: \nProvided that for the purpose of determining distribution of at least 90% of \naccounting income, the income distributed through bonus shares, units or \ncertificates as the case may be, shall not be taken into account.] \n \nExplanation.— For the purpose of this clause the expression “accounting \nincome” means income calculated under the generally accepted Accounting \nPrinciples and verified by the auditors 5[and Special Purpose Vehicle shall \nhave the same meaning as defined under the Real Estate Investment Trust \nRegulations, 2015].] \n6[    ] \n \n7[(99A) Profits and gains accruing to a person on the sale of immoveable property \n8[or shares of Special Purpose Vehicle] to any type of REIT scheme upto the 30th \n                                            \n1Clause (99) substituted by the Finance Act, 2008. Earlier it was substituted by SRO 728(I)/2002 \ndated 23.10.2002. The substituted clause (99) read as follows: \n \n“(99) \nAny income derived by a mutual fund or an investment company registered under the \nNon Banking finance companies (Establishment and Regulation) Rules, 2003, or a unit trust scheme \nconstituted by an assets management company registered under the Assets Management companies \nRules, 1995, or a Real Estate Investment Trust approved an authorized under Real Estate \nInvestment Trust Rules, 2006, established and managed by a REIT Management Company licensed \nunder the Real Estate Investment Trust Rules, 2006, if not less than ninety percent of its accounting \nincome of that year, as reduced by capital gains whether realized or unrealized, is distributed \namongst the unit or certificate holders or shareholders as the case may be:”  \nThe original Clause (99) read as under: \n“(99) \nAny income derived by a Mutual Fund or an investment company registered under the \nInvestment companies and Investment Advisors Rules, 1971 or a unit trust scheme constituted by an \nasset management company registered under the Assets Management companies rules, 1995, if not \nless than ninety percent of its income of that year is distributed amongst the unit or certificate holders \nor shareholders, as the case may be.” \n2 Words inserted by the Finance (Supplementary) Act, 2022. \n3 Expression inserted by the Finance Act, 2022. \n4Full stop at the end substituted by a colon and a proviso added by the Finance Act, 2014. \n5 Words inserted by the Finance (Supplementary) Act, 2022. \n6Inserted by the Finance Act, 2007. \n7 Clause (99A) substituted by the Finance Act, 2021. The omitted clause read as follows: \n“(99A)   Profits and gains accruing to a person on sale of immovable property to a 7[REIT Scheme] \nupto thirtieth day of June, 7[2015]7[“:”]] \n7[“Provided that profit and gains on sale of immovable property to a Developmental \nREIT Scheme with the object of development and construction of residential buildings shall be \nexempt upto thirtieth day of June, 7[2023]”], \n7[Provided further that the profit and gains on sale of immovable property to a rental \nREIT scheme shall be exempt up to the 30th day of June, 7[2023].” \n8 Words inserted by the Finance (Supplementary) Act, 2022. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n586 \n \nday of June, 2023.] \n \n1[Explanation.— For the purpose of this clause, Special Purpose Vehicle \nshall have the same meaning as defined under the Real Estate Investment Trust \nRegulations, 2015.] \n \n2[(99B) Income of a Special Purpose Vehicle buying Diversified Payment Rights \nfrom the Authorized Dealers in Pakistan.  \n \nExplanation.— For the purpose of this clause, Diversified Payment Rights, Special \nPurpose Vehicle and Authorized Dealers shall mean the ‘Diversified Payment \nRights’, ‘Special Purpose Vehicle’ and ‘Authorized Dealers’, respectively, in each \ncase, as referred in the State Bank of Pakistan‘s Circular(s) or Regulations on \nDiversified Payment Rights;] \n \n3[    ] \n \n4[  ] \n \n5[  ] \n \n6[   ]  \n \n7[   ] \n                                            \n1 Explanation added by the Finance (Supplementary) Act, 2022. \n2 Clause (99B) inserted by the Finance Act, 2024. \n3 Clauses (100) and (101) omitted by the Finance Act, 2021. Earlier this amendment was made through \nTax Laws (Second  Amendment) Ordinance, 2021. The omitted clauses read as follows: \n“(100)  Any income, not being income from 3[manufacturing or] trading activity, of a modaraba \nregistered under the Modaraba Companies and Modaraba (Floatation and Control) Ordinance, 1980 \n(XXXI of 1980), for any assessment year commencing on or after the first day of July, 1999 3[:] \nProvided that not less than ninety per cent of its total profits in the year as reduced by \nthe amount transferred to a mandatory reserve, as required under the provisions of the said \nOrdinance or the rules made 3[thereunder, as are distributed amongst the shareholders]: \nProvided further that with effect from the first day of July, 1999 for the purpose of \ndetermining the distribution of ninety per cent profits, the profits distributed through bonus \ncertificates or shares to the certificate holders shall not be taken into account. \n(101)  Profits and gains derived between the first day of July, 2000 and the thirtieth day of June, 3[2024] \nboth days inclusive, by a venture capital company and venture capital fund registered under Venture \nCapital Companies and Funds Management Rules, 2000 3[and a Private Equity and Venture Capital \nFund]” \n4Clause (102) omitted by  the Finance Act, 2010. The omitted clause (102) read as follows: \n“(102)  Any dividend received by the Investment Corporation of Pakistan from any other company \nwhich has paid or will pay tax in respect of the profits out of which such dividends are paid.” \n5Clause (102A) inserted by the Finance Act, 2006.  \n6 Clause (102A) omitted by the Finance Act, 2024. The omitted clause read as follows: \n“(102A) Income of a person as represents a subsidy granted to him by the Federal Government for \nthe purposes of implementation of any orders of the Federal Government in this behalf.”  \n7Clause (103) substituted by the Finance Act, 2008. The substituted clause (103) read as follows: \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n587 \n \n1[    ] \n \n2[(103A) Any income derived from inter-corporate dividend within the group \ncompanies entitled to group taxation under section 59AA 3[ 4[  ] ] 5[“subject to the \ncondition that return of the group has been filed for the tax year.”].] \n \n6[  ] \n7[    ] \n8[    ] \n \n9[(103D) Dividend income and long term capital gains of any venture capital fund \nfrom investments in zone enterprises as defined in 10[the Special Technology \nZones Authority Act, 2021 (XVII of 2021)] for a period of ten years commencing \nfrom issuance of licence by the Authority to the zone enterprise.] \n \n11[    ] \n                                            \n“(103)  Any distribution received by a taxpayer from the National Investment (Unit) Trust or 7[a \ncollective Investment Scheme authorized or registered under the Non-Banking Finance Companies \n(Establishment and Regulation) Rules, 2003] 7[or a Private Equity and Venture Capital Fund] out of \nthe capital gains of the said Trust or Fund on which tax has already been paid.” \n1 Clause (103) omitted by the Finance Act, 2021. The omitted clauses read as follows: \n  “(103) \nAny distribution received by a taxpayer from a collective investment scheme registered by \nthe Securities and Exchange Commission of Pakistan under the Non-Banking Finance Companies \nand Notified Entities Regulations, 2007, including National Investment (Unit) Trust or REIT Scheme \nor a Private Equity and Venture Capital Fund out of the capital gains of the said Schemes or Trust or \nFund 1[:] ] \n1[Provided that this exemption shall be available to only such mutual funds, collective \ninvestment schemes that are debt or money market funds and these do not invest in shares.]” \n2Inserted by the Finance Act, 2007. \n3 Inserted by the Finance Act, 2008. \n4Expression “or section 59B” omitted by the Finance Act, 2016. \n5 Inserted by the Finance Act, 2015. \n6Clause (103B) omitted by the Finance Act, 2013. The omitted clause (103B) read as follows: \n“(103B) Any dividend in specie derived in the form of shares in a company, as defined in the \nCompanies Ordinance, 1984 (XLVII of 1984): \nProvided that when such shares are disposed off by the recipient, the amount \nrepresenting the dividend in specie shall be taxed in accordance with provisions of \nsection 5 of this Ordinance and the amount, representing the difference between the \nconsideration received and the amount hereinabove, shall be treated in accordance \nwith provisions of section 37 or section 37A, as the case may be.” \n7 New Clause 103C inserted through Finance Supplementary (Second Amendment) Act, 2019 \n8 Clause (103C) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clauses read as follows: \n“(103C) Dividend income derived by a company, if the recipient of the dividend, for the tax year 8[is \neligible for] group relief under section 59B, 8[ ].” \n9Inserted by the Finance Act, 2021. \n10  Expression “clause (p) of section 2 of the Special Technology Zones Authority Ordinance, 2020” \nsubstituted by the Finance Act, 2022. \n11 Clauses (104) and (105) omitted by the Finance Act, 2021. Earlier this amendment was made \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n588 \n \n1[   ] \n \n2[    ] \n \n3[(105B) \nAny income received by a taxpayer from a corporate agricultural \nenterprise, distributed as dividend out of tis income from agriculture.] \n \n4[(105C) Any income derived by Kuwait Foreign Trading Contracting and \nInvestment Company or Kuwait Investment Authority being dividend of the Pak-\nKuwait Investment Company in Pakistan from the year of incorporation of Pak-\nKuwait Investment Company.] \n \n5[  ] \n \n6[  ] \n \n(107)  Any income derived by any subsidiary of the Islamic Development Bank wholly \nowned by it and set up in Pakistan and engaged in owning and leasing of tankers. \n \n7[(107A) Any income derived by the Islamic Development Bank from its operations \nin Pakistan in connection with its social and economic development activities.] \n \n8[  ] \n                                            \nthrough Tax Laws (Second  Amendment) Ordinance, 2021. The omitted clauses read as follows: \n  “((104)  Any income derived by the Libyan Arab Foreign Investment Company being dividend of the  \nPak-Libya Holding Company. \n(105)  Any income derived by the Government of Kingdom of Saudi Arabia being dividend of the \nSaudi-Pak Industrial and Agricultural Investment Company Limited.]” \n1 Clause (105A) inserted by S.R.O. 749(I)/2004, dated 30.08.2004. \n2 Clause (105A) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(105A)  Any income derived by Kuwait Foreign Trading Contracting and Investment Company or  \nKuwait Investment Authority being dividend of the Pak-Kuwait Investment Company in Pakistan from \nthe year of incorporation of Pak-Kuwait Investment Company.]” \n3 Clause (105B) inserted by the SRO 106(I)/2008, dated 01.02. 2008. \n4 Clause (105C) inserted by the Tax Laws (Amendment) Act, 2023 (XVI of 2023) dated 20.04.2023. \nEarlier this clause was inserted through Tax Laws (Second Amendment) Ordinance, 2022 (VI of \n2022) dated 23.08.2022.       \n5Clause (106) omitted by the Finance Act, 2006. The omitted clause (106) read as follows:- \n“(106)  Any income derived by the Pakistan Water and Power Development Authority, established \nunder the Pakistan Water and Power Development Authority Act, 1958 (West Pakistan Act. No. XXXI \nof 1958).” \n6Clause (106A) omitted by the Finance Act, 2006. The omitted clause (106A) read as follows: \n“(106A) Any income derived by the corporatized entities of Pakistan Water and Power Development \nAuthority from the date of their creation upto the date of completion of the process of corporatization \ni.e. till the tariff is notified.” \n7Inserted by the Finance Act, 2011. \n8 Clause (108) omitted by the Finance Act, 2003. The omitted clause (108) read as follows:  \n“(108)  Any income derived by the International  Irrigating Management Institute (IIMI), Pakistan.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n589 \n \n \n1[  ] \n \n2[  ] \n3[  ] \n \n4[   ] \n \n5[    ] \n \n6[   ] \n \n7[    ] \n \n8[  ] \n \n9[  ] \n                                            \n1 Clause (109) omitted by the Finance Act, 2003. The omitted clause (109) read as follows: \n“(109)  Any amount collected by the Civil Aviation Authority up to the thirty-first December, 1998, on \naccount of security charges.” \n2Clause (110) omitted by the Finance Act, 2010. The omitted clause (110) read as follows: \n“(110)  Any income chargeable under the head \"capital gains\", being income from the sale of \nmodaraba certificates or any instrument of redeemable capital as defined in the Companies \nOrdinance, 1984 (XLVII of 1984), listed on any stock exchange in Pakistan or shares of a public \ncompany (as defined in sub-section (47) of section 2 ) and the Pakistan Telecommunications \nCorporation vouchers issued by the Government of Pakistan, derived by a taxpayer upto tax year \nending on the thirtieth day of June, 2010.” \n3Clause (110A) omitted by the Finance Act, 2010. The omitted clause (110A) read as follows: \n“(110A) Any gain on transfer of a capital asset of the existing stock exchanges to new corporatized \nstock exchange, in the course of corporatization of an existing stock exchange.” \n4Inserted by the Finance Act, 2007. \n5 Clause (110B) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n(110B) Any gain on transfer of a capital asset, being a membership right held by a member of an \nexisting stock exchange, for acquisition of shares and trading or clearing rights acquired by such \nmember in new corporatized stock exchange in the course of corporatization of an existing stock \nexchange.]” \n6Clause (110C) inserted by the Finance Act, 2018. \n7 Clause (110C) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clauses read as follows: \n“(110C)  Any gain by a person on transfer of a capital asset, being a bond issued by Pakistan \nMortgage Refinance Company  to refinance the residential housing mortgage market, during the \nperiod from the 1st  day of July, 2018 till the 30th  day of June, 2023.]” \n8Clause (111) omitted by the Finance Act, 2010. The omitted clause (111) read as follows: \n“(111)  Any income chargeable under the head “capital gains”, being income from the sale of shares \nof a  public company derived by any foreign institutional investor as is approved by the Federal \nGovernment for the purpose of this clause.” \n9Clause (112) omitted by the Finance Act, 2002. The omitted clause (112) read as follows: \n“(112)     Any income chargeable under the head \"capital gains\" derived by a person from the sale \nof shares of  industrial units of public sector corporations by the Privatisation Commission.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n590 \n \n \n1[  ] \n \n2[    ] \n3[    ] \n4[    ]  \n5[    ] \n \n6[(114B) Profit and gains accruing to persons mentioned in proviso to sub-section \n(1) of section 236C in respect of first sale of immovable property acquired from or \nallotted by the Federal Government or Provincial Government or any authority duly \ncertified by the official allotment authority, and the property acquired or allotted is \nin recognition of services rendered by the 7[persons specified in the said proviso].]  \n \n8[    ] \n                                            \n1Clause (113) omitted by the Finance Act, 2015. The omitted clause (113) read as follows:- \n“(113)Any income chargeable under the head \"capital gains\", being income from the sale of shares \nof a public company  set up in any Special Industrial Zone referred to in clause (126) of this Schedule, \nderived by a person for a period of five years from the date of commencement of its commercial \nproduction: \nProvided that the exemption under this clause shall not be available to a person  from the \nsale of shares of such companies which are not eligible for exemption from tax under clause \n(126).” \n2 Clause (114) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(114)  Any income chargeable under the head \"capital gains\" derived by a person from an industrial \nundertaking set up in an area declared by the Federal Government to be a \"Zone\" within the meaning \nof the Export Processing Zones Authority Ordinance, 1980 (IV of 1980).]” \n3 Clause (114A) omitted by the Finance Act, 2011. The omitted clause (114A) read as follows: \n“(114A) Any income chargeable under the head “capital gains”, derived by a person from sale of ships \nand all floating crafts including tugs, dredgers, survey vessels and other specialized craft upto tax \nyear ending on the thirtieth day of June, 2011. \n4New clause (114AA) added through Finance Act, 2020 dated 30th June, 2020.  \n5 Clause (114AA) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(114AA) Any income chargeable under the head “capital gains” derived by a resident individual \nfrom the sale of constructed residential property: \nProvided that exemption under this clause shall only apply, if – \n(a) \nat the time of sale, the residential property was being used for the purpose of personal \naccommodation by the resident individual, his spouse or dependents and for which any \nof the utility bills is issued in the name of such individual; \n(b) \nthe land area of the property does not exceed 500 square yards in case of a house and \n4000 square feet in case of a flat; and \n(c) exemption under this clause has not previously been availed by the individual, his \nspouse or dependents.] \n6 New clause (114B) added through Finance Act, 2019.  \n7 The words “Shaheed or the person who dies in service” substituted by the Finance Act, 2024. \n8Clause (115) omitted by the Finance Act, 2003. The omitted clause (115) read as follows:  \n“(115)  Any share of income received by a taxpayer out of capital gains on which tax has been paid \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n591 \n \n1[    ] \n2[    ] \n3[    ] \n4[    ] \n5[    ] \n                                            \nby the firm of which he is a partner: \n \n \nProvided that exemption under this clause shall not apply in respect of any tax year \ncommencing on or after the 1st day of July, 2002.” \n1Clause (116) omitted by the Finance Act, 2002, The omitted clause (116) read as follows: \n“(116) Any income derived by a taxpayer from the business of fish catching or fish processing, where \nthe fish catching business or fish processing unit is established by the taxpayer for the first time \nbetween first day of July, 1993, and 30th day of June, 1997, for a period of five years from the date \nof such establishment, subject to the condition that the said date shall be determined by the \nCommissioner on an application made by the taxpayer.”  \n2 Clause (117) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(117)  Any income derived by a person from plying of any vehicle registered in the territories of \nAzad Jammu and Kashmir, excluding income arising from the operation of such vehicle in Pakistan \nto a person who is resident in Pakistan and non-resident in those territories.] \n3Clause (118) omitted by the Finance Act, 2002. The omitted clause (118) read as follows: \n “(118). Profits and gains derived by a taxpayer from a pioneer industrial undertaking which is set up \nby 30th day of June, 1997 for a period of five years from the date of commencement of commercial \nproduction. The exemption under this clause shall apply to a pioneer industrial undertaking which- \n(a) \n is owned and managed by a company formed and registered under the \nCompanies Act, 1913, (VII of 1913), having its registered office in Pakistan; \n(b) \nis an undertaking the income, profits and gains of which are not liable to be \ncomputed in accordance with the rules contained in the Fifth Schedule; \n \n \n(c) \nfulfils the following conditions, namely :- \n(i) \nthat the undertaking is based on highly sophisticated technology; \n \n \n \n(ii) \nthat the technology employed has fast obsolescence; \n \n \n \n(iii) \nthat investment in the undertaking involves high risk; and \n(iv) \nthat the goods produced, or to be produced, are such that neither these \ngoods, nor identical or close substitutes thereof, are being produced in \nPakistan; and  \n(d) \nis approved, on an application made by the taxpayer in such form and manner \nand accompanied by such statements, certificates, documents and \nundertakings, and in accordance with such procedure, as may be prescribed, \nby the Central Board of Revenue.” \n4Clause (119) omitted by the Finance Act, 2002. The omitted clause (119) read as follows: \n “(119). Profits and gains derived by a taxpayer, being a resident company, from an industrial \nundertaking engaged in the manufacture of electronic equipment or components thereof which is set \nup in the North West Frontier Province or in the Islamabad Capital Territory by 30th day of June, \n1997, and is approved by the Central Board of Revenue for purposes of this clause, for a period of \nfive years from the date of commencement of commercial production.” \n5Clause (120) omitted by the Finance Act, 2006. The omitted clause (120) read as follows: \n“(120)   (1) Profits and gains derived by a taxpayer from an industrial undertaking for a period of \nfive years from the date of commencement of commercial production. \n(2) \nThe exemption under this clause shall apply to an undertaking which is- \n(a) \nset up between the first day of July, 1994, and the thirtieth day of June,2000, \nboth days inclusive; \n(b) \nowned and managed by a company formed exclusively for operating the said \nindustrial undertaking engaged in fruit processing and registered under the \nCompanies Ordinance, 1984 (XLVII of 1984), and having its registered office in \nPakistan; and \n(c) \nis not formed by splitting up or the reconstruction or reconstitution of business \nalready in existence or by transfer to a new business of any machinery or plant \nin Pakistan at any time before the commencement of the new business.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n592 \n \n1[    ] \n2[    ] \n3[  ] \n4[  ] \n5[  ]   \n \n \n                                            \n1 Clause (121) omitted by the Finance Act, 2003. The omitted clause (121) read as follows:  \n“(121) Profits and gains derived by an assessee from an Industrial undertaking set up in an area \ndeclared by the Federal Government to be a “Zone” within the meaning of the Export Processing \nZones Authority Ordinance, 1980 (IV of 1980) for the assessment years 1998-99, 1999-2000 and \n2000-2001. However, exemption under this clause shall be restricted to the remaining period of \nexemption to which a company was entitled before the relevant amendments made by the Finance \nAct, 1996 (IX of 1996). \n2Clause (122) omitted by the Finance Act, 2002. The omitted clause (122) read as follows: \n“ (122)   (1)   Profits and gains derived by a taxpayer from an industrial undertaking for a period of \nfive years from the date of commencement of commercial production. \n(2)  \nThe exemption under this clause shall apply to an industrial undertaking which is - \n(a) engaged in the manufacture of solar thermal, photovoltaic equipment for \nproduction of solar energy and solar appliances; \n(b) set up between the first day of July, 1997 and the thirtieth day of June, 2000; and \n(c) is not formed by splitting up or the reconstruction or reconstitution of business \nalready in existence or by transfer to a new business of any machinery or plant in \nPakistan at any time before the commencement of the new business.” \n3Clause (123) omitted by the Finance Act, 2002. The omitted clause (123) read as follows: \n“ (123) \nProfits and gains derived by a taxpayer from an industrial undertaking set up in an area \ndeclared by the Federal Government to be a \"Zone\" within the meaning of the Export Processing \nZones Authority Ordinance, 1980 (IV of 1980), for a period of five years from the date of \ncommencement of production, and for such further period as may be allowed by the Federal \nGovernment:  \nProvided that nothing contained in this clause shall apply to an industrial undertaking set \nup after the 30th June, 1997.” \n4Clause (124) omitted by the Finance Act, 2002. The omitted clause (124) read as follows:: \n “(124)   Profits and gains derived by a taxpayer up to the thirtieth day of June, 1997,from an industrial \nundertaking set up in the Karachi Export Processing Zone, declared by the Federal Government as \na ‘Zone’ within the meaning of the Export Processing Zone, Authority Ordinance, 1980 (IV of 1980).” \n5Clause (125) omitted by the Finance Act, 2002. The omitted clause (125) read as follows:: \n“(125) (1)  Profits and gains derived by a company for a period of five years from an industrial \nundertaking set up in such area and within such period and on such conditions as the Federal \nGovernment may, by notification in the Official Gazette, specify:  \nProvided that the exemption under this sub-clause shall not be available after the 31st \nJanuary, 1996, except to such companies otherwise qualifying under this clause, which have \nestablished letters of credit for the import of plant and machinery for such industrial undertaking \nby the 31st January, 1996. \n(2) \n  Income chargeable under the head \"Capital gains\" derived by a taxpayer from the sale \nof shares representing foreign equity in such company and on such conditions as the Federal \nGovernment may, by notification in the official Gazette, specify:  \nProvided that the exemption under this sub-clause shall not be  available to a taxpayer from \nthe sale of shares representing foreign equity in such companies which do not qualify for \nexemption under sub-clause (1).” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n593 \n \n1[(126) Any income of a public sector university established sololy for educational \npurposes and not for the purposes of profit, with effect from the 1st day of July, 2013.] \n \n2[3[(126A) Income derived by China Overseas Ports Holding Company Limited, \nChina Overseas Ports Holding Company Pakistan (Private) Limited, 4[Gawadar]  \nInternational Terminal Limited, \n5[Gawadar] Marine Services Limited and \n6[Gawadar] Free Zone Company Limited from 7[Gawadar] Port 8[9[and Gawadar \n                                            \n1Clause (126) substituted by the Finance Act, 2014. The substituted Clause (126) read as follows: \n \n“(126) (1) Profits and gains derived by a taxpayer from an industrial undertaking  set up between the \nfirst day of July, 1995, and the 31st day of December, 2002, both days inclusive, for a period of ten years beginning \nwith the month in which the undertaking is set up or commercial production is commenced, whichever is the \nlater:  \nProvided that the exemption under this clause shall not be available after the 31st January, \n1996, except to such taxpayers, otherwise qualifying under this clause, who have established letters of \ncredit for the import of plant and machinery for such industrial undertaking by the 31st January, 1996: \nProvided further that the extension in deadline from the 30th June, 1999, to the 31st December, \n2002, shall not apply to those projects whose cases are sub judice and that the Federal Government \nshall decide such cases in accordance with the verdict of the apex Court. \n(2) \nThe exemption under this clause shall apply to an industrial undertaking which fulfils the \nfollowing conditions, namely :- \n(a) \nthat it is set up in such area as may be notified by the Federal Government to be a Special \nIndustrial Zone ; \n(b) \nthat it is not formed by the splitting up, or the reconstruction or reconstitution of a business \nalready in existence or by transfer to a new business of any machinery or plant used in a \nbusiness which was being carried on in Pakistan at any time before the commencement \nof the new business; \n(c) \nthat it is owned and managed by a company formed exclusively for operating such \nindustrial undertaking and registered under the Companies Ordinance, 1984 (XLVII of \n1984), having its registered office in Pakistan ; and \n(d) \nthat it is not engaged in the manufacture of arms and ammunition, security printing, currency and \nmint, high explosives, radioactive substances, alcohol (except industrial alcohol), cotton ginning, \nspinning (except as part of integrated textile unit), sugar manufacturing (white), flour milling, steel \nre-rolling and furnace, Tobacco industry, ghee or vegetable oil industry, plastic bags (including \nPolyropylene, and Polyethylene), beverages (excluding fruit juices), polyester industry, \nautomobile assembly and cement industry. \n2Clause (126 A) substituted by the Finance Act, 2014. The substituted clause (126A) read as follows: \n“(126A) \nincome derived by –  \n \n \n(a)  \nGawadar Free Zone Company Limited; \n \n \n(b)  \nPSA Gawadar International Terminal Limited; \n \n \n(c) \nGawadar Marine Services Limited; and \n \n \n(d)  \nP.S.A. Gawadar (PTE) Ltd. \nfrom Gwadar Port operations for a period of twenty years beginning from the year in which the company \nis set up or commercial operation is commenced, whichever is the later.” \n3Clause (126A) substituted by the Finance Act, 2016. Substituted clause read as follows:- \n“(126A) income derived by China Overseas Ports Holding Company Limited from Gwadar Port \noperations for a period of 3[“twenty three”]years, with effect from the sixth day of February, 2007.” \n4The word “Gawadar”  substituted by Finance Act 2017. \n5The word “Gawadar”  substituted by Finance Act 2017. \n6The word “Gawadar”  substituted by Finance Act 2017. \n7The word “Gawadar”  substituted by Finance Act 2017. \n8 The words inserted through Tax Laws (Amendment) Ordinance, 2019 dated 8th October, 2019 \n9 Inserted through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n594 \n \nFree Zone]] operations for a period of twenty-three years, with effect from the sixth \nday of February, 2007.] \n \n1[(126AA)Profit and gains derived by a taxpayer from businesses set up in the \n2[Gawadar] Free Zone Area for a period of twenty three years with effect from the \nfirst day of July, 2016.] \n \n3[(126AB) Profit on debt derived by- \n \n(a) \nany foreign lender; or \n \n(b) \nany local bank having  more than 75 per cent shareholding of the \nGovernment or the State Bank of Pakistan, \n \nunder a Financing Agreement with the China Overseas Ports Holding \nCompany Limited, 4[China Overseas Port Holding Company Pakistan \n(Private) Limited, Gawadar International Terminals Limited, Gwadar \nMarine Services Limited and Gawadar Free Zone Company Limited,] \nGawadar International terminals Limited, Gawadar Marine Services \nLimited and Gawadar Free Zone Company Limited]     for a period of \ntwenty three years with effect from the first day of July, 2016;] \n \n5[(126AC) Income derived by contractors and sub-contractors of China Overseas \nPorts Holding Company Limited, China Overseas Ports Holding Company \nPakistan (Private) Limited, 6[Gawadar] International Terminal Limited, 7[Gawadar] \nMarine Services Limited and 8[Gawadar] Free Zone Company Limited from \n9[Gawadar] Port 10[and Gawardar Free Zone] 11[and Gawadar Free Zone] \noperations for a period of twenty years, with effect from the first day of July, 2016.] \n \n12[(126AD) (1) Any income derived by China Overseas Ports Holding Company \nLimited being dividend received from China Overseas Ports Holding Company \nPakistan (Private) Limited, Gwadar International Terminal Limited Gwadar Marine \n                                            \n1 Inserted by the Finance Act, 2016.  \n2The word “Gawadar”  substituted by Finance Act 2017. \n3Inserted by the Finance Act, 2016.  \n4The expression inserted though Finance Act, 2020 dated 30th June, 2020,with effect from 1st June,2020 \n5 Inserted by the Finance Act, 2016.  \n6The word “Gawadar”  substituted by Finance Act 2017. \n7The word “Gawadar”  substituted by Finance Act 2017. \n8The word “Gawadar”  substituted by Finance Act 2017. \n9The word “Gawadar”  substituted by Finance Act 2017. \n10The expression inserted though Finance Act, 2020 dated 30th June, 2020, with effect from 1st June, 2020 \n11 Words inserted through Tax Laws (Amendment) Ordinance 2019 dated 8th October, 2019 \n12Inserted by the Finance Act, 2016. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n595 \n \nServices Limited and Gwadar Free Zone Company Limited for a period of twenty-\nthree years with effect from the first day of July, 2016. \n \n(2) \nAny income derived by China Overseas Ports Holding Company \nPakistan (Private) Limited being dividend received from, Gwadar International \nTerminal Limited Gwadar Marine Services Limited and Gwadar Free Zone \nCompany Limited for a period of twenty-three years with effect from the first day of \nJuly, 2016.] \n \n1[   ] \n \n2[(126B) Profits and gains derived by a refinery—  \n  \n(a)  from new deep conversion refinery of at least 100,000 barrels per day for \nwhich approval is given by the Federal Government before the 31st day of \nDecember, 2021; or  \n  \n(b)   for the purpose of upgradation, modernization or expansion project of any \nexisting refinery which makes undertaking to the Federal Government in \nwriting before the 31st day of December, 2021 in this regard:  \n  \n    \n \nProvided that this exemption shall be available for a period of twenty \nyears beginning from the date of commencement of commercial production \nin the case of new refinery and ten years from the date of completion of up \ngradation, modernization or expansion project of existing refinery.  \n  \n    \n \nProvided further that the exemption under this clause shall only be \navailable to those refineries whose products fulfill Euro 5 standards.] \n \n3[   ] \n4[   ] \n                                            \n1Clause (126B) inserted by S.R.O. 1100(I)/2007, dated 10.11.2007. \n2Clause (126B) substituted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The substituted clause read as follows: \n“(126B) Profit and gains derived by 2[Khalifa Coastal Refinery] for a period of twenty years beginning \nin the month in which the refinery is setup or commercial production is commenced, whichever is the \nlater.]” \n3Inserted by the Finance Act, 2018. \n4Clause (126BA) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(126BA) Profits and gains derived by a refinery set up between the 1st  day of July, 2018 and the 30th \nday of June, 2023 with minimum 100,000 barrels per day production capacity for a period of twenty \nyears beginning in the month in which the refinery is set up or commercial production is commenced, \nwhichever is later. Exemption under this clause shall also be available to existing refineries, if— \n(a) \nexisting production capacity is enhanced by at least 100,000 barrels per day; \n(b) \nthe refinery maintains separate accounts for income arising from aforesaid additional \nproduction capacity; and \n(c)     the refinery is a deep conversion refinery.]” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n596 \n \n1[   ] \n2[   ] \n \n3[(126D) \nProfit and gains derived by a taxpayer from an industrial undertaking \nset up in the 4[Gawadar] declared by the Federal Government to be a Zone within \nthe meaning of Export Processing Zone Authority Ordinance, 1980 (IV of 1980) as \nExport Processing Zone, 5[Gawadar], for a period of ten years beginning with the \nmonth and year in which the industrial undertaking is set up or commercial \noperation commenced, whichever is later.] \n \n6[(126E) \nIncome derived by a zone enterprise as defined in the Special \nEconomic Zones Act, 2012 (XX of 2012) for a period of ten years starting from the \ndate the developer certifies that the zone enterprise has commenced commercial \noperation 7[or up to the 30th day of June, 2035, whichever is earlier]  and for a \nperiod of ten years to a developer of zone starting from the date of signing of the \ndevelopment agreement in the special economic zone as announced by the \nFederal Government] 8[: \n \nProvided that this clause shall also apply to a co-developer as defined in \nSpecial Economic Zone Rules, 2013 subject to the condition that a certificate has \nbeen furnished— \n \n(a) by the developer that he has not claimed exemption under this clause \nand has relinquished his claim in favour of the co-developer; and \n \n(b) by the Special Economic Zone Authority validating that the developer \nhas not claimed exemption under this clause and has relinquished claim \nin favour of the co-developer.] \n \n                                            \n1Inserted by S.R.O. 741(I)/2008, dated 10.07.2008. \n2Clause (126C) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(126C) (1) Profits and gains derived by a taxpayer from an industrial undertaking set up in Larkano \nIndustrial Estate between the 1st day of July, 2008 and the thirtieth day of June, 2013, both days \ninclusive, for a period of ten years beginning with the month in which the industrial undertaking is set \nup or commercial production commenced, whichever is the later. \n(2)  \nExemption under this clause shall apply to an industrial undertaking which is owned \nand managed by a company registered under the Companies Ordinance 1984 (XLVII of 1984) and \nformed exclusively for operating the said undertaking.]  \n3Inserted by S.R.O. 606(I)/2009, dated 29th June, 2009. \n4The word “Gawadar”  substituted by Finance Act 2017. \n5The word “Gawadar”  substituted by Finance Act 2017. \n6Clause (126E) substituted by the Finance Act, 2013. The substituted clause (126E) read as follows: \n“(126E) Corporate income tax holiday for a period of five years for projects from the date of start of commercial \noperations, and for developers of the Zone for a period of ten years from the date of start of developmental \nactivity in the Special Economic Zones as announced by the Federal Government.” \n7 Expression inserted by the Finance Act, 2025.   \n8The new proviso inserted though Finance Act, 2020 dated 30th June, 2020 \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n597 \n \n1[   ] \n \n2[(126EA)   Profits and gains derived by – \n \n(a) zone developer as defined in the Special Technology Zones Authority Act, \n2021 (XVII of 2021) from development and operations of the zones for a \nperiod of ten years starting from the date of signing of the development \nagreement;  \n \n(b) \nzone Enterprises as defined in the Special Technology Zones Authority \nAct, 2021 (XVII of 2021) for a period of ten years from the date of \nissuance of license by the Special Technology Zone Authority 3[or up the \n30th day of June, 2035, whichever is earlier]; and \n \n(c) \nSpecial Technology Zones Authority established under the Special \nTechnology Zones Authority Act, 2021 (XVII of 2021).] \n \n4[  ] \n5[  ] \n6[  ] \n                                            \n1 Clause (126EA) inserted by the Finance Act, 2021.  \n2The Clause (126EA) substituted by the Finance Act 2022. Substituted clause read as follows: \n  “(126EA) Profits and gains derived by—   \n(a) zone developer as defined in section 2 of the Special Technology Zones Authority \nOrdinance, 2020 from development and operations of the zones for a period of ten years \nstarting from the date of signing of the development agreement;   \n(b) profits and gains of Zone Enterprises as defined in section 2 of the Special Technology \nZones Authority Ordinance, 2020 for a period of ten years from the date of issuance of \nlicense by the Special Technology Zone Authority; and   \n(c) Special Technology Zones Authority established under the Special Technology Zones \nOrdinance 2020.” \n3 Expression inserted by the Finance Act, 2025.   \n4 Clause “(126F)” omitted by the Finance Act, 2015. The omitted clause (126F) read as follows:-\n \n“(126F) Profits and gains derived by a taxpayer located in the most affected and moderately \n \naffected areas of Khyber Pakhtunkhwa, FATA and PATA for a period of three years starting \n \nfrom the tax year 2010: \nProvided that this concession shall not be available to the manufacturers and \nsuppliers of cement, sugar, beverages and cigarettes.” \n5 Clause (126G) added by S.R.O 281(I)/2014, dated 10.04.2014. \n6Clause (126G) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“((126G) \nProfits and gains derived for a period of five years from the date of start of commercial \nproduction by the following companies from the projects mentioned against each that have been \ndeclared ‘Pioneer Industry’ by Economic Coordination Committee of the Cabinet:- \n(i) \nM/s. Astro Plastics (Pvt) Limited from their Biaxially Oriented Polyethylene \nTerephthalate (BOPET) Project; and \n(ii) \nM/s. Novatex Limited from their Biaxially Oriented Polyethylene Terephthalate (BOPET) \nProject.] \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n598 \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n5[  ] \n6[  ] \n7[   ]  \n8[   ] \n9[   ] \n10[   ] \n                                            \n1 Clause (126H) inserted by the Finance Act, 2014. \n2Clause (126H) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(126H) Profits and gains derived by a taxpayer, from a fruit processing or preservation unit set up in \nBalochistan Province, Malakand Division, Gilgit Baltistan and FATA between the first day of July, 2014 \nto the thirtieth day of June, 2017, both days inclusive, engaged in processing of locally grown fruits for \na period of five years beginning with the month in which the industrial undertaking is set up or \ncommercial production is commenced, whichever is later.] \n3 Clause “(126I)”added by the Finance Act, 2015. \n4 Clause (126I) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(126I) Profits and gains derived by a taxpayer, from an industrial undertaking set up by 31st day of \nDecember, 2016 and engaged in the manufacture of plant, machinery, equipment and items with \ndedicated use (no multiple uses) for generation of renewable energy from sources like solar and wind, \nfor a period of five years beginning from first day of July, 2015. 4[:]  \n[Provided that this clause shall also apply to such undertaking set up between the 1st March \n2019 and the 30th June, 2023 for a period of five years beginning from the date such industrial \nundertaking is set up.] \n5 Clause “(126J)” added by the Finance Act, 2015. \n6Clause (126J) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(126J) Profits and gains derived by a taxpayer, from an industrial undertaking set up between 1st day \nof July, 2015 and 30th day of June, 2016 engaged in operating warehousing or cold chain facilities for \nstorage of agriculture produce for a period of three years beginning with the month in which the \nindustrial undertaking is set up or commercial operations are commenced, whichever is later.]” \n7 Clause “(126K)” added by the Finance Act, 2015. \n8Clause (126K) omitted by the Finance Act, 2021. The omitted clause read as follows: \n “(126K) Profits and gains derived by a taxpayer, from an industrial undertaking set up between the \nfirst day of July, 2015 and the 30th day of June, 2017 for establishing and operating a halal meat \nproduction unit, for a period of four years beginning with the month in which the industrial undertaking \ncommences commercial production. The exemption under this clause shall apply if the industrial \nundertaking is – \n(a) \nowned and managed by a company formed for operating the said halal meat production unit \nand registered under the Companies Ordinance, 1984 (XLVII of 1984), and having its \nregistered office in Pakistan; \n(b) \nnot formed by the splitting up, or the re construction or reconstitution, of a business already \nin existence or by transfer to a new business of any machinery or plant used in a business \nwhich was being carried on in Pakistan at any time before the commencement of the new \nbusiness; and \n(c) \nhalal meat production unit is established and obtains a halal certification within the period \nbetween the first day of July, 2015 and the 30th day of June, 2017.]” \n9 Clause “(126L)” added by the Finance Act, 2015. \n10Clause (126L) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n599 \n \n1[(126M) Profits and gains derived by a taxpayer from a transmission line project \nset up in Pakistan on or after the1st day of July, 2015 for a period of ten years. The \nexemption under this clause shall apply to such project which is— \n \n(a) owned and managed by a company formed for operating the said \nproject and registered under the 2[Companies Act, 2017 (XIX of \n2017)], and having its registered office in Pakistan; \n(b) not formed by the splitting up, or the reconstruction or \nreconstitution, of a business already in existence or by transfer to \na new business of any machinery or plant used in a business \nwhich was being carried on in Pakistan at any time before the \ncommencement of the new business; and \n \n(c) owned by a company fifty per cent of whose shares are not held \nby the Federal Government or Provincial Government or a Local \nGovernment or which is not controlled by the Federal Government \nor a Provincial Government or a Local Government: \n \nProvided that the exemption under this clause shall not \napply to projects set up on or after the thirtieth day of June, \n3[2022].] \n \n4[   ] \n5[   ] \n                                            \n“(126L) Profits and gains derived by a taxpayer, from an industrial undertaking set up in the Provinces \nof Khyber Pukhtunkhwa and Baluchistan between 1st day of July, 2015and 30th day of June, 2018 \nfor a period of five years beginning with the month in which the industrial undertaking is set up or \ncommercial production is commenced, whichever is later: \nProvided that exemption under this clause shall be admissible where— \n(a) \nthe industrial undertaking is setup between the first day of July, 2015 and 30th \nday of June,2018, both days inclusive; and \n(b) \nthe industrial undertaking is not established by the splitting up or reconstruction \nor reconstitution of an undertaking already inexistence or by transfer of \nmachinery or plant from an undertaking established in Pakistan at any time \nbefore 1st July 2015.] \n1 Clause “(126M)” added by the Finance Act, 2015. \n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n3 The figure “2018” substituted by the Finance Act, 2021. Earlier this substitution was made through \nTax Laws (Amendment) Ordinance, 2021. \n4 Clause “(126N)” added by the Finance Act, 2015.  \n \n5Clause (126N) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(126N) Profits and gains derived by a taxpayer from an industrial undertaking, duly certified by the \nPakistan Telecommunication Authority, engaged in the manufacturing of cellular mobile phones, for a \nperiod of five years, from the month of commencement of commercial production: \nProvided that the industrial undertaking has been setup and commercial production has \ncommenced between the first day of July, 2015 and the thirtieth day of June, 2017 and the industrial \nundertaking is not formed by the splitting up, or the reconstruction or reconstitution, of a business \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n600 \n \n1[   ]  \n2[   ] \n3[   ] \n                                            \nalready inexistence or by transfer to a new business of any machinery or plant used in a business which \nwas being carried on in Pakistan 5[:]” \n1 New clause (126O) inserted through Finance Supplementary (Second Amendment) Act, \n2019 \n2Clause (126O) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(126O) Profits and gains of a company from a green field industrial undertaking for a period of five \nyears incorporated on or after the first day of July, 2019 provided that the green field industrial \nundertaking is not formed by the splitting up or reconstitution of an undertaking already in existence or \nby transfer of machinery or plant from an undertaking established in Pakistan before the \ncommencement of the new business.]”  \n3Clause (127) omitted by the Finance Act, 2002. The omitted clause (127) read as follows: \n“ (127) (1)  Profit and gains derived by a taxpayer from an industrial undertaking set up between the \nfirst day of July, 1995, and the thirtieth day of June,1997, both days inclusive, for a period of eight \nyears beginning with the month in which commercial production is commenced. \n(2) The exemption under this clause shall apply to an industrial undertaking which fulfils the \nfollowing conditions, namely :- \n(i) \nIt is set up in a rural area i.e., outside the limits of any municipal corporation, municipal \ncommittee, cantonment board or Islamabad Capital Territory and in no case within the \nfollowing areas namely :- \n \n(a) \nup to ten kilometres from the municipal or cantonment limits of Karachi or \nLahore; and  \n \n(b) \nup to ten kilometres from the existing limits of municipal corporations or \ncantonments boards; \nExplanation: The distance between an industrial undertaking and the outer boundary of \na municipal or cantonment limit shall be measured in a straight line on horizontal plane \nas provided in section 11 of the General Clauses Act, (X of 1897), and the said distance, \nwherever required, will be defined and determined by the concerned officer of the \nDistrict Administration. \n(ii) \nIt is not formed by the splitting up, or the reconstruction or reconstitution of a business \nalready in existence or by transfer to a new business of any machinery or plant used in \na business which was being carried on in Pakistan at any time before the \ncommencement of the new business. \n(iii) It is owned and managed by a company formed for operating such industrial \nundertaking and registered under the Companies Ordinance, 1984 (XLVII of 1984), \nhaving its registered office in Pakistan. \n(iv) It is an undertaking engaged in any of the following agro-based industries:- \n \n(a) \ncultivation, production, processing and preservation of flowers and ornamental \nplants; \n \n(b) \ncattle, sheep and goat forming for the production and processing of meat. It will \ncover rearing, sale and slaughtering of animals and processing and packing of \nmeat and meat products; \n \n(c) \ndairy farming for the production of milk; \n \n(d) \nprocessing, packing, preservation and canning of milk and milk products with or \nwithout addition of other things; \n \n(e) \nprocessing, packing, preservation and canning of meat and meat products; \n \n(f) \nprocessing, packing, preservation and canning of fruits and vegetable; \n \n(g) \ninland farming and preservation, packing and canning of fish and seafood with \nor without addition of other things; \n \n(h) \ncultivation, production and multiplication of high yielding seeds of cereals, \npulses, vegetables, fruits, oilseeds, and cash crops like sugarcane, cotton coca, \ncoffee, tea, herbs and spices; \n \n(i) \ncultivation, production and extraction of edible oils;  \n \n(j) \npoultry farming and processing, packing, preservation and canning of poultry \nmeat with or without addition of other things; and \n \n(k) \nmanufacture of cattle and poultry feeds.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n601 \n \n1[  ] \n2[  ] \n3[  ] \n4[   ] \n \n(132)  Profits and gains derived by a taxpayer from an electric power generation \nproject set up in Pakistan on or after the 1st day of July, 1988. The exemption \nunder this clause shall apply to such project which is— \n \n(a) owned and managed by a company formed for operating the said project \nand registered under the 5[Companies Act, 2017 (XIX of 2017), and \n                                            \n1Clause (128) omitted by the Finance Act, 2002. The omitted clause (128) read as follows: \n“ (128) \nAny income accruing or arising outside Pakistan to an industrial undertaking set up in \nan area declared by the Federal Government to be a `Zone' within the meaning of the Export \nProcessing Zones Authority Ordinance, 1980 (IV of 1980), provided the said income accrues or \narises from such activities of the said undertaking as are approved by the Federal Government:  \nProvided that nothing contained in this clause shall apply to an industrial undertaking \nset up after the 30th June, 1997.” \n2Clause (129) omitted by the Finance Act, 2003. The omitted clause (129) read as follows:  \n“(129)  Any income of Saudi-Pak Industrial and Agricultural Investment Company Limited in Pakistan \nfor a period of twenty years commencing with the thirty-first day of December, 1982.” \n3Clause (130) omitted by the Finance Act, 2002. The omitted clause (130) read as follows: \n“(130) Any income of Pakistan-Kuwait Investment Company in Pakistan for a period of twenty years \nfrom the date of its incorporation.” \n4Clause (131) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n “(131)  Any income- \n(a)  \nof company registered under the Companies Ordinance 1984 (XLVII of 1984),  and \nhaving its registered office in Pakistan, as is derived by  it by way of royalty, commission \nor fees from a foreign enterprise in consideration for  the use outside Pakistan of any \npatent, invention, model, design, secret  process or formula or similar property right, or \ninformation concerning  industrial, commercial or scientific knowledge, experience or \nskill made available or provided to such enterprise by the company or in the  \nconsideration of technical services rendered outside Pakistan to such enterprise by the \ncompany under an agreement in this behalf, or  \n(b) \nof any other taxpayer as is derived by him, in the income year relevant to assessment \nyear beginning with the first day of July, 1982 and any assessment year thereafter, by \nway of fees for technical services rendered outside Pakistan to a foreign enterprise \nunder an agreement entered into in this behalf :- \n \nProvided that— \n(i) \nsuch income is received in Pakistan by or on behalf of the said company or other taxpayer, as \nthe case may be, in accordance with the law for the time being in force for regulating payments \nand dealings in foreign exchange ; and \n(ii) \nwhere any income as aforesaid is not brought into Pakistan in the year in which it is earned \nand tax is paid thereon, an amount equal to the tax so paid shall be deducted from the tax \npayable for the year in which it is brought into Pakistan and, where no tax is payable for that \nyear or the tax payable is less than the amount to be deducted, the whole or such part of the \nsaid amount as is not deducted shall be carried forward and deducted from the tax payable \nfor the year next following and so on.”  \n5 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n602 \n \nhaving its registered office in Pakistan; \n \n(b) not formed by the splitting up, or the reconstruction or reconstitution, of \na business already in existence or by transfer to a new business of any \nmachinery or plant used in a business which was being carried on in \nPakistan at any time before the commencement of the new business; \nand \n \n(c) \nowned by a company fifty per cent of whose shares are not held \nby the Federal Government or Provincial Government or a \n1[Local Government] or which is not controlled by the Federal \nGovernment or a Provincial Government or a \n2[Local \nGovernment]:  \n \nProvided that the condition laid down in sub-clause (a) shall not \napply to the Hub Power Company Limited 3[:] \n \n4[Provided further the exemption under this clause shall not \napply to oil fired power plants setup 5[between 22nd October, 2002 \nand 30th June, 2006] 6[but shall apply to Dual Fuel (Oil/Gas) power \nprojects set up on or after the first September, 2005] 7[:] ] \n \n8[Provided further that the exemption under this clause shall be \navailable to companies registered in Pakistan or Azad Jammu and \nKashmir owning and managing Hydel Power Projects, set up in Azad \nJammu and Kashmir or Pakistan 9[:]] \n \n10[Provided further that exemption under this clause shall also \nbe available to the expansion projects of the existing Independent \nPower Projects already in operation11[“:”] \n \n12[Provided also that conditions laid down in sub-clause (b) \n                                            \n1The words “local authority” substituted by the Finance Act, 2008. \n2The words “local authority” substituted by the Finance Act, 2008. \n3 Full stop substituted by S.R.O. 940(I)/2002, dated 19.12.2002. \n4Inserted by the Finance Act, 2007. \n5 The words, figures and comma “on or after 22nd October, 2002” substituted by the Finance Act, \n2006. \n6Inserted by S.R.O. 1009(I)/2005 dated 26.09.2005. \n7Full stop substituted by the Finance Act, 2007. \n8Inserted by the Finance Act, 2007. \n9Full stop substituted by S.R.O. 405(I)/2008, dated 26.04.2008. \n10 Added by S.R.O. 405(I)/208, dated 26.04.2008. \n11 Full stop substituted by S.R.O. 248(I)/2015 dated 27.03.2015. \n12 Proviso added by S.R.O. 248(I)/2015 dated 27.03.2015 \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n603 \n \nshall not apply to electric power generation project formed by the \nsplitting up, or the reconstruction or the reconstitution of an electric \npower generation business already in existence and availing \nexemption under this clause] 1[:  \n2[Provided further that the exemption under this clause shall be \navailable to persons, who enter into agreement or to whom letter of \nintent is issued by the Federal or Provincial Government for setting up \nan electric power generation project in Pakistan on or before the 30th \nday of June, 2021 and who obtains the letter of support on or before \nthe 30th day of June, 2023.] \n \n3[  ] \n4[   ] \n \n5[(132AA) Profits and gains derived from sale of electricity by National Power \nParks Management Company (Private) Limited or demerged entities of National \nPower Parks Management Company (Private) Limited commencing from the \ncommercial operation dates and continuing after the date of change of ownership \nas a result of privatization by the Privatization Commission of Pakistan.] \n \n6[  ] \n \n7[   ] \n8[(132C) Profits and gains derived by a taxpayer from a bagasse/biomass based \ncogeneration power project having one or more boilers of not less than 60 bar \n(kg/CM3) pressure each, commissioned after the first day of January 2013.] \n \n                                            \n1Full stop substituted and proviso added by the Finance Act, 2021. Earlier this amendment was made \nthrough Tax Laws (Second  Amendment) Ordinance, 2021. \n2 Proviso substituted by the Finance (Supplementary) Act, 2022. The substituted proviso read as \nfollows: \n“Provided further that no exemption under this clause shall be available to persons, who enter \ninto agreement or to whom letter of intent is issued by Federal or Provincial Government for setting \nup an electric power generation project in Pakistan after the 30th day of June, 2021.” \n3Inserted by S.R.O. 650(I)/2009, dated 09.07.2009. \n4Clause (132A) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(132A) Profit and gains derived by Bosicor Oil Pakistan Limited for a period of seven and half years \nbeginning from the day on which the refinery is set up or commercial production is commenced \nwhichever is later.]” \n5Inserted by the Finance Act, 2021.  \n6Clause (132B) inserted by the Finance Act, 2014. \n7Clause (132B) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(132B) Profits and gains derived by a taxpayer from a coal mining project in Sindh, supplying coal \nexclusively to power generation projects.]” \n8 Clause (132C) inserted by the Finance Act, 2021.  \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n604 \n \n1[   ] \n2[   ] \n \n3[  ] \n \n4[  ] \n \n5[  ] \n \n6[  ] \n7[   ] \n8[  ] \n                                            \n1 Clause (133) substituted by the Finance Act, 2003. The substituted clause (133) read as follows: \n   “(133)  Income from export of computer software and its related services developed in Pakistan: \nProvided that the exemption under this clause shall not be available after the 30th day of June, \n2016.” \n2Clause (133) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(133) Income from exports of computer software or IT services or IT enabled services upto the period \nending on 30th day of June, 2[ ] 2[2025:] \n2[“Provided that eighty per cent of the export proceeds is brought into Pakistan in foreign \nexchange remitted from outside Pakistan through normal banking channels.”]  \n \nExplanation.- For the purpose of this clause – \n(a) \n“IT Services” include software development, software maintenance, system integration, \nweb design, web development, web hosting, and network design, and  \n(b)  \n“IT enabled services” include inbound or outbound call centres, medical transcription, \nremote monitoring, graphics design, accounting services, HR services, telemedicine \ncenters, data entry operations 2[, locally produced television programs] and insurance \nclaims processing.] \n3Clause (133A) omitted by the Finance Act, 2008. The omitted clause (133A) read as follows: \n“(133A) Any income derived by an individual from transfer of his membership rights or shares of a \nstock exchange in Pakistan along with a room in the Stock Exchange to a company at any time \nbetween the first day of July, 2005, and the thirtieth day of June, 2008.” \n4 Clause (134) omitted by the Finance Act, 2003. The omitted clause (134) read as follows: \n“(134)  Any amount received on encashment of any certificate issued in pursuance of the US Dollar \nBearer Certificate Rules, 1991:  \nProvided that exemption under this clause shall not be available in respect of certificates \npurchased on or after the 15 June, 1995.” \n5Clause (135) omitted by the Finance Act, 2014. The Omitted clause (135) read as follows: \n \n“(135) Any amount received on encashment of Special US Dollar Bond issued under the Special \nUS Dollar Bonds Rules, 1998.” \n6 Inserted by S.R.O. 64(I)/2012, dated 27.01.2012. \n7Clauses (135A) and (136) omitted by the Finance Act, 2021. Earlier this amendment was made through \nTax Laws (Second  Amendment) Ordinance, 2021. The omitted clauses read as follows: \n“(135A)Any income derived by a non-resident from investment in OGDCL exchangeable bonds issued \nby the Federal Government.] \n(136)  Any income of a special purpose vehicle as defined in the Asset Backed Securitization Rules, 1999 made \nunder the Companies Ordinance, 1984 (XLVII of 1984): \nProvided that, if there is any income which accrues or arises in the accounts of the \nspecial purpose vehicle, after completion of the process of the securitization7[“or redemption of \nsukuks”], it shall be returned to the Originator as defined by the said rules within the income \nyear next following the year in which the income has been determined and such income shall \nbe taxable in the hands of the Originator.]” \n8Clause (137) omitted by the Finance Act, 2006. The omitted clause (137) read as follows: \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n605 \n \n \n1[  ] \n \n2[(139)  (a) The benefit represented by free provision to the employee of medical \ntreatment or hospitalization or both by an employer or the reimbursement received \nby the employee of the medical charges or hospital charges or both paid by him, \nwhere such provision or reimbursement is in accordance with the terms of \nemployment: \n \nProvided that National Tax Number of the hospital or clinic, as the \ncase may be, is given and the employer also certifies and attests the \nmedical or hospital bills to which this clause applies; \n \n(a) any medical allowance received by an employee not exceeding ten per \ncent of the basic salary of the employee if free medical treatment or \nhospitalization or reimbursement of medical or hospitalization charges is \nnot provided for in the terms of employment; or \n \n \n3[  ] \n                                            \n“ (137) Income of Fugro Geodetic Limited from execution of contract with the Government of Pakistan \nfor survey for the establishment of the Continental Shelf of Pakistan.” \n1Clause (138) omitted by the Finance Act, 2008. The omitted clause (138) read as follows: \n“(138)  Any income referred to in Section 3.4 (a) of the Facilitation Agreement between the President \nof the Islamic Republic of Pakistan and the taxpayer purchasing the KotAddu Power Station from \nPakistan Water and Power Development Authority for a period of ten years from 28th June, 1996; \nprovided, however, that the exemption under this clause shall only be available subject to the \nbusiness of the said taxpayer being restricted to owing and operating the KotAddu power station.” \n2Clause (139) substituted by the Finance Act, 2003. The substituted clause (139) read as follows:  \n “(139)        (a)  \nAny benefit, reimbursement received by an employee on account of medical  \ncharges or hospital charges, or both, incurred by an employee, as provided for \nunder the terms of the employee’s employment agreement; or where such \nbenefit for reimbursement, medical charges or hospital charges, or both are not \nprovided for under the terms of employment’s agreement, medical allowance \nupto maximum of 10% of the basic pay for the year: \nProvided that National Tax Number of the hospital or clinic, as the case may be, \nis given and the employer also certifies and attests the medical or hospital bills \nto which this clause applies; or \n(b)  \nAny amount paid by a taxpayer, being an individual and resident in Pakistan,  \nby  way  of personal expenditure on medical service, to the extent of 10% of \ntaxable income returned in return of income or Rs 30,000 whichever is lower. \nProvided that the receipts in respect of such expenditure being name, National \nTax Number and complete address of the medical practitioners are furnished \nalong with his return of income.” \n3Sub-clause (c) omitted by the Finance Act, 2006. The omitted sub-clause (c) read as follows:  \n  “(c) \nany amount paid during a year by a taxpayer, being a resident individual, by \nway of personal expenditure on medical service to the extent of ten per cent of \ntaxable income declared in his return of income for the said tax year or thirty \nthousand rupees – whichever is the less: \n \nProvided that the receipts of such expenditure bearing name, National Tax Number and \ncomplete address of the medical practitioners are furnished along with his return of income.” \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n606 \n \n1[(140)  All payments on account of principal, interest, or fees received by the \nOverseas Private Investment Corporation (OPIC), from development project \nundertaken in pursuance to the Investment Incentive Agreement signed between \nthe Government of Pakistan and the Government of the United States of America, \ndated 18th November, 1997.] \n \n2[(140A) Any profit on debt received by Japan International Cooperation Agency \n(JICA), from Islamabad-Burhan Transmission Reinforcement Project (Phase-I) \nundertaken in pursuance to the loan agreement for Islamabad-Burhan \nTransmission Reinforcement Project (Phase-I).] \n \n3[   ] \n \n4[   ] \n \n5[(142) Income from social security contributions derived by Balochistan \nEmployees‘ Social Security Institution, Employees‘ Social Security Institution \nKhyber Pakhtunkhwa, Punjab Employees‘ Social Security Institution and Sindh \nEmployees‘ Social Security Institution. \n \nExplanation.— For the removal of doubt, it is clarified that all incomes \nother than social security contributions shall not be exempt;] \n \n6[   ] \n7[   ] \n8[   ]  \n9[   ] \n                                            \n1Added by S.R.O. 1353(I)/2012, dated 31.10.2012. \n2Inserted by the Finance Act, 2017 \n3 Clause “(141)” added by the Finance Act, 2015. \n4Clause (141) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(141) Profit and gains derived by LNG Terminal Operators and Terminal Owners for a period of five \nyears beginning from the date when commercial operations are commenced.”]”.]” \n5 Clause “(142)” added by the Finance Act, 2015. \n6Added by the Finance Act, 2017 \n7Clause (143) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(143) Profit and gains derived by a start–up as defined in clause (62A) of section 2 for the tax year \nin which the start-up is certified by the Pakistan Software Export Board and the following two tax \nyears.]” \n8 Clauses (144) and (145) added by S.R.O. 887(I)/2018, dated 23.07.2018. \n9 Clauses (144) and (145) omitted by S.R.O. 1213(I)/2018 dated 05.10.2018.The omitted clauses \nread as under: \n “(144) Profits and gains derived by individuals from any source in the districts of Chitral, Dir and Swat \n(which includes Kalam), the former Tribal Area in Kohistan district, Malakand former Protected Areas \nthe former Tribal Area adjoining Mansehra district, the former State of Amb, Zhob district, Loralai district \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n607 \n \n \n1[(145A) Any income which was not chargeable to tax prior to the commencement \nof the Constitution (Twenty-fifth Amendment) Act, 2018 (XXXVII of 2018) of any \nindividual domiciled or company and association of persons resident in the Tribal \nArea forming part of the Provinces of Khyber Pakhtunkhwa and Balochistan under \nparagraph (d) of Article 246 of the Constitution with effect from the 1st day of June, \n2018 to the 30th day of June, 2[   ] 3[  ] 4[2026] (both days inclusive).]   \n \n5[   ] \n6[   ] \n \n7[(147) Any income derived by the Federal Government Employees Housing \nAuthority and Naya Pakistan Housing and Development Authority for the tax year \n2020 and the following four tax years.] \n \n8[   ] \n \n                                            \n(excluding Duki Tehsil), Dalbandin Tehsil of Chagai district and Marri and former Bugti Tribal territories \nof Sibi district, former Tribal Areas adjoining the district of Peshawar, Kohat, Bannu, Lakki Marwat, Dera \nIsmail Khan, Tank as well as former Tribal Areas i.e. Bajaur Agency, Orakzai Agency, Mohmand \nAgency, Khyber Agency, Kurram Agency, North Waziristan Agency and South Waziristan Agency, \nprovided that existing business set ups register themselves with field offices of FBR by 30th September, \n2018. \n“(145) Profits and gains of existing businesses conducted by association of persons and companies \nfrom any source in the districts of Chitral, Dir and Swat (which includes Kalam), the former Tribal Area \nin Kohistan district, Malakand former Protected Areas the former Tribal Area adjoining Mansehra \ndistrict, the former State of Amb, Zhob district, Loralai district (excluding Duki Tehsil), Dalbandin Tehsil \nof Chagai district and Marri and former Bugti Tribal territories of Sibi district, former Tribal Areas \nadjoining the district of Peshawar, Kohat, Bannu, Lakki Marwat, Dera Ismail Khan, Tank as well as \nformer Tribal Areas i.e. Bajaur Agency, Orakzai Agency, Mohmand Agency, Khyber Agency, Kurram \nAgency, North Waziristan Agency and South Waziristan Agency, provided that existing business set \nups register themselves with field offices of FBR by 30th September, 2018. \nProvided further that the exemption under this clause shall be restricted to the \nassociation of persons and companies whose registered offices are in the aforesaid Areas.] \n1 New clause (145A) added through Finance Act, 2019. \n2 The figure “2023” substituted by Finance Act, 2023. \n3 The figure “2024” substituted by Finance Act, 2024. \n4 The figure “2025” substituted by Finance Act, 2025. \n5 Added by S.R.O. 1213(I)/2018, dated 05.10.2018. \n6 Clause (146) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n “(146) Any income which was not chargeable to tax prior to the commencement of the Constitution  \n(Twenty-fifth Amendment) Act, 2018 (XXXVII of 2018) of any individual domiciled or company and \nassociation of persons resident in the Tribal Areas forming part of the Provinces of Khyber \nPakhtunkhwa and Balochistan under paragraph (d) of Article 246 of the Constitution with effect from \nthe 1st day of June, 2018 to the 30th day of June, 2023 (both days inclusive).] \n7 New clause (147) added though Finance Act, 2020 dated 30th June, 2020. \n8 Clause (148) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows: \n“(148)     Any income derived by Islamic Naya Pakistan Certificates Company Limited (INPCCL)”. \n\n\f\nSecond Schedule – Part-I_____ __________________________ \n608 \n \n1[(149) Any sum—  \n  \n(i)    remitted to Pakistan through banking channels in foreign currency received \nby an international buying house from its non-resident principal to meet its \nexpenses in Pakistan; and  \n  \n(ii)   chargeable under the head “Salary” received by a person who, not being a \ncitizen or resident of Pakistan, is engaged as an expert by an international \nbuying house.  \n  \nExplanation.—For the purpose of this clause international buying house \nmeans persons acting as buying offices, buyers’ agents, or representatives \nof international buyers for facilitating exports from Pakistan and are \nregistered as liaison offices with Board of Investment or companies \nregistered with SECP. Provided that such buying houses act as cost \ncenters with the sole purpose to bring export orders to Pakistan on behalf \nof their principals and do not enter into any local business transactions in \nPakistan and their expenses are remitted to Pakistan.] \n \n 2[(150) Income derived by Siyahkalem Engineering Construction Industry and \nTrade Company Limited 3[and Alteraz Engineering Consultant]  from contract \ndated 23rd  day of May 2017 with Earthquake Reconstruction and Rehabilitation \nAuthority, financed by the Saudi Fund for Development with effect from tax year \n2017. \n \n(151) Any income derived by a person from cinema operations for five years from \nthe commencement of cinema operations 4[: \n \nProvided that the exemption under this clause shall be available to a \nperson till 30th June, 2030 or five years from commencement of cinema \noperations whichever is earlier.] \n \n5[   ] \n \n(153) Profits and gains from the production of feature film derived between the \nfirst day of July, 2022 and the thirtieth day of June, 2027 both days inclusive by a \nresident producer or a resident production house.]  \n                                            \n1 Clause (149) inserted by the Finance Act, 2021. \n2 Clause (150), (151), (152) and (153) added by the Finance Act, 2022. \n3 Words inserted by the Finance Act, 2023. \n4 Full stop substituted with a colon and thereafter a new proviso added by the Finance Act, 2025. \n5 Clause (152) omitted by the Finance Act, 2025. The omitted clause read as follows: \n   “(152) Profits and gains derived between the first day of July, 2022 and the thirtieth day of June, 2025 \nboth days inclusive, by a venture capital company and venture capital fund registered under relevant \nVenture Capital Companies and Funds Management Rules issued by Securities and Exchange \nCommission of Pakistan.” \n” \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n \n533 \nPART II \nREDUCTION IN TAX RATES \n \n \nIncomes or classes of income, or persons or classes of persons, \nenumerated below, shall be liable to tax at such rates which are less than the rates \nspecified in the First Schedule, as are specified hereunder: \n \n1[   ] \n \n2[   ] \n \n3[   ]   \n \n4[  ] \n \n5[  ] \n \n6[  ] \n                                            \n1Clause (1) omitted by the Finance Act, 2005. The omitted clause (1) read as follows:  \n“(1) The rates of income tax, as specified in the First Schedule and as applicable to the profits and \ngains derived by a resident company from an undertaking setup between the First day of July, 1981 \nand the Thirtieth day of June, 1998, both days inclusive, and engaged in the exploration and \nextraction of such mineral deposits, other than petroleum, as is specified by the Federal Government \nby a notification in the Official Gazette, shall be reduced by 50% for a period of five years immediately \nnext following the period of five years from the date of commercial production.”  \n2  Clause (2) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n“(2) \nAny income of persons whose profits or gains from business are computed under the \nFifth Schedule to this Ordinance as is derived from letting out to other similar persons any pipeline \nfor the purpose of carriage of petroleum shall be charged to tax at the same rate as is applicable to \nsuch persons in accordance with the provisions of the said Schedule.”  \n3  Clause (3) substituted by the Finance Act, 2016. Substituted clause read as follows:- \n(3) The tax in respect of income from services rendered 3[and construction contracts] outside \nPakistan shall be charged at the rate of one per cent of the gross receipts, provided that 3[receipts \nfrom services and income from contracts] are brought into Pakistan in foreign exchange through \nnormal banking channel. \n4  Clause (3) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n“(3) (a) The tax in respect of income from services rendered outside Pakistan and construction \ncontracts executed outside Pakistan shall be charged at the rates as specified in sub-clause (b), \nprovided that receipts from services and income from contracts are brought into Pakistan in foreign \nexchange through normal banking channel. \n(b)The rates in respect of income from services rendered outside Pakistan shall be 50% of the rates as \nspecified in clause (2) of Division III of Part III of the First Schedule and the rates in respect of contracts \nexecuted outside Pakistan shall be 50% of the rates as specified in clause (3) of Division III of Part III of the \nFirst Schedule.”]”  \n5Clause (3A) omitted by the Finance Act, 2014. The omitted clause (3A) read as follows:  \n \n“(3A) \nThe tax in respect of income from construction contracts out side Pakistan shall be \ncharged at the rate of one per cent of the gross receipts provided that such income is brought into \nPakistan in foreign exchange through normal banking channel.” \n6 Clause (3B) inserted by the Finance Act, 2016. \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n610 \n \n1[   ] \n2[   ] \n3[   ] \n \n4[(5A)  The rate of tax to be deducted under sub-section (2) of section 152, in \nrespect of payments 5[from] profit on debt payable to a non-resident person having \nno permanent establishment in Pakistan, 6[other than those covered under clauses \n(78) and (79) of Part I of the Second Schedule,] shall be 10% of the gross amount \npaid 7[:]   \n \n8[Provided that tax deducted on profit on debt from debt instruments, \nGovernment securities including treasury bills and Pakistan Investment \nBonds shall be final tax on profit on debt payable to a non-resident person \nhaving no permanent establishment in Pakistan and the investments are \nexclusively made through a Special Rupee Convertible Account maintained \nwith a Bank in Pakistan.] \n                                            \n1  Clause (3B) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n“(3B) The income of Pakistan Cricket Board derived from sources outside Pakistan including media \nrights, gate money, sponsorship fee, in-stadium rights, out-stadium rights, payments made by \nInternational Cricket Council, Asian Cricket Council or any other Cricket Board shall be taxed at a \nrate of four per cent of the gross receipts from such sources: \nProvided that Pakistan Cricket Board may opt to pay tax at the rate of four per cent of the \ngross receipts from tax year 2010 and onwards: \nProvided further that this option shall be available subject to withdrawal of appeals, \nreferences and petitions on the issue of tax rate pending before any appellate forum or tax authority: \nProvided further that the outstanding tax liability payable under this clause up to tax year \n2015 is paid by 30th June, 2016.”] \n2Clause (4) omitted by the Finance Act, 2003. The omitted clause (4) read as follows: \n“(4) In the case of an industrial undertaking set up in an area declared by the Federal Government \nto be a \"Zone\" within the meaning of the Export Processing Zones Authority Ordinance, 1980 (IV of \n1980), the income, profits and gains of such undertaking accruing or arising after the expiry of the \nperiod of exemption under clause (132) of Part I shall be charged to tax for a period of five years \nthereafter at the rate equal to twenty-five per cent of the rates specified in the First Schedule:  \nProvided that nothing contained in this clause shall apply in respect of undertakings whose \nperiod of exemption under clause (124) of Part I will expire after the 30th June, 1997.” \n3Clause (5) omitted by the Finance Act, 2009. The omitted clause (5) read as follows: - \n“(5) The tax chargeable in respect of commission received by an export indenting agent or an export \nbuying house shall be at the rate equal to the rate of tax applicable to the exporter on export of goods \nto which such commission relates.” \n4Clause (5A) substituted by SRO 218(I)/2008, dated 06.03.2008. The substituted clause (5A) read as \nfollows: \n“(5A)The rate of withholding tax in respect of payments for profit on debt payable to a non-resident \nperson, having no permanent establishment in Pakistan, shall be the rate as provided in Avoidance \nof Double Taxation Treaty of the respective country of the non-resident.” \n5The word “for” substituted by the Finance Act, 2009. \n6 This expression inserted by the Finance Act, 2021. Earlier this expression was inserted through Tax \nLaws (Amendment) Ordinance, 2021. \n7 Full stop substituted by the Finance Act, 2011. \n8 Inserted by  the Finance Act, 2011. \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n611 \n \n \n1[(5AA)    The rate of tax to be deducted under sub-section (2) of section 152, in \nrespect of payments to an individual, on account of profit on debt earned from a \ndebt instrument, whether conventional or shariah     compliant,     issued     by     \nthe  Federal Government under the Public Debt Act, 1944 and purchased \nexclusively through a bank account maintained abroad, a non-resident Rupee \naccount repatriable (NRAR) or a foreign currency account maintained with a \nbanking company in Pakistan shall be ten percent of the gross amount paid: \n \nProvided that tax deducted on such profit on debt shall be final tax.] \n \n2[(5AB) The rate of tax to be deducted under section 151 shall be ten percent \nfrom the profit on debt from a debt instrument, whether conventional or Shariah \ncompliant, issued by the Federal Government under the Public Debt Act, 1944 \n(XVIII of 1944) or its wholly owned special purpose company, purchased by a \nresident citizen of Pakistan who has already declared foreign assets to the Board \nthrough a Foreign Currency Value Account (FCVA) maintained with authorized \nbanks in Pakistan under the foreign exchange regulation issued by the State \nBank of Pakistan:  \n  \n   \n \nProvided that the tax so deducted shall be the final tax.  \n  \n(5AC) The rate of tax to be deducted under sub-section (2) of section 152 or \nunder section 151, as the case may be, shall be zero percent of the gross amount \nof profit on debt paid, covered under clauses (78) and (79) of Part I of the Second \nSchedule.] \n \n3[   ] \n4[   ] \n5[   ] \n                                            \n1Clause (5AA) inserted though Finance Act, 2020 dated 30th June, 2020 \n2 Clauses (5AB) and (5AC) inserted by the Finance Act, 2021. Earlier these clauses were inserted \nthrough Tax Laws (Amendment) Ordinance, 2021. \n3Inserted by the Finance Act, 2007. \n4  Clause (5B) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted  clause read as follows:  \n“(5B) The tax in respect of capital gains derived by a person from the sale of shares or assets by a \nprivate limited company to Private Equity and Venture Capital Fund shall be charged at the rate of \nten per cent of such gains.]” \n5Clause (6) omitted by the Finance Act, 2008. The omitted clause (6) read as follows: \n“(6) In the case of resident person the profit on Special US Dollar Bonds purchased out of any \nincremental deposits made in the existing foreign currency accounts on or after the 16th day of \nDecember, 1999, or out of new accounts opened on or after the said date, shall be liable to \ndeduction of income tax under clause (c) of sub-section (1) of section 151 at the rate of 10 per cent \nof the amount of the said profit.” \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n612 \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n \n5[(9AA) In respect of import of white sugar from the 25th day of August, 2020 to \nthe 15th day of November, 2020 both days inclusive, tax under section 148 shall \nbe collected at the rate of 0.25% as per quantity, quality, mode and manner \nprescribed by Ministry of Commerce during the said period.  \n  \n(9AB)  Tax under section 148 on commercial import of the white sugar shall be \ncollected at the rate of 0.25% from the 26th day of January 2021 till the 30th day \nof June, 2021. \n \n6[   ] \n                                            \n1Clause (7) omitted by the Finance Act, 2005. The omitted clause (7) read as follows: \n“(7) In case of any resident individual, the tax from profit or interest of any National Savings \nSchemes of Directorate of National Savings or Post Office Savings Account in which investment \nis made on, or after, the first day of July, 2001, shall be deducted at the rate of ten per cent of \nsuch profit or interest: \nProvided that no tax shall be deducted from income or profits paid on- \n(a) \nDefence Savings Certificates, Special Savings Certificates Savings Accounts or Post \nOffice Savings Account, made on, or after, the first day of July, 2001, where such \ndeposit does not exceed one hundred and fifty thousand rupees; and  \n(b) \nInvestment in Monthly income Saving Accounts Scheme of Directorate of National \nSavings on, or after, the first day of July, 2001, where monthly installment in an account \ndoes not exceed one thousand rupees.” \n2Clause (8) omitted by the Finance Act, 2005. The omitted clause (8) read as follows: \n“(8) In the case of Daewoo Corporation, Seoul, Korea (hereinafter referred to as the Contractor), \npayments received in full or in part (including a payment by way of an advance) in pursuance of the \ncontract agreements made with the National Highway Authority on the thirtieth day of December, \n1991, for design and construction of Lahore-Islamabad Motorway shall be deemed to be the income \nof the Contractor and charged to tax at the rate of three per cent of such payments which shall \nconstitute final discharge of his tax liability under this Ordinance and the Contractor shall not be \nrequired to file the return of income under section 114.” \n3Clause (9) omitted by S.R.O. 140(I)?2013, dated 26.02.2013. The omitted clause (9) read as \nfollows: \n“(9) Tax under section 148 shall be collected at rate of the 1% on import of all fibres, yarns and \nfabrics and goods covered by the Zero Rating Regime of the Sales Tax notified by Central Board of \nRevenue.” \n4Clause (9A) omitted  by S.R.O. 140(I)?2013, dated 26.02.2013. The omitted clause (9A) read as \nfollows: \n“(9A)  Tax under section 148 shall be collected at the rate of 3% on the import value of raw material \nimported by an industrial undertaking for its own use: \n \nProvided that the rate of 3% shall be applicable on production of an exemption \n \ncertificate issued by the Commissioner.” \n5 Clauses (9AA), (9AB) and (9AC) inserted by the Finance Act, 2021. Earlier theses clauses were   \ninserted through SROs 771(I)/2020 dated 24.08.2020 and 235(I)/2021 dated 23.02.2021.  \n6 Clause (9AC) omitted by the Finance Act, 2025. The omitted clause read as follows: \n   “(9AC)  Subject to quota allotment by Commerce Division, tax under section 148 shall be collected  \nat the rate of 0.25% on import of raw sugar imported by sugar mills from the 26th day of January, \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n613 \n \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n5[  ] \n6[  ] \n7[  ] \n8[  ] \n                                            \n2021 to the 30th day of June, 2021 both days inclusive provided that such imports shall not exceed \nfifty thousand metric tons per sugar mill and three hundred thousand metric tons in aggregate by the \nsugar industry.] \n  \n1Clause (9B) omitted by Finance Act, 2014. The omitted clause (9B) read as follows:  \n“(9B) \nTax under section 148 shall be collected at the rate of 1% on import value of remeltable steel \n(PCT Heading 72.04) and directly reduced Iron imported by an industrial undertaking for its own use.” \n \n2Clause (9C) omitted by Finance Act, 2014. The omitted clause (9C) read as follows: \n“(9C) Tax under section 148 shall be collected at the rate of 1% in case of manufacturers and 3% in \ncase of commercial importers covered under Notification No. S.R.O. 1125(I)/2011 dated the 31st \nDecember, 2011.” \n3Clause (10) omitted by the Finance Act, 2008. The omitted clause (10) read as follows: \n“(10)  In the case of M/s Fauji Foundation and Army Welfare Trust, so much of the income chargeable \nunder the head \"Income from business \" as is not exempt under clause (58) of Part I, shall be \ncharged to tax at the rate of 20% of such income.” \n4Clause (11) omitted by the Finance Act, 2006. The omitted clause (11) read as follows: \n“(11)  In the case of a non-resident O&M Contractor payments, received in full or in part including a \npayment by way of an advance, for the operation and maintenance of a private sector power project \nand transmission line projects approved by the Federal Government shall be deemed to be the \nincome of the said O&M Contractor and charged to tax at the rate of five per cent of such payments \nfor a period of three years beginning with the date of commencement of company's operations which \nshall constitute the final discharge of tax liability by the O&M Contractor under this Ordinance in \nrespect of the said project.” \n5Clause (12) omitted by the Finance Act, 2006. The omitted clause (12) read as follows: \n“(12)  In the case of consortium of M/s. STFA Construction Company of Turkey and M/s. JDN of \nBelgium (hereinafter referred to as the contractor) all payments received in pursuance of the \ncontract agreement No. CEN-126/93, made with the Ormara Naval Harbour Project Board, on the \nfourteenth day of June, 1993, for the construction of a Naval Harbour at Ormara (including off-\nshore and land development works), chargeable to tax in any assessment year, shall be deemed \nto be the income of the contractor and charged to tax at the rate of three per cent which shall \nconstitute final discharge of contractor's tax liability under this Ordinance.” \n6 Clause (13) omitted by the Finance Act, 2008. The omitted clause (13) read as follows: \n“(13) Tax under section 148 shall be collected at the rate of 1% on imports of capital goods and raw \nmaterial imported exclusively for its own use by a manufacturer registered with Sales Tax \nDepartment.” \n7 Clause (13A) omitted by the Finance Act, 2008. The omitted clause (13A) read as follows: \n“(13A)    In respect of phosphatic fertilizers imported and specified in Notification No. S.R.O. \n609(I)/2004, dated 16th July, 2004 the tax under section 148 of the Income Tax Ordinance, 2001 \nshall be collected at the rate of 1% of its import value as increased by customs-duty, sales tax and \nfederal excise duty, if any, levied thereon.” \n8 Clause (13B) omitted by the Finance Act, 2008. The omitted clause (13B) read as follows: \n“(13B)  In respect of goods falling under HS Code 801.1100, 801.3200, 802.1200, 802.9010, \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n614 \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n5[  ] \n6[  ] \n                                            \n902.4010, 902.4090, 2101.1110, 2101.1120, 0902.2000, 904.1110,  907.0000, 908.1000, \n3702.3100, 3705.2000, 3707.9000,  4011.2090, 6301.1000, 8204.0000, 8301.1000, 8511.1000, \n8525.4000, 8529.9010, 9004.1000 0904.1120 (White Pepper), 0904.1190 (Long Pepper), \n0906.1000 (Cassia), 0813.4010 (Tamarind), 0908.3020 (Small Cardamom), 0908.3010 (Big \nCardamom), 0909.1000 (Star Aniseeds), 0802.5000 (Pistachio), 1211.9000 (Medical Herbs), \n1301.1010 (Seed Lac), 1903.0010 (Sago Seeds), 1301.9090 (Gum Gopal), 3706.9000 Other \n(cinematographic film), 9613.1000 (Pocket lighters, gas fuelled, non-refillable) and 9613.2000 \n(Pocket lighters, gas fuelled, refillable) and such other goods as notified by Central Board of \nRevenue of the First Schedule to the Customs Act, 1969 (IV of 1969), imported, the tax under \nsection 148 shall be collected at the rate of 2% of its import value as increased by customs-duty, \nsales tax and federal excise duty, if any, levied thereon.” \n1Clause (13C) omitted by the Finance Act, 2015. The omitted clause (13C) read as follows:- \n“(13C)  In respect of manufacturers of cooking oil or vegetable ghee or both, the rate of income tax \non purchase of locally produced edible oil shall be 2% of the purchase price.” \n2Clause (13D) omitted by the Finance Act, 2005. Earlier clause (13D) was inserted by S.R.O. \n769(I)/2004, dated 06.09.2004. The omitted clause (13D) read as follows:  \n“(13D)  In respect of import of polyester yarn/fibre all types, the tax under section 148 shall be \ncollected at the rate of two per cent of the value of such items as increased by customs-duty and \nsales tax, if any, levied thereon.” \n3Clause (13E) omitted by Finance Act, 2014. The omitted clause (13E) read as follows: \n \n“(13E) In respect of potassic fertilizers imported in pursuance of Economic Coordination \nCommittee of the cabinet’s decision No. ECC-155/12/2004 dated the 9th December, 2004, the tax under \nsection 148 of the Income Tax Ordinance, 2001 shall be collected at the rate of one per cent of its \nimport value as increased by customs-duty and sales tax, if any, levied thereon.” \n4 Clause (13F) omitted by S.R.O. 1037(I)/2005, dated 14.10.2005. The omitted clause (13F) read as \nfollows:  \n“(13F) In respect of import of blankets (acrylic), the tax under section 148 of the Income Tax \nOrdinance, 2001 shall be collected at the rate of two per cent of the value of such items as \nincreased by customs-duty and sales tax, if any, levied thereon.” \n5Clause (13G) omitted by S.R.O.140(I)/2013, dated 26.02.2013. The omitted clause (13G) read as \nfollows: \n“(13G) Tax under section 148 on the following item shall be collected @ 1% of  their import value as \nincreased by customs-duty, sales tax and federal excise duty, if any levied thereon: \n \n \niv.  \nGold; \n \nv.  \nMobile telephone sets; \n \nvi.  \nSilver;” \n6Clause (13H) omitted by Finance Act, 2008. The omitted clause (13H) read as follows: \n \n“(13H) Tax under section 148 on the following items shall be collected @ 2% of their import value \nas increased by Customs duty, Federal Excise Duty and sales tax, if any levied thereon;  \n(i) \nraw material for steel industry including remeltable; and re-rollable scrap; \n(ii) \nraw material for manufacturer of poultry feed; \n(iii) \nstationery;  \n(iv) \nedibale oil including crude oil imported as raw material   for manufacturer of ghee or \ncooking oil; \n(v) \nEnergy saver lamps [PCT heading 8539.10]; \n(vi) \nBitumem [PCT heading 2714]; \n(vii) \nFixed wireless terminal [PCT heading 8525.2040] \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n615 \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n5[  ] \n6[  ] \n7[  ] \n8[  ] \n                                            \n(viii) \nPesticides and wedicides.” \n1Clause (13HH) omitted by Finance Act, 2014. The omitted clause (13HH) read as follows: \n \n“(13HH) Tax shall be deducted under section 153 at the rate of 1% on the sale value of rice to \nbe sold by Rice Exporters Association of Pakistan (REAP) to Utility Store Corporation, in accordance \nwith the provisions of the agreement, signed with Ministry of Food, Agriculture and Livestock (MINFAL) \non May 5, 2008.” \n2Clause (13HHH) omitted by the Finance Act, 2014. Earlier it was inserted by SRO 645(I)/2008, dated \n20.06.2008. The omitted clause (13HHH) read as follows: \n “(13HHH)  Tax shall be deducted under section 153 at the rate 0.75% on the sale value of rice to be \nsold by Rice Exporters Association of Pakistan (REAP) to Utility Store Corporation, in accordance with \nthe provisions of the agreement, signed by REAP with Ministry of Food, Agriculture and Livestock \n(MINFAL) on May 5, 2008:  \n \nProvided that this clause shall be applicable up to June 30, 2008.” \n \n3Clause “(14)” omitted by the Finance Act, 2015. The omitted clause (14) read as follows:- \n“(14) \nIn case of owners of 3[goods transport vehicles], the rate of tax as specified in clause (i) of \nDivision III of Part IV of First Schedule shall be reduced to Rs.2 per kilogram of the laden weight.” \n4Clause (14A) omitted by the Finance Act, 2015. The omitted clause (14A) read as follows:- \n“(14A) In case of passenger transport vehicles, the rate of tax as specified in sub-clause (c) of \nclause (2) in Division III of Part IV of the First Schedule shall be reduced to 250 rupees per seat \nper annum.” \n5Clause (14B) omitted by the Finance Act, 2015. The omitted clause (14B) read as follows:-  \n“(14B) In case of owners of goods transport vehicles, the rate of tax as specified in clause (i) of \nDivision III of Pat IV of First Schedule shall be reduced to two Rupees per kilogram of the laden weight \nfor the period commencing on the 1st July, 2012 and ending on the 17th November, 2012 (both days \ninclusive): \nProvided that owners of the passenger transport vehicles may pay tax for the period 1st day of \nJuly, 2012 to 30th day of June, 2013 at the rates under this clause, if the tax is paid by the 30th day of \nJune, 2014: \nProvided further that the tax already paid from 1st day of July, 2012, as per rates specified in \nDivision III of part IV of the First Schedule, shall not be refunded.” \n6 Clause (14) omitted by the Finance Act, 2008. The omitted clause (14) read as follows: \n“(14)  Tax shall be deducted under section 154 at the rate of 0.75% from foreign exchange proceeds \non account of exports of – \n \n(i)  \nrice marketed under a brand name up to fifty kilograms packs; \n \n(ii) \ncanned and bottled fish including sea-food and other food items; and \n \n(iii) \nprecious and semi-precious stones whether uncut, cut, or polished.” \n7Clause (15) omitted by the Finance Act, 2008. The omitted clause (15) read as follows: \n“(15) Tax shall be deducted under section 154 at the rate of 0.75% from foreign exchange proceeds \non account of exports of fish and fisheries products packed in retail packs of five hundred grams to \ntwo kilograms.” \n8 Clause (16) omitted by the Finance Act, 2008. The omitted clause (16) read as follows: \n“(16)  In the case of a non-resident company, rate of deduction of tax under section 150 on dividends \nreceived from a company engaged exclusively in mining operations, other than petroleum, shall be \n7.5 per cent of the gross amount of dividend.” \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n616 \n \n1[  ] \n2[  ] \n3[   ] \n4[   ] \n5[   ] \n6[   ] \n7[   ] \n \n8[(18C) The rate of tax as specified in Division-III of Part-I of First Schedule shall \nbe reduced to 7.5% in case of dividends declared by a company as are \n“attributable” to profits and gains derived from a bagasse and biomass based co-\ngeneration power project qualifying for exemption under clause (132C) of Part-I of \nthis Schedule:  \n  \nProvided that the amount of “attributable” dividends shall be computed in \naccordance with the following formula, namely:-  \n  \nAXB/C  \n  \nWhere-  \n  \n                                            \n1Clause (17) omitted by Finance Act, 2014. The omitted clause (17) read as follows: \n \n“(17) \n The rates of tax as specified in Division III of Part-I of First Schedule shall be reduced \nto 7.5% in case of dividends declared or distributed by purchaser of a power project privatised by \nWAPDA.” \n2 Clauses (18) added by the Finance Act, 2002. \n3  Clause (18) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n“(18)  In the case of a modaraba the rate of income tax shall be 25% of total income excluding such \npart of total income to which Division III of Part I of the First Schedule or section153 or section 154 \napplies.] \n4 Clause (18A) Inserted by the Finance Act, 2014. \n5  Clause (18A) omitted by the Finance Act, 2021. The omitted clause read as follows:  \n“(18A) The rate of tax as specified in Division II of Part 1 of the First Schedule shall be reduced to \n20% for a company setting up an industrial undertaking between the first day of July, 2014 to the \nthirtieth day of June, 2017, for a period of five years beginning from the month in which the industrial \nundertaking is set up or commercial production is commenced whichever is later: \nProvided that fifty percent of the cost of the project including working capital is through owner \nequity foreign direct investment.]” \n6 Clause (18B) inserted by the Finance Act, 2016. \n7  Clause (18B) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n“(18B) The rate of tax as specified in Division II of Part I of the First Schedule shall be reduced by \n2% in case of a company whose shares are traded on stock exchange if: \n(a) \nit fulfils prescribed shari’ah compliant criteria approved by State Bank of Pakistan, \nSecurities and Exchange Commission of Pakistan and the Board; \n(b) \nderives income from manufacturing activities only; \n(c) \nhas declared taxable income for the last three consecutive tax years; and \n(d) \nhas issued dividend for the last five consecutive tax years.”]” \n8 Clause (18C) inserted by the Finance Act, 2021. \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n617 \n \n  \nA \nis the total amount of dividend for the year;  \n  \nB \nis the accounting profit for the year attributable to the bagasse and \nbiomass based cogeneration power project qualifying for exemption \nunder clause (132C) of Part-I of this Schedule; and  \n  \n \nC \nis the total accounting profit before tax for the year.  \n \n Explanation. — For the removal of doubt, it is clarified that accounting profit \nattributable to the bagasse/biomass based cogeneration power project would be \ndetermined by the external auditor of the company and the external auditor shall \nissue a certificate to this effect.] \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n \n5[  ] \n                                            \n1Clause (19) omitted by the Finance Act, 2014. The omitted clause (19) read as follows: \n “(19)  In respect of tax year commencing on or after the first day of July, 2002,the rate of income \ntax in respect of income of amalgamated company for its different businesses shall be the same as \napplicable to such businesses in the relevant tax year for the tax year in which amalgamation takes \nplace and two tax years next following.” \n \n2Clause (20) omitted by the Finance Act, 2014. The omitted clause (20) read as follows: \n“(20)  The rates of tax as specified in clause (b) of Division-III of Part-I of First Schedule shall \nbe reduced to 7.5% in case of dividend declared or distributed on shares of a company set up for \npower generation.” \n3Clause (21) omitted by the Finance Act, 2015. The omitted clause (21) read as follows: \n“(21)  In the case of any resident person engaged in the business of shipping, a presumptive income \ntax shall be charged in the following manner, namely:- \n(a)  ships and all floating crafts including tugs, dredgers, survey vessels and other specialized craft \npurchased or bare-boat chartered and flying Pakistan flag shall pay tonnage tax of an amount \nequivalent to one US $ per gross registered tonnage per annum; and \n(b)  ships, vessels and all floating crafts including tugs, dredgers, survey vessels and other \nspecialized craft not registered in Pakistan and hired under any charter other than bare-boat \ncharter shall pay tonnage tax of an amount equivalent to fifteen US cents per tonne of gross \nregistered tonnage per chartered voyage provided that such tax shall not exceed one US $ per \ntonne of gross registered tonnage per annum: \nProvided that the reduction under this clause shall not be available after the 30th June, 2020. \nExplanation.- For the purpose of this clause the expression “equivalent amount” means \nthe rupee equivalent of a US dollar according to the exchange rate prevalent on the first day of \nDecember in the case of a company and the first day of September in other cases in the relevant \nassessment year.” \n4Clause (22) omitted by the Finance Act, 2007. The omitted clause (22) read as follows; \n“[(22)  \nIn respect of companies getting enlisted on any stock exchange in Pakistan during the \nperiod first July, 2005 to thirtieth June, 2006, the rate of income tax shall be reduced by 1%.]” \n5Clause (23) omitted by the Finance Act, 2014. The omitted clause (23) read as follows: \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n618 \n \n1[  ] \n \n2[(24A) The rate of tax, under clause (a) of sub-section (1) of section 153, from \ndistributors of cigarette \n3[shall be 2.5% gross amount of payment] and \npharmaceutical products 4[  ] 5[  ] shall be 1% of the gross amount of payments.] \n \n6[  ] \n7[   ] \n8[   ] \n                                            \n“(23)  In respect of Urea fertilizer imported, the tax under section 148 shall be collected at the \nrate of 1% of its import value as increased by customs-duty, sales tax and federal excise duty], if any \nlevied thereon.” \n1Clause (24) omitted by the Finance Act, 2014. The omitted clause (24) read as follows: \n“(24)  In respect of pulses imported, the tax under section 148 shall be collected at the rate of \ntwo per cent of the value of such pulses as increased by customs-duty, sales tax and federal excise \nduty], if any, levied thereon.” \n2Inserted by the Finance Act, 2009. \n3 Expression inserted by the Finance Act, 2024. \n4Inserted by the Finance Act, 2010. \n5 The expression “and for large distribution houses who fulfill all the conditions for a large import house \nas laid down under clause (d) of sub-section (7) of section 148, for large import houses,” omitted by \nthe Finance Act, 2021. \n6 Clause (24AA) added by the Finance Act, 2018. \n7  Clause (24AA) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n“(24AA) The rate of tax, under section 152 in the case of M/S CR-NORINCO JV (Chinese \nContractor) as recipient, on payments arising out of commercial contract agreement signed with the \nGovernment of Punjab for installation of electrical and mechanical (E&M) equipment for construction \nof the Lahore Orange Line Metro Train Project, shall be 6% of the gross amount of payment.]” \n8Clause (24B) omitted by the Finance Act, 2014. The omitted clause (24B) read as follows:  \n \n“(24B) (a)  \nIn case of Steel Melters, who have opted under the Sales Tax Special \nProcedure Rules 2007.— \n(i)  \nfor the Tax Year 2011, the rate of minimum tax under sub-section (1) of section \n113 shall be 0.5% of turnover of Rs. 280 per metric ton, whichever is higher, \nprovided that the consequent tax liability is deposited by 31st May, 2012. \n(ii)  \nfor the Tax Years 2008 to 2010, the rate of Withholding Tax under section \n153(1)(a) on purchase of steel scrap shall be 1% of value of purchases or Rs. \n300 per metric ton whichever is higher, provided that the consequent tax liability \nis deposited by 30th June, 2012; and  \n(iii) \nfor the Tax Years 2011 and 2012 the rate of Withholding Tax under section \n153(1)(a) on purchase of steel scrap shall be 1% of value of purchases of Rs. \n400 per metric ton whichever is higher provided that the consequent tax liability \nfor the Tax Year 2011 is deposited by 30th June, 2012.  \n(b)  \nIn case of Steel Re-rolling Mills, who have opted under the Sales Tax Special Procedure \nRules, 2007.— \n(i)  \nfor the Tax Year 2011, the rate of minimum tax under sub-section (1) of section \n113 shall be 0.5% of turnover of Rs.315 per metric ton, whichever is higher, \nprovided that the consequent tax liability is deposited by 31st May, 2012. \n(ii)  \nfor the Tax Years 2008 to 2010, the rate of Withholding Tax under section \n153(1)(a) on purchase of ingots and billets shall be 1% of value of purchases of \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n619 \n \n1[   ] \n \n2[(24C) The rate of tax under clause (a) of sub-section (1) of section 153 in the \ncase of distributors, dealers, sub-dealers, wholesalers and retailers of fast moving \nconsumer goods, fertilizer, electronics excluding mobile phones, sugar, cement      \n3[, steel], and edible oil as recipient of payment shall be 0.25% of gross amount of \npayments subject to the condition that beneficiaries of reduced rate are appearing \non the Active Taxpayers’ Lists issued under the provisions of the Sales Tax Act, \n1990 and the Income Tax Ordinance, 2001 (XLIX of 2001):  \n  \nProvided that the benefit under this clause shall only be available to those \nTier-1 retailers as defined under Sales Tax Act, 1990 who are integrated and \nconfigured with Board or its computerized system for real time reporting of sales \nor receipts.] \n \n4[  ]  \n \n5[   ] \n \n6[(24CB) The rate of tax under clauses (b) and (c) of sub-section (1) of section 153 \nand sub-section (1) of section 236A to be deducted and collected from the National \nLogistics Corporation shall be 3% of the gross amount of payment and gross sale \nprice of a lease of the right to collect tolls, respectively:  \n                                            \nRs.400 per metric ton, whichever is higher provided that the consequent tax \nliability is deposited by 30th June, 2012; and  \n(iii)  \nfor the Tax Years 2011 and 2012, the rate of Withholding Tax under section \n153(1)(a) on purchase of ingots and billets shall be 1% of the value of purchases of Rs.450 per \nmetric ton, whichever is higher, provided that the consequent tax liability for the tax year 2011 is \ndeposited by 30th June, 2012.” \n1New clauses (24C) & (24D) added through Finance Act, 2019.  \n2  Clause (24C) substituted by the Finance Act, 2021. Earlier an amendment was made through Tax \nLaws (Amendment) Ordinance, 2021. The substituted clause read as follows:  \n“(24C)  The rate of tax under clause (a) of sub-section (1) of section 153 in case of dealers and sub-\ndealers of sugar, cement and edible oil, as recipient of the payment, shall be 0.25% of the gross \namount of payments.]” \n3 Expression added by the Finance Act, 2022.  \n4New clause (24CA) inserted through Finance Act, 2020 dated 30th June, 2020 \n5 Clause (24CA) omitted by the Finance act, 2025. The omitted clause read as follows: \n  “(24CA) The rate of tax under clause (a) of sub-section (1)  of section 153 in case of a person, other \nthan a company, as a recipient of payment for goods supplied to Utility Stores Corporation of Pakistan \nshall be 1.5% of the gross amount of payment in respect of supply of tea, spices, salt, dry milk, sugar, \npulses wheat flour and ghee for the period commencing from the 7th day of April, 2020 and ending \non 30th day of September, 2020: \n          Provided that this clause shall not be applicable to supply of tea, spices, salt and dry milk which \nare sold under a brand name: \n          Provided further that this clause shall not be applicable where rate of tax under clause (a) of   \nsub-section (1) of section 153 is less than 1.5% of the gross amount of payment under any provisions \nof the Ordinance.” \n6 Clause (24CB) inserted by Finance Act, 2025. \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n620 \n \n \n \n \nProvided that the tax so deductible and collected shall be minimum tax \nand in case the normal income tax, chargeable under Division II of Part I of the \nFirst Schedule on the taxable income of the taxpayer, is higher than the amount of \ntax under this clause, the taxpayer shall be liable to pay the normal income tax.] \n \n1[(24D) The rate of minimum tax under sub-section (1) of section 113 in the case \nof distributors, dealers, sub-dealers, wholesalers and retailers of fast moving \nconsumer goods, fertilizer, locally manufactured mobile phones, sugar, electronics \nexcluding imported mobile phones, cement 2[, steel] and edible oil shall be 0.25% \nsubject to the condition that beneficiaries of reduced rate are appearing on the \nActive Taxpayers’ Lists issued under the provisions of the Sales Tax Act, 1990 and \nthe Income Tax Ordinance, 2001:  \n  \nProvided that the benefit under this clause shall be available to only those \nTier-1 retailers as defined under Sales Tax Act, 1990 who are integrated and \nconfigured with Board or its computerized system for real time reporting of sales \nor receipts.] \n \n3[  ] \n \n4[  ] \n \n5[(27) The tax on payments under the Compulsory Monetization of Transport \nFacility for Civil Servants in BS-20 to BS-22 (as reduced by deduction of driver’s \nsalary) shall be charged at the rate of 5% as a separate block of income.] \n \n6[  ] \n                                            \n1  Clause (24D) substituted by the Finance Act, 2021. Earlier an amendment was made through Tax \nLaws (Amendment) Ordinance, 2021. The substituted clause read as follows:  \n“(24D) The rate of minimum tax under sub-section (1) of section 113 in case of dealers and sub-\ndealers of sugar, cement and edible oil shall be 0.25% subject to the condition that the names of \nsuch dealers and sub-dealers are appearing on the active taxpayers’ lists issued under the provisions \nof the Sales Tax Act, 1990 and the Income Tax Ordinance, 2001 (XLIX of 2001).]” \n \n2 Expression added by the Finance Act, 2022.  \n3Clause (25) omitted by the Finance Act, 2007. The omitted clause (25) read as follows: \n“(25) Services of sizing, weaving stitching, dying, printing, embroidery and washing rendered or \nprovided to an exporter or an export house shall be treated as export and chargeable to tax at the \nrate equal to the rate of tax applicable to the exporter on export of goods to which such services \nrelate as specified in Division IV of Part III of the First Schedule.”. \n4Clause (26) omitted by the Finance Act, 2014. The omitted clause (26) read as follows: \n“(26) The rate of tax as specified in Division II of Part IV, of the First Schedule, in the case of \nadvertising agents, shall be 5% of the amount of the payment.” \n5 Added by S.R.O. 569(I)/2012, dated 26.05.2012. \n6 Clause (28) omitted by the Finance Act, 2009. The omitted clause (28) read as follows: \n“(28) The rate of tax to be deducted under section 155, as specified in Division V, Part III of First \nSchedule, shall be as under:- \n(a)  \nin the case of individual and association of persons at S.Nos.3 and 4 of the \nTable─ \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n621 \n \n1[   ] \n2[   ] \n3[   ] \n4[   ]  \n5[   ] \n6[   ] \n \n                                            \nS.No. \nGross amount of rent \nRate of tax \n(1) \n(2) \n(3) \n(3) \nWhere the gross amount of rent \nexceeds Rs.400,000 but does \nnot exceed Rs.1,000,000  \n \nRs.12,500 plus 7.5 per cent of \nthe gross amount exceeding \nRs.400,000 \n(4)  \nWhere the gross amount of rent \nexceeds Rs.1,000,000 \nRs.57,500 plus 10 per cent of \nthe gross amount exceeding \nRs.1,000,000; and \n \n(b)  \nin the case of company at S.Nos.2 and 3 of the Table─ \nS.No. \nGross amount of rent \nRate of tax \n(1) \n(2) \n(3) \n(2) \nWhere the gross amount of rent \nexceeds Rs.400,000 but does \nnot exceed Rs.1,000,000  \n \nRs.20,000 plus 7.5 per cent of \nthe gross amount exceeding \nRs.400,000 \n(3)  \nWhere the gross amount of rent \nexceeds Rs.1,000,000 \nRs.65,000 plus 10 per cent of \nthe gross amount exceeding \nRs.1,000,000.” \n \n1Clause (28A) inserted by the Finance Act, 2013. \n2  Clause (28A) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n   “(28A) \nThe rate of tax under section 148 on import of hybrid cars shall be reduced as below:— \n \nEngine Capacity \nRate of reduction \nUpto 1200 cc \n100% \n1201 to 1800 cc \n50% \n1801 to 2500 cc \n25%] \n \n3Clause (29) omitted by the Finance Act, 2014. The omitted clause (29) read as follows: \n“(29) \nThe rate of tax under section 153A as specified in Part IIA of the First Schedule shall be \nreduced to 0.1% in case of cigarette manufacturers who are registered under the Sales Tax Act, 1990.” \n4Clause (30) omitted by the Finance Act, 2014. The omitted clause (30) read as follows: \n“(30) \nThe rate of tax as specified in column (3), against serial no. 2 in clause (1), in Division \nI of the Part I of First Schedule to the ordinance shall be reduced to 5%, for taxable income \ndeclared in a return for tax year 2012, filed under clause (87) or (88) of the Part IV of this \nSchedule.” \n5 Clause (28B) added by the Finance Act, 2015. \n6  Clause (28B) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax \nLaws (Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n“(28B) The rate of tax shall be 0.15% under section 231A on cash withdrawal by an exchange \ncompany, duly licensed and authorized by the State Bank of Pakistan, exclusively dedicated for its \nauthorized business related transactions, subject to the condition that a certificate issued by the \nconcerned Commissioner Inland Revenue for a financial year mentioning details and particulars of \nits Bank Account being used entirely for business transactions is provided.” \n\n\f\nSecond Schedule – Part-II_____ __________________________ \n622 \n \n1[(28C)The rates of tax as specified in Division II of Part-IV of the First Schedule \nshall be five percent in the case of a person running online marketplace as defined \nin clause (38B) of section 2.] \n \n2[(28D) The rate of minimum tax under section 113 for tax year 2020 shall be 0.5% \nin the case of a trader having turnover upto one hundred million Rupees: \n \n \n \nProvided that the tax liability of traders for tax year 2019 and 2020 in \ncase of traders who filed return of income for tax year 2018 shall not be less than \nthe tax paid for the tax year 2018. \n \n \nExplanation.- For the purpose of this clause, ‘trader’ shall mean an individual \nengaged in business of buying and selling of goods in the same state not include \na distributor. \n \n(28E) The rate of minimum tax under section 113 3[   ] shall be 0.5% in case of a \ntrader of yarn being an individual.] \n \n4[(28F) The rate of tax under clause (b) of sub-section (1) of section 153 in case of \noil tanker contractor services shall be  2% of the gross amount of the payments. \n \n5[(31) The rate of tax under clause (a) of sub-section (1) of section 153 shall be \n1% on payment for sale of gold and silver and articles thereof and the tax so \ndeducted shall be adjustable;] \n \n \n \n \n \n \n \n \n                                            \n1Added by the Finance Act, 2017. \n2Clauses (28D) & (28E) inserted through Tax Laws(Second Amendment), 2019 dated 26th \nDecember, 2019. \n3 The expression “for tax year 2020” omitted by the Finance Act, 2021. \n4 Clause (28F) added by the Finance Act, 2021. \n5 Clause (31) added by the Finance Act, 2022. \n\n\f\nSecond Schedule – Part III____ __________________________ \n \n624 \n   PART III \nREDUCTION IN TAX LIABILITY \n \n \nIncome, or classes of income, or person or classes of person, enumerated \nbelow, shall be allowed reduction in tax liability to the extent and subject to such \nconditions as are specified hereunder:- \n \n \n1[    ] \n2[    ] \n3[     ] \n4[     ] \n \n5[(2) The tax payable by a full time teacher or a researcher, employed in a \nnon profit education or research institution duly recognized by Higher Education \nCommission, a Board of Education or a University recognized by the Higher \nEducation Commission, including government 6[  ] research institution, shall be \nreduced by an amount equal to 7[25]% of tax payable on his income from salary \n8[:] \n \n                                            \n1 Clause (1) omitted by the Finance Act, 2022. The omitted clause read as follows: \n(1) \n1[(1)  Any amount received as- \n(a)  flying allowance by 1[ ]flight engineers, navigators of Pakistan Armed Forces, Pakistani \nAirlines or Civil Aviation Authority, Junior Commissioned Officers or other ranks of \nPakistan Armed Forces; and \n(b)   submarine allowance by the officers of the Pakistan Navy, shall be taxed @ 2.5% as \na separate block of income 1[:] ] \n[Provided that the reduction under this clause shall be available to so much of \nthe flying allowance or the submarine allowance as does not exceed an amount equal \nto the basic salary.]” \n2Sub-Clause (1A) omitted by Finance Act, 2014. The omitted sub-clause (1A) read as follows: \n“(1A) \nWhere the taxable income 2[other than income on which the deduction of tax is final], in a tax \nyear, of a taxpayer aged 2[60] years or more on the first day of that tax year does not exceed 2[one \nmillion] rupees, his tax liability on such income shall be reduced by 50%.” \n3Clause (1AA) inserted by the Finance Act, 2014. \n4 Clause (1AA) omitted by the Finance Act, 2022. The omitted clause read as follows: \n   “(1AA) Total allowances received by pilots of any Pakistani airlines shall be taxed at a rate of 7.5%, \nprovided that the reduction under this clause shall be available to so much of the allowances as exceeds \nan amount equal to the basic pay.” \n5Sub-Clause (2) substituted by the Finance Act, 2006. The substituted sub-clause (2) read as follows: \n“(2) \nIn addition to the reduction specified in sub-clause (1), the tax payable by a full time teacher or \na researcher, employed in a non-profit education or research institution including government training \nand research institution duly recognized by a Board of Education or a University or the Higher \nEducation Commission, shall be further reduced by an amount equal to 75% of the tax payable after \nthe aforesaid reduction.” \n6The words “training and” omitted through Finance Act, 2019. \n7The figure “40” substituted by the Finance Act, 2019. \n8 Full stop substituted by “colon” though Finance Act, 2019. \n\n\f\nSecond Schedule – Part III____ __________________________ \n624 \n \n1[Provided that this clause shall not apply to teacher of medical profession \nwho derive income from private medical practice or who receive share of \nconsideration received from patients.]  \n \n2[   ] \n3[   ] \n \n4[(3A) The tax payable by a full-time teacher or a researcher, employed in a non-\nprofit education or research institution duly recognized by Higher Education \nCommission, a Board of Education or a University recognized by the Higher \nEducation Commission, including government research institution, shall be \nreduced by an amount equal to 25% of tax payable on his income from salary:  \n \nProvided that this clause shall not apply to teacher of medical profession \nwho derive income from private medical practice or who receive share of \nconsideration received from patients:  \n \nProvided further that the provision of this clause shall be deemed to have \nbeen in force with effect from the first day of July, 2022 and shall cease to have \neffect after tax year 2025.] \n \n5[(4) In respect of old and used automotive vehicles, tax under section 148 shall \nnot exceed the amount specified in Notification No. S.R.O. 577(I)/2005, dated the \n6th June, 2005.] \n                                            \n1New provision inserted through Finance Act, 2019. \n2  Clause (2) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n“(2) The amount of tax payable, in a year in which the rupee is revalued or devalued, by a taxpayer \nwhose profits or gains are computed in accordance with the rules contained in the Fifth Schedule to \nthis Ordinance and who had entered with the Government into an agreement which provides for such \nreduction, shall be reduced to the amount that would be payable in the absence of the revaluation \nor devaluation of the rupee.” \n3Omitted by the Finance Act, 2008. The omitted clause (3) read as follows: \n“(3)  Where any company engaged in the business of distribution of cigarette manufactured in \nPakistan is required to pay minimum tax on the amount representing its turnover under section 113, \nthe amount of tax payable under the said section shall be reduced by eighty per cent.” \n4 Clause (3A) inserted by Finance Act, 2025. \n5Clause (4) substituted by the Finance Act, 2011. The substituted clause (4) read as follows: \n“(4) \nIn respect of old and used automotive vehicles specified in Notification No. S.R.O. 932(I)/2004, \ndated the 20th November, 2004, the tax under section 148 of the Income Tax Ordinance, 2001, shall \nnot exceed the amount specified in column (3) of the Table below, namely:— \nTABLE \nS.No. \nVehicles meant for transport of persons \nIncome tax in Pak Rupees \n(1) \n(2) \n(3) \n1. \nUpto 800CC \nRs.29,852 \n2. \nFrom 801CC to 1000CC \nRs.34,497 \n3. \nFrom 1001CC to 1300CC \nRs.67,282 \n4. \nFrom 1301CC to 1600CC \nRs.105,061 \n5. \nFrom 1601CC to 1800CC \nRs.120,256” \n \n\n\f\nSecond Schedule – Part III____ __________________________ \n625 \n \n1[   ] \n \n2[(3[6]) The tax payable under clause (c) of sub-section (1) of section 39, in respect \nof any amount paid as yield or profit on investment in Bahbood Savings Certificate \nor Pensioners Benefit Account 4[and Shuhada Family Welfare Account] shall not \nexceed 5[5%] of such profit.] \n \n6[  ] \n7[   ] \n \n(9) The tax payable on profits and gains derived by a person from low cost   \nhousing projects shall be reduced by fifty percent. The reduction in tax liability \nunder this clause shall apply to such project which is— \n \n(a) \nowned and managed by a company formed for operating the said project \nand registered under the  Companies  Act,  2017  (XIX  of  2017)  and \nhaving its registered office in Pakistan; and \n \n(b) \nnot formed by the splitting up, or the reconstruction or reconstitution,  of \na business already in existence or by transfer to a new business of  any \nmachinery or plant used in a business which was being carried on in \nPakistan at any time before the commencement of the new business; \nand \n \n(c) \na low cost  housing  project  under  which  the maximum sale price of a \nsingle housing unit is two and a half million rupees] 8[: \n \n \n  \nProvided that exemption under this clause shall continue to \nremain available to such projects which commence on or before the 30th \nday of June, 2024.] \n \n                                            \n1Clause (5) omitted by the Finance Act, 2014. The Omitted clause (5) read as follows: \n“(5)  \nWhere the corporatized entities of Pakistan Water and Power Development Authority (DISCOs) \nand National Transmission and Dispatch Company (NTDC), are required to pay minimum tax under \nsection 113, the purchase price of electricity shall be excluded from the turnover liable to minimum tax \nup to the tax year 2013.” \n2Added by the Finance Act, 2008. \n3 Clause (5) renumbered by the Finance Act, 2009. \n4Inserted by the Finance Act, 2018 \n5 The expression “10%” substituted by the Finance Act, 2022. \n6 Clause (7) added by the Finance Act, 2018. \n7  Clauses (7) and (8) omitted by the Finance Act, 2021. Earlier this amendment was made through \nTax Laws (Second  Amendment) Ordinance, 2021. The omitted clauses read as follows:  \n“((7) The amount of tax payable by foreign film-makers from making films in   Pakistan shall be \nreduced by fifty percent on income from film-making in Pakistan. \n(8) The amount of tax payable by resident companies deriving income from film-making shall be \nreduced by seventy percent on income from film-making..” \n8  Full stop substituted and proviso added by the Finance Act, 2021. Earlier this amendment was made \nthrough Tax Laws (Second  Amendment) Ordinance, 2021. \n\n\f\nSecond Schedule – Part III____ __________________________ \n626 \n \n1[  ] \n2[  ]  \n3[  ] \n \n4[(9A) The amount of tax payable on income chargeable under the head, “Capital \nGains” on disposal of immovable property shall be reduced by fifty percent on the \nfirst sale of immovable property acquired or allotted to ex-servicemen and serving \nacquired or allotted to ex-servicemen and serving personal of Armed Forces or ex-\nemployees or serving personnel of Federal and Provincial Governments, being \noriginal allottees of the immovable property, duly certified by the allotment \nauthority5[:]]  \n \n \n6[Provided that for capital gains arising after completion of three years from \nthe date of acquisition of immovable property the amount of tax payable shall be \nreduced by seventy-five percent.]    \n \n7[(9B) The tax payable on the income, profits and gains of projects of ‘low cost \nhousing’ developed or approved by Naya Pakistan Housing and Development \nAuthority (NAPHDA) or under the Ehsaas Programme shall be reduced by 90%] \n8[: \nProvided that exemption under this clause shall continue to remain available \nto such projects which commence on or before the 30th day of June, 2024.] \n \n9[   ] \n                                            \n1Clause (7) omitted by Finance Act, 2014.the omitted clause (7) read as follows: \n“(7)  \nWhere any 1[taxpayer] engaged in the business of distribution of cigarettes manufactured in \nPakistan is required to pay minimum tax on the amount representing its turnover under section 113, \nthe amount of tax payable under the said section shall be reduced by eighty per cent.” \n2Clause (8) omitted by Finance Act, 2014. The omitted clause (8) read as follows: \n“(8) For the distributors of pharmaceutical products, fertilizers, consumers goods including fast moving \nconsumers goods, the rate of minimum tax on the amount representing their annual turnover under \nsection 113 shall be reduced by eight per cent.” \n3Clause (9) omitted by Finance Act, 2014. The Omitted clause (9) read as follows: \n“(9)In cases of oil marketing companies, oil refineries and Sui Southern Gas Company Limited 3[and \nSui Northern Gas Pipelines Limited] the rate of minimum tax shall be reduced to 0.5% only for the cases \nwhere annual turnover exceeds rupees one billion.” \n4New clause (9A) added through Finance Act, 2019.  \n5Full stop substituted by semi colon through Tax Laws(Second Amendment) Ordinance, 2019 dated \n26th December, 2019. \n6New proviso inserted through Tax Laws(Second Amendment) Ordinance, 2019 dated 26th \nDecember, 2019, \n7New clause (9B) inserted through Finance Act, 2020 dated 30th June, 2020 \n8  Full stop substituted and proviso added by the Finance Act, 2021. Earlier this amendment was \nmade through Tax Laws (Second  Amendment) Ordinance, 2021. \n9Clause (10) omitted by Finance Act, 2014. The Omitted clause (10) read as follows: \n“(10) \nFor cases of flour mills the rate of minimum tax on the amount representing their annual turnover \nunder section 113 shall be reduced by eighty per cent.” \n\n\f\nSecond Schedule – Part III____ __________________________ \n627 \n \n1[   ] \n2[   ] \n3[   ] \n4[   ] \n5[   ] \n6[   ] \n \n7[(17) The tax payable by cotton ginners on their income and profits shall not be \nmore than sum of 1% of their turnover from cotton lint, cotton seed, cotton seed oil \nand cotton seed cake:  \n  \n   \nProvided that the tax so payable shall be final tax in respect of their cotton \nginning and oil milling activities only.] \n \n8[(18) The rate of withholding tax on value of offshore supply contract of an \nIndependent Power Producer located wholly or partly in territories of AJ&K shall \nbe 1% provided:  \n  \n(i) \nPPIB has issued Letter of Support for the project;  \n  \n                                            \n1Clause (11) omitted by Finance Act, 2014. The Omitted clause (11) read as follows: \n“(11) \nThe amount of surcharge payable on the Income Tax liability for the Tax Year 2011 under section 4A \nshall be computed on the proportionate amount of Income Tax liability for three and a half months.” \n2Clause (12) omitted by Finance Act, 2014. The Omitted clause (12) read as follows: \n“(12) \nFor the ease of M/s Pakistan International Airlines Corporation the rate of minimum tax on the \namount representing their annual turnover under section 113 shall be reduced by fifty per cent.” \n3Clause (13) omitted by Finance Act, 2014. The Omitted clause (13) read as follows: \n“(13) \nFor the petroleum agents and distributors who are registered under the Sales Tax Act, 1990 \nand rice mills and dealers, the rate of minimum tax under section 113 on the amount representing their \nannual turnover under section 113 shall be reduced by eighty per cent.” \n4Clause (14) omitted by Finance Act, 2014. The Omitted clause (14) read as follows: \n“(14) \nFor the poultry industry including poultry breeding, broiler production, egg production and \npoultry feed production, the rate of minimum tax under section 113 on the amount representing their \nannual turnover under section 113 shall be reduced by fifty per cent.” \n5Clause (15) omitted by Finance Act, 2014. The Omitted clause (15) read as follows: \n“[(15) For the motorcycle dealers registered under the Sales Tax Act, 1990, the rate of minimum tax \nunder section 113.— \n(i)  \nfor the Tax Year 2011 shall be reduced by fifty per cent provided that they \ndeposit their minimum tax on turnover by the 30th June, 2012; and \n(ii)  \nfor the Tax Year 2012 onwards shall be reduced by seventy-five per cent.” \n6Clause (16) omitted by Finance Act, 2015. The Omitted clause (16) read as follows:- \n“(16) The minimum penalty for failure to furnish statement under section 115, 165 or 165A as \nmentioned in column (3) against serial No. (1A) in the Table given in sub-section (1) of section 182 \nshall be reduced to ten thousand rupees.” \n7 Clause (17) inserted and shall be deemed to have been inserted with effect from the 1st day of July, \n2019, by the Finance Act, 2021. Earlier this clause was inserted through Tax Laws (Amentment) \nOrdinance, 2021. \n8 Clauses (18), (19) and (20) inserted by the Finance Act, 2021. \n\n\f\nSecond Schedule – Part III____ __________________________ \n628 \n \n(ii) \nits EPC Contract has been executed and submitted to NEPRA for EPC \nstage tariff determination prior to the enactment of Finance Act, 2018;  \n  \n(iii) \noffshore supply contract arrangement of offshore supply contractor \nhaving permanent establishment in Pakistan falls under the purview \nof cohesive business operation as contemplated under Income Tax \nOrdinance, 2001; and  \n  \n(iv) \nsuch 1% tax shall be full and final liability of the offshore contractor.  \n  \n(19) The tax payable by woman enterprises on profit and gains derived from \nbusiness chargeable to tax under the head “Income from Business” shall be \nreduced by 25%.  \n  \nExplanation.—For the purpose of this clause a woman enterprise means a \nstartup established on or after first day of July 2021 as sole proprietorship \nconcern owned by a woman or an AOP all of whose members are women \nor a company whose 100% shareholding is held or owned by women:  \n  \nProvided that benefit of this clause shall not be available to a business \nthat is formed by the transfer or reconstitution or reconstruction or splitting \nup of an existing business. \n  \n1[   ] \n \n \n \n \n \n \n \n \n \n                                            \n1 Clause (20) omitted by the Finance Act, 2022. The omitted clause read as follows: \n“(20) The tax payable by a person other than a banking or insurance company in respect of profit on \ndebt from investment in Federal Government securities shall be fifteen percent of the gross amount \nof the profit on debt:  \n  \nProvided that tax so payable shall be final tax on the income representing profit on debt from \ninvestment in Federal Government securities.” \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n \n631 \nPART IV \nEXEMPTION FROM SPECIFIC PROVISIONS \n \n \nIncome, or classes of income, or persons or classes of persons, enumerated \nbelow, shall be exempt from the operation of such provisions of this Ordinance, \nsubject to such conditions and to the extent, as are specified hereunder:- \n \n1[  ] \n \n2[(1A) the provision of clause (d) of section 46 shall not apply to Sukuk issued by \n“The Second Pakistan International Sukuk Company Limited” 3[and the Third \nPakistan International Sukuk Company Limited].] \n \n4[   ] \n \n(3) \nThe provisions of clause (b) of 5[component C of the formula contained in] \nsub-section (2) of section 61 shall not apply in case of donations made to Agha \nKhan Hospital and Medical College, Karachi: \n \n6[  ] \n \n7[  ] \n \n                                            \n1Clause (1) omitted by the Finance Act, 2003. The omitted clause (1) read as follows: \n“(1) The provisions ofclause (k) of section 21 shall not apply to any expenditure incurred by a \nbanking company or a financial institution owned and controlled by the Federal Government on the \nprovisions of perquisites, allowances or other benefits to any employee in pursuance of any law.” \n2Clause (1A) inserted by S.R.O. 1029(I)/2014 dated 29.11.2014. \n3Addedby the Finance Act, 2018. \n4  Clause (2) omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted clause read as follows:  \n“(2) In the case of losses referred to in section 57 in respect of an industrial undertaking set up in \nan area declared by the Federal Government to be a \"Zone\" within the meaning of Export Processing \nZones Authority Ordinance, 1980 (IV of 1980), the period of six 4[tax years] specified in the said \nsection shall not apply.” \n5 The words “component C of” substituted by the Finance Act, 2003. \n6Clause (3A) omitted by the Finance Act, 2008. The omitted clause (3A) read as follows: \n“(3A) The provisions of sub-sections (5) and (5A) of section 34 and section 70 shall not apply to any \nbenefit derived by way of waiver of profit on debt or the debt itself under the State Bank of Pakistan, \nBanking Policy Department’s Circular No.29 of 2002, dated the 15th October, 2002, to the extent not \nset off against the losses under Part VIII of Chapter III.” \n7Clause (4) omitted by the Finance Act, 2003. The omitted clause (4) read as follows: \n“(4) The provisions of section 111 shall not apply in respect of any amount invested in the acquisition \nof Foreign Exchange Bearer Certificates issued under the Foreign Exchange Bearer Certificates \nRule, 1985.” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n630 \n \n1[(4A) No provision of this Ordinance shall apply for recoup of tax credit already \nallowed to National Power Parks Management Company (Private) Limited for \ninvestment in plant and machinery notwithstanding non issuance of share \ncertificates or any restructuring of its ownership pattern or debt to equity ratio prior \nto  privatization as part of the privatization process.] \n \n2[(5) The provisions of section 111 regarding un-explained income or assets shall \nnot apply in respect of, — \n \n(i)  \nany amount of foreign exchange deposited in a private Foreign \nCurrency account held with an authorized bank in Pakistan in \naccordance with the Foreign Currency Accounts Scheme introduced \nby the State Bank of Pakistan: \n \nProvided that the exemption clause shall not be available in \nrespect of any incremental deposits made on or after the 16th day of \nDecember, 1999 in such accounts held by a resident person or in \nrespect of any amount deposited in accounts opened on or after the \nsaid date by such person. \n \n(ii)  \nany amount invested in the acquisition of Three Years Foreign \nCurrency Bearer Certificates issued under the Foreign \nCurrency Bearer Certificates Rules, 1997. \n \n(iii)  \nrupees withdrawn or assets created out of such withdrawal in \nrupees from private foreign currency accounts, or encashment \nof Foreign Exchange Bearer Certificates, US Dollar Bearer \nCertificates and Foreign Currency Bearer Certificates.] \n \n3[  ]  \n                                            \n1 Clauses (4A) inserted by the Finance Act, 2021. \n2 Clause (5) substituted by the Finance Act, 2005. The substituted clause (5) read as follows:  \n“(5) The provisions of section 111 shall not apply in respect of any amount of foreign exchange \ndeposited in a private Foreign Currency account held with an authorized bank in Pakistan in \naccordance with the Foreign Currency Accounts Scheme introduced by the State Bank of Pakistan: \n \nProvided that the exemption under this clause shall not be available in respect of any incremental \ndeposits made on or after the 16th day of December, 1999 in such accounts held by a resident \nperson or in respect of 2[any amount] deposited in accounts opened on or after the said date by such \nperson.” \n3Clause (9A) omitted though Finance Act, 2020 dated 30th June, 2020 the omitted clause read a follows: \n“(9A) Provisions of clause (a) of sub-section (1) of section 153, shall not apply to steel melters 3[and] \ncomposite steel units, as a payer, in respect of purchase of scrap, provided that tax is collected in \naccordance with section 235B: \n \nProvided that steel melters 3[ ] and composite steel units may opt to pay tax in accordance with \nsection 235B, for tax year 2012 and 2013, if tax liability for the said tax years is paid by the 30th day of \nJune, 2014: \n\n\f\nSecond Schedule – Part IV____ __________________________ \n631 \n \n1[(9AA) Provisions of clause (a) of sub-section (1) of section 153, shall not apply \nto ship breakers as recipient of payment: \n \nProvided that this clause shall only apply for ships imported after the 1st July \n2014.] \n \n2[  ] \n \n3[  ] \n \n4[  ] \n5[  ] \n6[  ] \n7[  ] \n                                            \nProvided further that where tax has been deducted under clause (a) of sub-section (1) of section 153 \nor paid under an order under section 161, it shall not be refundable.” \n1Inserted by the Finance Act, 2014. \n2Clause (6) omitted by the Finance Act, 2003. The omitted clause (6) read as follows: \n“(6) The provisions of section 111 shall not apply in respect of any amount invested in the acquisition \nof US Dollar Bearer Certificate issued under the US Dollar Bearer Certificates Rules, 1991.” \n3Clause (7) omitted by the Finance Act, 2005. The omitted clause (7) read as follows: \n“(7) The provisions of section 111 shall not apply in respect of any amount invested in the \nacquisition of Three-Years Foreign Currency Bearer Certificates issued under the Foreign Currency \nBearer certificates Rules, 1997.” \n4Clause (8) omitted by the Finance Act, 2005. The omitted clause (7) read as follows: \n“(8) The provisions of section 111 shall not apply in respect of rupees withdrawn or assets created \nout of such withdrawal in rupees from private foreign currency accounts, or encashment of Foreign \nExchange Bearer Certificates, US Dollar Bearer Certificates and Foreign Currency Bearer \nCertificates.” \n5 Clause (9) omitted by the Finance Act, 2003. The omitted clause (9) read as follows: \n“(9) The provisions of section 111 shall not apply in respect of any amount invested by a sponsor \nor an original allottee in the purchase of shares of a company owning and managing an industrial \nundertaking specified in rule 5A of the Third Schedule of the Income Tax Ordinance, 1979.” \n6Clause (10) omitted by Finance Act, 2014. The omitted clause (10) read as follows: \n \n“(10)  The provisions of section 111, Part-X and Part-XI of Chapter X shall not apply in respect \nof any amount invested in the purchase of Special US Dollar Bonds issued under the Special U.S. \nDollar Bond Rules, 1998: \nProvided that the exemption under this clause shall not be available in respect of the \namount invested in the said Bonds purchased out of incremental deposits made in the existing \nforeign currency accounts on or after 16th day of December, 1999, or out of foreign currency \naccounts opened on or after the said date, or on payment of the amount referred to in sub-rule \n(3) of rule 5 of Special U.S. Dollar Bond Rules, 1998 after the said date.” \n7Clause (10A) omitted by Finance Act, 2014. The omitted clause (10A) read as follows: \n“(10A) (i)  \nThe provisions of serial No.5 of the Table given in sub-section (1) of  section \n182 and clause (a) of sub-section (1) of section 205 shall not  apply to business located in the most \naffected and moderately affected areas of Khyber Pakhtunkhwa, FATA and PATA, provided  that the \nprincipal amount of tax due is paid by the 30th day of June,  \n2010; \n(ii)  \nthe provisions of section 235, regarding advance tax on electricity, shall not apply to \ncommercial and industrial consumers of electricity located in the most affected and \nmoderately affected areas of Khyber Pakhtunkhwa, FATA and PATA till the 30th day of \nJune, 2011; \n(iii)  \nthe provisions of section 154, regarding withholding tax on exports, shall not be applicable to \n\n\f\nSecond Schedule – Part IV____ __________________________ \n632 \n \n \n1[  ] \n                                            \nthe export of goods originating from the most affected and moderately affected areas of \nKhyber Pakhtunkhwa, FATA and PATA, till the 30th day of June,2011: \nProvided that this clause shall only be restricted to the exporters based in the above areas; \n(iv)  \nthe provisions of section 148 shall not be applicable on the import of plant and \nmachinery for establishment of businesses in the most affected and moderately affected \nareas of Khyber Pakhtunkhwa, FATA and PATA till the 30th day of June, 2011: \nProvided that this concession shall not be available to the manufacturers and suppliers of \ncement, sugar, beverages and cigarettes; \n \n \nExplanation.— For the purpose of this Schedule,— \n(a)  \nmost affected areas means district Peshawar, Malakand Agency, and districts \nof Swat, Buner, Shangla, Upper Dir, Lower Dir, Hangu, Bannu, Tank, Kohat and \nChitral; and  \n(b)  \nmoderately affected areas means districts of Charsadda, Nowshera, D.I. Khan, \nBatagram, LakkiMarwat, Swabi and Mardan.” \n1 Clause (11) omitted by the Finance Act, 2008. The omitted clause (11) read as follows: \n“(11)  The provisions of section 113, regarding minimum tax, shall not apply to,- \n(i)  \nNational Investment (Unit) Trust or a collective investment scheme authorized or \nregistered under the Non-banking Finance Companies (Establishment and \nRegulation) Rule, 2003 1[or a real estate investment trust approved and authorized \nunder the Real Estate Investment Trust Rules, 2006], or any other company in respect \nof turnover representing transactions in shares, or securities listed on a registered \nstock exchange; \n(ii) \npetroleum dealers, in so far as they relate to turnover on account of sale of petroleum \nand petroleum products, notwithstanding their status as a company, a registered firm \nor an individual, engaged in retail sale of petroleum and petroleum products through \npetrol pumps for the purposes of assessment of their income and determination of tax \nthereon: \n \nProvided that this exemption shall not apply to the sale of petroleum and petroleum products \nthrough petrol pumps which are directly operated or managed by companies engaged in distribution \nof petroleum and petroleum products. \nExplanation.- For the removal of doubt it is declared that the companies engaged in \ndistribution of petroleum and petroleum products other than through petrol pumps shall \nnot be entitled to the benefits of this exemption; \n(iii)  Hub Power Company Limited so far as they relate to its receipts on account of sale of \nelectricity; \n(iv)  KotAddu Power Company Limited (KAPCO) for the period it continues to be entitled \nto exemption under clause (138) of Part-I of this Schedule; \n(v) \ncompanies, qualifying for exemption under clause (132) of Part-I of this Schedule, in \nrespect of receipts from sale of electricity; \n(vi) \nProvincial Governments and local authorities, qualifying for exemption under section \n49 and other Government or semi-Government bodies which are otherwise exempt \nfrom income tax: \n \nProvided that nothing shall be construed to authorize any refund of tax already paid or the \ncollection of any outstanding demand created under the said section; \n(vii)  Pakistan Red Crescent Society; \n(viii)  special purpose, non-profit companies engaged in scrutinizing the receivables of \nProvincial Governments or the companies; \n(ix) \nnon-profit organizations approved under clause (36) of section 2 or clause (58) or \nincluded in clause (61) of Part-I of this Schedule; \n(x)  \na taxpayer who qualifies for exemption under clause (133) of Part-I of this Schedule, in respect \nof income from export of computer software or IT services or IT enabled services; \n(xi)  a resident person engaged in the business of shipping who qualifies for application of \nreduced rate of tax on tonnage basis as final tax under clause (21) of Part II of the \nSecond Schedule; \n(xii)  a venture capital company, venture capital fund and Private Equity and Venture \n\n\f\nSecond Schedule – Part IV____ __________________________ \n633 \n \n1[(11A) \nThe provisions of section 113, regarding minimum tax, shall not apply to,-  \n \n(i)  \nNational Investment (Unit) Trust or a collective investment scheme \nauthorized or registered under the Non-banking Finance Companies \n(Establishment and Regulation) Rules, 2003 or a real estate \ninvestment trust approved and authorized under the Real Estate \nInvestment Trust 2[“Regulations, 2015”], 3[or a pension fund registered \nunder the Voluntary Pension System Rules, 2005] or any other \ncompany in respect of turnover representing transactions in shares, \nor securities listed on a registered stock exchange;  \n \n(ii)  \npetroleum dealers, in so far as they relate to turnover on account of \nsale of petroleum and petroleum products, notwithstanding their \nstatus as a company, a registered firm or an individual, engaged in \nretail sale of petroleum and petroleum products through petrol pumps \nfor the purposes of assessment of their income and determination of \ntax thereon: \n \nProvided that this exemption shall not apply to the sale of \npetroleum and petroleum products through petrol pumps which are \ndirectly operated or managed by companies engaged in distribution of \npetroleum and petroleum products. \n \nExplanation.-  For the removal of doubt it is declared that the \ncompanies engaged in distribution of petroleum and petroleum \nproducts other than through petrol pumps shall not be entitled to the \nbenefits of this exemption; \n(iii)  \nHub Power Company Limited so far as they relate to its receipts on \naccount of sale of electricity; \n \n                                            \nCapitalFund] which is exempt under clause (101) of Part-I of this Schedule; \n(xiii)  a Modaraba registered under the Modaraba Companies and Modaraba (Floatation \nand Control) Ordinance, 1980 (XXXI of 1980); \n(xiv)  Corporate and Industrial Restructuring Corporation (CIRC); \n(xv)  a Small Company as defined in section 2;  \n(xvi)  The corporatized entities of Pakistan Water and Power Development Authority, so far \nas they relate to their receipts on account of sales of electricity, from the date of their \ncreation upto the date of completion of the process of corporatization i.e. till the tariff \nis notified; and  \n(xvii)  a morabaha bank or a financial institution approved by  the State Bank of Pakistan or \nthe Securities and Exchange Commission of Pakistan (SECP), as the case may be, \nfor the purpose of Islamic Banking and Finance in respect of turnover under a \nmorabaha arrangement; and  \n(xviii) WAPDA First Sukuk Company Limited.” \n1Inserted by the Finance Act, 2009. \n2 The word and figure “Rules, 2006” substituted by the Finance Act, 2015. \n3 Inserted by the Finance Act, 2011. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n634 \n \n1[    ] \n \n(v) \ncompanies, qualifying for exemption under clause (132)2[3[ ] ]of Part-I \nof this Schedule, in respect of receipts from sale of electricity; \n \n(vi)  Provincial Governments and Local Governments, qualifying for \nexemption under section 49 and other Government bodies which are \notherwise exempt from income tax: \n \nProvided that nothing shall be construed to authorize any refund \nof tax already paid or the collection of any outstanding demand \ncreated under the said section; \n \n \n(vii)  Pakistan Red Crescent Society; \n \n(viii) special purpose, non-profit companies engaged in securitizing the \nreceivables of Provincial Governments; \n \n \n4[    ] \n \n \n [    ] \n \n(xi)  \na resident person engaged in the business of shipping who qualifies \nfor application of reduced rate of tax on tonnage basis as final tax \nunder clause (21) of Part II of the Second Schedule; \n \n(xii)  a venture capital company, venture capital fund and Private Equity \nand Venture Capital Fund which is exempt under clause (101) of Part-\nI of this Schedule; \n \n5[   ] \n \n                                            \n1Sub-clause (iv) omitted by the Finance Act, 2015. The omitted sub-clause (iv) read as follows:- \n“(iv) \nKotAddu Power Company Limited (KAPCO) for the period it continues to be entitled to \nexemption under clause (138) of Part-I of this Schedule;” \n2The words  and brackets “and clause (132B)” inserted by the Finance Act, 2014. \n3The word “and (132B)” omitted by the Finance Act, 2015. \n4 Sub-clauses (ix) and (x) omitted by the Finance Act, 2021. The omitted sub-clauses read as   follows: \n“(ix)  \nnon-profit organizations approved under clause (36) of section 2 or clause (58) or included \nin clause (61) of Part-I of this Schedule; \n \n(x)  \na taxpayer who qualifies for exemption under clause (133) of Part-I of this Schedule, in \nrespect of income from export of computer software or IT services or IT enabled services;” \n5Sub-clause (xiii) substituted though Finance Act 2020 dated 30th June, 2020 the substituted sub-\nclause read as follows: “(xiii) a Modaraba registered under the Modaraba Companies and Modaraba \n(Floatation and Control) Ordinance, 1980 (XXXI of 1980);” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n635 \n \n  \n1[    ] \n \n \n(xiv)  Corporate and Industrial Restructuring Corporation (CIRC); \n \n2[    ] \n \n(xvi) a morabaha bank or a financial institution approved by the State  Bank \nof Pakistan or the Securities and Exchange Commission of Pakistan \n(SECP), as the case may be, for the purpose of Islamic Banking and \nFinance in respect of turnover under a morabaha arrangement; 3[    ] \n \n \n(xvii)  WAPDA First Sukuk Company Limited4[“; and”] \n \n5[  ] \n \n6[    ]  \n \n7[“(xviii) Pakistan International Sukuk Company Limited.”] \n \n8[“(xix) Second Pakistan International Sukuk Company Limited.”] \n \n(xix)  LNG Terminal Operators and LNG Terminal Owners. \n \n(xx)  taxpayers located in the most affected and moderately affected areas \nof Khyber Pakhtunkhwa, FATA and PATA for tax year 2010, 2011 and \n2012 excluding manufacturers and suppliers of cement, sugar, \nbeverages and cigarettes. \n \n(xxi)  Rice Mills for the Tax Year 2015. \n \n(xxii)  taxpayers qualifying for exemption under clauses (126I) of Part-I of \nthis Schedule in respect of income from manufacture of equipment \nwith dedicated use for generation of renewable energy. \n \n                                            \n1 Sub-clause (xiii) omitted by the Finance Act, 2021. The omitted sub-clauses read as follows: \n“(xiii) a modaraba qualifying for exemption under clause (100) of Part-I of this Schedule.” \n2 Sub-clause (xv) omitted by the Finance Act, 2021. The omitted sub-clause read as follows: \n“(xv) The corporatized entities of Pakistan Water and Power Development Authority, so far as they \nrelate to their receipts on account of sales of electricity, from the date of their creation upto the \ndate of completion of the process of corporatization i.e. till the tariff is notified;” \n3The word “and” omitted by the Finance Act, 2015. \n4Full stop substituted by Finance Act, 2015. \n5 Clauses (xviii), (xix), (xx), (xxi), (xxii), (xxiii), (xxiv) and (xxv) added by the Finance Act, 2015. \n6 Sub-clause (xviii) omitted by the Finance Act, 2021. The omitted sub-clauses read as follows: \n“(xviii)  companies, qualifying for exemption under clause (132B) of Part-I of this Schedule, in \nrespect of receipts from a coal mining project in Sindh, supplying coal exclusively to power \ngeneration projects.” \n7Inserted by S.R.O. 1029(I)/2014 date 19.11.2014. \n8Inserted by S.R.O. 1029(I)/2014 date 19.11.2014. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n636 \n \n(xxiii) taxpayers qualifying for exemption under clauses (126J) of Part-I of \nthis Schedule in respect of income from operating warehousing or cold \nchain facilities for storage of agriculture produce. \n \n(xxiv) taxpayers qualifying for exemption under clauses (126K) of Part-I of \nthis Schedule in respect of income from operating halal meat \nproduction, during the period mentioned in clause (126K). \n \n(xxv)  taxpayers qualifying for exemption under clauses (126L) of Part-I of \nthis Schedule in respect of income from a manufacturing unit set up \nin Khyber Pukhtunkhwa Province between 1st day of July, 2015 and \n30th day of June, 20181[; and] ] \n \n2[“(xxvi) China Overseas Ports Holding Company Limited, China Overseas \nPorts Holding Company  Pakistan (Private) Limited, Gwadar \nInternational Terminal Limited, Gwadar Marine Services Limited and \nGwadar Free Zone Company Limited for a period of twenty three  \nyears, with effect from the sixth day of February, 2007.”] \n \n \n3[(xxvii) companies, qualifying for exemption under clause (126M) of Part-I of \nthis Schedule, in respect of profits and gains derived from a \ntransmission line project.”] \n \n \n \n4[“(xxviii) Third Pakistan International Sukuk Company Limited.”] \n \n       5[    ] \n \n \n6[    ] \n \n \n       7[(xxx)   taxpayers qualifying for exemption under clause  (126)  of  Part-I  of  \nthis Schedule with effect from the tax year 2014.] \n \n8[(xxxi) National Disaster Risk Management Fund. \n \n (xxxii) Deposit Protection Corporation established under sub-section (1) of \nsection 3 of the Deposit Protection Corporation Act, 2016 (XXXVII of \n2016).  \n \n                                            \n1Inserted by the Finance Act, 2016 \n2Inserted by the Finance Act, 2016 \n3Inserted by the Finance Act, 2016 \n4Inserted by the Finance Act, 2018. \n5Added by the Finance Act, 2017. \n6 Sub-clause (xxix) omitted by the Finance Act, 2021. The omitted sub-clause read as follows: \n“((xxix) start-up as defined in clause (62A) of section 2.]” \n7Inserted by the Finance Act, 2018 \n8New Subclauses shall be added through Finance Supplementary (Second Amendment) Act, 2019. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n637 \n \n \n(xxxiii) SARMAYA-E-PAKISTAN LIMITED.  \n \n \n(xxxiv) Green field industrial undertaking qualifying for exemption under \nclause (126O) of Part I of the Second Schedule:] \n \n \n1[(xxxv) The Prime Minister’s COVID-19 Pandemic Relief Fund-2020; \n \n(xxxvi) the Federal Government Employees Housing Authority and Naya \nPakistan Housing and Development Authority for the tax year 2020 \nand the following four tax years; \n \n(xxxvii) Hajj Group Operators in respect of turnover relating to Hajj operations \nfor the tax year 2021; \n \n(xxxviii) A resident company engaged in hotel business in Pakistan in \nrespect of turnover for the period starting on the first day of April, \n2020 and ending on the thirtieth day of September, 2020.] \n \n2[(xxxix) Islamic Naya Pakistan Certificates Company Limited (INPCCL);  \n  \n(xl) \nreceipts from sale of electricity produced from a bagasse and biomass \nbased cogeneration power project qualifying for exemption under \nclause (132C) of Part-I of this Schedule;  \n  \n(xli) \nNational Power Parks Management Company (Private) Limited or \ndemerged entities of National Power Parks Management Company \n(Private) Limited commencing from the commercial operation dates \nand continuing after the date of change of ownership as a result of \nprivatization by the Privatization Commission of Pakistan.”;  \n  \n3[    ] \n \n(xliii) \nPersons qualifying for exemption under clause 4[(126E) and (126EA)] \nof Part I of this Schedule;  \n  \n(xliv) \nPersons mentioned in Table I of clause (66) of Part I of Second \nSchedule.] \n \n 5 [(xlv)  Mobile phone manufacturers engaged in the local manufacturing of \nmobile phone devices.] \n                                            \n1New sub-clauses inserted through Finance Act, 2020 dated 30th June, 2020. \n2 Clauses (xxxix), (xl), (xli), (xlii), (xliii) and (xliv) added by the Finance Act, 2021. Earlier sub-clause \n(xxxix) wad added through Tax Laws (Amendment) Ordinance, 2021. \n3 Sub-clause (xlii) omitted by the Finance Act, 2022.  The omitted sub-clause read as follows: \n   “(xlii) Persons qualifying for exemption under clause (126E) of Part I of this Schedule for tax year \n2021 and onwards;”  \n4 The expression “(126EA)” substituted by the Finance Act, 2024.   \n5 Sub-clause (xlv) added by the Finance Act, 2022.  \n\n\f\nSecond Schedule – Part IV____ __________________________ \n638 \n \n \n 1 [(xlvi) The Prime Minister's Relief Fund for Flood, Earthquake and Other \nCalamities with effect on and from the 5th August, 2022.]  \n \n2[(11B) \nThe provisions of section 150 shall not apply in respect of inter-\ncorporate dividend within the group companies entitled to group taxation under \nsection 59AA 3[  ] 4[“subject to the condition that the return of the group has been \nfiled for the latest completed tax year”].] \n \n5[(11C) \nThe provisions of section 151 shall not apply in respect of inter-\ncorporate profit on debt within the group companies entitled to group taxation \nunder section 59AA 6[  ] 7[“subject to the condition that the return of the group has \nbeen filed for the latest completed tax year”].] \n \n8[(11D) The provisions of section 113C shall not apply to LNG Terminal Operators \nand LNG Terminal Owners.”] \n \n9[(11E) The provisions of clause (b) of sub-section (1) of section 153 shall not apply \nto payments received by Sui Southern Gas Company Limited and Pakistan  LNG \nTerminal Limited from Sui Northern Gas Pipelines Limited on account of   re-\ngasification charges.] \n \n10[(12)  \n(a)  \nThe provisions of clause (l) of section 21 and clause (a) of sub-section \n(1) of section 153 shall not apply where agricultural produce is purchased directly \nfrom the grower of such produce subject to provision of a certificate by the grower \nto the withholding agent in the following format, namely:— \n \n \n \nCERTIFICATE TO BE FILED BY THE GROWER OF  \nAGRICULTURAL PRODUCE \n \n \n \nIt is certified that I …………………………. Holder of CNIC Number  \n                                            \n1 Sub-clause (xlvi) added by the Finance Act, 2023. Earlier sub-clause (xlvi) was added through S.R.O. \n1590(I)/2022 dated 23.08.2022. \n2Added by the Finance Act, 2012. \n3The words “or section 59B” omitted by the Finance Act, 2016. \n4 Clauses (xxxix), (xl), (xli), (xlii), (xliii) and (xliv) added by the Finance Act, 2021. \n5Added by the Finance Act, 2012. \n6The words “or section 59B” omitted by the Finance Act, 2016. \n7Substituted by the Finance Act, 2015. \n8 Inserted by the Finance Act, 2015. \n9Inserted by the Finance Act, 2018 \n10Added by S.R.O. 787(I)/2011, dated 22.08.2011. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n639 \n \n…………………………………… have sold following agricultural produce, namely: \n \ni) \nname of agricultural produce (wheat, rice, cotton, sugarcane, etc. \n………………………………………………….. \n \nii)  \nquantity ……………………………………….. \n \niii)  \ntotal price ……………………………………... \n \niv)  \nland identification (if any) …………………… \n \n \nto Mr / M/s ………………………………………. on (date) ……………………. and \nbeing the grower / producer of the said agricultural produce and owner of \nagricultural land area measuring (optional) …………………………… located in \n………………………………. I am not liable to any Withholding Income Tax. \n \n \n \n \n \n \n \nSignature / Thumb impression  ………………………………….. \n \n \n \nName ……………………………………………………………….. \n \n \n \nCNIC ………………………………………………………………… \n \n \n \nAddress …………………………………………………………….. \n \nDate……………………………. \n \n(b)  \nthe provisions of clause (a) of sub-section (1) of section 153 shall not \napply only in case of cash payments made for meeting the incidental \nexpenses of a business trip to the crew of oil tanker. This exemption \nshall not apply in case of any other payments made by owners of oil \ntankers; and \n \n1[(12A) The provisions of section 150 shall not apply to dividend paid to \nTransmission Line Projects under Transmission Line Policy 2015.] \n \n2[(12B) The provisions of section 148 shall not apply to the import of following \ngoods for a period commencing from 20th day of March, 2020 and ending on 3[ ]  \n4[31st day of December, 2021]]. \nTABLE \n \nS. No. \nDescription \nPCT \n(1) \n(2) \n(3) \n1. \nReal-time PCR system (standard 96-well plate and 0.2ml tubes format, \n5 channel) \n                                            \n1Inserted by the Finance Act, 2018 \n2New clause (12B) inserted though Finance Act, 2020 dated 30th June, 2020 \n3 The expression “30th day of September, 2020” substituted by the Finance Act, 2021. Earlier this \nsubstituted by the SRO 1241(I)/2020 dated 20.11.2020.  \n4 The expression “30th day of June, 2021” substituted by the Finance Act, 2022. Earlier this substitution \nwas made through SRO 1008(I)/2021 dated 09.08.2021.  \n\n\f\nSecond Schedule – Part IV____ __________________________ \n640 \n \n2. \nBiosafety Cabinet \nRespective \nHeadings.\"; \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \nRespective \nHeadings.\"; \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n3. \nAuto Clave 50 Liter Capacity \n4. \nMulti channel pipette (0.5-10 µl) \n5. \nSingle channel pipette \na) 2 µl b) 10 µl c) 200 µl d) 1000 µl \n6. \nMuti channel pipette 20-200 ml \n7. \nVacuum fold \n8. \nMicro Centrifuge (Non-refrigerated, Rotor capacity: 12 x 1.5 / 2.0 ml \nvessels, 2 x PCR strip, Max. speed: 12,100 x g (13,400 rpm)) \n9. \nPCR Cabinet (HEPA filter system, UV and white light) \n10 \nReal-time PCR kit for the detection of Coronavirus (SARS-CoV-2) \n11 \nViral RNA Extraction Kit and machine (Automatic Extractors) \n12 \nVTM (Viral Transport Medium) \n13 \nDr Oligo Synthesizer \n14 \nRefrigerator/freezer (-20 ºC) \n15 \nVortex Machine \n16 \nRefrigerated Centrifuge Machine (Rotor capacity 1.5ml x 24, max. \nspeed 14000 rpm) \n17 \nUPS (6 KVA) \n18 \nTyvek Suits \n19 \nN-95 \n20 \nBiohazard Bags (18 Liters) \n21 \nPAPR (Powdered Air Purifying respirators) \n22 \nMultimode ventilator with air compressor \n23 \nVital sign monitor with 2IBPand ETco2 two Temp. \n24 \nICU motorized patient bed with side cabinet and over bed table \n25 \nSyringe infusion pump \n26 \nInfusion pump \n27 \nElectric suction machine \n28 \nDefibrillator \n29 \nX-Ray Mobile Machine \n30 \nSimple Nebulizer \n31 \nUltrasound machine \n32 \nNoninvasive BIPAP \n33 \nECG Machine \n34 \nPulse Oximeters \n35 \nRipple mattress \n36 \nBlood gas analyzer \n37 \nAMBU Bag \n38 \nNitrile Gloves \n39 \nLatex Gloves \n40 \nGoggles \n41 \nFace Shields \n\n\f\nSecond Schedule – Part IV____ __________________________ \n641 \n \n42 \nGum Boots \n \n \n \n \n \n \n \n \n \nRespective \nHeadings.\"; \n43 \nMackintosh bed sheets \n44 \nSurgical Masks \n45 \nAir Ways \n46 \nDiaflow \n47 \nDisposible Nebulizer Mask Kit \n48 \nECG Electrodes \n49 \nETT Tube (Endotracheal Tubes) All sizes \n50 \nHumidifier Disposable Flexible \n51 \nIV Cannula all sizes \n52 \nIV Chambers \n53 \nOxygen Recovery Kit \n54 \nPadded Sheets \n55 \nStomach Tube \n56 \nStylet for Endotracheal Tube \n57 \nSuction Tube control valve \n58 \nTracheostomy Tube 7, 7.5, 8 \n59 \nVentilator Circuit \n60 \nVentury Masks \n61 \nDisposable shoes cover (water proof) \n \n1[(12BA) The provisions of section 148 shall not apply on import of thirty million \nadult 3xPly Knit face masks received as humanitarian assistance from M/s HANES \nBrands Inc. North Carolina, USA for distribution within the population of Lahore \nDivision, Government of the Punjab.] \n   \n2[(12C) The provision of section 148 shall not apply to persons importing pulses \nfor a period commencing from the 7th day of April, 2020 and ending on 30th \nSeptember, 2020. \n \n(12D)  The provisions of section 148 shall not apply on   the import of finished drug \nRemdesivir 100 mg injection and injectable solution 100 mg vial for the period \nstarting from the 22nd day of June, 2020 and ending on the date as may be notified \nby the Board in the official Gazette on recommendation of the National Health \nServices, Regulation and Coordination Division. \n \n(12E) The provisions of section 148 shall not apply to persons on import of \nmedicines for treatment of life threatening rare diseases not manufactured in \nPakistan, subject to the following conditions, namely:— \n \n                                            \n1New clause (12BA) added by the Finance Act 2022. Earlier this addition was made through SRO \n1009(I)/2021 dated 09.08.2021. \n2New clauses (12C), (12D) and (12E) inserted through Finance Act 2020 dated 30th June, 2020 \n\n\f\nSecond Schedule – Part IV____ __________________________ \n642 \n \n(i) \nthe import is approved by the Board, through notification in the official \nGazette; \n \n(ii) \nthe specification and quantity of medicine is recommended by the National \nHealth Services, Regulation and Coordination Division in a prescribed \nformat on a case to case basis; and \n \n(iii) \nsuch medicine is required for the personal use of the importing person or his \nimmediate family member: \n \nProvided that where circumstances exist to take immediate action in \nemergency situations, the Board may, on recommendation of a provincial health \ndepartment or a tertiary care hospital of the Federal or Provincial Government, \nprovisionally allow import of such quantity of medicine under this clause which \ndoes not exceed sixty days usage.] \n \n1[  ] \n \n2[  ] \n \n3[  ] \n \n(12H)  (a) The provisions of section 148 shall not apply on import of following goods \nfor a period of three months starting from the 23rd of June, 2020, namely:— \n \nS. No. \nDescription \nPCT Code \n(1) \n(2) \n(3) \n1. \nOxygen gas \n2804.4000 \n2. \nCylinders (for oxygen gas) \n7311.0090 \n3. \nCryogenic tanks (for oxygen gas) \n7311.0030 \n(b) \nthe concessions given in this clause shall also apply in respect of the \nletters of credit opened or goods declaration forms filed on or after the \n23rd June, 2020;  \n  \n                                            \n1 Clauses (12F), (12G), (12H), (12I), (12J), (112K), (12L), (12M) and (12N) added by the Finance Act, \n2021. Earlier these clauses were inserted through SROs 642(I)/2020 dated 28.07.2020, 750(I)/2020 \ndated 20.08.2020, 772(I)/2020 dated 24.08.2020, 922(I)/2020 dated 29.09.2020, 99(I)/2021 dated \n26.01.2021, 132(I)/2021 dated 03.02.2021, 235(I)/2021 dated 23.02.2021 (read with corrigendum \ndated 17.05.2021), 589(I)/2021 dated 25.05.2021 respectively. \n2 Clause (12F) omitted by the Finance Act, 2025. The omitted clause read as follows: \n“(12F) The provision of section 148 shall not apply on import of 1.5 million tons of wheat having PCT \nHeading 1001.1900 and 1001.9900 in pursuance of Cabinet Decision in case No.399/23/2020 dated \nthe 16th June, 2020;” \n \n3 Clause (12G) omitted by the Finance Act, 2025. The omitted clause read as follows: \n“(12G) The provisions of section 148 shall, in pursuance of the Cabinet Decision in case No.  \n541/30/2020 dated the 4th August, 2020, not apply on import by the Trading Corporation of Pakistan \nof 300,000 metric tons of white sugar having PCT heading 1701.9910,1701.9920, specification B;” \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n643 \n \n(12I) The provisions of section 148 shall not apply on import of 83 X Micron \nsprayers for Anti-Locust Operation (Respective heading) by National Disaster \nManagement Authority (NDMA).  \n  \n1[  ]  \n \n(12K) (a) The provisions of section 148 shall not apply on import of following goods \nby the manufacturers of oxygen for a period of three months starting from the 25th \nday of December, 2020, namely:— \n \nS. No. \nDescription \nPCT Code \n(1) \n(2) \n(3) \n1. \nCryogenic Tanks (for oxygen Gas) \n7311.0030 \n \n(b) \nthe concessions given in this clause shall also apply in respect of the \nletters of credit opened or goods declaration forms filed on or after the \n25th day of December, 2020;  \n  \n(12L) The provisions of section 148 and 153 shall not apply on import and \nsubsequent supply of five hundred thousand metric tons of white sugar imported \nby the Trading Corporation of Pakistan;  \n  \n(12M) The provisions of section 148 shall not apply on import of following goods \nfor a period of one hundred and eighty days starting from the 14th day of May, \n2021, namely:— \n \nS. No. \nDescription \nPCT Code \n(1) \n(2) \n(3) \n1. \n- Oxygen  \n2804.4000 \n2. \n- - - Other (Oxygen Cylinders) \n7311.0090 \n3. \n- - - For Cryogenic (Tanks/Vessels) \n7311.0030 \nOxygen \nConcentrators/Generators/Manufacturing \nPlants of all specifications and capacities. \nRespective headings. \n \n(12N) Border sustenance markets—  \n  \n(a) \nThe provisions of section 148 shall not apply on the import of goods \nwhich takes place within the jurisdiction of Border sustenance markets \nspecified in Table-I below:— \n \n \nTABLE-I \n \n                                            \n1 Clause (12J) omitted by the Finance Act, 2025. The omitted clause read as follows: \n   “(12J) The provisions of section 148 shall, in pursuance of the Cabinet Decision in case No. \n34/02/2021, dated the 12th January, 2021, not apply on import of three hundred thousand metric \ntons of wheat through tendering process by the Trading Corporation of Pakistan;” \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n644 \n \n \n \nPCT \nHeading  \n \n1. \n07011000 \n -SEED (Potatoes) \n2. \n07020000 \nTOMATOES, FRESH OR CHILLED. \n3. \n07031000 \n-ONIONS AND SHALLOTS \n4. \n07032000 \n-GARLIC \n5. \n07049000 \n-OTHERS which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n6. \n07061000 \n-CARROTS AND TURNIPS \n7. \n07070000 \nCUCUMBERS AND GHERKINS FRESH OR  \nCHILLED. \n8. \n07081000 \n-PEAS (PISUM SATIVUM) \n9. \n07082000 \n-BEANS (VIGNA SPP., PHASEOLUS SPP.) \n10. \n07089000 \n-OTHER LEGUMINOUS VEGETABLES \n11. \n07131000 \n- Peas (Pisum sativum) \n12. \n07132010 \nGrams (Dry/Whole) \n13. \n07132090 \n---other- \nwhich \nqualifies \nfor \nexemption \nor \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n14. \n07133100 \n-- Beans of the species Vigna mungo (L.) Hepper or \nVigna radiata (L.) Wilczek \n15. \n07133200 \n-- small red (Adzuki) beans (Phaseolus or Vigna \nangularis) \n16. \n07133300 \nKidney beans including white beans \n17. \n07133400 \n-- Bambara – vigna subteranea or vaahdzeia \nsubterrea \n18. \n07133500 \n- - Cow peas (Vigna unguiculata) \n19. \n07133990 \n-- Other which qualifies for exemption or concession \nor reduced rate  under the provisions of Customs \nAct, 1969 and Sales Tax Act, 1990 or Federal \nExcise Act, 2005 for Border Sustenance Markets \n20. \n07134010 \n - Lentils (Dry Whole) \n21. \n07135000 \n- Broad beans (Vicia faba var. major) and horse \nbeans (Vicia faba var. equina, Vicia faba var. minor) \n22. \n07136000 \n- Pigeon peas (cajanus cajan)  \n23. \n07139090 \n- Other which qualifies for exemption or concession \nor reduced rate  under the provisions of Customs \nAct, 1969 and Sales Tax Act, 1990 or Federal \nExcise Act, 2005 for Border Sustenance Markets \n\n\f\nSecond Schedule – Part IV____ __________________________ \n645 \n \n24. \n09051000 \nVanilla (Neither crushed nor ground) \n25. \n09061100 \nCinnamon  \n26. \n09061900 \nOther (Cinnamon And Cinnamon Tree Flowers) \n27. \n09071000 \n - - Neither crushed nor ground (Cloves) \n28. \n09072000 \n - - Crushed or ground (Cloves) \n29. \n09081100 \n - - Neither Crushed nor ground (Nutmeg) \n30. \n09081200 \n - - Crushed or ground (Nutmeg) \n31. \n09082100 \n - - Neither crushed nor ground (Maze) \n32. \n09082200 \n - - Crushed or ground (Maze) \n33. \n09083110 \n - - - Large (Cardammoms) \n34. \n09083120 \n - - - Small (Cardammoms) \n35. \n09083200 \n - - Crushed or ground (Cardammoms) \n36. \n09092100 \n  - - Neither crushed nor ground (Coriander) \n37. \n09092200 \n - - Crushed or ground (Coriander) \n38. \n09093100 \n - - Neither crushed nor ground (Seeds of Cumins) \n39. \n09093200 \n - - Crushed or ground (Seeds of Cumins) \n40. \n09096100 \n - - Neither crushed nor ground (Seeds of Anise, \nBadian, Caraway, Fennel etc) \n41. \n09096200 \n - - Crushed or ground (Seeds of Anise, Badian, \nCaraway, Fennel etc) \n42. \n09109910 \n- - - THYME; BAY LEAVES \n43. \n10031000 \nBarley (Seeds) \n44. \n10039000 \nOther (Barley) \n45. \n12060000 \nSunflower seeds ,whether or not broken \n46. \n12129200 \nLocust beans  \n47. \n12130000 \nCereal straws and husks \n48. \n15161000 \nAnimal Fats and Oil and their fractions \n49. \n15162010 \nVegetable Fats and their fractions \n50. \n15162020 \nVegetable Oils and their fractions \n51. \n82089010 \n- - - Knives and cutting blades for paper and paper \nboard \n52. \n04011000 \n -OF A FAT CONTENT, BY WEIGHT, NOT \nEXCEEDING 1 % (Milk and Cream) \n53. \n04012000 \n -OF A FAT CONTENT, BY WEIGHT, EXCEEDING \n1 % BUT NOT EXCEEDING 6 % (Milk and Cream) \n54. \n04014000 \n - Of a fat content, by weight, exceeding 6 % but not \nexceeding 10% (Milk and Cream) \n55. \n04015000 \n - Of a fat content, by weight, exceeding 10 % (Milk \nand Cream) \n56. \n07039000 \n-LEEKS \nAND \nOTHER \nALLIACEOUS \nVEGETABLES \n57. \n07041000 \n-CAULIFLOWERS AND HEADED BROCCOLI \n58. \n07042000 \n-BRUSSELS SPROUTS \n59. \n07051100 \n- - CABBAGE LETTUCE (HEAD LETTUCE) \n\n\f\nSecond Schedule – Part IV____ __________________________ \n646 \n \n60. \n07051900 \n- - OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n61. \n07052100 \n- - WITLOOF CHICORY (CICHORIUM INTYBUS \nVAR.FOLIOSUM) \n62. \n07052900 \n- - OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n63. \n07069000 \n-OTHER \nwhich \nqualifies \nfor \nexemption \nor \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n64. \n07096000 \nFruits of the genus Capsicum or of the genus \nPimenta \n65. \n08042000 \nFigs \n66. \n08061000 \n -FRESH (Grapes) \n67. \n08062000 \n ---DRIED (Grapes) \n68. \n08071100 \n- - WATERMELONS \n69. \n08071900 \n- - OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n70. \n08081000 \n-APPLES \n71. \n09021000 \nGreen Tea \n72. \n09022000 \nOther Green Tea \n73. \n09101200 \n - - Crushed or ground (Ginger) \n74. \n09103000 \n-TURMERIC (CURCUMA) \n75. \n09109990 \n- - - OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n76. \n17021110 \nLactose (Sugar ) \n77. \n17021120 \n- - - Lactose syrup \n78. \n17021900 \n- - OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n79. \n17029020 \n- - - CARAMEL \n\n\f\nSecond Schedule – Part IV____ __________________________ \n647 \n \n80. \n23040000 \nOIL-CAKE AND OTHER  SOLID RESIDUES, \nWHETHER OR NOT GROUND OR IN THE FORM \nOF \nPELLETS, \nRESULTING \nFROM \nTHE \nEXTRACTION OF SOYA BEAN OIL. \n81. \n23099000 \nOther (animal feed) \n82. \n52042010 \n --- FOR Sewing (Thread) \n83. \n52042020 \nFor embroidery (Thread) \n84. \n82011000 \n- Spades and shovels \n85. \n82055900 \nOther (Tools for masons, watchmakers, miners and \nhand tools nes) \n86. \n82083000 \n- For kitchen appliances or for machines used by the \nfood industry \n87. \n82089090 \n- - - Other which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n88. \n04031000 \n-YOGURT \n89. \n07019000 \nOther (Potatoes) \n90. \n07104000 \n- Sweet corn \n91. \n07109000 \n- Mixtures of vegetables  \n92. \n08041010 \nFresh (Dates) \n93. \n08041020 \nDried (Dates) \n94. \n08091000 \n-APRICOTS \n95. \n08092100 \n- - Sour cherries (Prunus cerasus) \n96. \n08092900 \n- - Other which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n97. \n08093000 \n-PEACHES, INCLUDING NECTARINES \n98. \n08094000 \n-PLUMS AND SLOES \n99. \n08101000 \nStrawberries \n100. \n08105000 \nKiwi Fruit \n101. \n09101100 \n - - Neither crushed nor ground (Ginger) \n102. \n10011900 \nOther (Durum wheat (excl. seed for sowing)) \n103. \n10019900 \nOther (Wheat and meslin (excl. seed for sowing, \nand durum wheat)) \n104. \n11010010 \nOf Wheat (Flour) \n105. \n11010020 \nOf Meslin (Flour) \n106. \n19021920 \n- - - VERMACELLI \n107. \n19059000 \nOther (Packed Cake) \n108. \n20071000 \nHomogenised perparations  \n109. \n20079100 \nCitrus Fruit  \n\n\f\nSecond Schedule – Part IV____ __________________________ \n648 \n \n110. \n20079900 \nOther which qualifies for exemption or concession \nor reduced rate  under the provisions of Customs \nAct, 1969 and Sales Tax Act, 1990 or Federal \nExcise Act, 2005 for Border Sustenance Markets \n111. \n34013000 \n-ORGANIC SURFACE-ACTIVE PRODUCTS AND \nPREPARATIONS FOR WASHING THE SKIN, IN \nTHE FORM OF LIQUID OR CREAM AND PUT UP \nFOR RETAIL SALE, WHETHER OR NOT  \nCONTAINING SOAP \n112. \n34022000 \n- Preparations put up for retail sale \n113. \n34029000 \n---- Other which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n114. \n69111090 \nOthers (Tableware and kitchenware of porcelain or \nchina) \n115. \n69119000 \nOther (Household articles nes & toilet articles of \nporcelain or china) \n116. \n70134900 \nOther (Glassware for table or kitchen purposes \n(excl. glass having a linear c) \n117. \n70139900 \nOther (Glassware nes (other than that of 70.10 or \n70.18)) \n118. \n82159910 \n- - - Spoons \n119. \n82159990 \nOther (Tableware articles not in sets and not plated \nwith precious meta)l \n120. \n87120000 \nBicycles and other cycles (including delivery \ntricycles), not motorised.  \n121. \n96170010 \n- - - Vacuum flasks \n122. \n96170020 \n- - - OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions of \nCustoms Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n \n(b) The provisions of section 154 shall not apply to the export of goods which \ntakes place within the jurisdiction of Border sustenance markets specified \nin Table - II below:—  \n  \nTABLE-II \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n649 \n \nSr.# \nPCT \nHeading \nDescription \n1. \n02012000 \nOther cuts with bone in (Meat of bovine animals, \nfresh or chilled) \n2. \n 02013000 \nBoneless (Meat of bovine animals, fresh or chilled) \n3. \n \n02022000 \nOther cuts with bone in (Meat of bovine animals, \nfrozen) \n4. \n 02023000 \nBoneless (Meat of bovine animals, frozen) \n5. \n 03021100 \nFish \n6. \n 04090000 \nHoney \n7. \n 06022000 \nPlants \n8. \n 07011000 \n -SEED (Potatoes) \n9. \n 07019000 \nOther (Potatoes) \n10.  07020000 \nTOMATOES, FRESH OR CHILLED. \n11.  07031000 \n-ONIONS AND SHALLOTS \n12.  07032000 \nGarlic \n13.  07061000 \n-CARROTS AND TURNIPS \n14.  \n07069000 \n-OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions \nof Customs Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n15.  07070000 \nCucumbers \n16.  07093000 \nEgg Plant \n17.  07096000 \nFruits of the genus Capsicum or of the genus \nPimenta (pepper) \n18.  07099900 \nOthers (Lady Finger) \n19.  07101000 \nFresh Potato \n20.  07102100 \nPea \n21.  07103000 \nSpinach \n22.  08031000 \n - Plantains (Bananas) \n23.  08039000 \n - Other  (Bananas) \n24.  08041010 \nFresh (Dates) \n25.  08041020 \nDried (Dates) \n26.  08045020 \n--- Mangoes \n27.  08052100 \n-- Mandarins (including tangerines and satsumas) \n28.  08052910 \n ---Kino (fresh) \n29.  08061000 \nGrapes (Fresh) \n30.  08071100 \n- - WATERMELONS \n31.  08071900 \nMelons \n32.  08091000 \nApricots \n33.  08092900 \nCherries \n34.  08093000 \nPeaches \n35.  08101000 \nStrawberries \n36.  08109010 \nPomegranates \n\n\f\nSecond Schedule – Part IV____ __________________________ \n650 \n \n37.  08109090 \nFresh fruits nes (Other) \n38.  08133000 \nApple \n39.  09021000 \nGreen Tea \n40.  09022000 \nOther green tea \n41.  09030000 \nMate. \n42.  09042110 \nRed Chillies (Whole) \n43.  \n09042190 \n--- Other which qualifies for exemption or \nconcession or reduced rate  under the provisions \nof Customs Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n44.  09042210 \nRed Chillies (Powder) \n45.  \n09042290 \n--- Other which qualifies for exemption or \nconcession or reduced rate  under the provisions \nof Customs Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n46.  09051000 \n - - Neither crushed nor ground (Vanilla) \n47.  09052000 \n - - Crushed or ground (Vanilla) \n48.  10061010 \n - - - SEED FOR SOWING (Rice) \n49.  \n10061090 \n- - - OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions \nof Customs Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n50.  10062000 \n-HUSKED (BROWN) RICE \n51.  10063010 \n - - - BASMATI (Rice) \n52.  \n10063090 \n- - - OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions \nof Customs Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n53.  10064000 \n-BROKEN RICE \n54.  11010010 \nFlour (of Wheat) \n55.  12074000 \n- Sesamum seeds \n56.  12079900 \nOther (hemp Seeds) \n57.  12119000 \nAjwain \n58.  15162020 \nVegetable Oils and their fractions \n59.  19021920 \n- - - VERMACELLI \n60.  19041090 \nPapad \n61.  20071000 \n- Homogenised preparations \n62.  20081900 \n  --Nimko \n63.  21069090 \n - - - OTHER (Custard Powder) \n64.  23099000 \nOther (Animal feed) \n65.  25010010 \nTable Salt \n\n\f\nSecond Schedule – Part IV____ __________________________ \n651 \n \n66.  25010020 \n --- Rock Salt \n67.  25010030 \n  --- Sea Salt \n68.  \n25010090 \n --- Other which qualifies for exemption or \nconcession or reduced rate  under the provisions \nof Customs Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n69.  34060000 \nCandles \n70.  36050000 \nSafety Match \n71.  39264090 \n -OTHER (Plastic Articles) \n72.  53101000 \nWoven fabrics of jute or of other textile bast fibres, \nunbleached \n73.  53109010 \n- - - Jute (hessian cloth) \n74.  56074100 \n- - Binder or baler twine \n75.  \n56074900 \n- - Other which qualifies for exemption or \nconcession or reduced rate  under the provisions \nof Customs Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n76.  56075000 \n- Of other synthetic fibres \n77.  58021100 \n -- Unbleached (Terry toweling in similar woven \nterry fabrics, of cotton) \n78.  58021900 \n -- Other (Terry toweling In similar woven Terry \nfabrics, OF cotton) \n79.  58022000 \n- Terry towelling and similar woven terry fabrics, of \nother textile materials \n80.  58023000 \n- Tufted textile fabrics  \n81.  58043000 \n- Hand made lace \n82.  \n58050000 \nHand-woven tapestries of the type Gobelins, \nFlanders, Aubusson, Beauvais and the like, and \nneedle-worked tapestries (for example, petit point, \ncross stitch), whether or not made up.  \n83.  58064000 \n- Fabrics consisting of warp without weft \nassembled by means of an adhesive (bolducs)  \n84.  \n59011000 \n- Textile fabrics coated with gum or amylaceous \nsubstances, of a kind used for the outer covers of \nbooks or the like \n85.  61119000 \nMix Goods/Garments (Babies garments & clothg \naccessories) \n86.  62031990 \n ---OTHER (Men or Boys Suits etc.) \n87.  62042200 \n- - Of cotton \n88.  62042900 \n- - Of other textile materials \n89.  62043900 \n- - Of other textile materials \n90.  62044210 \n- - -  Shisha embroidered dresses \n\n\f\nSecond Schedule – Part IV____ __________________________ \n652 \n \n91.  \n62129000 \n -OTHER which qualifies for exemption or \nconcession or reduced rate  under the provisions \nof Customs Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise Act, 2005 for Border Sustenance \nMarkets \n92.  63021090 \n -OTHER (Bed linen, Toilet linen etc.) \n93.  \n63051000 \nJute Bags (of jute or of other textile bast fibres of \nheading 53.03) \n94.  63052000 \nSacks and bags, for packing of goods, of cotton \n95.  63090000 \nWorn clothing and other worn articles \n96.  69111090 \nOther (Tableware and kitchenware of porcelain or \nchina) \n97.  69119000 \nOthers (Household articles nes & toilet articles of \nporcelain or china) \n98.  70133700 \nDrinking glasses (excl. glasses of glass ceramics \nor of lead crystal a \n99.  73181690 \nNuts, iron or steel, nes (Others) \n100.  82055900 \nTools for masons, watchmakers, miners and hand \ntools nes (Other) \n101.  82059000 \nHand tools (Other, including sets of articles of two \nor more subheadings of this heading) \n102.  82119100 \n- - Table knives having fixed blades \n103.  82119200 \n- - Other knives having fixed blades \n104.  82159990 \nTableware articles not in sets and not plated with \nprecious metal \n105.  84485100 \n Needle \n106.  96170010 \n- - - Vacuum flasks \n107.  \n96170020 \n- - - Other which qualifies for exemption or \nconcession or reduced rate  under the provisions \nof Customs Act, 1969 and Sales Tax Act, 1990 or \nFederal Excise  \nAct, 2005 for Border Sustenance Markets \n \nThe exemption under this clause shall be available on the import of goods \nsubject to following conditions, namely:—  \n  \n(i) \nSuch goods shall be supplied only within the limits of Border \nSustenance Markets established in cooperation with Iran and \nAfghanistan;  \n   \n \n \n(ii) \nIf the goods, on which exemption under this table has been availed, \nare brought outside the limits of such markets, income tax shall be \ncharged on the import value as per provisions of section 148 of this \nOrdinance;  \n  \n(iii) \nSuch items in case of import, shall be allowed clearance by the \n\n\f\nSecond Schedule – Part IV____ __________________________ \n653 \n \nCustoms Authorities subject to furnishing of bank guarantee equal to \nthe amount of income tax involved and the same shall be released \nafter presentation of consumption certificate issued by the \nCommissioner Inland Revenue having jurisdiction;  \n  \n(iv) \nThe said exemption shall only be available to a person upon furnishing \nproof of having a functional business premises located within limits of \nthe Border Sustenance Markets; and   \n  \n(v) \nBreach of any of the conditions specified herein shall attract relevant \nlegal provisions of the Ordinance, besides recovery of the amount of \nincome tax along with default surcharge and penalties involved.] \n \n1[   ]  \n \n2[(12O) The provisions of section 148 shall not apply on import of drones donated \nby Ministry of Agriculture and Rural Affairs (MARA), Government of China to \nPakistan through Sea Route. \n \n(12P) The provisions of section 148 shall not apply on import of machinery and \nequipment as listed in S. No 32 of Part-I of Fifth Schedule to the Customs Act, \n1969 subject to the same conditions and limitations as specified therein.] \n    \n3[   ] \n4[   ] \n5[   ] \n6[   ] \n                                            \n1 Clause (12)(c) omitted by SRO 550(I)/2012 dated 23-5-20012. The Omitted clause (12)(c) read as: \nfollows:- \n \n“(12)(c)  \nWithholding Tax under clause (a) of sub-section (1) of section 153 shall be deductible \nat one per cent on local purchase of steel scrap by those steel melters who have opted under \nSales Tax Special Procedures and are compliantly filing returns under the said scheme.” \n2 New clauses (12O) and (12P) added by the Finance Act 2022. Earlier clause (12O) was added   \nthrough SRO 1407(I)/2021 dated 29.10.2021. \n3 Clause (13) omitted by the Finance Act, 2005. The omitted clause (13) read as follows: \n“(13) The provisions of section 113 shall not apply to Hub Power Company Limited so far as they \nrelate to its receipts on account of sale of electricity.” \n4 Clause (13A) omitted by the Finance Act, 2005. The omitted clause (13A) read as follows: \n“(13A)  The provisions of section 113 shall not apply to KotAddu Power Company Limited (KAPCO) \nfor the period it continues to be entitled to exemption under clause (138) of Part-I of this Schedule.” \n5 Clause (14) omitted by the Finance Act, 2006. The omitted clause (14) read as follows:  \n“(14)  A company registered and authorized by the Federal Government to import gold and silver \nshall be liable to pay tax on import of gold at the rate of two rupees per eleven grams six hundred \nand sixty-four milligrams and five rupees per kilogram in the case of silver in accordance with the \nprovisions of section 148 and such payment of tax shall be deemed to be full and final liability of tax \nin respect of income accruing from such import including liability of tax under section 113.” \n6Clause (15) omitted by the Finance Act, 2005. The omitted clause (15) read as follows:  \n“(15)  The provisions of section 113 shall not apply to companies, qualifying for exemption under \n\n\f\nSecond Schedule – Part IV____ __________________________ \n654 \n \n \n(16)  The provisions of sections 1[113,] 148, 151, 153, 155 2[and 156] shall not \napply to the institutions of the Agha Khan Development Network (Pakistan) listed \nin Schedule 1 of the Accord and Protocol dated November 13, 1994, executed \nbetween the Government of the Islamic Republic of Pakistan and Agha Khan \nDevelopment Network: \n \nProvided that such institutions shall continue to collect and deduct tax \nunder section 3[149, 151, 152, 153, 155, 156 or 233] from others persons, \nwherever required thereunder 4[.] \n \n5[  ] \n \n6[  ] \n \n \n7[  ] \n8[  ] \n \n(19) The provisions of 9[sections 113 and] 151 shall not apply to non-residents, \n(excluding local branches or subsidiaries or offices of foreign banks, companies, \nassociations of persons or any other person operating in Pakistan), in respect of \ntheir receipts from Pak rupees denominated Government and corporate securities \nand redeemable capital, as defined in the 10[Companies Act, 2017 (XIX of 2017)], \nlisted on a registered stock exchange, where the investments are made exclusively \nfrom foreign exchange remitted into Pakistan through a Special Convertible Rupee \nAccount maintained with a bank in Pakistan. \n \n                                            \nclause (132) of Part-I of this Schedule, in respect of receipts from sale of electricity.” \n1 Inserted by the Finance Act, 2009. \n2The comma, figures and words ” ,156 and 157” substituted by the Finance Act, 2003. \n3The figure “113” substituted by the Finance Act, 2003. \n4Colon substituted by the Finance Act, 2008. \n5Clause (16A) omitted by the Finance Act, 2015. The omitted clause (16A) read as follows:- \n“(16A) The provisions of section 153(1)(b) shall not be applicable to the persons making payments \nto electronic and print media in respect of the advertising services. \n6Proviso omitted by the Finance Act, 2008. The omitted proviso read as follows: \n \n“Provided further that in respect of application of section 113, this clause shall take effect from \nthe first day of July, 1991.” \n7Clause (17) omitted by the Finance Act, 2005. The omitted clause (17) read as follows: \n“(17)  The provisions of section 113, shall not apply to Provincial Governments and local authorities, \nqualifying for exemption under section 49 and other Government or semi-Government bodies which \nare otherwise exempt from income tax: \nProvided that nothing contained in this clause shall be construe to authorize any refund of tax already \npaid or the collection of any outstanding demand created under the said section.” \n8Clause (18) omitted by the Finance Act, 2005. The omitted clause (18) read as follows: \n“(18)  The provisions of section 113 shall not apply to Pakistan Red Crescent Society.” \n9The word “section” substituted by the Finance Act, 2009. \n10 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, 2021. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n655 \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n5[  ] \n6[  ] \n7[  ] \n8[  ] \n9[  ] \n10[  ] \n11[  ]  \n                                            \n1 Clause (20) omitted by the Finance Act, 2005. The omitted clause (20) read as follows: \n“(20)  The provisions of section 113 shall not apply to special purpose, non-profit companies engaged \nin securitizing the receivables of Provincial Governments or the companies.” \n2Clause (21) omitted by the Finance Act, 2005. The omitted clause (21) read as follows: \n“(21)  The provisions of section 113 shall not apply to non-profit organisations approved under clause \n(36) of section 2 or clause (58) or included in clause (61) of Part-I of this Schedule.” \n3Clause (22) omitted by the Finance Act, 2005. The omitted clause (22) read as follows: \n“(22)  The provisions of section 113 shall not apply to a taxpayer who qualifies for exemption under \nclause (133) of Part-I of this Schedule.” \n4Clause (22A) omitted by the Finance Act, 2005. The omitted clause (22A) read as follows:  \n“ (22A) The provisions of section 113 shall not apply to a resident person engaged in the business \nof shipping who qualifies for application of reduced rate of tax on tonnage basis as final tax under \nclause (21) of Part II of the Schedule.” \n5Clause (23) omitted by the Finance Act, 2005. The omitted clause (23) read as follows: \n“(23)  The provisions of section 113 shall not apply to a venture capital company and venture capital \nfund which is exempt under clause (101) of Part-I of this Schedule.” \n6 Clause (24) omitted by the Finance Act, 2005. The omitted clause (24) read as follows: \n“(24)  The provisions of section 113 shall not apply to a modaraba registered under the Modaraba \nCompanies and Modaraba (Floatation and Control) Ordinance, 1980 (XXXI of 1980).” \n7Clause (25) omitted by the Finance Act, 2005. The omitted clause (25) read as follows: \n“(25)  Nothing in section 113 shall apply to Corporate and Industrial Restructuring Corporation \n(CIRC).” \n8 Clause (26) omitted by the Finance Act, 2005. The omitted clause (26) read as follows: \n“(26)  The provisions of section 148 shall not apply to goods or classes of goods imported by \ncontractors and sub-contractors engaged in the execution of power project under the agreement \nbetween the Islamic Republic of Pakistan and Hub Power Company Limited.” \n9 Clause (27) omitted by the Finance Act, 2005. The omitted clause (27) read as follows: \n“(27) The provisions of section 148 shall not apply to such specially equipped motor vehicle or \nsupport equipment imported by a disabled person, as is allowed by the Federal Government.” \n10Clause (28) omitted by the Finance Act, 2005. The omitted clause (28) read as follows: \n“(28)  The provision of section 148 shall not apply to in case of such goods imported into Pakistan \nas are exempt from customs duties and sales tax under Headings 9913, 9914 and 9915 of Sub-\nChapter III of Chapter 99 of First Schedule the Customs Act, 1969 (IV of 1969).” \n11Clause (29) omitted by the Finance Act, 2005. The omitted clause (29) read as follows:  \n“(29) The provisions of section 148 shall not apply to goods imported by direct and indirect exporters \ncovered under — \n(a)  Sub-Chapter 4 of Chapter XII of S.R.O. 450(I)/2001 dated 18.06.2001; \n(b)  Sub-Chapter 6 of Chapter XII of S.R.O. 450(I)/2001 dated 18.06.2001; and \n(c)  Sub-Chapter 7 of Chapter XII of S.R.O. 450(I)/2001 dated 18.06.2001;” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n656 \n \n1[  ]  \n2[  ] \n3[  ] \n4[  ] \n5[  ] \n6[  ] \n7[  ] \n8[  ] \n \n9[  ] \n \n                                            \n1Clause (30) omitted by the Finance Act, 2005. The omitted clause (30) read as follows: \n“(30) The provisions of section 148 shall not apply in respect of goods specified under Heading \n9929, Sub-Chapter VIII of Chapter 99 of the First Schedule to the Customs Act, 1969 (IV of 1969);” \n2 Clause (31) omitted by the Finance Act, 2005. The omitted clause (31) read as follows: \n“(31) The provisions of section 148shall not apply in respect of such mobile telephone sets as are \nexempt from custom duty and are charged to sales tax in the manner prescribe in the Notification \nNo. S.R.O 390(I)/2001 dated 18th June, 2001.” \n3 Clause (31A) omitted by the Finance Act, 2005. The omitted clause (31A) read as follows: \n“(31A)  The provisions of section 148 shall not apply to plant, machinery and equipment imported as \nare subject to 5% rate of customs-duty under Chapter 84 of the First Schedule to the Customs Act, \n1969 (IV of 1969), or are exempt from customs-duty or subject to a lower rate of customs-duty under \nrelevant Customs notifications.” \n4Clause (31B) omitted by the Finance Act, 2005. The omitted clause (31B) read as follows: \n“(31B)   The provisions of section 148 shall not apply in respect of agricultural tractors imported in \nCBU condition.” \n5Clause (32) omitted by the Finance Act, 2003. The omitted clause (32) read as follows: \n   “(32) The provisions of sections 149 and 152 relating to fee for technical services shall not apply to \nM/s Siddiq Sons Tin Plate Limited in respect of salaries of expatriate employees, royalty or \ntechnological and know-how fee for technical assistance for projects located in Special Industrial \nZone, Windher, Balochistan, who have established L/Cs prior to the 31st January, 1996.” \n6Clause (33) omitted by the Finance Act, 2008. The omitted clause (33) read as follows: \n“(33) The provisions of sections 151 and 233 shall not apply to any person making payment to \nNational Investment (Unit) Trust or a mutual fund established by the Investment Corporation of \nPakistan or an investment company registered under the Investment Companies and Investment \nAdvisers Rules 1971 or a unit trust scheme constituted by an Asset Management Company \nregistered under the Asset Management Companies Rules, 1995 or a real investment trust, \napproved and authorized under the Real Estate Investment Trust Rules, 2006, established and \nmanaged by a REIT management company licensed under the Real Estate Investment Trust Rules, \n2006 or a Private Equity and Venture Capital Fund.” \n7Clause (34) omitted by the Finance Act, 2005. The omitted clause (34) read as follows: \n“(34) The provision of section 151 shall not apply in respect of profit or interest paid on a Term Finance \nCertificate held by a company which has been issued on, or after, the first day of July, 1999.” \n8 Clause (35) omitted by the Finance Act, 2005. The omitted clause (35) read as follows: \n“(35) The provisions of section 151 shall not apply to any payment made by way profit or interest to \nany person on Term Finance Certificates being the instruments of redeemable capital under the \nCompanies Ordinance, 1984 (XLVII of 1984), issued by Prime Minister’s Housing Development \nCompany (Pvt) Limited (PHDCL).” \n9 Clause (36) omitted by the Finance Act, 2008. The omitted clause (36) read as follows: \n“(36)  The provisions of clause (c) of sub-section (1) of section 151 shall not apply in respect of any \namount paid as interest or profit on Special US Dollar Bonds issued under the Special US Dollar \nBonds Rules, 1998.” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n657 \n \n1[(36A) The provisions of clause (a) of sub-section (1) of section 151 shall not apply \nin respect of any amount paid as yield or profit on investment in Bahbood Savings \nCertificate or Pensioner’s Benefit Account 2[and Shuhada Family Welfare \nAccount.] \n \n3[(36B) The provisions of section 151 shall not apply to profit on debt paid on \npromissory notes and sales tax refund bonds issued under the provisions of the \nSales Tax ,Act, 1990. \n \n(36C) The provisions of section 151 shall not apply to profit on debt paid on \nPakistan Banao Certificate, \n \n(36D) The provisions of sections 150 and 151 shall not be apply to SARMAYA-E-\nPAKISTAN LIMITED \n \n(36E) The provisions of section 151 shall not apply on profit on debt paid on bonds \nissued under the Federal Government Duty Drawback Bonds Rules,2019] \n \n4[  ] \n \n(38)  The provisions of section 151, 5[153 6[“,233 and 236Q”] ] shall not apply to \nspecial purpose vehicle for the purpose of securitization7[“or issue of sukuks”]. \n \n8[(38A)  The provisions of sections 150, 151 and 233 shall not apply to a Venture \nCapital Company;] \n \n9[(38AA)  The provisions of section 150 shall not apply to China Overseas Ports \nHolding Company Limited, China Overseas Ports Holding Company  Pakistan \n(Private) Limited, Gwadar International Terminal Limited, Gwadar Marine Services \nLimited and Gwadar Free Zone Company Limited for a period of twenty-three  \nyears.] \n \n10[(38AAA) The provisions of section 152 shall not apply to Special Purpose \nVehicle referred to in clause 99B of Part I of this Schedule.] \n                                            \n1Inserted by the Finance Act, 2004. \n2Inserted by the Finance Act, 2018 \n3 New Clauses 36B, 36C, 36D & 36E inserted through Finance Supplementary (Second Amendment) \nAct, 2019 \n4Clause (37) omitted by the Finance Act, 2005. The omitted clause (37) read as follows: \n“(37)  The provisions of section 151 shall not apply to Pak rupee accounts or certificates referred to \nin clause (83) of Part I of this Schedule.” \n5Inserted by the Finance Act, 2002. \n6The figure and word “and 233” substituted by the Presidential Order No.F.2(1)2016-Pub dated \n31.08.2016.  \n7Added by the Presidential Order No.F.2(1)2016-Pub dated 31.08.2016.  \n8 Inserted by the Finance Act, 2004. \n9inserted by the Finance Act, 2016. \n10 Clause (38AAA) inserted by the Finance Act, 2024.  \n\n\f\nSecond Schedule – Part IV____ __________________________ \n658 \n \n \n1[  ] \n \n2[(38C) The provisions of section3[150,] 151, 152, 153 and 233 shall not apply to \nthe Islamic Development Bank.] \n \n4[(38D) The provisions of section 151 and 153 shall not apply to the National \nDisaster Risk Management Fund.] \n  \n5[  ] \n6[  ] \n7[  ] \n8[  ] \n                                            \n1Clause (38B) omitted by Finance Act, 2014. The omitted clause (38B) read as follows: \n“(38B) The provisions of section 150 shall not apply to the Islamic Development Bank.” \n2Clause (38C) inserted by the Finance Act, 2011.. \n3The figure and comma “150,” inserted by Finance Act, 2014. \n4 New clause (38D) inserted through Finance Supplementary (Second Amendment) Act, 2019 \n5Clause (39) omitted by the Finance Act, 2003. The omitted clause (39) read as follows: \n“(39) The provisions of section 151 shall not apply to a person who produces a certificate from the \nCommissioner of Income Tax concerned to the effect that his income during the income year is \nexempt from tax.” \n6 Clause (40 omitted by the Finance Act, 2005. The omitted clause (40) read as follows: \n“(40)  The provisions of sub-section (6) of section 153in so far as they relate to payments on account \nof supply of goods from which tax is deductible under the said section shall not apply in respect of \nany person being a manufacturer of such goods, unless he opts for the presumptive tax regime: \nProvided that a declaration of option is furnished in writing within three months of the \ncommencement of the tax year and such declaration shall be irrevocable and shall remain in force \nfor three years: \nProvided further nothing contained in this clause shall apply to any manufacturer of goods for \nwhich special rates of deduction of tax are specified under the repealed Ordinance.” \n7Clause (41) omitted by the Finance Act, 2017. The omitted clause (41) read as follows: \n“(41)The provisions of 7[sub-section “7[(1B) of section 152]] shall not apply in respect of a non-\nresident person unless he opts for the presumptive tax regime: \nProvided that a declaration of option is furnished in writing within three months of the \ncommencement of the 7[tax] year and such declaration shall be irrevocable and shall remain in \nforce for three years.” \n8Clause (41A) omitted by Finance Act 2014. The omitted clause (41A) read as follows: \n“(41A) The provisions of sub-section (7) of section 148 and clause (a) of sub-section (1) of section 169 \nshall not apply in respect of a person if he opts out of presumptive tax regime subject to the condition \nthat minimum tax liability under normal tax regime shall not be less than 60% of tax already collected \nunder sub-section (7) of section148.” \n \nEarlier Clause (41A) was omitted by the Finance Act, 2008. Which was inserted by S.R.O. \n1130(I)/2005, dated 14.11.2005 and read as follows: \n“(41A) Notwithstanding anything contained in the Finance Act, 2005 (VII of 2005), with respect to the \nomission of clause (40) of Part IV of the Second Schedule to this Ordinance, nothing in sub-section \n(6A) of Section 153 of this Ordinance shall apply to any person being a manufacturer, where \ndeclaration of option for the presumptive tax regime has been furnished and transactions pertaining \nto such option have been undertaken and completed on or before the 30th June, 2005: \n \nProvided that all declaration of options already furnished shall cease to have effect after the \n30th June, 2005.” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n659 \n \n1[  ] \n2[  ]  \n3[  ] \n \n(42) The provisions of 4[sub-section 5[(3)] of section 153] shall not apply in \nrespect of payments received by a resident person for providing services by way \nof operation of container or chemical or oil terminal at a sea-port in Pakistan or of \nan infrastructure project covered by the Government’s Investment Policy, 1997. \n \n6[  ] \n7[  ] \n8[(43A) The provisions of sub-section (1) of section 153 shall not apply to payments \nreceived by a person 9[  ] on account of supply of petroleum product imported by \nthe same person under the Government of Pakistan’s deregulation policy of POL \nproducts;] \n \n10[(43B) The provisions of clause (a) sub-section (1) of section 153 shall not apply \n                                            \n1Clause (41AA) omitted by Finance Act 2014. The omitted clause (41AA) read as follows: \n“(41AA) The provisions of sub-section (4) of section 154 and clause (b) of sub-section (1) of section \n169 shall not apply in respect of a person if he opts out of presumptive tax regime subject to the \ncondition that minimum tax liability under normal tax regime shall not be less than 50% of tax already \ndeducted under sub-section (4) of section 154.” \n2Clause (41AAA) omitted by Finance Act 2014. The omitted clause (41AAA) read as follows: \n“(41AAA) The provisions of clause (a) of sub-section (1) of section 153 and clause (b) of sub-section \n(1) of section 169 shall not apply in respect of a person if he opts out of presumptive tax regime subject \nto the condition that minimum tax liability under normal tax regime shall not be less than 70% of tax \nalready deducted under clause (a) of sub-section (1) of section 153.” \n3Clause (41B) omitted by Finance Act 2014. The omitted clause (41B) read as follows: \n \n“(41B)The provisions of sub-section (2) of section 152 shall not apply in respect of \npayments to foreign news agencies, syndicate services and non-resident contributors, who \nhave no permanent establishment in Pakistan” \n4Substituted for the word and figure “section 153” by the Finance Act, 2002 \n5The brackets and figure (6) substituted by the Finance Act, 2011. \n6 Omitted by the Finance Act, 2008. The omitted clause (42A) read as follows: \n“(42A) The provisions of sub-section (6) of section 153 shall not apply in respect of payments \nreceived by a person for supply of relief goods for earthquake victims against funds from the \nPresident Relief Fund for Earthquake Victims, 2005, or any other such source of the Government or \nthe purchases made by approved voluntary Non-Profit Organizations or welfare bodies for the \naforesaid purpose.” \n7 Clause (43) omitted by the Finance Act, 2004. The omitted clause (43) read as follows: \n“(43) The provisions of sub-section (1) of section 153shall not apply to payments received by Pak-\nArab Refinery Limited on account of supply of its products.” \n8Clause (43A) substituted by the Finance Act, 2003. The substituted clause (43A) read as follows: \n“(43A) The provisions of section 153, shall not apply to payments received by M/s Total PARCO \nPakistan Limited for the supply of petroleum products.” \n9The words and brackets “including Permanent Establishment of Non-resident Petroleum Exploration \nand Production (E&P) Companies” omitted by the Finance Act, 2008. \n10Inserted by the Finance Act, 2007. Earlier it was omitted vide Finance Act, 2003 which read as follows: \n \n“(43B) The provisions of section 153 shall not apply to the payments received by Al Rahim Trading \nCo. (Pvt) Limited, Karachi for the supply of petroleum products.” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n660 \n \nto payments received on sale of air tickets by travelling agents, who have paid \nwithholding tax on their commission income.] \n \n1[(43C) The provision of clause (a) of sub-section (1) of section 153 shall not be \napplicable to any payment received by a petroleum agent or distributor who is \nregistered under Sales Tax Act, 1990 on account of supply of petroleum products.] \n \n2[(43D) The provisions of 3[clauses (a) and (b)] of sub-section (1) of section 153 \nshall not apply in case of an oil tanker contractor with effect from 1st July 2008, \nprovided that such contractor pays tax @ 2.5%, on the payments for rendering or \nproviding of carriage services 4[   ]  ].] \n \n5[(43E) The provisions of 6[clauses (a) and (b)] of sub section (1) of section 153 \nshall not apply in case of goods transport contractors, provided that such \ncontractors pay tax at the rate of 7[ ] 8[3.5%] on payments for rendering or providing \nof carriage services.] \n9[(43F) The provisions of section 153 shall not apply in the case of a start-up, being \nrecipient of payment, as defined in clause (62A) of section 2.] \n \n10[(43G) The provisions of section 153 shall not apply to commodity futures \ncontracts listed on a Futures Exchange licensed under the Futures Market Act, \n2016 (XIV of 2016).] \n \n11[(43H) The provisions of clause (b) of sub-section (1) of section 153 shall not \napply to an exhibitor or a distributor of a feature film, as a payer, on payment made \nto a distributor, producer or importer of a feature film.] \n                                            \n1Added by S.R.O. 57(I)/2012, dated 24.01.2012. Earlier it was inserted by S.R.O. 961(I)/2002, dated \n23.12.2002 and then omitted by the Finance Act, 2003. The omitted clause (43C) read as follows: \n“(43C) The provisions of section 153 shall not apply to the payments received by Hascombe Storage \n(PVT) Limited, Karachi, for the supply of petroleum products.” \n2Inserted by S.R.O. 126(I)/2013, dated 13.02.2013. Earlier it was inserted by S.R.O. 253(I)/2003, dated \n07.03.2003 and then omitted by the Finance Act, 2003. The omitted clause (43D) read as follows: \n“(43D) The provisions of section 153 shall not apply to the payments received by M/s. Overseas \nTrading Corporation, Karachi, for the supply of petroleum products.” \n3  The expression “clause (a)” substituted by the Finance Act, 2021.   \n4  The expression “w.e.f. tax year 2012” omitted by the Finance Act, 2021.   \n5Inserted by S.R.O 980(I)/2013, dated 18.11.2013. Earlier it was inserted by S.R.O. 408(I)/2003, \ndated 08.05.2003 and then omitted by the Finance Act, 2003. The omitted clause (43E) read as \nfollows: \n“(43E) The provisions of section 153 shall not apply to the payments received by M/s. ICI Pakistan \nLimited, for the supply of petroleum products.” \n6  The expression “clause (a)” substituted by the Finance Act, 2021.   \n7Figure “2.5” substituted through Finance Act, 2019. \n8 The figure “3%” substituted by the Finance Act, 2021.   \n9Inserted by the Finance Act, 2017. \n10 Clause (43G) inserted by the Finance Act, 2021. \n11 Clause (43H) inserted by the Finance Act, 2022. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n661 \n \n \n1[  ] \n \n(45) The provisions of 2[sub-section 3[(1)] of section 153] shall not apply to any \nmanufacturer-cum-exporter as 4[the prescribed person]: \n \nProvided that— \n \n(a) \nthe manufacturer-cum-exporter shall deduct tax from payments \nmade in respect of goods sold in Pakistan; \n \n(b) \nif tax has not been deducted from payments on account of supply of \ngoods in respect of goods sold in Pakistan, the tax shall be paid by \nthe manufacture-cum-exporter, if the sales in Pakistan are in excess \nof five per cent of export sales 5[.] ] \n \n \n6[(45A) \n7[  ] The rate of deduction of withholding tax under clauses (a) and (b) \nof sub-section (1) of section 153 shall be one per cent on local sales, supplies \n                                            \n1Clause (44) omitted by the Finance Act, 2005. The omitted clause (44) read as follows: \n“(44) The provisions of section 148shall not apply to an indirect exporter as defined in the Duty and Tax \nRemission for Export Rules, 2001 issued under Notification No. S.R.O. 185(I)/2001, dated the 21st \nMarch 2001.” \n2 The word and figure “section 153” substituted by the Finance Act, 2002. \n3 The brackets and figure “(6)” substituted by the Finance Act, 2003. \n4The words “a payer” substituted by the Finance Act, 2003. \n5 The expression “; and” and paragraph (c) omitted by the Finance Act, 2021. The omitted paragraph \nread as follows: \n   “(c) nothing contained in this clause shall apply to payments made on account of purchase of the \ngoods in respect of which special rates of tax deduction have been specified 5[under the provisions \nof the repealed Ordinance.]” \n6Clause (45A) substituted by S.R.O. 333(I)/2011, dated 02.05.2011. The substituted clause (45A) read as \nfollows: \n“(45A) \n(a)  \nThe rate of deduction of withholding tax under clauses  \n(a) and (b) of sub-section (1) of \nsection 153 shall be one  per cent on local sales, supplies or services made or rendered to \nthe following categories of sales tax zero- rated taxpayers, namely:— \n \n \n(i)  \ntextile and articles thereof; \n \n \n(ii)  \ncarpets; \n(iii)  \nleather and articles thereof including artificial leather footwear; \n \n \n(iv)  \nsurgical goods; and \n \n \n(v)  \nsports goods; \n(b)  \nprovisions of clause (a) of sub-section (1) of section 111 of the Income Tax Ordinance, 2001 \n(XLIX of 2001) shall not apply to the amounts credited in the books of accounts maintained for \nthe period ending the 30th June, 2011 by the sellers suppliers, service providers to the \ncategories of sales tax zero-rated tax payers as mentioned at sub-clause (i) above; and \n(c)  \nprovisions of sub-clauses (a) and (b) above shall be applicable only to new cases of sellers, \nsuppliers, service providers of the above mentioned categories of sales tax zero-rated \ntaxpayers, who get themselves registered by the 30th June, 2011.” \n7 The expression “(a)” omitted by the Finance Act, 2021. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n662 \n \nand services provided or rendered to the 1[taxpayers falling in the] following \ncategories 2[ ] namely:- \n \n \n(i) \ntextile and articles thereof; \n \n(ii)  \ncarpets; \n(iii)  \nleather and articles thereof including artificial leather footwear; \n \n(iv)  \nsurgical goods; and \n \n(v)  \nsports goods; \n \n \n3[Explanation.—For removal of doubt, it is clarified that the relief \nof reduced rate for withholding tax under clause (a) and (b) of subsection \n(1) of section 153 is available only to the local sales, supplies and \nservices made by the taxpayers of categories specified at serial no (i) to \n(v) of this clause:] \n \n4[Provided that the rate of deduction of withholding tax under \nclauses (a) and (b) of sub-section (1) of section 153 shall be 0.5% on \nlocal sales, supplies and services made by traders of yarn to the above \nmentioned categories of taxpayers.]  \n5[   ] \n \n6[   ] ] \n \n7[(45B) The provisions of section 153 shall not apply on the purchase of used motor \nvehicles from general public.] \n \n                                            \n1Words inserted by S.R.O 669(I)/2013, dated 17.07.2013. \n2The words “of sales tax zero-rated taxpayers,” omitted by S.R.O 669(I)/2013, dated 17.07.2013. \n3 Explanation inserted by the Finance Act, 2021. \n4Proviso substituted through Tax Laws(Second Amendment) 2019 dated 26th December, 2019, the \nsubstituted proviso read as under: \n \n  “Provided that withholding tax under clauses (a) and (b) of sub-section (1) of section 153 shall \nnot be deducted from sales, supplies and services made by traders of yarn to the above mentioned \ncategories of taxpayers. Such traders of yarn shall pay minimum tax @ 0.1% on their annual turnover \non monthly basis on 30th day of each month and monthly withholding tax statement shall be e-filed \nunder the provisions of section 165 of this Ordinance.” \n5 Sub-clause (b) omitted by the Finance Act, 2021. The sub-clause read as follows: \n“(b)  provisions of clause (a) of sub-section (1) of section 111 of this Ordinance shall not apply to the \namounts credited in the books of accounts maintained for the period ending on the 30th June 2011, \nby the sellers, suppliers, service providers to the categories of sales tax zero-rated taxpayers, \nas mentioned in sub-clause (a) [.]” \n6Sub-clause (c) omitted through Tax Laws (Second Amendment) Ordinance 2019 dated 28th \nDecember, 2019. omitted sub-clause read as under: \n“(c)  \nprovisions of sub-clauses (a) and (b) shall be applicable only to the cases of \nsellers, suppliers, service providers of the above mentioned categories of sales tax zero-\nrated taxpayers, who are already registered and to those taxpayers who get themselves \nregistered by the 30th June, 2011.” \n7 Clause (45B) added by the Finance Act, 2021. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n663 \n \n1[(46) The provisions of sub-section (1) of section 153 shall not apply to any \npayment received by an oil distribution company or an oil refinery 2[3[“and \nprovisions of sub-section (2A) of section152 shall not apply to”] Permanent \nEstablishment of Non-resident Petroleum Exploration and Production (E&P) \nCompanies] for supply of its petroleum products.] \n \n4[(46A) the provisions of sub-section 5[(3)] of section 153 shall not apply to any \npayment received by a manufacturer of iron and steel products relating to sale of \ngoods manufactured by him.] \n \n6[(46AA) The provisions of section 153 shall not apply to the following persons as \nrecipients of payment, namely:— \n \n(i) \na Provincial Government; \n \n(ii) \na local authority; \n \n(iii) \npersons who are residents of Azad Kashmir and execute contracts in \nAzad Kashmir only and produce a certificate to this effect from the \nconcerned income tax authority; \n \n7[(iv) subject to fulfillment of procedure laid down in clause (12) of Part IV \nof Second Schedule, persons receiving payments exclusively for the \nsupply of agriculture produce including following—  \n  \n (I) \nfresh milk;  \n  \n (II) \nfish by any person engaged in fish farming;  \n  \n                                            \n1Clause (46) substituted by the Finance Act, 2004. The substituted clause (46) read as follows:  \n“(46) The provisions of sub-section (1) of section 153, shall not apply in respect of payments received \non account of supply of petroleum products by Attock Petroleum Limited.” \n2Inserted by the Finance Act, 2008. \n3 Substituted by the Finance Act, 2015.  \n4Inserted by S.R.O. 847(I)/2007, dated 22nd August, 2007. \n5 The brackets and figure “(6)” substituted by the Finance Act, 2011. \n6New clause (46AA) inserted through Finance Act 2020 dated 30th June, 2020 \n7 Sub-clause (iv) and (v) substituted by the Finance Act, 2021. The substituted sub-clauses read as \nfollows: \n“(iv) persons receiving payments from a company or an association of persons having turnover of \nfifty million rupees or more or from an individual having turnover of fifty million rupees or more \nexclusively for the supply of agriculture produce including fresh milk, fish by any person \nengaged in fish farming, live chicken, birds and eggs by any person engaged in poultry farming \nand by an industrial undertaking engaged in poultry processing which has not been subjected \nto any process other than that which is ordinarily performed to render such produce fit to be \ntaken to market; \n(v) companies receiving payments for the supply of electricity and gas;” \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n664 \n \n (III) live chicken, birds and eggs by any person engaged in poultry \nfarming;  \n  \n (IV) live animals by any person engaged in cattle farming;  \n  \n (V) \nunpackaged meat; and  \n  \n (VI) raw hides:  \n  \nProvided that this clause shall not apply to the payments \nfor agriculture produce which has been subjected to any \nprocess other than that which is ordinarily performed to render \nsuch produce to be fit to be taken to the market.”; and  \n  \n(v) \ncompanies receiving payments for the supply of electricity and gas \nincluding companies receiving payments for the transmission of \nelectricity and gas.] \n \n(vi) \ncompanies receiving payments for the supply of crude oil; \n \n(vii) \nhotels and restaurants receiving payments in cash for providing \naccommodation or food or both, as the case may be; \n \n(viii) shipping companies and air carriers receiving payments for the \nsupply of passenger tickets and for the cargo charges of goods \ntransported; \n \n(ix) \nindividuals who are not registered under section 181 of the Ordinance, \nreceiving payments for the supply of sand, bricks, grit, gravel, crushed \nstone, soft mud or clay; and \n(x) \nartisans, plumbers, electricians, surface finishers, carpenters, \npainters or daily wagers, receiving payments in respect of services \nprovided or rendered to the construction sector including construction \nof buildings, roads, bridges and other such structures or the \ndevelopment of land, subject to the following conditions, namely:— \n \n(a) services under this clause are provided or rendered by an \nindividual who is not registered under section 181; \n \n(b) the name, Computerized National Identity Card Number and \naddress of such individual is recorded by the recipient of such \nservice; and \n \n(c) payment for such services is made directly to such individual.”;] \n \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n665 \n \n1[  ] \n2[  ] \n3[  ] \n4[  ] \n5[(47A) The provisions of section 153 shall not apply in respect of payments \nreceived by a resident person for supply of such goods as were imported by the \nsame person and on which tax has been paid under section 148.] \n \n6[(47B) The provisions of sections 150, 151 7[, ] 233 8[and Part I, Division VII of the \nFirst Schedule] shall not apply to any person making payment to National \nInvestment Unit Trust or a collective investment scheme 9[ ] or Approved Pension \nFund or an Approved Income Payment Plan or a REIT Scheme 10[including Special \nPurpose Vehicle] 11[  ] or a recognized provident fund or an approved \nsuperannuation fund or an approved gratuity fund.] \n \n                                            \n1.Clause (46A) omitted by the Finance Act, 2004. Earlier clause (46A) was inserted by S.R.O. \n855(I)/2003 dated 29.08.2003. The omitted clause (46A) read as follows:  \n“(46A) The provisions of sub-section (1) of section 153, shall not apply to the payments received by \nM/s. TOTAL PARCO Pakistan Limited (TPPL) for the supply of petroleum products.” \n2Clause (46B) omitted by the Finance Act, 2009. The omitted clause (46B) read as follows: \n“(46B) the provisions of sub-section (6B) of section 153, in so far as they relate to payments on account of \nsale of goods from which tax is deductible under section 153, shall not apply in respect of an individual or \nassociation of persons being a manufacturer of such goods, for the tax year 2007.” \n3Clause (46C) omitted by the Finance Act, 2004. Earlier clause (46C) was inserted by S.R.O. \n857(I)/2003 dated 27.08.2003. The omitted clause (46C) read as follows:  \n“(46C) The provisions of sub-section (1) of section 153, shall not apply to the payments received by \nM/s. Bosicor Pakistan Limited for the supply of its products.” \n4Clause (47) omitted by the Finance Act, 2009. The omitted clause (47) read as follows: \n“(47)  The provisions of sections 151 and 155 shall not apply to a person who produces a certificate \nfrom the Commissioner of Income Tax concerned to the effect that his income during the income \nyear is exempt from tax.” \n5 Added by the Finance Act, 2002. \n6Clause (47B) substituted by the Finance Act, 2008. The substituted clause (47B) read as follows: \n“(47B)  The provisions of sections 150, 151 and 233 shall not apply to any person making payment to National \nInvestment (Unit) Trust or a mutual fund established by the Investment Corporation of Pakistan or a \ncollective investment scheme authorized or registered under the Non-Banking Finance Companies \n(Establishment and Regulation) Rules, 2003 or a modaraba or Approved Pension Fund or an Approved \nIncome Payment Plan constituted by a Pension Fund Manager registered under Voluntary Pension \nSystems Rules, 2005 or a Real Estate Investment Trust approved and authorized under the Real Estate \nInvestment Trust Rules, 2006, established and managed by a REIT Management Company licensed under \nthe Real Estate Investment Trust Rules, 2006 or a Private Equity and Venture Capital Fund.” \n7The words “and” substituted by the Finance Act, 2012. \n8Inserted by the Finance Act, 2012. \n9 The words “or a modaraba” omitted by the Finance Act, 2021. \n10 Words inserted by the Finance (Supplementary) Act, 2022. \n11 The words “or a Private Equity and Venture Capital Fund” omitted by the Finance Act, 2021. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n666 \n \n1[Explanation.— For the purpose of this clause, Special Purpose Vehicle \nshall have the same meaning as defined under the Real Estate Investment Trust \nRegulations, 2015.] \n \n2[(47C) The provisions of sub-section (1) of section 154 shall not apply to an exporter \nin respect of cooking oil or vegetable ghee exported to Afghanistan, from whom \nadvance tax has been collected under section 148 on import of edible oil.] \n \n3[(47D)  The provisions of clause (a) of sub-section (3) of section 153 shall not \napply to cotton ginners.] \n \n4[  ] \n \n5[  ] \n \n6[  ] \n \n7[  ] \n \n8[  ] \n \n9[  ] \n \n                                            \n1 Explanation added by the Finance (Supplementary) Act, 2022. \n2 Inserted by the Finance Act, 2004. \n3 Clause (47D) substituted by the Finance Act, 2011. The substituted clause (47D) read as follows: \n“(47D) \nThe provisions of sub-section (6A) of section 153 shall not apply to cotton ginners.” \n4Clause (48) omitted by the Finance Act, 2003. The omitted clause (48) read as follows: \n“(48)  The provisions of section 236 shall not apply to a person who produces a certificate from the \nCommissioner of Income Tax concerned to the effect that his income during the income year is exempt \nfrom tax.” \n5 Clause (49) omitted by the Finance Act, 2003. The omitted clause (49) read as follows: \n“(49)  The provisions of section 236 shall not apply where the subscriber is a non-taxable non-profit \norganization.” \n6 Clause (50) omitted by the Finance Act, 2003. The omitted clause (50) read as follows: \n“(50)  The provisions of section 234 shall not apply to a person who produces a certificate from \nCommissioner of Income Tax concerned to the effect that his income during the income year is exempt \nfrom tax.” \n7Clause (51) omitted by the Finance Act, 2003. The omitted clause (51) read as follows: \n“(51)  The provisions of section 235 shall not apply to a person who produces a certificate from the \nCommissioner of Income Tax concerned to the effect that his income during the income year is exempt \nfrom tax.” \n8 Clause (52) omitted by the Finance Act, 2010. The omitted (clause (52) read as follows: \n“(52)  The provisions of clause (vi) of Notification No. SRO 593(I)/91, dated the 30th June, 1991, \nshall not apply to any importer being an industrial undertaking engaged in the manufacture of \nvanaspati ghee or oil.” \n9Clause (53) omitted by the Finance Act, 2005. The omitted clause (53) read as follows: \n“ (53) The provision of sections 148 and 153 shall not apply to the wheat imported by Trading \nCorporation of Pakistan in pursuance of Economic Coordination Committee of the Cabinet decision \nNo.ECC-67/5/2005 dated the 2nd July, 2004.” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n667 \n \n1[  ] \n \n2[  ] \n \n3[(56) The provisions of section 148, regarding withholding tax on imports shall not \napply in respect of— \n                                            \n1Clause (54) omitted by the Finance Act, 2005. The omitted clause (54) read as follows: \n“(54) The provisions of section 148 shall not apply to sugar imported in pursuance of Economic \nCoordination Committee of the Cabinet’s decision No.ECC16/2/2005 dated 08.02.2005.” \n2Clause (55) omitted by the Finance Act, 2005. Earlier this was inserted by S.R.O. 423(I)/2005, dated \n13.05.2005. The omitted clause (55) read as follows:  \n“(55)  The provision of section 148 shall not apply to the import of the following items, namely:- \n \n(a)  \nonions; \n \n(b) \npotatoes; \n \n(c)  \ntomatoes; \n \n(d) \ngarlic; \n \n(e) \nhalal meat of - \n \n \n(1)  \n(i)  \ngoat; and \n \n \n \n(ii) \nsheep; and \n \n \n(2)  \nbeef; and \n(f)  \nlive animals (bovine animals i.e. buffalos, cows, sheep, goats and camels only).” \n3 Clause (56) substituted by the Finance Act, 2008. The substituted clause (56) read as follows: \n“(56) The provisions of section 148, regarding withholding tax on imports, shall not apply in respect of;- \n(i)  \ngoods or classes of goods imported by contractors and sub-contractors engaged in \nthe execution of power project under the agreement between the Islamic Republic of \nPakistan and Hub Power Company Limited; \n(ii)  \nsuch specially equipped motor vehicle or support equipment  imported by a disabled \nperson, as is allowed by the Federal Government; \n(iii)  \nsuch goods imported into Pakistan as are exempt from customs duties and sales tax \nunder Headings 9913, 9914 and 9915 of Sub-Chapter III of Chapter 99 of First \nSchedule the Customs Act, 1969 (IV of 1969);  \n(iv)  \ngoods imported by direct and indirect exporters covered under - \n(a)  \nSub-Chapter 4 of Chapter XII of S.R.O. 450(I)/2001 dated  18.06.2001; \n(b)  \nSub-Chapter 6 of Chapter XII of S.R.O. 450(I)/2001 dated 18.06.2001; and  \n(c)  \nSub-Chapter 7 of Chapter XII of S.R.O. 450(I)/2001 dated 18.06.2001; \n (v)  \ngoods specified under Heading 9929, Sub-Chapter VIII of  Chapter 99 of the First \nSchedule to the Customs Act, 1969 (IV of 1969); \n (vi)  \nLiquefied Petroleum Gas (LPG) \n  (vii) Liquefied Natural Gas (LNG) \n  (viii)  agricultural tractors imported in CBU condition; \n   (ix)  an indirect exporter as defined in the Duty and Tax Remission for Export Rules, 2001 \nissued under Notification No. S.R.O. 85(I)/2001, dated the 21st March 2001; \n   (x)  Radio Navigational Aid Apparatus imported for an  airport or on after First January, \n2006. \n  (xii)  import of the following items, namely:- \n(a)  \nonions; \n(b)  \npotatoes; \n(c)  \ntomatoes; \n(d)  \ngarlic; \n(e)  \nhalal meat of- \n \n \n \n \n(1) \n(i)  \ngoat; and \n \n \n \n \n \n(ii)  \nsheep; and \n \n \n \n \n(2)  \nbeef; and \n(f)  \nlive animals (bovine animals i.e. buffalos, cows, sheep, goats and camels \nonly); \n\n\f\nSecond Schedule – Part IV____ __________________________ \n668 \n \n                                            \n (xiv)  \ngoods donated for the relief of earthquake victims as are exempt from \ncustoms duties and sales tax; and \n (xv)  \ntents, tarpaulin and blankets. \n(xvii)  \nimport of ships and floating crafts including tugs, dredgers, survey \nvessels and other specialized crafts, registered in Pakistan. \n (xviii)  \ngoods specified in column (2) of the Table below, falling under the PCT \nheading number mentioned in column (3) of the said Table, namely: - \n \n  \n \n \nTABLE \nS.No. \nDescription of goods. \nPCT heading number. \n(1)  \n(2)  \n(3) \n \n    1. \nCamera. \n9007.1100 \n \n    2. \nStudio lights. \n9405.4010 \n \n    3. \nScreen. \n9010.6000 \n \n    4.  \nCamera all kind lenses. \n9002.1100 \n \n    5. \nStand filers. \n9002.2000 \n \n    6. \nLenses video assist. \n9002.1900 \n \n    7. \nLights/studio lights. \n9405.4010 \n \n    8. \nLaboratory for processing. \n9010.5000 \n \n    9. \nSteam back. \n9405.4010 \n \n   10. \nMixing studio facility. \n9010.5000 \n \n   11. \nRe-mixing and accessories. \n9010.5000 \n \n   12. \nJummygib. \n9010.5000 \n \n   13. \nNegative. \n9010.5000 \n \n   14. \nPostive. \n9010.5000 \n \n   15. \nSound. \n9010.5000 \n \n   16. \nMagnetic sound/negative. \n9010.5000 \n \n   17. \nLighting equipment imported \n9405.4010 \n \n \nBy M/s Rafi Peer Theatre \n \n \nWorkshop.           \n_____________________________________________ \n \n (xix)  \none time import of 32 buses by Daewoo Express Bus Service Ltd. \n (xx) \ngoods temporarily imported into Pakistan for subsequent exportation \nand which are exempt from customs duty and sales tax under \nNotification No. S.R.O. 1065(I)/2005, dated the 20th October, 2005. \n xxi \ncapital goods imported by a manufacturer whose sales are 100% \nexports and produces a certificate from the Commissioner of Income \nTax to the effect that the imported capital goods shall be \n \n(a)  \ninstalled in his own industrial undertaking; and \n(b)  \nexclusively used for production of goods to be exported. \n(xxii)  \nCapital goods and raw material imported by manufacturer exporter \nregistered with Sales Tax Department as a manufacturer. \n(xxiii) \nPetroleum (E&P) companies covered under SRO. 678(I)2004 dated \n07.08.2004 except motor vehicles imported by such companies. \n(xxiv) \nCompanies importing high speed diesel oil, light diesel oil, high octane \nblending component or motor spirit, furnace oil, JP-1, MTBE, kerosene \noil, crude oil for refining and chemical use in refining thereof in respect \nof such goods; \n(xxv) \nThe re-importation of re-usable containers for re-export qualifying for \ncustoms-duty and sales tax exemption on temporary import under the \nCustoms Notification No. S.R.O.344(I)/95 dated the 25th day of April, \n1995; and \n(xxvi) \ngoods donated for relief of flood victims of year 2007 as exempt from \ncustoms-duty and sales tax. \n(xxvii)  \nPlant, machinery, equipment and specific items used in production of \nbio-diesel as are exempt from customs-duty and sales tax.” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n669 \n \n(i) \ngoods \nclassified \nunder \nPakistan \nCustoms \nTariff \nfalling \nunder1[“Chapter 86 and 99 except PCT Heading 9918”]; \n \n2[(ia)  Petroleum oils and oils obtained from bituminous minerals crude (PCT \nCode 2709.0000), Furnace-oil (PCT Code 2710.1941), High speed \ndiesel oil (PCT) Code 2710.1931), Motor spirit (PCT Code \n2710.1210), J.P.1 (PCT Code 2710.1912), base oil for lubricating oil \n(PCT Code 2710.1993), Light diesel oil (PCT Code 2710.1921) and \nSuper Kerosene Oil imported by Pakistan State Oil Company Limited, \nShell Pakistan Limited, Attock Petroleum Limited, Byco Petroleum \nPakistan Limited, Admore Gas Private Limited, Chevron Pakistan \nLimited, Total-PARCO Pakistan(Private) Limited, Hascol Petroleum \nLimited,3[Barki Energy (Private) Limited], Gas and Oil Pakistan (Pvt) \nLtd4[or any other oil marketing company licensed by Oil and Gas \nRegulatory Authority (OGRA)]and oil refineries.] \n \n(ii)  \ngoods imported by direct and indirect exporters covered under sub-\nchapter 7 of Chapter XII of SRO 450(I)/2001 dated June 18, 2001; \n(iii)  \ngoods temporarily imported into Pakistan for subsequent exportation \nand which are exempt from customs duty and sales tax under \nNotification 5[No.492(I)/2009, dated the 13th June, 2009];6[ ]  \n \n7[(iiia) Goods temporarily imported into Pakistan by international athletes \nwhich would be subsequently taken back by them within one hundred \nand twenty days of temporary import;] \n \n(iv)  \nManufacturing Bond as prescribed under Chapter XV of Customs Rules, \n2001 notified vide S.R.O. 450(I)/2001, dated June 18, 2001       8[; and] ] \n \n9[(v)  mineral oil imported by a manufacturer or formulator of pesticides \nwhich is exempt from customs-duties under the customs Notification \nNo. S.R.O. 857(I)/2008, dated the 16th August, 2008.] \n \n \n10[(vi) the Federal Government; \n \n \n(vii) \na Provincial Government; \n \n(viii) a Local Government \n                                            \n1The word and figures “Chapters 27, 86 and 99” substituted by the Finance Act, 2015. \n2 Inserted by the Finance Act, 2015. \n3The expression “Bakri Trading Company Pakistan (Pvt) Ltd, Overseas Oil Trading Company (Pvt) Ltd” \nsubstituted by the Finance Act, 2018. \n4Inserted by the Finance Act, 2017. \n5The words, figures, brackets, commas and symbol “No. S.R.O.1065(I)/2005, dated the 20th October, \n2005” substituted by the Finance Act, 2012. \n6The word “and” omitted by S.R.O. 860(I)/2008, dated 19.08.2008. \n7 Sub-clause (iiia) inserted by the Finance Act, 2021. Earlier this sub-clause was inserted through Tax \nLaws (Amendment) Ordinance, 2021. \n8Full stop substituted by S.R.O. 860(I)/2008, dated 19.08.2008. \n9Inserted by S.R.O. 860(I)/2008, dated 19.08.2008. \n10New clauses (vi) to (xii) added through Finance Act, 2020 dated 30th June, 2020 \n\n\f\nSecond Schedule – Part IV____ __________________________ \n670 \n \n \n(ix) \na foreign company and its associations whose majority share capital \nis held by a foreign government; \n \n(x) \na person who imports plant and machinery for execution of a contract \nwith the Federal Government or a provincial government or a local \ngovernment and produces a certificate from that government; \n \n(xi) \ncompanies importing high speed diesel oil, light diesel oil, high octane \nblending component or kerosene oil, crude oil for refining and \nchemical used in refining thereof in respect of such imports; and \n \n(xii) \nPetroleum (E&P) companies covered under the Customs and Sales \nTax Notification No. S.R.O.678(I)/2004, dated the 7th August, 2004, \nexcept motor vehicles imported by such companies.] \n \n \n \n1[(xiii)    Goods produced or manufactured and exported from Pakistan which \nare subsequently imported in Pakistan within one year of their \nexportation, provided conditions of section 22 of the Customs Act, \n1969 (IV of 1969) are complied with;  \n  \n(xiv) plant and machinery imported for setting up of a bagasse/biomass \nbased cogeneration power project qualifying for exemption under \nclause (132C) of Part-I of this Schedule.;  \n  \n(xv) \npersons authorized under Export Facilitation Scheme 2021 notified by \nthe Board with such scope, conditions, limitation, restrictions and \nspecification of goods.;  \n  \n  \n(xvi) motor vehicles upto 1000cc in CBU condition;  \n  \n(xvii)  Printed books excluding brochures, leaflets and similar printed matter, \nwhether or not in single sheets.(PCT code 49.01);   \n  \n(xviii) Newspapers, journals and periodicals, whether or not illustrated or \ncontaining advertising material (PCT code 49.02); and  \n  \n(xix)  blind talking mobile phones imported by blind persons as per rules \nissued by the Board (respective PCT headings);] \n \n2[(xx) Import of Cystagon, Cysta drops and Trientine capsules]   \n                                            \n1 Sub-clause (xiii), (xiv), (xv), (xvi), (xvii), (xviii) and (xix) added by the Finance Act, 2021. \n2 Sub-clause (xx) added by the Finance Act, 2025. \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n671 \n \n \n1[ 2[ ]  ] \n \n3[ 4[   ] ] \n \n5[  ]  \n \n6[  ] \n7[  ]  \n   \n8[(56F) The provision of sub-section (2) of section 156A and clause (a) of sub-\nsection (1) of section 169 shall not apply in respect of a person if the person opts \nto file return of total income along with accounts and documents as may be \nprescribed, subject to the condition that minimum tax liability under normal tax \nregime shall not be less than 10% of the commission or discount received.] \n \n                                            \n1Inserted by the Finance Act, 2013. \n2Clause (56A) omitted by the Finance Act, 2017. The omitted clause (56A) is read as follows: \n“(56A) The provisions of sub-section (7) of section 148 and clause (a) of sub-section (1) of section 169 \nshall not apply to a person who is liable to withholding tax under section 236E.” \n3Added by S.R.O 341(I)/2014, dated 02.05.2014. \n4Expression in clause (56B) omitted by the Finance Act, 2015. The omitted expression read as follows:- \n“(56B)Provisions of section 148 shall not apply in respect of import of potatoes between 5th of May, \n2014 and 31st of July, 2014, provided that such imports shall not exceeds 200,000 metric tons in \naggregate during the said period.” \n5Inserted by the Finance Act, 2014 and erroneously numbered (56B) as clause (56B) already existed.  \n6Clause (56B) omitted by the Finance Act 2018,the omitted clause (5656B) reads as follows \n (56B) The provision of sub-section (7) of section 148, and clause (a) of sub-section (1) of section 169 shall not apply \nto a person being a commercial importer if the person opts to file return of total income along with accounts \nand documents as may be prescribed, subject to the condition that minimum tax liability under normal tax \nregime shall not be less than 5.5%, of the imports, if the person is a company and 6% otherwise. \n7Clauses (56C),(56D),(56E) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted \nclauses read as follows: \n“(56C) The provisions of sub-section (3) of section 153, in respect of sale of goods and clause (a) of \nsub-section (1) of section 169 shall not apply to a person, if the person opts to file return of total income \nalong with accounts and documents as may be prescribed subject to the condition that minimum tax \nliability under normal tax regime shall not be less than 3.5% of the gross amount of sales, if the person \nis a company and 4% otherwise.] \n [(56D) The provisions of sub-section (3) of section 153, in respect of contracts and clause (a) of sub-\nsection (1) of section 169 shall not apply to a person if the person opts to file return of total income \nalong with accounts and documents as may be prescribed subject to the condition that minimum tax \nliability under normal tax regime shall not be less than 6% of contract receipts, if the person is a \ncompany and 6.5 %otherwise.] \n [(56E) The provisions of sub-section (2) of section 153 and clause (a) of sub-section (1) of section 169 \nshall not apply in respect of a person if the person opts to file return of total income along with accounts \nand documents as may be prescribed subject to the condition that minimum tax liability under normal \ntax regime shall not be less than 0.5% of gross amount of services received.” \n \n8Inserted by the Finance Act, 2014. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n672 \n \n1[  ] \n \n2[   ] \n \n3[(57) The provisions of 4[ 5[section] 6[ ] ] 7[  ] 8[  ] 153 shall not apply to companies \noperating Trading Houses which— \n \n(i)  \nhave paid up capital of exceeding Rs.250 million; \n(ii)  own fixed assets exceeding Rs.300 million at the  close of the Tax Year; \n \n(iii)  maintain computerized records of imports and  sales of goods; \n \n(iv)  maintain a system for issuance of 100% cash  receipts on sales; \n \n(v)  present accounts for tax audit every year; and \n \n(vi)  is registered 9[under the Sales Tax Act, 1990] \n \nProvided that the exemption under this clause shall not be available if \nany of the aforementioned conditions are not fulfilled for a tax year 10[ 11[:] ]  \n                                            \n1Clause (56G) omitted though Finance Act, 2020 dated 30th June, 2020 the omitted clause read as \nfollows: \n“(56G) The provisions of sub-section (3) of section 233 and clause (a) of sub-section (1) of section 169 \nshall not apply in respect of a person if the person opts to file return of total income along with accounts \nand documents as may be prescribed, subject to the condition that minimum tax liability under normal \ntax regime shall not be less than 10% of the commission.” \n2Clause (56H) omitted by the Finance Act, 2015. The omitted clause (56H) read as follows:-  \n“(56H) Provisions of section 148 shall not apply in respect of import of potatoes between 5th of May, \n2014 and 15th of November, 2014, provided that such import shall not exceed 300,000 metric tons \nin aggregate during the said period.” \n3 Added by the Finance Act, 2005. \n4The word “section” substituted by S.R.O. 439(I)/2013, dated 20.05.2013. \n5 The expression “sections 113 and” substituted by the Finance Act, 2016. \n6Inserted by S.R.O. 439(I)/2013, dated 20.05.2013. \n7The figure “113” omitted by S.R.O. 140(I)/2013 dated 26.02.2013. \n8The figure “148” omitted by S.R.O. 140(I)/2013 dated 26.02.2013. \n9The words “with sales tax department” substituted by the Finance Act, 2014 \n10The colon substituted by the Finance Act, 2008. \n11 Full stop substituted by Finance Act, 2009. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n673 \n \n1[2[“Provided further that minimum tax under section 113 shall be 0.5% \nupto the tax year 3[2021] and one per cent thereafter.”] ] \n \n4[Explanation.-5[(i)]For the removal of doubt, exemption under this \nclause, in respect of section 153, shall only be available as a recipient and \nnot as withholding agent.] \n \n6[“(ii) It is further clarified that in-house preparation and processing of \nfood and allied items for sale to customers shall not disqualify a company \nfrom being treated as a Trading House, provided that all the conditions in \nthis clause are fulfilled and sale of such items does not exceed two per cent \nof the total sales.”] \n \n7[  ] \n \n \n8[   ] \n9[   ] \n10[  ] \n \n11[(59) The provisions of section 151, regarding withholding tax on profit on debt, \nshall not apply— \n                                            \n1 Added by S.R.O. 439(I)2013, dated 20.05.2013. Earlier second proviso was omitted vide S.R.O. \n140(I)/2013 dated 26.02.2013. The omitted proviso read as follows: \n“Provided further that the exemption from application of section 113 shall be available for the \nfirst ten years, starting from the tax year in which the business operations commenced.”  \n2Second proviso substituted by the Finance Act, 2016. Substituted second proviso read as follows:- \n“Provided further that the exemption from application of section 113 shall be available for the \nfirst ten years, starting from the tax year in which the business operations commenced.” \n3The figure “2019” substituted by the Finance Act, 2018. \n4Added by the Finance Act, 2014. \n5Numbered by the Finance Act, 2015. \n6Added by the Finance Act, 2015.  \n7 Proviso omitted by the Finance Act, 2008. The omitted proviso read as follows” \n \n \n“Provided further that the exemption from application of section 113 shall be available for the \nfirst ten years, starting from the tax year in which the business operations concerned.”     \n8Inserted by the Finance Act, 2007. \n9 Clause (57A) omitted by the Finance Act, 2021. The omitted clause read as follows: \n   “(57A) The provisions of sections 153 and 169 shall not apply to large import houses: \nProvided that the exemption under this clause shall not be available if any of the conditions \nprovided in section 148 are not fulfilled for a tax year.]” \n10 Clause (58) omitted by the Finance Act, 2008. The omitted clause (58) read as follows: \n“(58) The provisions of section 205 shall not apply to telecom companies for default of not collecting \nwithholding tax under section 236 (1)(b) on sale of prepaid cards during tax year 2004, if the amount \nnot collected is deposited within three months:  \n \n \n \nProvided that nothing contained in this clause shall apply to the amounts collected under section \n236(1)(b), but not deposited in the Treasury.” \n11Added by the Finance Act, 2005. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n674 \n \n1[   ] \n \n(ii)  \nto any payment made by way profit or interest to any person on \nTerm Finance Certificates being the instruments of redeemable \ncapital under the 2[Companies Act, 2017 (XIX of 2017)], issued by \nPrime Minister’s Housing Development Company (Pvt) Limited \n(PHDCL); \n3[   ]  \n \n(iv)  in the case of any resident individual, no tax shall be deducted from \nincome or profits paid on,- \n \n4[  ] \n \n(b)  Investment in monthly income Savings Accounts Scheme of \nDirectorate of National Savings, where monthly installment \nin an account does not exceed one thousand rupees.] \n \n5[(60) The provisions of sections 148 and 153 shall not apply to fully as well partly \ndesigned/assembled cypher devices, for use within the country as are verified by \n6[Cabinet Division (NTISB)] with reference to design, quality and quantity.] \n \n7[(60A)  The provisions of section 148 shall not apply for import of plant, machinery \nand equipment including dumpers and special purposes motor vehicles imported \nby the following for construction of Sukkur-Multan section of Karachi-Peshawar \nMotorway project and Karakorum Highway(KKH) Phase-II (Thakot to Havellian \nSection) of CPEC project respectively, namely:- \n \n(a) M/s China State Construction Engineering Corporation Ltd. (M/s \nCSCEC); and \n \n(b) M/s China Communication Construction Company (M/s CCCC). \n \n                                            \n1Sub-clause (i) omitted by the Finance Act, 2016. Omitted sub-clause read as follows:-  \n“(i)  \nin respect of profit or interest paid on a Term Finance Certificate held by a company which \nhas been issued on, or after, the first day of July, 1999” \n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n3 Sub-clause (iii) omitted by the Finance Act, 2015. The omitted sub-clause (iii) reads as follows:- \n“(iii)  to Pak rupee accounts or certificates referred to in clause (83) of Part-I of this Schedule; and” \n4Paragraph (a) omitted by the Finance Act, 2013. The omitted paragraph (a) read as follows: \n“(a)  Defence Savings Certificates, Special Savings Certificates, Savings Accounts or Post \nOffice Savings Accounts, or Term Finance Certificates (TFCs), where such deposit does \nnot exceed one hundred and fifty thousand rupees; and” \n5Inserted by S.R.O. 85(I)/2006, dated 03.02.2006. \n6The letters “NTISB” substituted by the Finance Act, 2006. \n7Inserted by the Finance Act, 2018. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n675 \n \n(60AA)    The provisions of section 148 of the Income Tax Ordinance, 2001(XLIX of \n2001), shall not apply for import of construction materials or goods upto a maximum of \n10,898.000 million rupees imported by China State Construction Engineering \nCorporation (M/s CSCEC) for construction of Sukkur-Multan section of Karachi-\nPeshawar Motorway project of National Highway Authority under CPEC. \n \n(60B) The provisions of section 148 shall not apply on import of thirty-five \narmoured and security vehicles imported by or for Ministry of Foreign Affairs,  \nGovernment of Pakistan meant for security of visiting foreign dignitaries, subject \nto the following conditions, namely:- \n \n(a) that the vehicles imported under this clause shall only be used for the \nsecurity purpose of foreign dignitaries and will  be parked in Central Pool \nof Cars (CPC) in the Cabinet Division for further use as and when \nneeded; and \n  \n(b) that the importing Ministry at the time of import shall furnish an          \nundertaking to the concerned Collector of Customs to the extent of \ncustoms-dues exempted under this clause on consignment to \nconsignment basis binding themselves that the vehicles imported under \nthis clause shall not be re-exported, sold or otherwise disposed of\nwithout prior approval of the Board and in the manner prescribed \ntherefor. \n(60C)   The provision of section 148 shall not apply on import of equipment to be \nfurnished or installed for Rail Based Mass Transit Projects in Lahore, Karachi, \nPeshawar and Quetta under CPEC.] \n \n1[(60D) The provisions of section 148 shall not apply on import of fire fighting \nequipments by industrial undertakings set up in the special economic zones \nestablished by the Federal Government.] \n \n2[     ]  \n \n 3[(60DA) The provisions of section 148 shall not apply to the import of the capital \nequipment as defined in Special Technology Zones Authority Act, 2021 (XVII of \n2021). \n                                            \n1 New clause (60D) added through Finance Supplementary (Second Amendment) Act, 2019 \n2 Clause (60DA) inserted by the Finance Act, 2021. \n3 Clause (60DA) substituted by the Finance Act, 2022. The substituted clause read as follows: \n“(60DA) The provisions of section 148 shall not apply to the import of the capital equipment as defined  \nin section 2 of the Special Technology Zones Ordinance 2020 (XIII of 2020) by—   \n(a) zone developers as defined in section 2 of the Special Technology Zones Ordinance 2020 \nfor consumption in the special technology zones for the period of 10 years commencing from \nthe date of signing the development agreement;   \n(b) zone enterprises as defined in section 2 of the Special Technology Zones Authority \nOrdinance, 2020 for a period of ten years from the date of issuance of license by the Special \nTechnology Zone Authority; and   \n\n\f\nSecond Schedule – Part IV____ __________________________ \n676 \n \n(a) Zone developers as defined in Special Technology Zones Authority Act, \n2021 (XVII of 2021) for consumption in the special technology zones for the \nperiod of ten years commencing from the date of signing the development \nagreement; \n \n(b) Zone enterprises as defined in Special Technology Zones Authority Act, \n2021 (XVII of 2021) for a period of ten years from the date of issuance of \nlicense by the Special Technology Zone Authority; and \n \n(c) Special Technology Zones Authority established under Special Technology \nZones Authority Act, 2021 (XVII of 2021).] \n \n1[(60E) The provisions of section 148 shall not apply on mobile phones brought in \npersonal baggage under Baggage Rules, 2006.]  \n \n2[   ] \n \n3[   ] \n \n4[   ]  \n \n5[(62) The following provisions of Section 97 shall not apply in case of transfer of \nassets on amalgamation of companies or their businesses or acquisition of shares, \nrequiring that transferor: \n \n \n \n(a)  \nbe resident company; and \n \n \n \n(b)  \nbelong to a wholly-owned group of resident companies. \n \nProvided that:  \n                                            \n(c)    Special Technology Zones Authority established under the Special Technology Zones \nOrdinance 2020.]” \n1New clause (60E) added through Finance Act, 2019. \n2 Added by S.R.O. 273(I)/2006, dated 21.03.2006. \n3 Clause (61) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(61)  The provisions of section 231A shall not apply in respect of any cash withdrawal, from a bank, \nmade by an earthquake victim against compensation received from GOP including payments \nthrough Earthquake Reconstruction and Rehabilitation Authority (ERRA) account.” \n4 Clause (61A) omitted by the Finance Act, 2015. The omitted clause (61A) read as follows:- \n“(61A)  The provisions of section 231A shall not apply in respect of any cash withdrawal by exchange \ncompanies duly licensed and authorized by the State Bank of Pakistan on their bank account \nexclusively dedicated for their authorized business related transaction: \nProvided that.— \n(a)  exemption under this clause shall be available to exchange companies who are issued \nexemption certificate by the concerned Commissioner Inland Revenue for a financial year; \nand  \n \n(b)  the Commissioner shall issue the exemption certificate after obtaining relevant details and \nparticulars of the Bank Accounts.” \n5 Inserted by S.R.O. 885(I)/2006, dated 29.08.2006. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n677 \n \n \n(i)  \nthe transferee resident company shall own or acquire atleast 75% of \nthe share capital of the transferor company or the business in Pakistan \nof the transferor company; \n \n \n \n \n(ii)  \nthe amalgamated company is a company incorporated in Pakistan; \n \n(iii)  \nthe assets of the amalgamating company or companies immediately \nbefore the amalgamation become the assets of the amalgamated \ncompany by virtue of the amalgamation, otherwise than by purchase \nof such assets by the amalgamated company or as a result of \ndistribution of such assets to the amalgamated company after the \nwinding up of the amalgamating company or companies; \n \n(iv)  \nthe liabilities of the amalgamating company or companies immediately \nbefore the amalgamation become the liabilities of the amalgamated \ncompany by virtue of the amalgamation; and \n \n(v)  \nthe scheme of amalgamation is sanctioned by the State Bank of \nPakistan, any court or authority as may be required under the law.] \n \n1[   ] ] \n \n2[  ] \n \n3[(65) Any income derived by a project, approved by Designated National Authority \n(DNA), from the transfer or sale of Clean Development Mechanism Credits i.e. \nCertified Emission Reductions, verified Emission Reductions.] \n \n4[  ] \n \n                                            \n1Clause (63) omitted though Finance Act, 2020 dated 30th June, 2020 the omitted clause read as \nfollows:  \n“(63)  M/s Dawat-e-Hadiya, Karachi 1[and Lahore University of Management Sciences, Lahore] shall \nbe deemed to have been approved by the Commissioner for the purpose of sub-section (36) of section \n2 notwithstanding the provisions of clause (c) of sub-section (36) of section 2.” \n2 Clause (64) omitted by the Finance Act, 2009. The omitted clause (64) read as follows: \n“(64)No tax shall be collected under section 231B during the period commencing from the 21st \nFebruary, 2008 and ending on the 20th April, 2008 and shall apply to booking of a motor car and \ndelivered during the said period. \n3 Added by the Finance Act, 2008. \n4 Added by the Finance Act, 2008. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n678 \n \n1[(66) The provisions of section 235 shall not be applicable to the taxpayers 2[ ] \nregistered with sales tax as exporters or manufacturer of — \n(a) \ncarpets; \n(b) \nleather and articles thereof including artificial leather footwear; \n(c) \nsurgical goods; \n(d) \nsports goods; and \n(e) \ntextile and articles thereof.] \n3[(67) The provisions of sections 150, 151, 152, 153 and 233 shall not apply in \nrespect of payments made to the International Finance Corporation established \nunder the International Finance Corporation Act, 1956 (XXVII of 1956).] \n4[(67A) The provisions of section 100B and Eighth Schedule shall not apply to \ntransactions carried on upto 30th day of June, 2015, on any Stock Exchange of \nPakistan, by International Finance Corporation established under the International \nFinance Corporation Act, 1956 (XXVIII of 1956).] \n \n5[(68) The provisions of sections 151, 153 and 155 shall not apply in respect of \npayments made to the Pakistan Domestic Sukuk Company Ltd.] \n \n6[(69) The provisions of sections 150, 151, 152, 153 and 233 shall not apply in \nrespect of payments made to the Asian Development Bank established under the \nAsian Development Bank Ordinance, 1971 (IX of 1971).] \n \n7[(70) The provisions of section 148, regarding withholding tax on imports, shall \nnot apply in respect of goods or classes of goods for the execution of contract, \n                                            \n1 Clause (66) substituted through S.R.O. 1055(I)/2008 dated 10th October 2008. Substituted clause \nread as follows:- \n“(66) \nThe provisions of section 235, shall not be applicable to the exporters-cum-manufacturers  \nof — \n \n \n(a) \ncarpets; \n(b) \nleather and articles thereof including artificial leather footwear; \n(c) \nsurgical goods; \n(d) \nsports goods; and \n(e) \ntextile and articles thereof.] \n \n2 Words “who fall under the zero rated regime of sales tax and” omitted through Tax Laws(Second \nAmendment) 2019 dated 26th December, 2019  \n3 Added by S.R.O. 767(I)/2008, dated 21.07.2008.  \n4Added by the Finance Act, 2015. \n5Added by S.R.O. 772(I)/2008, dated 22.07.2008. \n6Added by S.R.O. 1012(I)/2008, dated 23.09.2008. \n7Added by S.R.O. 129(I)/2009, dated 07.02.2009. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n679 \n \nimported by contractors and sub-contractors engaged in the execution of power \nproject under the agreement between the Islamic Republic of Pakistan and HUB \nPower Company Limited.] \n \n1[(71) The provisions of this Ordinance shall not be applicable to the M/s TAISEI \nCorporation under the agreement between National Highway Authority, GOP, \nwhich falls under the zero rated regime of sales tax and registered with sales tax \nin respect of supply of products, services and equipment.] \n \n2[(72) The provisions of sections 150, 151, 152, 153 and 233 shall not apply in \nrespect of payments made to The ECO Trade and Development Bank.] \n \n3[   ] \n \n4[   ] \n \n5[(72AA) The provisions of section 152 shall not apply in case of a Hajj Group \nOperator in respect of Hajj operations.] \n \n6[  ] \n                                            \n1Inserted vide S.R.O. 712(I)/2009, dated 05.08.2009. \n2Added by S.R.O. 810(I)/2009, dated 19.09.2009. \n3 Inserted by the Finance Act, 2013. \n4 Clause (72A) omitted by the Finance Act, 2021. The omitted clause read as follows: \n“(72A) The provisions of clause (l) and section 21, sections 113 and 152 shall not apply in case of a \nHajj Group Operator in respect of Hajj operations provided that the tax has been paid at the rate of \nRs.3,500 per Hajji for the tax year 2013 and Rs.5,000 per Hajji for the tax year 20144[4[to 4[2017] ] in \nrespect of income from Hajj operations.]” \n5Clause (72AA) inserted though Finance Act, 2020 dated 30th June, 2020. \n6Clause (72B) omitted though Finance Act, 2020 dated 30th June, 2020 the omitted clause read as \nfollows: \n“(72B) The provisions of section 148 shall not apply to an industrial undertaking if the tax liability for \nthe current tax year, on the basis of determined tax liability for any of the preceding two tax years, \nwhichever is the higher, has been paid 6[in the manner as may be prescribed] and a certificate to this \neffect is issued by the concerned Commissioner.] \nProvided that the certificate shall only be issued by the Commissioner if an application for the \nsaid certificate is filed before the Commissioner, in the manner and after fulfilling the conditions as \nspecified by notification in the official Gazette, issued by the Board for the purpose of this clause6[:] ] \n6[Provided further that the Commissioner shall be deemed to have issued the exemption \ncertificate in cases where the certificate is automatically processed and issued by IRIS upon expiry of \nprescribed time period: \n  \n“Provided also that the Commissioner may modify or cancel the certificate issued automatically \nby IRIS on the basis of reasons to be recorded in writing after providing an opportunity of being heard.] \n6[“Provided further that the quantity of raw material to be imported which is sought to be \nexempted from tax under section 148 shall not exceed 6[125] per cent of the quantity of raw material \nimported and consumed during the previous tax year: \nProvided also that the Commissioner shall conduct audit of taxpayer’s accounts during the \nfinancial year in which the certificate is issued in respect of consumption, production and sales of the \nlatest tax year for which return has been filed and the taxpayer shall be treated to have been selected \nfor audit under section 214C: \n\n\f\nSecond Schedule – Part IV____ __________________________ \n680 \n \n1[(73) To mitigate part of the cost of obtaining foreign support to fill productivity \ngap, income tax payable by a foreign expert shall be exempted provided that such \nexpert is acquired with the prior approval of the Ministry of Textile Industry.] \n \n2[(74) The provisions of sub-section (8) of section 22 shall not apply to Civil Aviation \nAuthority (CAA) in respect of the asset transferred for the purpose of the ijara \nagreement between Pakistan Domestic Sukuk Company Limited and the Federal \nGovernment.] \n \n3[(75) The provisions of sub-section (15) of section 22 shall not apply to Civil \nAviation Authority (CAA) on the assets acquired from the Federal Government \nwhich were previously transferred for the purpose of the ijara agreement between \nPakistan Domestic Sukuk Company Limited and the Federal Government: \n \nProvided that depreciation shall be allowed at the written down value \nof the assets immediately before their transfer for the purpose of above \nmentioned Ijara agreement.]  \n \n4[  ]  \n5[(77) Provisions of sections 148 and 153 shall not be applicable on import and \nsubsequent supply of items with dedicated use of renewable sources of energy \nlike solar and wind etc., even if locally manufactured, which include induction \nlamps, SMD, LEDs with or without ballast with fittings and fixtures, wind turbines \nincluding alternator and mast, solar torches, 6[tubular day lighting devices such \nassolatube,] lanterns and related instruments, PV modules 7[with or without] the \nrelated components including invertors, charge controllers and batteries.] \n \n8[(78) 9[Coal Mining and Coal based Power Generation Projects in Sindh],— \n                                            \nProvided also if the taxpayer fails to present accounts or documents to the Commissioner or \nthe officer authorized by the Commissioner, the Commissioner shall, by an order in writing, cancel the \ncertificate issued and shall proceed to recover the tax not collected under section 148 for the period \nprior to such cancellation and all the provisions of the Ordinance shall apply accordingly 6[:] \n6[Provided also that exemption certificate shall not be issued to an industrial undertaking \nimporting raw materials, specified in sub-section (8) of section 148.” \n1Added by the Finance Act, 2010. \n2Added by the Finance Act, 2010. \n3 Added by the Finance Act, 2010. \n4 Clause (76) omitted by the Finance Act, 2012. The omitted clause (76) read as follows: \n“(76) The provisions of section 148 shall not apply on import of solar PV panels / modules, along with \nrelated components including investors, charge controllers and batteries, LVD induction lamps, SMD \nLEDs with or without ballast with fittings and fixtures, fully assembled wind turbines including \nalternator and mast, solar torches, lanterns and related instruments.” \n5 Added by S.R.O. 263(I)/2011, dated 19.03.2011. \n6Added by the Finance Act, 2015. \n7The word “along with” substituted by the Finance Act, 2012. \n8Added by S.R.O. 317(I)/2011, dated 19.04.2011. \n9 The words “With respect to a project situated in the Special Economic Zone at Thar coalfield” \nsubstituted by S.R.O. 609(I)/2011, dated 13.06.2011. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n681 \n \n \n(i)  \nthe dividend income of the shareholders of such a project shall \nbe exempt from provisions of section 150 from the date of \ncommencement of business till 30 years from such date; and  \n \n(ii)  \nthe payments made on account of sale or supply of goods or \nproviding or rendering of services during project construction \nand operations, shall be exempt from the provisions of section \n1[152(2A) and section] 153.] \n2[  ]  \n \n3[(79A) The provisions of clause (b) of sub-section (1) of section 153 shall not \napply to payments received by National Telecommunication Corporation against \nprovision of telecommunication services including ancillary services specified in \nsubsection (3) of section 41 of the Pakistan Telecommunication (Re-organization) \nAct, 1996 (XVII of 1996).] \n \n4[  ] \n \n5[    ]  \n6[    ]  \n7[    ]  \n8[    ]  \n9[    ]  \n                                            \n1The words “152(2A) and section” inserted by S.R.O. 235(I)/2015, dated 18.03.2015. \n2Clause (79) omitted by the Finance Act, 2015. The omitted clause (79) read as follows:- \n“[(79) \nThe provisions of clause (b) of proviso to sub-section (3) of section 153 shall not be applicable to \nthe tax withheld on payments received by a company for providing or rendering of services.] \n3 Clause (79A) inserted by the Finance Act, 2021. Earlier this clause was inserted through Tax Laws \n(Amendment) Ordinance, 2021. \n4Clause (80) omitted by the Finance Act, 2014. The omitted clause read as follows: \n“(80) \nThe provisions of section 153A, shall not apply to any manufacturer till 30th June, 2013.” \n5Clause (81) omitted by the Finance Act, 2019, omitted clause read as follows: \n“(81) The provisions of clause (a) of section 165, shall not apply to any manufacturer, distributor,  \ndealer and wholesaler required to collect advance tax under sub section (1) of section 236H”. \n6 Clause (81A) omitted by the Finance Act, 2019, omitted clause read as follows: \n   “(81A) The provisions of clause (a) of sub-section (1) of section 165 shall not apply to banking \ncompanies for furnishing information of taxes collected and deducted under sections 231A \nand 151.” \n7Clause (82) added by S.R.O. 978(I)/2013, dated 13.11.2013. \n8Clause (82) omitted by the Finance Act, 2016. Omitted clause read as follows:- \n“(82) \nThe provisions of sub-section (2) of section 116 shall not apply for the tax year 8[2014] \nto an individual or a member of an association of persons whose last declared or assessed \nincome, or  the declared income for the year is less than one million rupees. \n9Clause (83) omitted by the Finance Act, 2015. The omitted clause (83) read as follows:- \n“(83) The provision of sub-section (4) of section 116 shall not apply for the tax year 2013 to a person \nother than a company or a member of an association of person falling under final tax regime (FTR) \nand has paid tax less than thirty five thousand rupees.” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n682 \n \n1[    ] \n2[    ] \n3[    ]  \n4[    ] \n5[    ] \n                                            \n1Clause (84) omitted by the Finance Act, 2014. The omitted clause (84) was added by S.R.O. \n1040(I)/2013, dated 05.12.2013 and read as follows:  \n“(84) \nFor tax year 2013, the provisions of section 177 and section 214C shall not apply to a taxpayer, if the \ntax paid on the basis of taxable income declared by the taxpayer for the tax year 2013 is at least twenty five \npercent more than the tax assessed or paid, whichever is higher, for the tax year 2012.: \n \nProvided that the taxpayer files separate proforma for the said exemption with return, in the \nmanner specified in the circular issued by the Board.] \n2Clause (85) omitted by the Finance Act, 2014. The omitted clause read as follows: \n“(85) \nThe provisions of section 114(6)(ba) shall not apply to persons availing the benefit as provided \nin clause (84) who revise their returns before the due date of filing of return, for tax year 2013.” \n3Inserted by SRO 1065(I)/2013, dated 20.12.2013 \n4Clause (86)(a) substituted by the Finance Act, 2018. The substituted Clause (86)(a)  read as follows: \n(86)(a)  The provisions of section 111 shall not apply to- \n(i) \ninvestment made by an individual in a Greenfield industrial undertaking directly or as an \noriginal allottee in the purchase of shares of a company establishing an industrial \nundertaking or capital contribution in an association of persons establishing an industrial \nundertaking; \n(ii) \ninvestment made by an association of persons in an industrial undertaking; and \n(iii) \ninvestment made by a company in an industrial undertaking; \nIf the said investment is made on or after the 1st day of January, 2014, and commercial \nproduction commences on or before the 30th day of June, [ [2019] ]. \n(b) \nThe concessions given in this clause shall also apply to investment made in:- \n(i) \nConstruction industry in corporate sector. \n(ii) \nLow cost housing construction in the corporate sector. \n(iii) Livestock development projects in the corporate sector. \n(iv) New captive power plants. \n(v) Mining and quarrying in Thar coal, Balochistan and Khyber Pakhtunkhawa. \n(c) \nThe concessions given in sub-clause (a) shall not apply to investment made in:- \n(i) \n \nArms and ammunitions \n \n(ii) \nExplosives \n \n \n \n(iii) Fertilizers \n(i) \nSugar \n(ii) \nCigarettes \n(vi) Aerated beverages \n(vii) Cement \n(viii) Textile spinning units \n(ix) Flour mills \n(x) Vegetable ghee and \n(xi) Cooking oil manufacturing \n(d) \nThe term Green filed industrial undertaking shall include expansion projects for the \npurposes of this clause. \n(e) \nImmunity under this clause shall not be available to proceeds of crime relating to offences \nunder the following laws: \n(a) Control of Narcotics Substances Act, 1997;  \n \n(ii) \nAnti Terrorism Act, 1997; and \n \n(iii) Anti-Money Laundering Act, 2010]. \n5 Clause (86) omitted by the Finance Act, 2022. The omitted clause read as follows: \n  “(86)(a) The provisions of section 111 shall not apply to- \n\n\f\nSecond Schedule – Part IV____ __________________________ \n683 \n \n \n1[     ] \n                                            \n(i) \ninvestment made by an individual in a green field industrial undertaking \ndirectly or as an original allottee in the purchase of shares of a company \nestablishing an industrial undertaking or capital contribution in an association \nof persons establishing an industrial undertaking; \n(ii) \ninvestment made by an association of persons in an industrial undertaking; \nand \n(iii) investment made by a company in an industrial undertaking— \nif the said investment is made on or after the 1st day of January, 2014 and   \ncommercial production commences on or before the 30th day of June, 2019; \n(b) \nThe concessions given in this clause shall also apply to investment made in – \n(i) \nconstruction industry in corporate sector; \n(ii)        low  cost  housing  construction  in the corporate sector; \n(iii) \nlivestock development projects in the corporate sector; \n(iv) \nnew captive power plants; and \n(v) \nmining and quarrying in Thar coal, Balochistan and Khyber  \nPakhtunkhawa; \n(c) \nThe concessions given in sub-clause (a) shall not apply to investment made in-  \n(i) \narms and ammunitions; \n(ii) \nexplosives;  \n(iii) \nfertilizers;  \n(iv) \nsugar; \n(v) \ncigarettes; \n(vi) \naerated beverages;  \n(vii) \ncement; \n(viii) \ntextile spinning units;  \n(ix) \nflour mills; \n(x) \nvegetable ghee; and \n(xi) \ncooking oil manufacturing; \n(d) \nThe term green field industrial undertaking shall include expansion projects for \nthe purposes of this clause; and \n(e) \nImmunity under this clause shall not be available to proceeds of crime relating \nto offences under the following laws, namely:- \n(i) \nControl  of  Narcotics  Substances Act, 1997; \n(ii) \nAnti Terrorism Act, 1997; and \n(iii) \nAnti-Money \nLaundering \nAct, 2010.” \n1Clause (87) omitted by the Finance Act, 2014. The omitted clause read as follows: \n“(87) \nThe  provisions of sections 182, 205, 177 and 214C shall not apply to an individual, holding an \nNTN who files a return, as specified in Form “A” below, by twenty eight day of February, 2014, of the \ntax years from 2008 to 2012, for which returns have not been field: \n \n \nProvided that for each of the tax year, a minimum tax of twenty thousand rupees on the \nbasis of taxable income is paid by the taxpayer: \n \n \nProvided further that the taxpayer shall not be entitled to claim any adjustment of \nwithholding tax collected or deducted under the Ordinance: \n \n \nProvided also that the due date of filing of return for tax year 2013, in respect of \nindividuals availing concessions under this clause shall be twenty eighth day of February, 2014. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n684 \n \n1[ ] \n \n                                            \n \n1Clause (88) omitted by the Finance Act, 2014. The omitted clause read as follows: \n“(88) \nThe provisions of sections 182, 205, 177 and 214C shall not apply to an individual, if the \nindividual files a return or returns, as prescribed for this clause, by twenty eighth day of February, 2014 \nfor any or all of the tax years from 2008 to 2012; and \n(i) \nhas not filed any return for the last five years; \n \n(ii) \nis not an NTN holder as on 28th day of November, 2013; \n(iii) \ndeclares taxable income for the year which exceeds the amount on the basis of which, \ntax payable is twenty five thousand rupees or more; and  \n(iv) \nhas paid the tax on the basis of taxable income declared in the return or returns: \n \n \nProvided that concession under this clause shall only apply for the tax year or years, \nfor which the returns have been filed and for equal number of succeeding consecutive tax year, if tax \npaid for the succeeding tax year is at least equal to tax paid for tax year 2012: \n \n \nProvided further that the taxpayers shall not be entitled to claim any adjustment of \nwithholding tax under the Ordinance, collected or deducted during a tax year, for which a return is filed:\n \n \nProvided also that the due date of filing of return for tax year 2013, in respect of \nindividuals availing concessions under this clause shall be twenty eighth day of February, 2014.] \n\n\f\nSecond Schedule – Part IV____ __________________________ \n685 \n \n1[    ]  \n \n2[    ] \n \n3[4[    ] ] \n \n5[(91) The provisions of section 148 shall not apply to- \n \n(i) Tillage and seed bed preparation equipment as specified below \n \n \nEquipment \nPCT Code \n(i)  \nRotavator  \n \n \n \n8432.8010 \n(ii)  \nCultivator  \n \n \n \n8432.2910 \n(iii)  \nRidger  \n \n \n \n8432.8090 \n(iv)  \nSub soiler  \n \n \n \n6[8432.3900] \n(v)  \nRotary slasher  \n \n \n8432.8090 \n(vi)  \nChisel plow   \n \n \n8432.1010 \n(vii)  \nDitcher  \n \n \n \n8432.1090 \n(viii)  Border disc   \n \n \n8432.2990 \n                                            \n1Clause (89) omitted by the Finance Act, 2015. The omitted clause (89) read as follows:- \n“(89) \nThe Provisions of section 236I shall not apply to-  \n \n \n(a)    the Federal Government or a Provincial Government; \n(b) an individual entitled to privileges under the United Nations (Privileges and Immunities) \nAct, 1948 (XX of 1948);  \n(c) a foreign diplomat or a diplomatic mission in Pakistan; or \n(d) a person who is a non-resident and- \n(i) \nfurnishes copy of passport as an evidence to the educational institution that during \nprevious tax year, his stay in Pakistan was less than one hundred eighty-three \ndays; \n(ii) furnishes a certificate that he has no Pakistan-source income; and  \n(iii) fee is remitted directly from abroad through normal banking channels to the bank \naccount of the educational institution.” \n2Clause (90) omitted by the Finance Act, 2015. The omitted clause (90) read as follows:- \n“(90) \nThe provisions of section 236D shall not apply to- \n \n \n(a) \nthe Federal Government or a Provincial Government; \n(b) \nan individual entitled to privileges under the United Nations (Privileges and \nImmunities) Act, 1948(XX of 1948); or \n \n \n(c) \na foreign diplomat or diplomatic mission in Pakistan.” \n3Inserted by S.R.O. 1029(I)/2014 date 19.11.2014. \n4Clause (91) substituted by the Finance Act, 2016. Substituted clause read as follows:- \n“(91) \nthe provisions of sections 147, 151, 152, 231A, 231AA, 236A and 236K shall not apply to “The \nSecond Pakistan International Sukuk Company Limited”, as a payer.” \n5 Clause (91) added by the Finance Act, 2015. \n6The figure “8432.3090” substituted by the Finance Act, 2017. \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n686 \n \n(ix) \nDisc harrow   \n \n \n8432.2100 \n(x)  \nBar harrow   \n \n \n8432.2990 \n(xi)  \nMould board plow   \n \n8432.1090 \n(xii) \nTractor rear or front blade  \n8430.6900 \nLand leveller or land planer  \n8430.6900 \n(xiv)  Rotary tiller   \n \n \n8432.8090 \n(xv)  \nDisc plow  \n \n \n \n8432.1090 \n(xvi)  Soil-scrapper  \n \n \n8432.8090 \n(xvii) K.R.Karundi   \n \n \n8432.8090 \n(xviii)  Tractor mounted trancher  \n1[8701.9200] \n(xix)  Land leveler   \n \n \n8430.6900 \n \n \n \n \nEquipment \nPCT Code \n(i) \nSeed-cum-fertilizer \n2[8432.3100] \ndrill (wheat, rice \nbarley, etc.) \n \n(ii) \nCotton or maize \n \n3[8432.3900] \nplanter withfertilizer \nattachment \n \n(iii) \nPotato planter  \n \n4[8432.3900] \n \n(iv) \nFertilizer or  \n \n5[8432.4100] \nmanure spreader \nor broadcaster \n \n(v) \nRice transplanter   \n6[8432.3900] \n \n(vi) \nCanola or  \n \n7[8432.3100] \nsunflower drill \n                                            \n1The figure “8701.9020” substituted by finance act 2017. \n2The figure “8432.3010” substituted by finance act 2017. \n3The figure “8432.3090” substituted by finance act 2017. \n4The figure “8432.3090” substituted by finance act 2017. \n5The figure “8432.4000” substituted by finance act 2017. \n6The figure “8432.3090” substituted by finance act 2017. \n7The figure “8432.3010” substituted by finance act 2017. \n \n(ii) \nSeeding or planting equipment \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n687 \n \n(vii) \nSugarcane planter  \n1[8432.3900] \n \n \n \n \n \n(i)  \nTubewells filters or \n8421.2100, \nStrainers \n \n \n8421.9990 \n(ii)  \nKnapsack sprayers  \n8424.2010 \n(iii)  \nGranular applicator  \n8424.2010 \n(iv)  Boom or field sprayers  8424.2010 \n(v)  \nSelf propelled sprayers  8424.2010 \n(vi)  Orchard sprayer   \n8424.2010 \n \n \n \n \n \n(i) \nWheat thresher \n \n \n8433.5200 \n(ii) \nMaize or groundnut \n \n8433.5200 \nthresheror sheller \n \n \n(iii)  \nGroundnut digger   \n \n8433.5900 \n(iv)  Potato digger or harvester  \n8433.5300 \n(iv) \nSunflower thresher  \n \n8433.5200 \n(v)  \nPost hole digger   \n \n8433.5900 \n(vi)  Straw balers  \n \n \n8433.4000 \n(vii)  Fodder rake  \n \n \n8433.5900 \n(viii)  Wheat or rice reaper  \n \n8433.5900 \n(ix)  Chaff or fodder cutter  \n \n8433.5900 \n(x)  \nCotton picker  \n \n \n8433.5900 \n(xi) \nOnion or garlic harvester  \n8433.5200 \n(xii)  Sugar harvester   \n \n8433.5200 \n(xiii)  Tractor trolley or forage wagon8716.8090 \n(xiv)  Reaping machines  \n \n8433.5900 \n(xv)  Combined harvesters  \n \n8433.5100 \n(xvi)  Pruner/shears  \n \n \n8433.5900 \n       2[(xvii)   Corn harvester/corn picker  \nand silage maker with their  \nrespective PCT heading] \n                                            \n1 The figure “8432.3090” substituted by Finance Act 2017. \n2 Sub-paragraph (xvii) added by the Finance Act 2021. \n(iii) Irrigation, drainage and agro-chemical \napplication equipment \nEquipment PCT Code \n \n(iv) Harvesting, threshing and storage equipment \n \nEquipment PCT Code \n \n(v)    Post-harvest handling and processing & \nmiscellaneous machinery \n\n\f\nSecond Schedule – Part IV____ __________________________ \n688 \n \n \n \n \n \n \n(i) \nVegetables and fruits \n \n8437.1000 \nCleaning and sorting  \nor grading equipment \n \n(ii) \nFodder and feed cube   \n8433.4000 \nMaker equipment”] \n \n1[2[   ]   ] \n \n3[(92) The provisions of section 148 shall not apply to.— \n \nPCT Code \n \nAircraft, whether imported or  \n \n8802.4000 \nacquired on wet or dry lease \n \nMaintenance kits for use in \n \n \nRespective \ntrainer aircrafts of PCT  \n \n \nheadings \n \n \n \n \nheadings 8802.2000 and \n \n \n \n8802.3000 \n \nSpare parts for use in \n \n \n \nRespective  \naircrafts, trainer aircrafts or \n \n \nheadings \nsimulators \nMachinery, equipment and \n \n \nRespective \ntools for setting up \n \n \n \nheadings \nmaintenance, repair and \noverhaul (MRO) workshop by \nMRO company recognized \nby Aviation Division \n \nOperational tools, machinery,  \n \nRespective \nequipment and furniture and \n \n \nheadings \nfixtures on one-time basis for \nsetting up Greenfield airports \nby a company authorized by \nAviation Division \n                                            \n1Inserted by S.R.O. 1029(I)/2014 date 19.11.2014 \n2Clause (92) substituted by the Finance Act, 2016 substituted clause read as follows:- \n. “(92) the provisions of sections 147, 151 and 155 shall not apply to “The Second Pakistan \nInternational Sukuk Company Limited”, as a recipient. \n3 Clause (92) added by the Finance Act, 2015. \nEquipment PCT Code \n\n\f\nSecond Schedule – Part IV____ __________________________ \n689 \n \n \nAviation simulators imported \n \n \nRespective  \nby airline company \n \n \n \nheadings \nrecognized by Aviation Division”] \n \n1[2[   ]] \n \n3[(93) The provisions of sub-section (1) of section 154 shall not apply to taxpayers \noperating halal meat production and qualifying for exemption under clause(126K) \nof Part-I of this Schedule for the period specified in clause (126K).”] \n \n4[  ] \n5[ ] 6[  ] \n \n7[(95) The provisions of sections 147, 151, 152, 236A and 236K shall not apply to \nthe Second Pakistan International Sukuk Company Limited, the Third Pakistan \nInternational Sukuk Company Limited and The Pakistan Global Sukuk Programme \nCompany Limited, as a payer.] \n                                            \n1Inserted by S.R.O. 1029(I)/2014 date 19.11.2014 \n2 Clause (93) substituted by the Finance Act, 2016 substituted clause read as follows:- \n“(93) the provision of section 236C shall not apply to “Pakistan International Sukuk Company Limited”.] \n3Clause (93) added by the Finance Act, 2015. \n4 Clause (94) omitted through Finance Act, 2019, omitted clause read as follows: \n\"(94) The provisions of clause (b) of the proviso to sub-section (3) of section 153 shall not apply for \n4[“the period beginning on the first day of July, 2015 and ending on the thirtieth day of June, 4[ 4[ ]  \n4[2019] ] to a company being a filer and engaged in providing or rendering freight forwarding services, \nair cargo services, courier services, manpower outsourcing services, hotel services, security guard \nservices, software development services,4[“IT services and IT enabled services as defined in clause (133) of \nPart I of this Schedule”] tracking services, advertising services (other than by print or electronic media), share \nregistrar services, engineering services 4[,] car rental services 4[, building maintenance services, services \nrendered by Pakistan Stock Exchange Limited and Pakistan Mercantile Exchange Limited 4[inspection, \ncertification, testing and training services]]: \nProvided that the tax payable or paid on the income from providing or rendering aforesaid \nservices shall not be less than two percent of the gross amount of turnover from all sources and that \nthe company furnishes in writing an irrevocable undertaking by the fifteenth day of November, 2015 to \npresent its accounts to the Commissioner within thirty days of filing of return, for audit of its income tax \naffairs for 4[ 4[any of the tax years 2016 to 4[2019] ] 4[:] ”] \n \n 4[“Provided further that for tax year 4[ ] 4[2019], the company shall furnish irrevocable undertaking by \nNovember, 4[ ] 4[2018], to present its accounts to the Commissioner.” \n5 Substituted by the Finance Act, 2016. \n6Clause (95) substituted by the Finance Act 2018, the substituted  clause (95) reads as follows \n“(95) the provisions of sections 147, 150A , 151, 152, 231A, 231AA, 236A and 236K shall not apply \nto “The Second Pakistan International Sukuk Company Limited”[“and the Third Pakistan \nInternational Sukuk Company Limited”, as a payer.” \n7 Clause (95) substituted by the Finance Act, 2022. Earlier this clause was inserted through S.R.O \n1457(I)/2021 dated 11.11.2021. Substituted clause read as follows: \n“(95) the provisions of sections 147, 150A, 151, 152, 7[  ] 236A and 236K shall not apply to “The \nsecond Pakistan international Sukuk Company  Limited” and the Third Pakistan International Sukuk \nCompany Limited, as a payer.” \n\n\f\nSecond Schedule – Part IV____ __________________________ \n690 \n \n \n1[(95A) The provisions of section 236A shall not apply in respect of auction of \nfranchise rights to participating teams in a national or international league \norganized by any board or other organization established by the Government in \nPakistan for the purposes of controlling, regulating or encouraging major games \nand sports recognized by the Government with effect from the first day of July; \n2019.] \n \n2[ ] 3[  ]  \n \n4[(96) The provisions of sections 151, 153, 155 and 236C shall not apply to the \nSecond Pakistan International Sukuk Company Limited, the Third Pakistan \nInternational Sukuk Company Limited and the Pakistan Global Sukuk Programme \nCompany Limited, as a recipient;] \n \n5[(97) the provision of section 236C shall not apply to “Pakistan International Sukuk \nCompany Limited.] \n6[(97A) The provisions of sections 37, 236C and 236K shall not apply to National \nHighway Authority in respect of transfer of immovable property to the Pakistan \nGlobal Sukuk Programme Company Limited and in respect of transfer of \nimmoveable property to National Highway Authority from the Second Pakistan \nInternational Sukuk Company Limited or the Pakistan Global Sukuk Programme \nCompany Limited.] \n  \n7[(98) The provisions of section 148 shall not apply to import of ships and other \nfloating crafts including tugs, survey vessels and other specialized crafts \npurchased or bare-boat chartered by a Pakistani entity and flying Pakistani flag: \nProvided that exemption under this clause shall be available up to \nthe year 8[2030], subject to the condition that the ships and crafts are used \nfor the purpose for which they were procured, and in case such ships and \n                                            \n1 New cluse (95A) inserted through Finance Supplementary (Second Amendment) Act, 2019 \n2Substituted by the Finance Act, 2016. \n3Clause (96) substituted by the Finance Act 2018,the substituted  clause (96) reads as follows \n“(96)the provisions of sections 147 3[, 150A]  , 151 3[, 155 and 236K] shall not apply to “The Second \nPakistan International Sukuk Company Limited” 3[“and the Third Pakistan International Sukuk Company \nLimited”], as a recipient.” \n4 Clause (96) substituted by the Finance Act, 2022. Earlier this clause was inserted through S.R.O \n1457(I)/2021 dated 11.11.2021. Substituted clause read as follows: \n“(96) the provisions of sections 147, 150A, 151, 155 and 236K shall not  apply to “The second \nPakistan international Sukuk Company Limited” and the Third \nPakistan International Sukuk \nCompany Limited, as a recipient.” \n5 Substituted by the Finance Act, 2016. \n6 New cluse (97A) inserted by the Finance Act, 2022. Earlier this clause was inserted through S.R.O \n1457(I)/2021 dated 11.11.2021. \n7 Added by the Finance Act, 2016. \n8 The figure “2020” substituted by “2030” though Finance Act, 2020 dated 30th June, 2020  \n\n\f\nSecond Schedule – Part IV____ __________________________ \n691 \n \ncrafts are used for demolition purposes, tax collectible under section 148, \napplicable to ships and crafts purchased for demolition purposes, shall be \nchargeable.] \n \n1[(99) The provisions of section 148 shall not apply to import or acquisition of \naircraft on wet or dry lease by M/s Pakistan International Airlines Corporation with \neffect from 19th March, 2015.] \n \n2[     ] \n3[     ]  \n4[     ] \n5[     ] \n6[     ] \n7[      ] \n8[    ] \n \n9[     ] \n \n(102) The provisions of section 231B (1A) shall not apply to light commercial \nvehicles leased under the Prime Minister’s Youth Business Loan Scheme.] \n \n10[(102A) The provisions of section 233 shall not apply to commission received by \na retail branchless banking agent on any amount disbursed by the Ehsaas \nEmergency Cash Transfer Programme for the period commencing on 16th April, \n2020 and ending on 30th day of September, 2020.] \n \n                                            \n1 Added by the Finance Act, 2016. \n2 Clause (100) inserted by the Finance Act, 2018. \n3 Clause (100) omitted by the Finance Act, 2023. The omitted clause read as follows: \n   “(100) The provisions of section 236U shall not apply to an insurance collecting premium under:- \n(a) \nCrop Loan Insurance Scheme (CLIS); and \n(b) \nLivestock Insurance Scheme (LIS).” \n4Added by the Finance Act, 2017. \n5 clause (101) omitted by the Finance Act 2021. The omitted clause read as follows: \n“(101) The provisions of section 231A shall not apply in respect of cash withdrawal made from a \n“Branchless Banking (BB) Agent Account” utilized to render branchless banking services to \ncustomers.] \n6 New  clause (101A) inserted through Finance Supplementary (Second Amendment) Act, 2019 \n7 clause (101A) omitted by the Finance Act 2021. The omitted clause read as follows: \n“(101A) The provisions of section 231A shall not apply to a Pak Rupee account if the deposits in the \naccount are made solely from foreign remittances credited directly into such account.] \n8New clause (101AA) inserted through Finance Act, 2020 dated 30th June, 2020. \n9 clause (101AA) omitted by the Finance Act 2021. The omitted clause read as follows: \n“(101AA) The provisions of sections 231A, 231AA and 236P shall not apply to a Pak Rupee Account \nin a tax year to the extent of foreign remittances credited into such account during that tax year.] \n10New clause (102A) inserted through Finance Act, 2020 dated 30th June, 2020. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n692 \n \n1[(103) The provisions of section 7B shall not apply to yield or profit on investment \nin Bahbood Savings Certificate or Pensioner’s Benefit Account, provided that tax \non the said yield or profit on debt is paid at the rates specified  in Division I of Part \nI of the First Schedule subject to clause (6) of Part III. \n \n(104)  The provisions of section 5A shall not apply to a company where a restriction \nhas been imposed on distribution of dividend on account of an agreement with the \nGovernment of Pakistan. \n \n2[(104A) The provisions of section 4C shall not apply on capital gain derived from \nthe disposal of one residential immovable property, if the property —  \n \n(a) \nhas been in the personal use of the person for the last fifteen years;  \n \n(b) \nhas been declared by the person in his wealth statement under \nsection 116 for the last fifteen years; and  \n \n(c) \nappears as residence for personal use in tax record of the person.  \n \nProvided that this clause shall apply once in fifteen years.]  \n3[  ]  \n \n4[(105A) The provisions of section 177 and 214C 5[for selection of a person for \naudit shall not apply whose income tax affairs have been selected for audit in any \nof the preceding three tax years]: \n \nProvided that the Commissioner may select a person under section 177 for \naudit with approval of the Board.] \n \n6[  ]  \n \n7[  ] \n                                            \n1Added by the Finance Act, 2018. \n2 Clause (104A) inserted by the Finance Act, 2025. \n3 Clause (105) omitted through Finance Act, 2019, omitted clause read as follows:  \n(105) The provisions of section 177 and 214C shall not apply to a person \nwhose income tax affairs \nhave been audited in any of the preceding  \nthree tax years: \nProvided that the Commissioner may select a person under section 177 for audit, with approval of the \nBoard. \n4New clause (105A) inserted by the Finance Act, 2022. \n5 The expression “shall not apply to a person whose income tax affairs have been audited in any of the \npreceding four tax years” substituted by Finance Act, 2025. \n6 Clause (106) added by S.R.O. 887(I)/2018 dated 23.07.2018. \n7 Clause (106) omitted by S.R.O. 1213(I)/2018, dated 05.10.2018.The omitted clause is read as under: \n \n[“(106) The provisions of sections in Division III of Part V of Chapter X and Chapter XII of the Ordinance \nfor deduction or collection of tax shall not apply in the districts of Chitral, Dir and Swat (which includes \nKalam), the former Tribal Area in Kohistan district, Malakand former Protected Areas the former Tribal \n\n\f\nSecond Schedule – Part IV____ __________________________ \n693 \n \n \n1[(107) The provisions of section 111 relating to unexplained income or assets \nshall not apply in respect of any contribution paid to the Supreme Court of Pakistan \n– Diamer Bhasha & Mohmand Dams – Fund. \n \n(108) The provisions of sections 2[113 and 151] shall not apply to the Supreme Court \nof Pakistan – Diamer Bhasha & Mohmand Dams – Fund. \n \n3[   ] \n \n4[(109A) The provisions of sections in Division III of Part V of Chapter X and Chapter \nXII of the Ordinance for deduction or collection of withholding tax which were not \napplicable prior to commencement of the Constitution (Twenty-fifth Amendment) Act, \n2018 (XXXVII of 2018) shall not apply to individual domiciled or company and \nassociation of persons resident in the Tribal Areas forming part of the Provinces of \nKhyber Pakhtunkhwa and Balochistan under paragraph (d) of Article 246 of the \nConstitution with effect from the 1st day of June, 2018 to the 30th day of June, 5[  ] 6[  ] \n7[2026] (both days inclusive).] \n \n8[(110) The provisions of sections in Division III of Part V of Chapter X and Chapter \nXII of the Ordinance for deduction or collection of withholding tax which were not \napplicable prior to commencement of the Constitution (Twenty-fifth Amendment) \nAct, 2018 (XXXVII of 2018) shall not apply to individual domiciled or company and \nassociation of person resident in the Tribal Areas forming part of the Provinces of \nKhyber Pakhtunkhwa and Balochistan under paragraph (d) of Article 246 of the \n                                            \nArea adjoining Mansehra district, the former State of Amb, Zhob district, Loralai district (excluding Duki \nTehsil), Dalbandin Tehsil of Chagai district and Marri and former Bugti Tribal territories of Sibi district, \nformer Tribal Areas adjoining the district of Peshawar, Kohat, Bannu, Lakki Marwat, Dera Ismail Khan, \nTank as well as former Tribal Areas i.e. Bajaur Agency, Orakzai Agency, Mohmand Agency, Khyber \nAgency, Kurram Agency, North Waziristan Agency and South Waziristan Agency, if the payer and the \nrecipient are residents of the aforesaid areas. \nProvided the provision of section 149 shall not apply in respect of persons working in the \naforesaid areas even if the payer resides outside the aforesaid areas.”] \n1 Added by the Finance Supplementary (Amendment) Act, 2018. \n2 The expression “113, 151, 231A, 231AA and 236P “ substituted by the Finance Act 2021.  \n3 Clause (109) omitted by the Finance Act 2021. The omitted clause read  as follows: \n“(109) The provisions of section 236P shall not apply at the time of transfer of any sum to the Supreme  \nCourt of Pakistan - Diamer Bhasha & Mohmand Dams- Fund.]  \n4 New clause (109A) added through Finance Act, 2019. \n5 The figure “2023” substituted by the Finance Act, 2023. \n6 The figure “2024” substituted by Finance Act, 2024. \n7 The figure “2025” substituted by Finance Act, 2025. \n8 Added by S.R.O. 1213(I)/2018, dated 05.10.2018. \n\n\f\nSecond Schedule – Part IV____ __________________________ \n694 \n \nConstitution with effect from the 1st day of June, 2018 to the 30th day of June, 1[ ] \n2[ ] 3[2026] (both days inclusive).] \n \n4[(111) The provisions of section 48 shall not apply to so much of the income of \nbanking company as defined in the said section subject to reduced rate of tax at 20% \nunder rules 7D, 7E and 7F of the Seventh Schedule for tax years 2020 to 2023.] \n \n5[(111A) The provisions of section 100BA and rule 1 of the Tenth Schedule shall not \napply to the extent of payment of dividend to non-resident persons.] \n \n6[(111AB) The provisions of section 100BA and rule 1 of the Tenth Schedule shall not \napply to non-resident individual holding Pakistan Origin Card (POC) or National ID \nCard for Overseas Pakistanis (NICOP) or Computerized National ID Card (CNIC) \nmaintaining a Foreign Currency Value Account (FCVA) or Non-resident Pakistani \nRupee Value Account (NRVA) with authorized banks in Pakistan under the foreign \nexchange regulations issued by the State Bank of Pakistan.] \n \n7[(111AC) The provisions of section 100BA and rule 1 of the Tenth Schedule shall \nnot apply to non-resident individual holding Pakistan Origin Card (POC) or National \nID Card for Overseas Pakistanis (NICOP) in respect of transactions on which tax \nis collectible under section 236C and 236K of the Ordinance;] \n \n8[   ] \n9[   ] \n10[    ] \n11[   ] \n                                            \n1 The figure “2023” substituted by the Finance Act, 2023. \n2 The figure “2024” substituted by Finance Act, 2024. \n3 The figure “2025” substituted by Finance Act, 2025. \n4 New Clause 111 added through Finance Supplementary (Second Amendment) Act, 2019 \n5 New clause (111A) inserted through Finance Act, 2020 dated 30th June, 2020   \n6 Clause (111AB) inserted by the Finance Act, 2021. Earlier this clause was inserted through Tax Laws \n(Amendment) Ordinance, 2021.  \n7 Clause (111AC) inserted by the Finance Act, 2022.  \n8 New clauses (112), (113), (114) and (115) added through Tax Laws (Second Amendment) 2019 dated \n26th December, 2019.  \n9 Clause (112) omitted by the Finance Act 2021. The omitted clause read  as follows: \n“(112) The provision of section 236P shall not apply to special convertible rupee account (SCRA) of \na non-resident company having no permanent establishment in Pakistan.]”  \n10 New clause (112A) inserted through Finance Act, 2020 dated 30th June, 2020.  \n11 Clause (112A) substituted through Tax Laws (Amendment) Ordinance, 2021. The substituted clause \nread  as follows: \n“(112A) The provisions of section 236P shall not apply to a non-resident rupee account repatriable (NRAR) \nor a foreign currency account maintained with a banking company in Pakistan of a non-resident individual \ninvesting in a debt instrument, whether conventional or shariah compliant, issued by the Federal \nGovernment under the Public Debt Act, 1944.] \n\n\f\nSecond Schedule – Part IV____ __________________________ \n695 \n \n1[   ] \n \n(113) \nThe provision of sub-section (5B) of sections 147 shall not apply in respect \nof capital gains arising to a non-resident company having no permanent \nestablishment in Pakistan from investment in debt instruments and Government \nsecurities including treasury bills and Pakistan investment bonds through special \nconvertible rupee account (SCRA) maintained with a banking company or financial \ninstitution in Pakistan. \n  \n(114) \nThe provisions of section 2[“clause (ae) of sub-section (a) of section 114”] \nand 181 shall not apply to a non-resident company having no permanent \nestablishment in Pakistan solely by reason of capital gain or profit on debt earned \nfrom investments in debt securities and Government securities including treasury \nbills and Pakistan investment bonds through special convertible rupee account \nmaintained with a banking company or financial institution in Pakistan. \n \n3[  ] \n \n4[(114A) The provisions of clause (ae) of sub-section (1) of section 114 and section \n181 shall not apply to a non-resident individual holding Pakistan Origin Card (POC) \nor National ID Card for Overseas Pakistanis (NICOP) or Computerized National ID \nCard (CNIC) maintaining a Foreign Currency Value Account (FCVA) or a Non-\nresident Pakistani Rupee Value Account (NRVA) with authorized banks in Pakistan \nunder the foreign exchange regulations issued by the State Bank of Pakistan:  \n  \nProvided that this clause shall not apply if the person referred in this clause \nhas Pakistan-source taxable income other than the following; namely:—  \n  \n(a) profit on debt on FCVA or Non-resident Pakistani Rupee Value Account \n(NRVA);  \n (b) profit on debt earned on Government of Pakistan (GOP) securities \neither conventional or Shariah Compliant where investment has been \nmade from proceeds of FCVA or NRVA;  \n                                            \n1 Clause (112A) omitted by the Finance Act 2021. The omitted clause read  as follows: \n“(112A) The provisions of section 231A, 231AA and 236P shall not apply to the holders of Foreign Currency \nValue Account (FCVA) or Non-resident Pakistani Rupee Value Account (NRPRVA) in respect of these \naccounts only.] \n \n2 The expression 115(4) substituted through Finance Act, 2020 dated 30th June, 2020. \n3 New clause (114A) inserted though Finance Act, 2020 dated 30th June,2020  \n4 Clause (114A) substituted by the Finance Act 2021. Earlier this clause was substituted through Tax \nLaws (Amendment) Ordinance, 2021.The substituted clause read  as follows: \n“(114A) The provisions of clause (ae) of sub-section (1) of section 114 and section 181 shall not apply \nto a non-resident individual solely by reason of profit on debt earned from a debt instrument, whether \nconventional or shariah compliant, issued by the Federal Government under the Public Debt Act, 1944 \nand purchased exclusively through a bank account maintained abroad, a non-resident rupee account \nrepatriable (NRAR) or a foreign currency account maintained with a banking company in Pakistan.] \n \n\n\f\nSecond Schedule – Part IV____ __________________________ \n696 \n \n  \n(c) \ncapital gain on disposal of immovable property acquired from proceeds \nof FCVA or NRVA;  \n  \n(d) capital gain on disposal of securities traded on Pakistan Stock \nExchange and units of mutual funds that are acquired from proceeds \nof FCVA or NRVA; or  \n  \n(e) dividend income from securities traded on Pakistan Stock Exchange \nand mutual funds that are acquired from proceeds of FCVA or NRVA.] \n \n(115) \nThe provisions of section 153 shall not apply to traders being individuals \nhaving turnover upto one hundred million Rupees as a prescribed person. \n \n \nExplanation.- Trader in this clause shall have the meaning as provided in \nclause (28D) of Part II of the Second Schedule.]   \n \n1[(116) The provisions of section 151 2[  ] and 236P shall not apply to The Prime \nMinister’s COVID-19 Pandemic Relief Fund-2020. \n \n3[   ] \n \n4[(118) The provisions of withholding taxes contained in the Income Tax \nOrdinance, 2001 (XLIX of 2001) shall not apply to Islamic Naya Pakistan \nCertificates Company Limited (INPCCL) as a recipient.  \n  \n (119)  The provisions of section 153(1)(a) shall with effect from the first day of \nJuly, 2020 not apply to distributors, dealers, wholesalers and retailers of locally \nmanufactured mobile phone devices as withholding agent.] \n \n5[(120)  The provisions of Divisions II and III of Part V of Chapter X and Chapter \nXII of the Ordinance for deduction or collection of withholding tax shall not apply to \nthe persons mentioned in Table 1 of clause (66) of Part I of the second schedule \nas recipients of payment: \n \nProvided that such persons shall continue to perform functions as \nwithholding and collecting agent under the aforesaid provisions.] \n \n                                            \n1 New clauses (116) and (117) added through Finance Act, 2020 dated 30th June, 2020  \n2 The expression “, 231A, 231AA and 236P“ omitted by the Finance Act 2021.  \n3 Clause (117) omitted by the Finance Act 2021. The omitted clause read  as follows: \n“(117)  The provisions of section 236P shall not apply at  the time of transfer of any sum to The \nPrime Minister’s   COVID-19   Pandemic   Relief   Fund- 2020.]” \n4 Clauses (118) and (119) added by the Finance Act, 2021. Earlier these clauses were inserted through \nTax Laws (Amendment) Ordinance, 2021.   \n5 Clause (120) added by the Finance Act, 2022.    \n\n\f\nSecond Schedule – Part IV____ __________________________ \n697 \n \n1[(121)   The provisions of section 151 shall not apply to the Prime Minister's Relief \nFund for Flood, Earthquake and other calamities with effect on and from the 5th \nAugust, 2022.  \n \n(122)  The provisions of section 236 shall not apply on the amount donated through \nSMS to the Prime Minister's Relief Fund for Flood, Earthquake and other calamities \nwith effect on and from the 5th day of August, 2022.  \n \n(123)  The provisions of section 148 shall for a period of 2[three months from the \n1st day of December, 2022] not apply to goods required and imported for relief \noperation for flood affectees, duly certified by the National Disaster Management \nAuthority or the Provincial Disaster Management Authority.  \n \n(124) The provisions of section 148 shall not apply to tomato (PCT heading \n0702.0000) and onion (PCT heading 0703.1000) imported till the 31st day of \nDecember, 2022.] \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n                                            \n1 Clauses (121), (122), (123) and (124) added by the Finance Act, 2023. Earlier these clauses were \nadded through S.R.O. Nos. 1590(I)/2022 dated 23.08.2022, 1634(I)/2022 dated 30.08.2022 and \n1639(I)/2022 dated 31.08.2022 respectively.   \n2 The words “ninety days” substituted through S.R.O. No. 72(I)/2023 dated 25.01.2023.    \n\n\f\nThird Schedule – Part I_______ __________________________ \n \n700 \nTHE THIRD SCHEDULE \n1[PART-I \nDEPRECIATION \n(See Section 22) \n \nDepreciation rates specified for the purposes of section 22 shall be, — \n                                            \n1 Substituted by the Finance Act, 2005. The substituted Part I read as follows: \nPART I \nDEPRECIATION \n(See Section 22) \n \n \nDepreciation rates specified for the purposes of section 22 shall be – \n \nClass \nof \nasset. \nDescription. \nRate per cent \nof the written \ndown value. \n \nBUILDINGS \n \nI \nBuilding (not otherwise specified). \n5  \n(General rate) \nII \nFactory, workshop, cinema, hotel, hospital. \n10 \nIII \nResidential quarters for labour. \n10 \n \nFURNITURE \n \nIV \nFurniture (including fittings). \n10 \n \nMACHINERY AND PLANT \n \nV \nMachinery and plant (not otherwise specified). \n10 \n(General rate) \nVI \nComputer hardware, including printer, monitor and \nallied items. \n30 \nVII \nTechnical or professional books. \n20 \nVIII \n(i) \n(ii) \nShips. \nNew. \nSecond hand. \nAge at time of purchase: \n(a)       Not more than ten years \n(b)      Ten or more years. \n \n5 \n \n \n10 \n20 \nIX \nMotor vehicles (all types) \n20 \nX \nAircraft, aero-engines and aerial photographic \napparatus. \n30 \nXI \nBelow ground installations in mineral oil concerns the \nincome of which is liable to be computed in \naccordance with the rules in Part I of the Fifth \nSchedule. \n100% \n \nXII \nBelow ground installations, including but not limited to \nthe cost of drilling, casing, cementing, logging and \ntesting of wells, in offshore mineral oil concerns the \nincome of which is liable to be computed in \naccordance with the rules in Part I of the Fifth \nSchedule. \n100 \nXIII \nOffshore platforms and production installation in \nmineral oil concerns the income of which is liable to \nbe computed in accordance with the rules in Part I of \nthe Fifth Schedule. \n20 \n \n\n\f\nThird Schedule – Part I _________________________________ \n699 \n \n \nI. \nBuilding (all types). \n \n10% \nII. \nFurniture (including fittings) and machinery \nand plant (not otherwise specified), Motor \nvehicles (all types), ships, technical or \nprofessional books. \n \n15% \nIII. \nComputer hardware including printer, monitor \nand allied items 1[,machinery and equipment \nused in manufacture of I.T. products], aircrafts \nand aero engines. \n \n30% \nIV. \nIn case of mineral oil concerns the income of \nwhich is liable to be computed in accordance \nwith the rules in Part-I of the Fifth Schedule. \n \n2[   ] \n \n(b)  \nOffshore platform and production \n \ninstallations. \n \n \n \n \n \n \n20%] \n3[V. \nA ramp built to provide access to persons with \ndisabilities not exceeding Rs.250,000 each. \n100%] \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n                                            \n1 Inserted by the Finance Act, 2006. \n2 Entry (a) of serial number IV of the Table omitted by the Finance Act, 2021. Earlier this amendment \nwas made through Tax Laws (Second  Amendment) Ordinance, 2021. The omitted entry read as \nfollows: \n“(a) Below ground installations  100%” \n3 Added by the Finance Act, 2010. \n\n\f\nThird Schedule – Part II and Part III_______________________ \n \n702 \nPART II \nINITIAL ALLOWANCE 1[AND FIRST YEAR ALLOWANCE] \n2[(3[See Sections 23, 4[   ] and 23B])] \n \n(1) \nThe rate of initial allowance under section 23 shall be 5[25]% 6[for plant and \nmachinery 7[  ] ]. \n \n8[(2)  The rate of First Year Allowance under 9[   ] 10[section 23B] shall be 90%. \n \n \nPART III \nPRE-COMMENCEMENT EXPENDITURE \n(See Section 25) \n \n \nThe rate of amortisation of pre-commencement expenditure under section \n25 shall be 20%. \n \n \n \n \n \n \n \n \n \n \n \n \n \n                                            \n1Added by the Finance Act, 2008. \n2The word and figure “section 23” substituted by the Finance Act, 2008. \n3 The words, figures and letter “See Sections 23 and 23A” substituted by the Finance Act, 2009. \n4 The expression “23A” by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. \n5 Substituted for 50% by the Finance Act, 2013. Earlier it was substituted for 40% by the Finance Act, \n2002. \n6Inserted by the Finance Act, 2012. \n7Words “and 7[15]% for buildings” omitted through Finance Act, 2019. \n8Added by the Finance Act, 2008. \n9 The expression “section 23A and” by the Finance Act, 2021. Earlier this amendment was made \nthrough Tax Laws (Second  Amendment) Ordinance, 2021. \n10Inserted by the Finance Act, 2009. \n\n\f\nFourth Schedule ____________ __________________________ \n \n703 \nTHE FOURTH SCHEDULE \n(See Section 99) \n \nRULES FOR THE COMPUTATION OF THE PROFITS AND GAINS OF \nINSURANCE BUSINESS \n \nProfits on Life Insurance to be Computed Separately \n \n1. \nThe profits and gains of a taxpayer carrying on life insurance business \nchargeable under the head “Income from Business” shall be computed separately \nfrom the taxpayer’s income from other business. 1[Income from other business \nshall be profit or loss before tax as per profit and loss account prepared under the \nInsurance Ordinance, 2000 (XXXIX of 2000), excluding any surplus appropriation \nmade during the year.] \n \nComputation of Profits and Gains of Life Insurance Business \n \n2[2. \nThe profits and gains of a life insurance business shall be the current year’s \nsurplus appropriated to profit and loss account prepared under the Insurance \nOrdinance, 2000 (XXXIX of 2000), as per advice of the Appointed Actuary, net of \nadjustments under sections 22(8), 23(8) and 23(11) of the Insurance Ordinance, \n2000 (XXXIX of 2000) so as to exclude from it any expenditure other than \nexpenditure which is, under the provisions of Part IV of Chapter III, allowed as a \ndeduction in computing profits and gains of a business to the extent of the \nproportion of surplus not distributed to policy holders.] \nComputing the Surplus under Rule 2 \n \n3. \n(1) \nThe following 3[provisions] shall apply in computing the surplus for the \npurposes of rule 2, namely:– \n \n(a) \nthe amounts paid to, or reserved for, or expended on behalf of \npolicy-holders  shall be allowed as a deduction; \n \n(b) \nany amount either written off or reserved in the accounts, or \nthrough the actuarial valuation balance sheet to meet \ndepreciation, or loss on the realization of investments shall be \n                                            \n1Added by the Finance Act, 2004. \n2 Rule (2) substituted by the Finance Act, 2004. The substituted rule (2) read as follows:  \n“2. \nThe profits and gains of a life insurance business shall be the annual average of the surplus \narrived at by adjusting the surplus or deficit disclosed by actuarial valuation made for the last inter-\nvaluation period ending before the tax year for which the assessment is to be made so as to exclude \nfrom it any surplus or deficit included therein which was made in any earlier inter-valuation period \nand any expenditure other than expenditure which is, under the provisions of Part IV of Chapter III, \nallowed as a deduction in computing the profits and gains of a business.” \n3The word “rules” substituted by the Finance Act, 2003. \n\n\f\nFourth Schedule_____________ __________________________ \n702 \n \nallowed as a deduction, and any sums taken credit for in the \naccounts or actuarial valuation balance sheet on account of \nappreciation, or gains on the realisation of investments 1[shall \nbe included in the surplus]; and \n \n(c) \nprofit on debt 2[accrued] in the inter-valuation period in respect \nof any securities of the Federal Government which have been \nissued or declared to be income tax-free shall not be excluded, \nbut shall be exempt from tax 3[  ]. \n \n \n(2) \nFor the purposes of clause (a) of sub-rule (1) – \n \n(a) \nin the first computation of the surplus, no account shall be taken \nof amounts referred to in the 4[said clause] to the extent to which \nthey are paid out, or in respect of any surplus brought forward \nfrom a previous inter-valuation period; and \n \n(b) \nif any amount reserved for policy-holders ceases to be so \nreserved, and is not paid to, or expended on behalf of policy-\nholders, the sums previously allowed as a deduction under this \nOrdinance 5[or the repealed Ordinance] shall be treated as part \nof the 6[respective statutory fund] for the tax year in which the \namount ceased to be so reserved. \n \n \n(3) \nFor the purposes of clause (b) of sub-rule (1), if it appears to the \nCommissioner, after consultation with the Securities and Exchange Commission \nof Pakistan, that the rate of profit on debt or other factors employed in determining \nthe liability in respect of outstanding policies is inconsistent with the valuation of \ninvestments so as artificially to reduce the surplus, the Commissioner may make \nsuch adjustment to the allowance for depreciation, or in respect of appreciation, of \nsuch investment as the Commissioner thinks reasonable. \n \n7[  ] \n                                            \n1 Inserted by the Finance Act, 2003. \n2The word “received” substituted by the Finance Act, 2004. \n3The words and figures “in accordance with Part VII of Chapter III” omitted by the Finance Act, 2003. \n4 The word ”sub-clause” by the Finance Act, 2003. \n5 Inserted by the Finance Act, 2003. \n6The word “surplus” by the Finance Act, 2004. \n7Rule (4) omitted by the Finance Act, 2004. The omitted rule (4) read as follows:  \n“Adjustment of Tax Paid by Deduction at Source \n4. \nWhere, for any tax year, an assessment of the profits and gains of life insurance business is \nmade in accordance with the annual average of a surplus disclosed by a valuation for an inter-\nvaluation period exceeding twelve months, then, in computing the tax due for that year, no credit \nshall be allowed for the tax paid in the tax year, but credit shall be given for the annual average of \nthe tax paid by deduction 7[or otherwise on profit on debt received on any security of the Federal \nGovernment, a Provincial Government, a local authority or a company] during the period.” \n\n\f\nFourth Schedule_____________ __________________________ \n703 \n \nGeneral Insurance \n \n5. \nThe profits and gains of any business of insurance (other than life insurance) \nshall be taken to be the balance of the profits disclosed by the annual accounts \nrequired under the Insurance Ordinance, 2000 (XXXIX of 2000), to be furnished to \nthe Securities and Exchange 1[Commission] of Pakistan subject to the following \nadjustments – \n \n(a) \nany expenditure or allowance, or any reserve or provision for \nany expenditure, or the amount of any tax deducted at source \nfrom dividends or profit on debt received which is not deductible \nin computing the income chargeable under the head “Income \nfrom Business” shall be excluded; \n \n \n2[(b)  subject to the provisions of rule 6A, any amount of investment  \nwritten off shall be allowed as a deduction, but any amount \ntaken to reserve to meet depreciation of investments shall not \nbe allowed as a deduction, and any sums taken credit for in the \naccounts on account of appreciation of investment shall not be \ntreated as part of the profits and gains, unless these have been \ncrystallized as gains or losses on the realization of investments;] \n \n(c) \nno deduction shall be allowed for any expenditure, allowance, \nreserve, or provision in excess of the limits laid down in the \nInsurance Ordinance, 2000 (XXXIX of 2000), unless the excess \nis allowed by the 3[Securities] and Exchange Commission and \nis incurred in deriving income chargeable to tax 4[; and] \n \n5[(d)  no deduction shall be allowed for any expenditure incurred on \naccount of insurance premium or re-insurance premium paid to \nan overseas insurance or re-insurance company or a local agent \nof an overseas insurance company until tax at the rate of 5% is \nwithheld on the gross amount of insurance or re-insurance \npremium.] \n                                            \n1The word “Commissioner” substituted by the Finance Act, 2002. \n2Sub-rule (b) substituted by the Finance Act, 2008. The substituted sub-rule (b) read as follows: \n“(b) \nany amount either written off or taken to reserve to meet depreciation or loss on \nthe realization of investments shall be allowed as a deduction, and any sums \ntaken credit for in the accounts on account of appreciation, or gains on the \nrealization of 2[investments] shall be treated as part of the profits and gains, \nprovided the Commissioner considers the amount to be reasonable; and” \n3The word “Security” substituted by the Finance Act, 2003. \n4Full stop substituted by the Finance Act, 2008. \n5Added by the Finance Act, 2008. \n\n\f\nFourth Schedule_____________ __________________________ \n704 \n \nMutual Insurance Association \n \n6. \nThese rules shall also apply to the assessment of the profits and gains of \nany business of insurance carried on by a mutual insurance association and such \nprofits and gains shall be chargeable to tax under the head “Income from \nBusiness”. \n \n1[   ]  \n \n2[3[6B.In computing income under this Schedule, there shall be included capital \ngains on disposal of shares and dividend of listed companies, vouchers of Pakistan \nTelecommunication corporation, modaraba certificate or instruments of \nredeemable capital and derivative products and shall be taxed at the rates \nspecified in Division II of Part I of First Schedule.”] \n \n4[   ]  \n \n5[(6C) Notwithstanding anything contained in this Ordinance, where loss on \ndisposal of securities is sustained in a tax year, the loss shall be set off only against \nthe gain from any other securities chargeable to tax under Rule 6B and no loss \nshall be carried forward to the subsequent tax year.] \n                                            \n1 Rule (6A) omitted by the Finance Act, 2015. The omitted rule (6) read as follows:- \n“(6A)Exemption of Capital Gains from the sale of shares.- In computing income under this \nSchedule, there shall not be included “capital gains”, being income from the sale of modaraba \ncertificates or any instrument of redeemable capital as defined in the Companies Ordinance, 1984 \n(XLVII of 1984), listed on any stock exchange in Pakistan or shares of a public company (as defined \nin sub-section (47) of section 2) and the Pakistan Telecommunications Corporation vouchers issued \nby the Government of Pakistan, derived up to tax year ending on the thirtieth day of June, 2010.” \n2Added by the Finance Act, 2010. \n3 Rule 6B substituted by the Finance Act, 2016. Substituted rule read as follows:- \n “(6B) Capital gains on disposal of shares of listed companies, vouchers of Pakistan \nTelecommunication corporation, modaraba certificate or instruments of redeemable capital and \nderivative products shall be taxed at the following rates: \n \n3[“S.No. \nPeriod \nTax Year 2015 \nTax Year 2016 \n(1) \n(2) \n(3) \n(4) \n1 \nWhere holding period of a security \nis less than twelve months \n12.5% \n15% \n2 \nWhere holding period of a security \nis twelve months or more but less \nthan twenty four months \n10% \n12.5% \n3 \nWhere holding period of a security \nis twenty four months or more but \nless than four years; and”] \n0% \n7.5% \n \n4Proviso omitted by the Finance Act, 2015. The omitted proviso read as follows:- \n“Provided thatthis rule shall not apply to the securities held for a period of more than twelve \nmonths.” \n5Added by the Finance Act, 2010. \n\n\f\nFourth Schedule_____________ __________________________ \n705 \n \n1[6D. The provisions of section 4B shall apply to the taxpayers under this schedule \nand taxed at the rates specified in Division IIA of Part I of the First Schedule.”] \n \n2[6DA. The provisions of section 4C shall apply to the taxpayers under this \nSchedule and shall be taxed at the rates specified in Division IIB of Part I of the \nFirst Schedule from tax year 2022 onwards.]  \n \n3[(6DB) The provisions of section 99D shall apply to the taxpayers under this \nSchedule.] \n \n4[6E. Notwithstanding anything contained in this Schedule, the Commissioner shall \nbe authorized to examine and amend the amount of income as disclosed in the \nfinancial statement presented to the Securities and Exchange Commission of \nPakistan with respect to commission paid and claimed for losses.]  \n \nDefinitions  \n \n7. \nIn this Schedule, – \n \n“investments” includes all forms of shares, debentures, bonds, deposits and \nother securities, derivative instruments, and includes immovable property \nwhether or not occupied by the insurer;  \n \n“life insurance business” means life insurance business as defined in section \n4 of the Insurance Ordinance, 2000 (XXXIX of 2000);5[and] \n \n“Securities and Exchange Commission of Pakistan” means the Securities \nand Exchange Commission established under the Securities and Exchange \nCommission of Pakistan Act, 1997 (XLII of 1997) 6[:] \n \n7[“Securities” for the purposes of Rule 6B means shares of a public \ncompany, vouchers of Pakistan Telecommunication Corporation, Modaraba \nCertificates or instruments of redeemable capital and derivative products.”] \n \n8 [  ] \n \n                                            \n1 Inserted by the Finance Act, 2015. \n2 Rule 6DA inserted by the Finance Act, 2022. \n3 Rule (6DB) added by the Finance Act, 2023. \n4New clause (6E) inserted through Finance Act, 2019. \n5 Inserted by the Finance Act, 2002 \n6 Full stop substituted by the Finance Act, 2010. \n7 Added by the Finance Act, 2010. \n8Paragraph four omitted by the Finance Act, 2002. The omitted fourth paragraph of the Fourth \nSchedule read as under: \n“Securities and Exchange Commissioner of Pakistan” means the Securities and Exchange \nCommissioner of Pakistan established under the Securities and Exchange Commission of Pakistan \nAct, 1997 (XLII of 1997).” \n\n\f\nFifth Schedule – Part I________ __________________________ \n \n708 \nTHE FIFTH SCHEDULE \n(See Section 100) \n \nPART I \n \nRULES FOR THE COMPUTATION OF THE PROFITS AND GAINS FROM THE \nEXPLORATION AND PRODUCTION OF PETROLEUM \n \nExploration and Production of Petroleum a Separate Business \n \n1. \nWhere any person carries on, or is treated as carrying on, under an \nagreement with the Federal Government, any business which consists of, or \nincludes, the exploration or production of petroleum in Pakistan or setting up \nrefineries at Dhodak and Bobi fields, income of exploration and production \ncompanies from pipeline operations, and manufacture and sale of liquified \npetroleum gas or compressed natural gas, such business or part thereof, as the \ncase may be, shall be, for the purposes of this Ordinance, treated as a separate \nbusiness undertaking (hereinafter referred to as “such undertaking”) and the profits \nand gains of such undertaking shall be computed separately from the income, \nprofits, or gains from any other business, if any, carried on by the person. \n \nComputation of Profits \n \n2 \n(1) \nSubject to the provisions of this Part, the profits and gains of such \nundertaking 1[shall be] computed in the manner applicable to income, profits and \ngains chargeable under the head “Income from Business”. \n \n \n(2) \nWhere such person incurs any expenditure on searching for or \ndiscovering and testing a petroleum deposit or winning access thereto but the \nsearch, exploration, enquiry upon which the expenditure is incurred is given up \nbefore the commencement of commercial production, the expenditure allocable to \na surrendered area or to the drilling of a dry-hole shall be treated as lost at the time \nof the surrender of the area or the completion of the dry-hole, as the case may be. \n \n \n(3) \nWhere the agreement provides that any portion of the expenditure is \ntreated as lost under sub-rule (2) (hereinafter referred to as the “said loss”) and is \nallowed against any income of such undertaking, it shall be allowed in either of the \nfollowing ways as may be provided for in the agreement, namely: — \n \n(a) \nThe said loss in any year shall be set off against the income of \nthat year chargeable under the head “Income from Business” or \nany income (other than income from dividends) chargeable \nunder any other head and where the loss cannot be wholly set \noff in this manner the portion not so set off shall be carried \nforward to the following year and set off in the same manner and \n                                            \n1The word “are” substituted by the Finance Act, 2003. \n\n\f\nFifth Schedule – Part I________ __________________________ \n707 \n \nso on, but no loss shall be carried forward for more than six \nyears; or \n \n(b) \nthe said loss in any year shall be set off against the income of \nsuch undertaking of the tax year in which commercial production \nhas commenced and where the loss cannot be wholly set off \nagainst the income of such undertaking of that year, the portion \nnot set off against the income, if any, of such undertaking of that \nyear, and if it cannot be wholly so set off the amount of loss not \nso set off shall be carried forward to the following year, and so \non, but no loss shall be carried forward for more than ten years. \n \n \n(4) \nAfter the commencement of commercial production, all expenditure \nincurred prior thereto and not 1[treated as] lost under sub-rule (2) and not \nrepresented by physical assets in use at the time the commercial production shall \nbe allowed as a deduction, so, however, that the portion of such deduction to be \nso allowed in any year shall be such amount not exceeding ten per cent of the \naggregate amount deductible in respect of 2[onshore] areas, and not exceeding \ntwenty five per cent for offshore areas, as may be selected by the taxpayer. \n \n \n(5) \nAny expenditure, including a royalty paid to the Federal Government \nby an onshore petroleum exploration and production undertaking on, or after, the \nfirst day of July 2001 (not being in the nature of capital expenditure or personal \nexpenses of the taxpayer) laid out or expended after the commencement of \ncommercial production wholly and exclusively for the purpose of the business of \nproduction and exploration of petroleum carried on by such undertaking shall be \nallowed as a deduction, provided that – \n \n(a) \nno deduction shall be allowed in respect of such expenditure \nincurred in the acquisition of depreciable assets to which section \n22 applies or in the acquisition of an intangible to which section \n24 applies; \n \n(b) \n3[deductions under sections 22, 23 and 24 shall be admissible] \nin respect of assets referred to in clause (a); \n \n(c) \na depreciation deduction shall also be allowed under section 22 \nin respect of such expenditure incurred on the acquisition of the \nphysical assets acquired before the commencement of \ncommercial production and were being used by such \nundertaking on and after that date, as if such assets had been \nacquired at the time of the commencement of commercial \nproduction at their original cost, as reduced by the amount of \n                                            \n1 The words “deemed to be” substituted by the Finance Act, 2003. \n2The words “inshore” substituted by the Finance Act, 2003. \n3The words, comma and figures “sections 22, 23 and 24 apply” substituted by the Finance Act, 2003. \n\n\f\nFifth Schedule – Part I________ __________________________ \n708 \n \ndepreciation deduction, if any, previously allowed to be \ndeducted under this Ordinance. \n \n \n(6) \nIf, in any year, the deductions allowed Part IV of Chapter III and \nsub-rules (3) and (4) exceed the gross receipts from the sale of petroleum \nproduced in Pakistan, such excess shall be set off against other income (not being \ndividends) and carried forward in the manner and subject to the limitations in \nsection 57, so however that no portion of such excess shall be carried forward for \nmore than six years. \n \n \n(7) \nThe limitation of six years specified in 1[sub-rule] (6) shall not apply to \ndepreciation allowed to a person carrying on the business of offshore petroleum \nexploration and production, in respect of any machinery, plant or other equipment \nused in such exploration or production. \n \n \n(8) \nFor the purposes of section 22, where any asset used by a person in \nthe exploration and production of petroleum is exported or transferred out of \nPakistan, the person shall be treated as having made a disposal of the asset for a \nconsideration received equal to the cost of the asset as reduced by any \ndepreciation deductions allowed under this Ordinance (other than an initial \nallowance under section 23). \n \nDepletion Allowance \n \n3. \nIn determining the income of such undertaking for any year ending after the \ndate on which commercial production has commenced, an allowance for depletion \nshall be made equal to fifteen per cent of the gross receipts representing the well-\nhead value of the production, but not exceeding fifty per cent of the profits or gains \nof such undertaking before the deduction of such allowance. \n \nLimitation on Payment to Federal Government and Taxes \n \n4. \n(1) \nThe aggregate of the taxes on income and other payments excluding \na royalty as specified in the Pakistan Petroleum2[exploration]   (Production) Rules, \n1949 or the Pakistan Petroleum (Exploration and Production) Rules, 1986 and paid \nby an onshore petroleum and production undertaking on, or after, the first day of \nJuly 2001 to the Government in respect of the profits or gains derived from such \nundertaking for a tax year shall not exceed the limits provided for in the agreement, \nprovided the 3[said aggregate shall not be] less than fifty per cent of the profits or \ngains derived by an onshore petroleum exploration and production undertaking \nand forty per cent of the profits or gains derived by an offshore petroleum \nexploration and production undertaking, before deduction of the payment to the \nFederal Government. \n                                            \n1The word “sub-section” substituted by the Finance Act, 2003. \n2Inserted by the Finance Act, 2003 \n3 The words “aggregate is not” substituted by the Finance Act, 2003. \n\n\f\nFifth Schedule – Part I________ __________________________ \n709 \n \n \n(2) \nIn respect of any tax year commencing on, or after, the first day of \nJuly, 2002, the aggregate referred to in sub-clause (1) shall not be less than forty \nper cent of the profit or gains derived by an onshore petroleum exploration and \nproduction undertaking before the deduction of payment excluding royalty paid by \nan onshore 1[petroleum exploration and production undertaking] to the Federal \nGovernment. \n \n \n(3) \nIf, in respect of any tax year, the aggregate of the taxes on income \nand payments to the Federal Government is greater or less than the amount \nprovided for in the agreement, an 2[additional amount of tax] shall be payable by \nthe taxpayer, or an abatement of tax shall be allowed to the taxpayer, as the case \nmay be, so as to make the aggregate of the taxes on income and payments to the \nFederal Government equal to the amount provided for in the agreement. \n \n \n(4) \nIf, in respect of any year, the payments to the Federal Government \nexceed the amount provided for in the agreement, so much of the excess as \nconsists of any tax or levy referred to in sub-clause (b) of clause (3) of rule 6 shall \nbe carried forward and treated, for the purposes of this rule, as payments to the \nFederal Government for the succeeding year, provided that the whole of the \npayments to the Federal Government exceeding the amount provided for in such \nagreement may be carried forward if so provided for in any agreement with a \ntaxpayer made before the first day of 1970. \n \n \n3[(4A) Notwithstanding anything contained in this Schedule, a person, for tax \nyear 2012 and onward, may opt to pay tax at the rate of forty per cent of the profits \nand gains, net of royalty, derived by a petroleum exploration and production \nundertaking: \n \nProvided that this option shall be available subject to withdrawal \nof appeals, references and petitions on the issue of tax rate pending \nbefore any appellate forum: \n \nProvided further that the outstanding tax liability created under \nthis Ordinance up to tax year 2011 is paid by the 30th June, 2012: \n \n \n \n \nProvided also that this option is available only for one time and \n \n \nshall be irrevocable.] \n \n4[4A.Decommissioning cost.— With effect from the Tax Year 2010, \n“Decommissioning Cost” as certified by a Chartered Accountant or a Cost \nAccountants, in the manner prescribed, shall be allowed over a period of ten years \n                                            \n1 The word “company” substituted by the Finance Act, 2003. \n2 The words “additional tax” substituted by the Finance Act, 2003. \n3Added by the Finance Act, 2012.  \n4 Inserted by the Finance Act, 2010. \n\n\f\nFifth Schedule – Part I________ __________________________ \n710 \n \nor the life of the development and production or mining lease whichever is less, \nstarting from the year of commencement of commercial production or commenced \nprior to the 1st July, 2010, deduction for decommissioning cost as referred earlier \nshall be allowed from the Tax Year 2010 over the period of ten years or the \nremaining life of the development and production or mining lease, whichever is \nless.] \n \n1[4AA. The provisions of section 4B shall apply to the tax payers under this Part \nand taxed at the rates specified in Division IIA of Part I of the First Schedule.] \n \n2[4AB. The provisions of section 4C shall apply to the taxpayers under this \nschedule and shall be  taxed at the rates specified in Division IIB of Part I of the \nFirst Schedule from tax year 2022 onwards.] \n \n3[(4AC) The provisions of section 99D shall apply to the taxpayers under this \nSchedule.] \n \nProvision Relating to Rules \n \n5. \nThe 4[Board]may make rules for the purposes of any matter connected with, \nor incidental to the operation of this Part. \n \nDefinitions \n \n6. \nIn this Part, – \n \n(1) \n“agreement” means an agreement entered into between the Federal \nGovernment and a taxpayer for the exploration and production of \npetroleum in Pakistan; \n \n(2) \n“commercial production” means production as determined by the \nFederal Government; \n \n(3) \n“payments to the Federal Government” means amounts payable to the \nFederal Government or to any Federal Governmental authority in \nPakistan – \n \n(a) \nin respect of royalties as specified in the Pakistan Petroleum \n(Production) \nRules, \n1949, or the \nPakistan \nPetroleum \n(Exploration and Production) Rules, 1986; and \n \n                                            \n1Inserted by the Finance Act, 2015. \n2 Rule 4AB inserted by the Finance Act, 2022. \n3 Rule (4AC) inserted by the Finance Act, 2023. \n4The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nFifth Schedule – Part I________ __________________________ \n711 \n \n(b) \nin respect of any tax or levy imposed in Pakistan peculiarly \napplicable to oil production or to extractive industries or any of \nthem and not generally imposed upon all industrial and \ncommercial activities; \n \n(4) \n“petroleum” means crude oil, natural gas, and case-head petroleum \nspirits as defined in the Pakistan Petroleum (Production) Rules, 1949, \nor the Pakistan Petroleum (Exploration and Production) Rules, 1986, \nbut does not include refined petroleum products; \n \n(5) \n“surrender” means the termination of rights with respect to an area \nincluding the expiration of rights according to the terms of an \nagreement; \n \n(6) \n“surrendered area” means an area with respect to which the rights of \nthe person have terminated by surrender or by assignment or by \ntermination of the business; \n \n(7) \n“Taxes on income” and “tax” includes income tax, but does not include \npayments to the Federal Government; and \n \n(8) \n“well-head value” shall have the meaning assigned to it in the \nagreement between the Federal Government and the taxpayer, and in \nthe absence of any such definition in the agreement, the meaning \nassigned to it in the Pakistan Petroleum (Production) Rules, 1949, or \nthe Pakistan Petroleum (Exploration and Production) Rules, 1986. \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n\n\f\nFifth Schedule – Part II________ __________________________ \n \n714 \nPART II \n \nRULES FOR THE COMPUTATION OF THE PROFITS AND GAINS  \nFROM THE EXPLORATION AND EXTRACTION OF MINERAL DEPOSITS \n(OTHER THAN PETROLEUM) \n \nExploration and Extraction of Mineral Deposits a Separate Business \n \n1. \nWhere any person carries on, or is treated as carrying on, any business \nwhich consists of or includes the exploration or extraction of mineral deposits  of a \nwasting nature (other than petroleum) in Pakistan, such business or part thereof, \nas the case may be, shall be, for the purposes of this Ordinance 1[or the repealed \nOrdinance], treated as a separate undertaking (hereinafter referred to as “such \nundertaking”) and the profits and gains of such undertaking shall be computed \nseparately from the income, profits and gains from any other business, if any, \ncarried on by the person. \n \nComputation of Profits \n \n2. \n(1) \nSubject to the provisions of this Part, the profits and gains of such \nundertaking shall be computed in the manner applicable to income, profits and \ngains chargeable under the head “Income from Business”. \n \n \n(2) \nAll expenditure on prospecting and exploration incurred by such \nundertaking up to the date of commercial production shall be, to the extent to which \nit cannot be set off against any other income of such undertaking, treated as a loss. \n \n(3) \nThe loss referred to in sub-rule (2) shall be carried forward and set off \nagainst the income of such undertaking after the commencement of commercial \nproduction, so, however, that if it cannot be wholly set off against the income of \nsuch undertaking of the tax year in which the commercial production had \ncommenced, the portion not so set off shall be carried forward to the following year \nand so on, but no such loss shall be carried forward for more than ten years \nbeginning with the year in which commercial production commenced. \n \n \n(4) \nAfter the commencement of commercial production, depreciation in \nrespect of machinery and plant for extracting the ore shall be allowed as a \ndeduction from the profits and gains of the tax year in which they are used for the \nfirst time in an amount equal to the original cost of such asset and the provisions \nof section 22 shall apply accordingly. \n \n2[2A. The provisions of section 4B shall apply to the taxpayers under this Part and \ntaxed at the rates specified in Division IIA of Part I of the First Schedule.] \n                                            \n1 Inserted by the Finance Act, 2003. \n2 Inserted by the Finance Act, 2015. \n\n\f\nFifth Schedule – Part II________ __________________________ \n713 \n \nDepletion Allowance \n \n3. \n(1) \nIn determining the profits and gains of such undertaking for any year \nan additional allowance (hereinafter referred to as the “depletion allowance”) shall \nbe made equal to twenty per cent of the taxable income of such undertaking \n(before the deduction of such allowance). \n \n \n(2) \nNo deduction under sub-rule (1) shall be made unless an amount \nequal to the depletion allowance is set apart and left as a reserve to be utilised for \nthe development and expansion of such undertaking. \n \n \n(3) \nWhere a depletion allowance is made in any tax year and \nsubsequently it is utilised for any purpose contrary to the provisions of sub-rule (2), \nthe amount originally allowed under this Ordinance shall be treated as having been \nwrongly allowed and the Commissioner may, notwithstanding anything contained \nin the Ordinance, recompute the taxable income of the taxpayer for the relevant \ntax years and the provisions of section 122 shall apply, so far as may be, thereto, \nthe period of five years specified in the section being reckoned from the end of the \ntax year 1[  ] in which the amount was so utilised. \n \n2[   ] \n \nProvisions Relating to Rules \n \n5. \nThe 3[Board] may make rules providing for any matter connected with, or \nincidental to, the operations of this Part. \n \n                                            \n1 The words “relevant to the tax year” omitted by the Finance Act, 2003. \n2 Rule 4 omitted by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. The omitted rule read as follows: \n“Tax Exemption of Profits from Refining or Concentrating Mineral Deposits \n4. \n(1) \nWhere such undertaking is also engaged in the business of refining or concentrating in \nPakistan the mineral deposits extracted by it in Pakistan, so much of the profits and gains (hereinafter \nreferred to as the “said amount”) derived from such business as does not exceed ten per cent of the \ncapital employed in such business (such capital being computed in accordance with such rules as \nmay be made by the 2[Board] for the purposes of this rule) shall be exempt from tax. \n(2) Where the profits and gains of such business computed for any tax year cover a period \nwhich is less or more than one year, the amount of profits and gains exempt under sub-rule (1) shall \nbe the amount which bears the same proportion to the said amount of profits as the said period bears \nto a period of one year. \n \n(3) \nThe profits and gains of the business to which this rule applies shall be computed in \naccordance with Part IV of Chapter III. \n \n(4) \nNothing contained in this rule shall apply to an undertaking formed by the splitting up or \nreconstruction or reconstitution of business already in existence or by the transfer to a new business \nof any building, machinery, or plant used in a business which was carried on before the 1st day of \nJuly, 1975. \n(5) The provisions of this rule shall apply to the tax year 2[  ] in which commercial production \nis commenced or the loss or allowance, if any, under sub-rules (3) or (4) of rule 2, as the case may \nbe, has been set off or deducted in full, whichever is the latter, and for the next following four years. \n3 Substituted by the Finance Act, 2007. \n\n\f\nFifth Schedule – Part II________ __________________________ \n714 \n \nDefinitions \n \n6. \nIn this Part, – \n \n(1) “commercial production” means production as determined by the \nCommissioner; and \n \n(2) “petroleum” has the same meaning as in clause (4) of rule 6 of Part I. \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n\n\f\nSixth Schedule – Part I________ __________________________ \n \n717 \nTHE SIXTH SCHEDULE \n \nPART I \nRECOGNISED PROVIDENT FUNDS \n[See sections 2( 1[48] ) and 21(e)] \n \n1. \nRecognition of provident funds.— (1) The Commissioner may accord \nrecognition to any provident fund which, in his opinion, complies with the \nrequirements of rule 2, and may at any time, withdraw such recognition if, in his \nopinion, the circumstances of the fund cease to warrant the continuance of the \nrecognition. \n \n \n(2) \nAn order according recognition shall take effect on such date as the \nCommissioner may fix in accordance with such rules as the 2[Board] may make in \nthis behalf, such date not being later than the last day of the financial year in which \nthe order is made. \n \n \n(3) \nAn order according recognition to a provident fund shall not, unless \nthe Commissioner otherwise directs, be affected by the fact that the fund is \nsubsequently amalgamated with another provident fund on the occurrence of an \namalgamation of the undertakings in connection with which the two funds are \nmaintained or that it subsequently absorbs the whole or a part of another provident \nfund belonging to an undertaking which is wholly or in part transferred to, or \nmerged in, the undertaking of the employer maintaining the first-mentioned fund. \n \n \n(4) \nAn order withdrawing recognition shall take effect from such date as \nthe Commissioner may fix. \n \n \n(5) \nThe Commissioner shall neither refuse nor withdraw recognition of \nany provident fund, unless he has given to the trustees of the fund a reasonable \nopportunity of being heard. \n \n2. \nConditions for approval. — (1) In order that a provident fund may receive \nand retain recognition it shall satisfy the conditions hereinafter specified and any \nother conditions which the 3[Board] may, by rules, prescribe  - \n \n(a) \nall employees shall be employed in  Pakistan , or shall be employed \nby an employer whose principal place of business is in Pakistan: \n \n                                            \n1 The figure “49” substituted by the Finance Act, 2005. \n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n3 The words “Central Board of Revenue” substituted by the Finance Act, 2007.  \n\n\f\nSixth Schedule – Part I________ __________________________ \n716 \n \nProvided that the Commissioner may, if he thinks fit, and subject \nto such conditions, if any, as he thinks proper to attach to the \nrecognition, accord recognition to a fund maintained by an employer \nwhose principal place of business is not in Pakistan, provided the \nproportion of employees employed outside Pakistan does not exceed \nten per cent; \n \n(b) \nthe contributions of an employee in any year shall be a definite \nproportion of his salary for that year, and shall be deducted by the \nemployer from the employee's salary in that proportion, at each \nperiodical payment of such salary in that year, and credited to the \nemployee's individual account in the fund: \n \nProvided that an employee, who retains his employment while \nserving in armed forces of Pakistan or when taken into, or employed \nin, the national service under any law for the time being in force, may, \nwhether he receives from the employer any salary or not contribute to \nthe fund during his service in the armed forces of Pakistan or while so \ntaken into, or employed in, the national service a sum not exceeding \nthe amount he would have contributed had he continued to serve the \n1[employer]; \n \n(c) \nthe contributions of an employer to the individual account of an employee \nin any year shall not exceed the amount of the contributions of the \nemployee in that year, and shall be credited to the employee's individual \naccount at intervals not exceeding one year: \n \nProvided that, subject to any rules which the 2[Board] may make \nin this behalf, the Commissioner may, in respect of any particular fund, \nrelax the provisions of this clause — \n \n(i) \nso as to permit the payment of larger contributions by an \nemployer to the individual accounts of employees whose \nsalaries do not, in each case, exceed five hundred rupees \nper month; \n \n(ii) \nso as to permit the crediting by employers to the individual \naccounts of employees of periodical bonuses or other \ncontributions 3[  ] of a contingent nature, where the \ncalculation and payment of such bonuses or other \ncontributions is provided for on definite principles by the \nregulations of the fund; \n                                            \n1The word “employers” substituted by the Finance Act, 2003. \n2 The words “Central Board of Revenue” ssubstituted by the Finance Act, 2007. \n3The words “is provided for on definite principles by the regulations” omitted by the Finance Act, \n2003. \n\n\f\nSixth Schedule – Part I________ __________________________ \n717 \n \n  \n(d) \nthe employer shall not be entitled to recover any sum \nwhatsoever from the fund, save in cases where the employee is \ndismissed for misconduct or voluntarily leaves his employment \notherwise than on account of ill-health or other unavoidable \ncause before the expiration of the term of service specified in \nthis behalf in the regulations of the fund: \n \nProvided that in such cases the recoveries made by the \nemployer shall be limited to the contributions made by him to \nthe individual account of the employee, and to interest credited \nin respect of such contributions in accordance with the \nregulations of the fund and accumulations thereof; \n \n(e) \nthe fund shall be vested in two or more trustees or in the Official \nTrustees under a trust which shall not be recoverable save with \nthe consent of all the beneficiaries; \n \n(f) \nthe fund shall consist of contributions as above specified, \nreceived by the trustees, or accumulations thereof, and of \ninterest credited in respect of such contributions and \naccumulations, and of securities purchased therewith and of \nany capital gains arising from the transfer of capital assets of \nthe fund, and of no other sums; \n \n(g) \nthe accumulated balance due to an employee shall be payable \non the day he ceases to be an employee of the employer \nmaintaining the 1[fund]: \n \nProvided that notwithstanding anything contained in \nclause (f) or (g):— \n \n(i) \nat the request made in writing by the employee who \nceases to be an employee of the employer maintaining \nthe fund, the trustees of the fund may consent to retain \nthe whole or any part of the accumulated balance due to \nthe employee to be drawn by him at any time on demand; \n \n(ii) \nwhere the accumulated balance due to an employee who \nhas ceased to be an employee is retained in the fund in \naccordance with the  preceding clause, the fund may \nconsist also of interest in respect of such accumulated \nbalance; \n                                            \n1The word “funds” substituted by the Finance Act, 2003. \n\n\f\nSixth Schedule – Part I________ __________________________ \n718 \n \n(iii) \nthe fund may also consist of any amount transferred from \nthe individual account of an employee in any recognised \nprovident fund maintained by his former employer and the \ninterest in respect thereof; \n \n(h) \nsave as provided in clause (g) or in accordance with such \nconditions and restrictions as the Central Board of Revenue \nmay, by rules, specify, no portion of the balance to the credit of \nan employee shall be payable to him: \n \nProvided that in order to enable an employee to pay the \namount of tax assessed on his total income as determined \nunder sub-rule (4) of rule 7, he shall be entitled to withdraw from \nthe balance to his credit in the recognised provident fund a sum \nnot exceeding the difference between such amount and the \namount to which he would have been assessed if the \ntransferred balance referred to in sub-rule (2) of rule 7 had not \nbeen included in his total income. \n \n3. \nEmployer's annual contributions, when deemed to be income received \nby employee. —That portion of the annual accretion in any year to the balance at \nthe credit of an employee participating in a recognised provident fund as consists \nof - \n \n(a) \ncontributions made by the employer in excess of 1[one-tenth of] \nthe salary 2[or Rs.3[150,000], whichever is low] of the employee; \nand \n \n(b) \ninterest credited on the balance to the credit of the employee in \nso far as it exceeds one-third of the salary of the employee or is \nallowed at a rate exceeding such rate as may be fixed by the \nFederal Government in this behalf by notification in the official \nGazette, shall be 4[treated]to have been received by the \nemployee in that year and shall be included in his total income \nfor that year and shall be liable to income tax. \n \n4. \nExclusion from total income of accumulated balance. — (1)  Subject to \nsuch rules as may be made by the 5[Board] in this behalf, the accumulated balance \ndue and becoming payable to an employee participating in a recognised provident \nfund shall be excluded from the computation of his total income. \n                                            \n1The words “one-twelfth of” substituted by the Finance Act, 2002. \n2Inserted by the Finance Act, 2008. \n3The figure “100,000” substituted by the Finance Act, 2016. \n4The word “deemed” substituted by the Finance Act, 2002. \n5 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nSixth Schedule – Part I________ __________________________ \n719 \n \n \n \n(2) \nThe provisions of sub-rule (1) shall also apply where, on the cessation \nof his employment, the employee obtains employment with any other employer \nand the accumulated balance due and becoming payable to him is transferred to \nhis individual account in any recognised provident fund maintained by such other \nemployer. \n \n5. \nTax on accumulated balance. — Where the accumulated balance due to \nan employee participating in a recognised provident fund is included in his total \nincome, the Commissioner shall calculate the total of the various sums of tax which \nwould have been payable by the employee in respect of his total income for each \nof the years concerned if the fund had not been a recognised provident fund and \nthe amount by which such total exceeds the total of all sums paid by, or on behalf \nof such employee by way of tax for such years shall be payable by the employee \nin addition to any other tax for which he may be liable for the income year in which \nthe accumulated balance due to him becomes payable.  \n \n6. \nDeduction at source of tax payable on accumulated balance.— The \ntrustees of a recognised provident fund, or any person authorised by the \nregulations of the fund to make payment of accumulated balance due to \nemployees shall, in cases where rule 5 applies, at the time an accumulated \nbalance due to an employee is paid, deduct therefrom the amount payable under \nthat rule and the provisions of Part V of Chapter X shall, so far as may be, apply \nas if the accumulated balance were income chargeable under the head \"Salary\". \n \n7. \nTreatment of balance in newly recognised provident fund. — (1) Where \nrecognition is accorded to a provident fund with existing balance, an account shall \nbe made of the fund up to the day immediately preceding the day on which the \nrecognition takes effect showing the balance to the credit of each employee on \nsuch day and containing such further particulars as the Central Board of Revenue \nmay prescribe. \n \n \n(2) \nThe account referred to in sub-rule (1) shall also show in respect of \nthe balance to the credit of an employee the amount thereof which is to be \ntransferred to that employee's account in the  recognised provident fund, and such \namount (hereinafter called his `transferred balance') shall be shown as the balance \nto his credit in the recognised provident fund on the date on which the recognition \nof the fund takes effect, and the provisions of sub-rule (4) and the proviso to clause \n(h) of rule 2 shall apply thereto. \n \n \n(3) \nAny portion of the balance to the credit of an employee in the existing \nfund which is not transferred to the recognised fund shall be excluded from the \naccounts of the recognised fund and shall be liable to income tax in accordance \nwith the provisions of this Ordinance, other than this Part. \n \n\n\f\nSixth Schedule – Part I________ __________________________ \n720 \n \n \n(4) \nSubject to such rules as the 1[Board] may make in this behalf, the \nCommissioner shall make a calculation of the aggregate of all sums comprised in a \ntransferred balance which would have been liable to income-tax if this Part had been \nin force from the date of the institution of the fund, without regard to any tax which may \nhave been paid on any sum, and such aggregate, if any, shall be deemed to be income \nreceived by the employee in the income year in which the recognition of the fund takes \neffect and shall be included in the employee's total income for that year, and, for the \npurposes of assessment, the remainder of the transferred balance shall be \ndisregarded, but no other exemption or relief, by way of refund or otherwise, shall be \ngranted in respect of any sum comprised in such transferred balance: \n \nProvided that, in cases of serious accounting difficulty, the \nCommissioner may, subject to the said rules, make a summary \ncalculation of such aggregate. \n \n \n(5) \nNothing in this rule shall affect the rights of the persons administering \nan unrecognised provident fund or dealing with it, or with the balance to the credit \nof any individual employees, before recognition is accorded, in any manner which \nmay be lawful. \n \n8. \nAccounts of recognised provident funds. — (1) The accounts of a \nrecognised provident fund shall be maintained by the trustees of the fund and shall \nbe in such form and for such periods, and shall contain such particulars, as may \nbe prescribed. \n \n \n(2) \nThe accounts shall be open to inspection at all reasonable times by \nincome tax authorities, and the trustees shall furnish to the Commissioner such \nabstracts thereof as may be prescribed. \n \n9. \nTreatment of fund transferred by employer to trustee. — (1) Where an \nemployer, who maintains a provident fund (whether recognised or not) for the \nbenefit of his employees and has not transferred the fund or any portion of it, \ntransfers such fund or portion to trustees in trust for the employees participating in \nthe fund, the amount so transferred shall be deemed to be of the nature of capital \nexpenditure. \n \n \n(2) \nWhen an employee participating in such fund is paid the accumulated \nbalance due to him therefrom, any portion of such balance as represents his share \nin the amount so transferred to the trustees (without addition of interest, and \nexclusive of the employee's contributions and interest thereon) shall, if the \nemployer has made effective arrangement to secure that tax shall be deducted at \nsource from the amount of such share when paid to the employee, be deemed to \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nSixth Schedule – Part I________ __________________________ \n721 \n \nbe an expenditure by the employer, within the meaning of section 1[20], incurred \nin the 2[tax] year in which the accumulated balance due to the employee is paid. \n \n10. \nParticulars to be furnished in respect of recognised provident \nfunds.— The trustees of a recognised provident fund and any employer who \ncontributes to a recognised provident fund shall, when required by notice from the \nCommissioner, within such period (not being less than twenty one days from the date \n3[of service] of the notice), as may be specified in the notice, furnish such return, \nstatement, particulars or information, as the Commissioner may require. \n \n11. \nProvisions of this Part to prevail against regulations of the fund. \n— Where there is a repugnance between any regulations of a recognised \nprovident fund and any provision of this Part or of the rules made thereunder, the \nregulation shall, to the extent of the repugnance, be of no effect, and the \nCommissioner may, at any time, require that such repugnance shall be removed \nfrom the regulations of the fund. \n \n12. \nAppeals.— (1) An employer objecting to an order of Commissioner refusing \nto recognise, or an order withdrawing recognition from a provident fund may \nappeal, within sixty days of the 4[service] of such order, to the 5[Board]. \n \n \n(2) \nThe 6[Board] may admit an appeal after the expiration of the period \nspecified in sub-rule (1), if it is satisfied that the appellant was prevented by \nsufficient cause from presenting it within that period. \n \n \n(3) \nThe appeal shall be in such form and shall be verified in such manner \nand shall be accompanied by such fee as may be prescribed. \n \n13. \nProvisions relating to rules. — In addition to any power conferred by this \nPart, the 7[Board] may make rules:- \n \n(a) \nprescribing the form of application for recognition and the \nstatement and other particulars and documents to be submitted \ntherewith; \n \n                                            \n1The figure “23” substituted by the Finance Act, 2003. \n2The word “income” substituted by the Finance Act, 2003. \n3Inserted by the Finance Act, 2003. \n4The word “making” substituted by the Finance Act, 2003. \n5The words “Central Board of Revenue” substituted by the Finance Act, 2007 \n6The words “Central Board of Revenue” substituted by the Finance Act, 2007 \n7 The words “Central Board of Revenue” substituted by the Finance Act, 2007 \n\n\f\nSixth Schedule – Part I________ __________________________ \n722 \n \n(b) \nlimiting the contributions to a recognised provident fund by \nemployees of a company, who are shareholders in the company; \n \n(c) \nproviding for the assessment by way of penalty of any \nconsideration received by an employee for an assignment of, or \ncreation of a charge upon, his beneficial interest in a recognised \nprovident fund; \n(d) \ndetermining the extent to, and the manner in, which exemption \nfrom payment of tax may be granted in respect of contributions \nand interest credited to the individual accounts of employees in \na provident fund from which recognition has been withdrawn; \n \n(e) \nregulating the investment of the moneys of a recognised \nprovident fund; and \n \n(f) \ngenerally, to carry out the purposes of this Part and to secure \nsuch further control over the recognition of provident funds and \nthe administration of recognised provident funds as it may deem \nrequisite. \n \n14. \nDefinitions. —In this Part, unless the context otherwise requires , \n \n(a) \n\"accumulated balance due to an employee\" means the balance \nto his credit, or such portion thereof as may be claimable by him \nunder the regulations of the fund, on the day he ceases to be \nan employee of the employer maintaining the 1[fund]; \n \n(b) \n\"annual accretion\" in relation to the balance to the credit of an \nemployee, means the increase  to such balance in any year, \narising from contributions and interest; \n \n(c) \n\"balance to the credit of an employee\" means the total amount \nto the credit of his individual account in a provident fund at any \ntime; \n \n(d) \n\"contribution\" means any sum credited by or on behalf of, any \nemployee out of his salary or by an employer out of his own \nmoney, to the individual account of an employee, but does not \ninclude any sum credited as interest; \n \n(e) \n\"employee\" means an employee participating in a provident \nfund, but does not include a personal or domestic servant; \n                                            \n1The word “funds” substituted by the Finance Act, 2003. \n\n\f\nSixth Schedule – Part I________ __________________________ \n723 \n \n(f) \n\"employer\" means any person who maintains a provident fund \nfor the benefit of his or its employees, being an individual, a \ncompany or an association of persons engaged in any business \nthe profits and gains whereof are chargeable to income tax \nunder the head \"Income from Business\"; \n \n(g) \n\"regulations of fund\" means the special body of regulations \ngoverning the constitution and administration of a particular \nprovident fund; and  \n \n(h) \n\"salary\" includes dearness allowance, if the terms of \nemployment so provide, but excludes all other allowances and \nperquisites. \n \n15. \nApplication of this Part. — This Part shall not apply to any provident fund \nto which the Provident Funds Act, 1925 (XIX of 1925) applies. \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n\n\f\nSixth Schedule – Part II_______ __________________________ \n \n726 \nPART II \n[ See sections1 [12](5) and 21(e), and the Second Schedule] \n \nAPPROVED SUPERANNUATION FUNDS \n \n1. \nApproval of superannuation funds.— (1) The Commissioner may accord \napproval to any superannuation fund or any part of a superannuation fund which, \nin his opinion, complies with the requirements of rule 2, and may, at any time \nwithdraw such approval if, in his opinion, the circumstances of the fund or the part, \nas the case may be, cease to warrant the continuance of the approval. \n \n \n(2) \nAn order according approval or withdrawing approval shall take effect \nfrom such date as the Commissioner may fix. \n \n \n(3) \nThe Commissioner shall neither refuse nor withdraw approval to any \nsuperannuation fund or any part of a superannuation fund unless he has given the \ntrustees of that fund a reasonable opportunity of being heard. \n \n2. \nConditions for approval. — In order that a superannuation fund may \nreceive and retain approval, it shall satisfy the conditions hereinafter specified and \nany other conditions which the 2[Board] may, by rules prescribe - \n \n(a) \nthe fund shall be a fund established under an irrevocable trust, in \nconnection with a trade or undertaking carried on in Pakistan, and not \nless than ninety per cent of the employees shall be employed in \nPakistan; \n \n(b) \nthe fund shall have for its sole purpose the provision of annuities for \nemployees in the trade or undertaking on their retirement at or after a \nspecified age or on their becoming incapacitated prior to such \nretirement, or for widows, children or dependants of persons who are \nor have been such employees on the death of these persons; \n \n(c) \nthe employer in the trade or undertaking shall be a contributor to the \nfund; and \n \n(d) \nall annuities, pensions and other benefits granted from the fund shall \nbe payable only in Pakistan. \n \n3. \nApplication for approval.— (1) An application for approval of a \nsuperannuation fund, or part of a superannuation fund, shall be made in writing by \nthe trustees of the fund to the Commissioner by whom the employer is assessable, \n                                            \n1The figure “2” substituted by the Finance Act, 2009. \n2 The words “Central Board of Revenue” substituted by the Finance Act, 2007 \n\n\f\nSixth Schedule – Part II_______ __________________________ \n725 \n \nand shall be accompanied by a copy of the instrument under which the fund is \nestablished and by two copies of the regulations and, where the fund has been in \nexistence during any year or years prior to the financial year in which the \napplication for approval is made, also two copies of the accounts of the funds \nrelating to such prior year or years (not being more than three years immediately \npreceding the year in which the said application is made) for which such accounts \nhave been made up, but the Commissioner may require such further information \nto be supplied as he thinks proper. \n \n \n(2) \nIf any alternation in the regulations, constitutions, objects or conditions \nof the fund is made at any time after the date of the application for approval, the \ntrustees of the fund shall forthwith communicate such alteration to the \nCommissioner mentioned in sub-rule (1), and, in default of such communication, \nany approval given shall, unless the Commissioner otherwise directs, be deemed \nto have been withdrawn from the date on which the alteration took effect.  \n \n4. \nContributions by employer, when deemed to be his income. — Where \nany contributions by an employer (including the interest thereon, if any), are repaid \nto the employer, the amount so repaid shall be deemed for the purpose of tax to \nbe the income of the employer of the income year in which it is so repaid. \n \n5. \nDeduction of tax on contributions paid to an employee. — Where any \ncontributions made by an employer (including interest on contributions, if any), are \nrepaid to an employee during his life-time in circumstances other than those \nreferred to in clause (25) of Part I of the Second Schedule, tax on the amount so \nrepaid shall be deducted by the trustees 1[at the rate applicable to the year of \nwithdrawal] and shall be paid by the trustees to the credit of the Federal \nGovernment within such time and in such manner as may be prescribed. \n \n6. \nDeduction from pay of and contributions on behalf of employees to be \nincluded in a statement under section 165. — Where an employer deducts from \nthe emoluments paid to an employee or pays on his behalf any contributions of \nthat employee to an approved superannuation fund, he shall include all such \ndeductions or payments in a statement which he is required to furnish under \nsection 165. \n \n7. \nLiability of trustees on cessation of approval. — If a fund, or a part of a \nfund, for any reason ceases to be an approved superannuation fund, the trustees \nof the fund shall nevertheless remain liable to tax on any sum paid on account of \nreturned contributions (including interest on contributions, if any), in so far as the \nsum so paid is in respect of contributions made before the fund or part of the fund, \nas the case may be, ceased to be an approved superannuation fund under the \nprovisions of this Part. \n                                            \n1The words and commas “at the average rate of tax at which the employee was liable to tax during the \npreceding three years or during such period, if less than three years, as he was a member of the \nfund,” substituted by the Finance Act, 2008. \n\n\f\nSixth Schedule – Part II_______ __________________________ \n726 \n \n8. \nParticulars to be furnished in respect of superannuation fund. — The \ntrustees of an approved superannuation fund and any employer who contributes \nto an approved superannuation fund shall, when required by notice from the \nCommissioner, within such period (not being less than twenty-one days from the \ndate 1[of service] of the notice), as may be specified in the notice, furnish such \nreturn, statement, particulars or information, as the Commissioner may require. \n \n9. \nProvisions of the Part to prevail against regulations of the fund. \n— Where there is a repugnance between any regulation of an approved \nsuperannuation fund and any provision of this Part or of the rules made thereunder \nthe regulation shall, to the extent of the repugnance, be of no effect ; and the \nCommissioner may, at any time, require that such repugnance shall be removed \nfrom the regulations of the fund. \n \n10. \nAppeals. —(1) An employer objecting to an order of the Commissioner \nrefusing to accord approval to a superannuation fund or an order withdrawing such \napproval may appeal, within sixty days of the 2[service] of such order, to the \n3[Board]. \n \n \n(2) \nThe 4[Board] may admit an appeal after the expiration of the period \nspecified in sub-rule (1), if it is satisfied that the appellant was prevented by \nsufficient cause from presenting it within that period. \n \n \n(3) \nThe appeal shall be in such form and shall be verified in such manner \nand shall be accompanied by such fee as may be prescribed. \n \n11. \nProvisions relating to rules. —(1) In addition to any power conferred by \nthis Part, the 5[Board] may make rules - \n \n(a) \nprescribing the statements and other information to be \nsubmitted along with an application for approval; \n \n(b) \nprescribing the returns, statements, particulars, or information \nwhich the Commissioner may require from the trustees of an \napproved superannuation fund or from the employer; \n \n(c) \nlimiting the ordinary annual contribution and any other \ncontributions to an approved superannuation fund by an \nemployer; \n                                            \n1 Inserted by the Finance Act, 2003.. \n2The word “making” substituted by the Finance Act, 2003. \n3The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n4 The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n5The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nSixth Schedule – Part II_______ __________________________ \n727 \n \n(d) \nregulating the investment or deposit of the moneys of any \napproved superannuation fund; \n \n(e) \nproviding for the assessment by way of penalty of any \nconsideration received by an employee for an assignment of, or \ncreation of a charge upon, his beneficial interest in an approved \nsuperannuation fund; \n \n(f) \nproviding for the withdrawal of approval in the case of a fund \nwhich ceases to satisfy the requirements of this Part or of the \nrules made thereunder; and \n \n(g) \ngenerally, to carry out the purposes of this Part and to secure \nsuch further control over the approval of superannuation funds \nand the administration of approved superannuation funds as it \nmay deem requisite. \n \n12. \nDefinitions.— In this Part, unless the context otherwise requires \n\"contributions\", \"employee', \"employer\", \"regulations of a fund\" and \"salary\" have, \nin relation to superannuation funds, the meanings assigned to those expressions \nin rule 14 of Part I in relation to provident funds. \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n\n\f\nSixth Schedule – Part III_______ __________________________ \n \n730 \nPART III \n[ See sections 2(4) and 21(e), and the Second Schedule] \n \nAPPROVED GRATUITY FUNDS \n \n1. \nApproval of Gratuity Funds. — (1) The Commissioner may accord approval \nto any gratuity fund which, in his opinion, complies with the requirements of rule 2 and \nmay, at any time, withdraw such approval if, in his opinion, the circumstances of the \nfund cease to warrant the continuance of the approval. \n \n \n(2) \nAn order according approval or withdrawing approval shall take effect \nfrom such date as the Commissioner may fix. \n \n \n(3) \nThe Commissioner shall neither refuse nor withdraw approval to any \ngratuity fund unless he has given the trustees of that fund a reasonable opportunity \nof being heard. \n \n2. \nConditions for approval. — In order that a gratuity fund may receive and \nretain approval, it shall satisfy the conditions hereinafter specified and any other \nconditions which the 1[Board] may, by rules, prescribe – \n \n(a) \nthe fund shall be a fund established under an irrevocable trust in \nconnection with trade or undertaking carried on in Pakistan, and not \nless than ninety per cent of the employees shall be employed in \nPakistan; \n \n(b) \nthe fund shall have for its sole purpose the provision of a gratuity to \nemployees in the trade or undertaking on their retirement at or after a \nspecified age or on their 2[becoming incapacitated prior to] such \nretirement, or on termination of their employment after a minimum \nperiod of service specified in the regulations of the fund or to the \nwidows, children or dependents of such employees on their death; \n \n(c) \nthe employer in the trade or undertaking shall be a contributor to the \nfund; and \n \n(d) \nall benefits granted by the fund shall be payable only in Pakistan. \n \n3. \nApplication for approval. — (1) An application for approval of a gratuity \nfund shall be made in writing by the trustees of the fund to the Commissioner by \nwhom the employer is assessable and shall be accompanied by  copy of the \ninstrument under which the fund is established and by two copies of the rules and, \nwhere the fund has been in existence during any year or years prior to the financial \nyear in which the application for approval is made, also two copies of the accounts \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2The words “employment after” substituted by the Finance Act, 2003. \n\n\f\nSixth Schedule – Part III_______ __________________________ \n729 \n \nof the fund relating to such prior year or years (not being more than three years \nimmediately preceding year in which the said application is made) for which such \naccounts have been made up, but the Commissioner may require such further \ninformation to be supplied as he thinks proper. \n \n \n(2) \nIf any alteration in the rules, constitution, objects or conditions of the \nfund is made at any time after the date of the application for approval, the trustees \nof the fund shall forthwith communicate such 1[alteration] to the Commissioner \nmentioned in sub-rule (1), and in default of such communication, any approval \ngiven shall, unless the Commissioner otherwise orders, be deemed to have been \nwithdrawn from the date on which the alteration took effect. \n \n4. \nGratuity deemed to be salary. —Where any gratuity is paid to an employee \nduring his life-time, the gratuity shall be treated as salary paid to the employee for \nthe purposes of this Ordinance. \n \n5. \nLiability of trustees on cessation of approval. —If a gratuity fund for any \nreason ceases to be an approved gratuity fund, the trustees of the fund shall \nnevertheless remain liable to tax on any gratuity paid to any employee. \n \n6. \nContributions by employer, when deemed to be his income. —  Where any \ncontributions by an employer (including the interest thereon, if any,) are repaid to the \nemployer, the amount so repaid shall be deemed for the purposes of tax to be the \nincome of the employer of the income year in which they are so repaid. \n \n7. \nParticulars to be furnished in respect of gratuity funds. — The trustees \nof an approved gratuity fund and any employer who contributes to an approved \ngratuity fund shall, when required by notice from the Commissioner, furnish, within \nsuch period not being less than twenty-one days from the date 2[of service] of the \nnotice as may be specified in the notice, such return, statement, particulars or \ninformation, as the Commissioner may require. \n \n8. \nProvisions of the Part to prevail against regulations of the fund. —\nWhere there is a repugnance between any rule of an approved gratuity fund and \nany provision of this Part or of the rules made thereunder the said rule shall, to the \nextent of repugnance, be of no effect and the Commissioner may, at any time, \nrequire that such repugnance shall be removed from the rules of the fund. \n \n9. \nAppeals. — (1) An employer objecting to an order of the Commissioner \nrefusing to accord approval to a gratuity fund or an order withdrawing such \napproval may appeal, within sixty days of the 3[receipt] of such order, to the \n4[Board]. \n                                            \n1The word “alterations” substituted by the Finance Act, 2003. \n2Inserted by the Finance Act, 2003. \n3 The word “making” substituted by the Finance Act, 2003. \n4The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nSixth Schedule – Part III_______ __________________________ \n730 \n \n \n(2) \nThe 1[Board] may admit an appeal after the expiration of the period \nspecified in sub-rule (1), if it is satisfied that the appellant was prevented by \nsufficient cause from presenting it within that period. \n \n \n(3) \nThe appeal shall be in such form and shall be verified in such manner \nand shall be accompanied by such fee as may be prescribed. \n \n10. \nProvisions relating to rules. —(1) In addition to any power conferred in \nthis Part, the 2[Board] may make rules – \n \n(a) \nprescribing the statements and other information to be submitted \nalong with an application for approval; \n \n(b) \nlimiting the ordinary annual and other contributions of an employer to \nthe fund; \n \n(c) \nregulating the investment or deposit of the moneys of an approved \ngratuity fund; \n \n(d) \nproviding for the assessment by way of penalty of any consideration \nreceived by an employee for an assignment of, or the creation of a \ncharge upon, his beneficial interest in an approved gratuity fund; \n \n(e) \nproviding for withdrawal of the approval in the case of a fund which \nceases to satisfy the requirements of this Part or the rules made \nthereunder; and \n \n(f) \ngenerally, to carry out the purposes of this Part and to secure such \nfurther control over the approval of gratuity funds and the \nadministration of gratuity funds as it may deem requisite. \n \n11. \nDefinitions.—In this Part, unless the context otherwise requires, \n\"contribution\", \"employee\", \"employer\", \"regulations of a fund\" and \"salary\" have in \nrelation to gratuity funds, the meaning assigned to those expressions in rule 14 of \nPart I in relation to provident funds. \n \n \n \n \n \n \n \n                                            \n1The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n2The words “Central Board of Revenue” substituted by the Finance Act, 2007. \n\n\f\nSeventh Schedule ___________ __________________________ \n \n733 \n1[THE SEVENTH SCHEDULE] \n(See section 100A) \n \nRULES FOR THE COMPUTATION OF THE PROFITS AND GAINS OF A \nBANKING COMPANY AND TAX PAYABLE THEREON \n                                            \n \n1 The Seventh Schedule substituted by the Finance Act, 2007. The substituted “The Seventh \nSchedule” read as follows: \n \n“THE SEVENTH SCHEDULE \nEXPORTED GOODS \n[See Division IV of Part III of First Schedule] \n \nPART I \n[Specified goods manufactured in Pakistan] \nS. No. \n(1) \nDescription \n(2) \nDescription \n(3) \n1. \nA[  ]  \n \n2. \nEngineering goods, including electrical goods \n \n3. \nB[  ] \n \n4. \nJewellery, pharmaceuticals, C[  ], durries, horticultural products \n \n5. \nCeramic D[tiles] and wares \n \n6. \nCutlery \n \n7. \nEngineering goods manufactured in Pakistan as specified in the \nEngineering Goods (Control) Order, 1983 \n \n8. \nWooden furniture and wooden doors and windows \n \n9. \nGoods specified under Chapters, Heading and Sub-Heading Nos. of the \nPakistan Custom Tariff  \n \nE[  ] \n \n \n10. \nVegetables, fresh fruit and cut flowers   \n \nF[11. \nProcessed poultry meat] \n \nAEarlier the words “Leather and textile made ups” omitted by the Finance Act, 2005. \nB Earlier the words , figures, brackets and comma “Goods specified under heading  \n   No.90.18of the Fifth Schedule to the Customs Act, 1969 (IV of 1969) omitted by the  \n   Finance Act, 2005. \nC Earlier the words “Sports goods, toilet linen including terry towels” omitted by the  \n   Finance Act, 2005. \nD Earlier substituted the word “tiples” by the Finance Act, 2003. \nE Earlier omitted by the Finance Act, 2005. \nF Earlier added by the Finance Act, 2002. \n PART II \n[Goods manufactured in Pakistan] \nS. \nNo. \nDescription \n \n \n \n \n \n \nDescription \n(1) \n(2) \n(3) \n1. \nExport of goods manufactured in Pakistan subject to other provisions \nof A[this] Schedule \n \nB[1A \n(1) \nLeather and textile made ups \n \n \n(2) \nGoods specified under heading No.90.18 of the First  \n \nSchedule to the Customs Act, 1969 (IV  of 1969). \n \n \n(3) \nSports goods, toilet linen including terry towels. \n \n \n(4) \nGoods specified under Chapters, Heading and Sub- \n \nHeading Nos. of The Pakistan Customs Tariff. \n \n \n(i) \n42.05 \nOther articles of leather \n \n(ii) \n57.01 \nHand-knitted carpets and rugs \n \n(iii) \n61.01 \nMen and boys overcoats, jackets \nknitted or crocheted \n\n\f\nSeventh Schedule ___________ __________________________ \n732 \n \n                                            \n \n(iv) \n61.02 \nWomen and girls overcoats, \njackets knitted or crocheted \n \n(v) \n61.03 \nMen and boys suits, jackets, \ntrousers, shirts knitted or \ncrocheted \n \n(vi) \n61.05 \nMen and boys shirts knitted or \ncrocheted \n \n(vii) \n61.06 \nWomen and girls blouses, shirts \nknitted or crocheted \n \n(viii) \n61.09 \nT-shirts knitted or crocheted \n \n(ix) \n61.12 \nTracksuits, swimwear knitted or \ncrocheted \n \n(x) \n63.01, 2000, 3000, 4000 \nBlankets, wool, cotton and MMF. \n \n(xi) \n63.02 \nBed linen, table linen and kitchen \nlinen] \n2. \n(i)    Refined/treated salt \n \n \n(ii)   Ground barytes \n \n \n(iii)  Granite blocks and slabs \n \n \n(iv)  Heat insulating bricks  \n \n \n(v)   Magnesite refractory \n \n3. \nSale in Pakistan of goods manufactured in Pakistan against an \ninternational tender, where the contract under which such sale is \nmade is approved by the Commissioner \n \n \nA Earlier inserted by the Finance Act, 2003. \nB  Earlier inserted by the Finance Act, 2005. \n \nPART III \n[Goods not covered by Part I A[, II or IV] II] \n \nS. No. \n \n \nDescription \n1. \nAll other goods not covered under Part I B[, ] Part II C[and Part IV] of this Schedule \n2. \nThe following goods or class of goods produced or manufactured in Pakistan, namely: - \n \nD[  ] \n \n(ii) \nrice \n \n(iii)   \nrice bran \n \n(iv)   \nwheat bran \n \n(v)    \nlamb skin \n \nE[  ]  \nF[2A. \nFollowing types of goods not covered by other provisions of this Schedule, namely:- \n \n(i)  \nleather and articles thereof \n \n(ii) \ntextile and textile articles \n \n(iii) \ncarpets \n \n(iv) \nsurgical goods \n3. \n \nSuch other goods as may be notified by the Central Board of Revenue \nA Earlier the word “or” substituted by the Finance Act, 2005. \nB Earlier the word “and” substituted by the Finance Act, 2005. \nC Earlier inserted by the Finance Act, 2005. \nD Earlier the figure and word “(i) raw cotton” omitted by the Finance Act, 2005. \nE Earlier the bracket, figures and words “(vi) cotton yarn” omitted by the Finance Act, 2005. \nF Inserted by the Finance Act, 2005. \nA[PART IV \n[goods not covered by Part I, II and III] \nS.No. \nDescription \n(i) \nraw cotton \n(ii) \nCotton yarn \n(iii) \nsuch other goods as may be notified by the Central Board \nof Revenue]” \nA Earlier added by the Finance Act, 2005. \n\n\f\nSeventh Schedule ___________ __________________________ \n733 \n \n1. 1[Subject to the provisions of Chapter VII and VIII, income], profits and gains of \na banking company shall be taken to be the balance of the income from all sources \nbefore tax, disclosed in the annual accounts required to be furnished to the State \nBank of Pakistan subject to the following provisions, namely:—  \n \n(a) \nDeduction shall be allowed in respect of depreciation, initial \nallowance and amortization under sections 22, 23 and 24 provided \nthat accounting depreciation, initial allowance or amortization \ndeduction shall be added to the income. No allowance or deduction \nunder this rule shall be admissible on assets given on finance lease. \n \n2[(aa) \nWhere a taxpayer incurs expenditure on leasehold improvements in \nrespect of leased or rented property, the amount so incurred, as \nreflected in the audited accounts, shall be capitalized and amortized \nat the rate of ten percent (10%) per annum:  \n \n(i) \namortization under this clause shall commence from the date \n \non which the leasehold improvements are first put to use by \n \nthe taxpayer; and  \n \n(ii) \nin the event of termination of the lease prior to the completion \n \nof the amortization period, the unamortized balance of the \n \ncapitalized leasehold improvements shall be allowed as a \n \ndeduction in the tax year in which such termination occurs, \n \nafter setting off any proceeds received from the disposal or \n \ntransfer of such leasehold improvements.] \n(b) \nSection 21, sub-section (8) of section 22 and Part III of Chapter IV \nshall, mutatis mutandis, for computation of a banking company \napply. \n \n3[(ba) \nNotwithstanding anything contained in any applicable financial \nreporting standard, including International Financial Reporting \nStandard (IFRS) 16, the depreciation on right-of-use assets and the \nfinance cost relating thereto shall not be admissible as a deduction. \nIn lieu thereof, the actual rent expense incurred during the tax year \nshall be allowed as an expense, subject to the condition that the \nbanking company furnishes a certificate from its external auditor to \nthe effect that such rent expense has been actually incurred during \nthe tax year:  \n                                            \n \n \n1The word “Income” substituted by the Finance Act, 2018 \n2 Clause (aa) inserted by the Finance Act, 2025. \n3 Clause (ba) inserted by the Finance Act, 2025. \n\n\f\nSeventh Schedule ___________ __________________________ \n734 \n \n \nProvided that, in view of the implementation of IFRS 16 with \neffect from the tax year 2020, where a banking company has claimed \nexcess deductions on account of right-of-use asset depreciation and \nrelated finance costs in prior tax years, the differential amount, being \nthe excess of such deductions over the actual rent expense incurred, \nshall be offered to tax in the tax year 2025;  \n \n \nProvided further that, where the deduction claimed in respect \nof right-of-use asset depreciation and related finance cost in the prior \ntax years is less than the actual rent expense incurred, the \ndifferential amount shall be allowed as an admissible expense in the \ntax year 2025:   \n \nExplanation. — The adjustments specified in the foregoing provisos \nshall be duly certified by the external auditor of the banking \ncompany.] \n1[(c)\n \n \nProvisions for advances and off balance sheet items shall be allowed \nupto a maximum of 1% of total advances; 2[and provisions for \nadvances and off-balance sheet items shall be allowed at 5% of total \nadvances for consumers and small and medium enterprises (SMEs) \n(as defined under the State Bank Prudential Regulations)] provided \na certificate from the external auditor is furnished by the banking \ncompany to the effect that such provisions are based upon and are \nin line with the Prudential Regulations. Provisioning in excess of 1% \n3[of total advances for a banking company and 5% of total advances \nfor consumers and small and medium enterprises (SMEs)] would be \nallowed to be carried over to succeeding years: \n \n \n \n \n4[Provided that if provisioning is less than 1% of advances, for \na banking company then actual provisioning for the year shall be \nallowed:] \n \n \n \n5[Provided further that if provisioning is less than 5% of \nadvances for consumers and small and medium enterprises (SMEs) \nthen actual provisioning for the year shall be allowed and this \nprovisioning shall be allowable from the first day of July, 2010] 6[: \n                                            \n1 Substituted by the Finance Act, 2009. The substituted sub-rule (c) read as follows: \n  “(c)  Provisions for classified advances and off balance sheet items shall be allowed in \naccordance with the provisions of sections 29 and 29A.” \n2 Inserted by the Finance Act, 2010. \n3 Proviso substituted by the Finance Act, 2011. The substituted proviso read as follows: \n“Provided that if provisioning is less than 1% of the advances, then actual provisioning \nfor the year shall be allowed.” \n4 Inserted by the Finance Act, 2011. \n5 Inserted by the Finance Act, 2011. \n6 Full stop substituted and new proviso inserted by the Finance Act, 2025. \n\n\f\nSeventh Schedule ___________ __________________________ \n735 \n \n \n \nProvided also that the certificate from the external auditor shall \nbe complete in all respects and shall on prescribed format containing \nfollowing —  \n \n(i) \nthe amount of provision, category-wise, allowed in accordance \nwith the Prudential Regulations issued by the State Bank of \nPakistan;  \n \n(ii)  \nthe amount of provision, category-wise, recognized under the \nInternational Financial Reporting Standard (IFRS) 9;  \n \n(iii)  \nthe amount of provision, category-wise, as disclosed in the \nannual accounts of the banking company; and  \n \n(iv) \nthe amount of provision, category-wise, which is eligible for \ndeduction under clauses (c), (d), (da), (e) and (f) of Rule 1 of \nthis Schedule, and the certificate shall specifically identify and \ncertify such amount, confirming its consistency with the \napplicable regulatory framework, the Seventh Schedule, and \nfinancial reporting standards.  \n \nExplanation – For removal of the doubt, it is further clarified that in \ncase of non-filing of certificate or incomplete filing of certificate at the \ntime of filing of return, the provisions under rule 1(c) shall not be \nadmissible and requirements specified herein, shall apply in respect \nof tax year 2025 and onwards.] \n \n \n1[Explanation.- For removal of doubt, it is clarified that- \n \n(i) \nprovision for advance and off balance sheet items allowed \nunder this clause, at the rate of 1 percent or 5 percent, as the \ncase may be, shall be exclusive of reversals of such provisions; \n \n(ii) \nreversal of “bad debts” classified as “doubtful” or “loss” are \ntaxable as the respective provisions have been allowed under \nthis clause; 2[  ] \n  \n(iii) \nwith effect from tax year 2020 and onward; reversal of “bad \ndebts” classified as “loss” are taxable as the respective \nprovisions have been allowed under this clause 3[; and] \n \n                                            \n1 Explanation added through Finance Act, 2019. \n2 The word “and” omitted by the Finance Act, 2025. \n3 Full stop substituted by the Finance Act, 2025. \n\n\f\nSeventh Schedule ___________ __________________________ \n736 \n \n1[(iv) only such provisions in respect of non-performing advances as \nare classified as “loss”, in accordance with and based upon the \nPrudential Regulations issued by the State Bank of Pakistan \nshall be admissible as an expense under clause (c) of Rule 1 of \nthis Schedule; and  \n \n (v)  any provision including general provision made otherwise than \nin accordance with the aforesaid Prudential Regulations shall \nnot be admissible as a deduction in computing the taxable \nincome of a banking company under this Schedule.] \n \n \n \n2[ ] \n \n 3[(d) The amount of “bad debts” classified as “substandard” or “doubtful” \nunder the Prudential Regulations issued by the State Bank of Pakistan \nor provisions for advances, off-balance sheet items or any other \nfinancial asset classified in stage I, II or III as performing, under-\nperforming or non-performing under any applicable accounting \nstandard including IFRS 09 shall not be allowed as expense:  \n \nProvided that only “bad debts” classified as “loss” pertaining to \nnon-performing assets under the Prudential Regulations issued by the \nState Bank of Pakistan shall be allowed as expense.] \n \n4[(da) Provisions or Expected Credit loss for Advances and off balance sheet \nitems or any other financial asset existing before or after the 1st day of \nJanuary, 2024 under IFRS 09 shall not be allowed as an expense or \ndeduction.] \n \n5[(e)  Where any addition made under sub-rule (d) is reclassified by the \ntaxpayer under the Prudential Regulations issued by the SBP, 6[ ] \n                                            \n1 Serial numbers (iv) and (v) inserted by the Finance Act, 2025. \n2Inserted by the Finance Act, 2009. Earlier sub-rule (d) was omitted by the Finance Act, 2008 which \nread as follows: \n“(d) The amount claimed as expense, on account of “irrecoverable debt” classified under the \nPrudential Regulations issued by the State Bank of Pakistan as “substandard”, shall not be allowed.” \n3 sub-rule (d) substituted by the Finance Act, 2024. The substituted sub-rule read as follows: \n “[(d) The amount of “bad debts” classified as “sub-standard” 3[“or doubtful”] under the Prudential \nRegulations issued by the State Bank of Pakistan shall not be allowed as expense.]” \n4 Sub-rule (da) inserted by the Finance Act, 2024. \n5 Inserted by the Finance Act, 2009. Earlier sub-rule (e) was omitted by the Finance Act, 2008 which \nread as follows: \n“(e) Where any addition made under paragraph (d) is reclassified by the taxpayer as ‘doubtful’ or \n‘loss’, under the Prudential Regulations issued by the State Bank of Pakistan, a deduction shall be \nallowed in computing the income for that tax year.” \n6 Words “as ‘doubtful’ or” omitted though Finance Act, 2019. \n\n\f\nSeventh Schedule ___________ __________________________ \n737 \n \n‘loss’, provision of sub-rule (c) shall mutatis mutandis apply in \ncomputing the provision for that tax year.] \n \n1[(f)  Where any addition made under sub-rule (d) is reclassified by the \ntaxpayer in a subsequent year as ‘recoverable’, a deduction shall be \nallowed in computing the income for that tax year.] \n \n2[(fa)  the auditor‘s certificate, as required under clause (c), shall be on the \nfollowing format, namely:- \n \n \n[On the Letterhead of the External Auditor-Chartered Accountant \nFirm]  \n \nCERTIFICATE UNDER RULE 1(C) OF THE SEVENTH SCHEDULE \nTO THE INCOME TAX ORDINANCE, 2001 FOR TAX YEAR \n____________  \n \nTo:  \n \nThe Commissioner Inland Revenue, Zone-, Federal Board of \nRevenue,  \n \nI, the undersigned statutory auditor of [Name of Banking Company], \nhaving conducted the audit of the annual financial statements for the \nyear ended [insert date], in accordance with the applicable auditing \nstandards and the requirements of the Prudential Regulations issued \nby the State Bank of Pakistan (SBP), the International Financial \nReporting Standard (IFRS) 9, and the Seventh Schedule to the \nIncome Tax Ordinance, 2001, hereby certify the following: \n \nTable-1 \nCategory wise Gross Provisions \"In Rupees\" \nParticulars \nAllowed \nunder SBP \nPrudential \nRegulations: \nRecognized \nunder IFRS \n9: \nDisclosed \nin Annual \nAccounts \nEligible for \nDeduction \nunder Rule \n1(c), 1(d) & \n1(e) \nSubstandard \n(xxxx) \n  \n(xxxx) \n(xxxx) \nDoubtful \n(xxxx) \n  \n(xxxx) \n(xxxx) \nLoss \n(xxxx) \n  \n(xxxx) \n(xxxx) \nGeneral \nProvision \n(xxxx) \n  \n(xxxx) \n(xxxx) \n                                            \n1 Inserted by the Finance Act, 2009. Earlier sub-rule (f) was omitted by the Finance Act, 2008 which \nread as follows: \n“(f) Where any addition made under paragraph (d) is reclassified by the taxpayer in a subsequent \nyear as ‘recoverable’, a deduction shall be allowed in computing the income for that tax year.” \n2 Clause (fa) inserted by the Finance Act, 2025. \n\n\f\nSeventh Schedule ___________ __________________________ \n738 \n \nSpecific \n  \n  \n(xxxx) \n(xxxx) \nStage 1 \n  \n(xxxx) \n(xxxx) \n(xxxx) \nStage 2 \n  \n(xxxx) \n(xxxx) \n(xxxx) \nStage 3 \n  \n(xxxx) \n(xxxx) \n(xxxx) \nOthers (if any) \n(xxxx) \n(xxxx) \n(xxxx) \n(xxxx) \nTotal \n(xxxx) \n(xxxx) \n(xxxx) \n(xxxx) \n \nTable-2 \nCategory wise Reversal against Provisions \"In Rupees\" \nParticulars \nUnder SBP \nPrudential \nRegulations: \nRecognized \nunder IFRS 9: \nDisclosed \nin Annual \nAccounts: \nTaxable \nunder Rule \n1(c), 1(d) & \n1(e): \nSubstandard \n(xxxx) \n  \n(xxxx) \n(xxxx) \nDoubtful \n(xxxx) \n  \n(xxxx) \n(xxxx) \nLoss \n(xxxx) \n  \n(xxxx) \n(xxxx) \nGeneral \nProvision \n(xxxx) \n  \n(xxxx) \n(xxxx) \nSpecific \n  \n  \n(xxxx) \n(xxxx) \nStage 1 \n  \n(xxxx) \n(xxxx) \n(xxxx) \nStage 2 \n  \n(xxxx) \n(xxxx) \n(xxxx) \nStage 3 \n  \n(xxxx) \n(xxxx) \n(xxxx) \nOthers (if any) \n(xxxx) \n(xxxx) \n(xxxx) \n(xxxx) \nTotal \n(xxxx) \n(xxxx) \n(xxxx) \n(xxxx) \n \nWe further certify that the above amounts have been derived from and \nare consistent with: \n \n(i) \nThe relevant provisions of the Prudential Regulations of SBP; \n(ii) \nIFRS 9 and applicable financial reporting frameworks; \n(iii) \nThe disclosures made in the audited financial statements of the \nbanking company; and \n(iv) \nThe eligibility criteria specified in clause (c), (d) and (e) of Rule \n1 of the Seventh Schedule to the Income Tax Ordinance, 2001. \n \nThis certificate is issued specifically for the purpose of compliance with the \nproviso to Rule 1(c) of the Seventh Schedule to the Income Tax Ordinance, \n2001, as applicable for the tax year 2025 and onwards. \n \nFor and on behalf of  \n[Name of Audit Firm and Signing Partner] \nChartered Accountants] \n\n\f\nSeventh Schedule ___________ __________________________ \n739 \n \n(g) \n1[Subject to the aforesaid clauses of rule 1 of this Schedule] \nAdjustment made in the annual accounts, on account of 2[ 3[the \napplication of International Financial Reporting Standard IFRS-09 \n(Financial Instruments),] or policy or any guidelines or instructions of \nState Bank of Pakistan 4[in respect of IFRS-09] ] shall be excluded in \narriving at taxable income. \n \n \n5[Provided that the provisions of this clause, to the extent of the \namendments made herein, shall apply in respect of the tax year 2025 \nand onwards.] \n  \n6[Explanation.─ For removal of doubt, it is clarified that nothing \nin this clause shall be so construed as to allow a notional loss, or \ncharge to tax any notional gain on any investment under any \nregulation or instruction unless all the events that determine such gain \nor loss have occurred and the gain or loss can be determined with \nreasonable accuracy.] \n \n(h) \nAn adjustment shall be made for exclusions from income on account \nof paragraph (g) for determining the cost of related item in the financial \nstatement in the year of disposal of such item or asset or the discharge \nof the liability, as the case may be. \n \n \n7[Explanation.- For removal of doubt, it is clarified that nothing \ncontained in this Schedule shall be so construed as to restrict power \nof Commissioner, while conducting audit of the income tax affairs \nunder section 177, to call for record or such other information and \ndocuments as he may deem appropriate in order to examine accounts \nand records to conduct enquiry into expenditure, income, assets and \nliabilities of a banking company and all provisions of this Ordinance \nshall be applicable accordingly.]  \n \n \n2. \n(i) \nWhere a deduction is allowed for any expenditure (other than \non account of charge for irrecoverable debt) in the manner \nreferred to in rule 1 and the liability or a part of the liability to \nwhich the deduction relates is not paid within three years of \n                                            \n1 Expression inserted by the Finance Act, 2025. \n2 Expression “application of international accounting standards 39 and 40” substituted by the Finance \nAct, 2024. \n3 Expression “any applicable accounting standard” substituted by the Finance Act, 2025. \n4 Expression inserted by the Finance Act, 2025. \n5 Proviso inserted by the Finance Act, 2025. \n6 Added by the Finance Act, 2017 \n7 Explanation added through Finance Act, 2019.  \n\n\f\nSeventh Schedule ___________ __________________________ \n740 \n \nthe end of the tax year in which the deduction was allowed, \nthe unpaid amount of the liability shall be chargeable to tax \nunder the head “Income from Business” in the first tax year \nfollowing the end of three years. \n \n \n(ii) \nWhere an unpaid liability is chargeable to tax as a result of \nthe application of sub-rule (i) and such liability or a part \nthereof is subsequently paid, a deduction shall be allowed for \nthe amount paid in the tax year in which the payment is \nmade. \n \n \n(iii) \nLoss on sale of shares of listed companies, disposed of \nwithin one year of the date of acquisition, shall be adjustable \nagainst business income of the tax year. Where such loss is \nnot fully set off against business income during the tax year, \nit shall be carried forward to the following tax year and set off \nagainst capital gain only. No loss shall be carried forward for \nmore than six years immediately succeeding the tax year for \nwhich the loss was first computed. \n \n \n3. \nTreatment for shariah compliant banking.—  \n \n \n(1) \nAny special treatment for ‘Shariah Compliant Banking’ \napproved by the State Bank of Pakistan shall not be provided \nfor any reduction or addition to income and tax liability for the \nsaid ‘Shariah Compliant Banking’ as computed in the manner \nlaid down in this schedule. \n \n (2) \nA statement, certified by the auditors of the bank, shall be \nattached to the return of income to disclose the comparative \nposition of transaction as per Islamic mode of financing and as \nper normal accounting principles. Adjustment to the income of \nthe company on this account shall be made according to the \naccounting income for purpose of this schedule. \n \n1[3A. Notwithstanding any other provision of this Ordinance, where any \nassets are transferred by an Authorized Dealer, as a consequence of a \nDiversified Payment Rights transaction, to a Special Purpose Vehicle, it \nshall be treated as a financing transaction irrespective of the method of \naccounting adopted by the Authorized Dealer.  \n \n \nExplanation.— For the purpose of this clause, Diversified Payment \nRights, Special Purpose Vehicle and Authorized Dealer shall mean the \n‘Diversified Payment Rights’, ‘Special Purpose Vehicle’ and ‘Authorized \n                                            \n1 Rule 3A added by the Finance Act, 2024.  \n\n\f\nSeventh Schedule ___________ __________________________ \n741 \n \nDealer’, respectively, in each case, as referred in the State Bank of \nPakistan‘s Circular(s) or Regulations on Diversified Payment Rights.]  \n \n \n4. \nHead office expenditure.— \n \n \n(1) \nIn case of foreign banks head office expenditure shall be \nallowed as deduction as per the following formula, namely:—  \n \n \nHead office expenditure = (A/B) XC \n \n \n \nWhere— \n \n \nA. \nis the gross receipts of permanent establishment in Pakistan; \n \nB. \nis the world gross receipts; and \n \n \n \nC. \nis the total Head Office expenditure. \n \n \n(2) \nThe head office expenditure shall have the meaning as given \nin sub-sections (3) and (4) of section 105. \n \n \n(3) \nThe head office expenditure shall only be allowed if it is charged \nin the books of accounts of the permanent establishment and a \ncertificate from external auditors is provided to the effect that \nthe claim of such expenditure: \n \n \n \n \n(i) \nhas been made in accordance with the provision of this \nrule; and \n \n \n \n \n(ii) \nis reasonable in relation to operation of the permanent \nestablishment in Pakistan. \n \n \n5. \nAdvance tax.— \n \n \n(1) \nThe banking company shall be required to pay advance tax for \nthe year under section 147 in twelve 1[ ] installments payable \nby 15th of every month. Other provisions of section 147 2[ ] shall \napply as such. \n \n3[(1A) A banking company required to make payment of advance tax \nin accordance with sub-rule (1), shall estimate the tax payable \nby it for the relevant Tax Year, at any time before the installment \npayable on 15th June, of the relevant year is due. In case the \ntax payable is likely to be more than the amount it is required to \npay under sub-rule (1), the banking company shall furnish to the \nCommissioner an estimate of the amount of tax payable by it \n                                            \n1The word “equal” omitted by the Finance Act, 2018. \n2The expression “except sub section (4A) and (6)” omitted by the Finance Act, 2018. \n3 Inserted by S.R.O. 561(I)/2012, dated 29.05.2012. \n\n\f\nSeventh Schedule ___________ __________________________ \n742 \n \nand thereafter pay in the installment due on 15th June the \ndifference, if any, of fifty per cent of such estimate and advance \ntax already paid upto 15th June, of the relevant tax year. The \nremaining fifty per cent of the estimate shall be paid after 15th \nJune in six equal installments payable by 15th of each \nsucceeding month of the relevant tax year.] \n \n \n(2) \nProvisions of withholding tax under this Ordinance shall not \napply to a banking company as a recipient of the amount on \nwhich tax is deductible. \n \n6. \nTax on income computed—Income computed under this Schedule shall \nbe chargeable to tax under the head “Income from Business” and tax payable \nthereon shall be computed at the rate applicable in Division II of Part I of the First \nSchedule. 1[     ] \n \n \n2[  ] \n \n \n3[  ] \n \n \n4[  ] \n \n \n5[  ] \n \n \n6[  ] \n                                            \n1The expression omitted by the Finance Act, 2015. The omitted expression read as follows:-  \n“The net income from “Dividend” and net income from “Capital Gains on sale of shares of listed \ncompanies” shall be taxed at the rate of ten 1[and twelve and a half, respectively:” \n2First proviso omitted by the Finance Act, 2015. The omitted proviso read as follows:- \n \n“Provided that where the shares of listed companies are disposed of within one year of the date of \nacquisition, the gain shall be taxed at the rate provided in Division II of Part I of the First Schedule:” \n3 Second proviso omitted by the Finance Act, 2015. The omitted proviso read as follows:-  \n \n“Provided further that the “Dividend” received by a banking company from its asset management \ncompany shall be taxed at the rate of 20%:” \n4Third proviso omitted by the Finance Act, 2015. The omitted proviso read as follows:- \n“Provided also that the dividend received from Money Market Funds and Income Funds shall be \ntaxed at the rate of 25% for tax year 2013onwards.” \n \n5Rule (6A) omitted by the Finance Act, 2015. The omitted rule (6A) read as follows:- \n“6A. For the purpose of rule 6, net income from dividend shall be computed according to the \nfollowing formula, namely:- \n(A/C) × B \n \nWhere- \n \n \nA  \nis the total amount of expenditure as per this Schedule; \n \n \nB  \nis the gross amount of dividend received; and \n \n \nC  \nis the gross amount of receipts including dividend.” \n6Rule (6B) omitted by the Finance Act, 2015. The omitted rule (6B) read as follows:- \n\n\f\nSeventh Schedule ___________ __________________________ \n743 \n \n \n1[6C. Enhanced rate of tax on taxable income from Federal Government \nsecurities.- (1) The taxable income arising from additional income earned from \nadditional investment in Federal Government securities for the tax years 2020 and \n2[2021], shall be taxed at the rate of 37.5% instead of the rate provided in Division \nII of Part I of the First Schedule. \n \n \n(2) \nA banking company shall furnish a certificate from external auditor \nalong with accounts while e-filing return of Income certifying the amount of the \nmoney invested in Federal Government securities in preceding tax year, additional \ninvestments made for the tax year and mark-up income earned from the additional \ninvestments for the tax year. \n \n \n(3) \nNotwithstanding anything contained in this Ordinance, the \nCommissioner may require the banking company to furnish details of the \ninvestments in Federal Government securities to determine the applicability of the \nenhanced rate of tax. \n \n \n(4) \n“Additional income earned” means mark-up income earned from \nadditional investment in Federal Government securities by the bank for the tax \nyear. \n \n(5)  “Additional investments” means average investment made in Federal \nGovernment securities by the bank during the tax year, in addition to the average \ninvestments held during the tax year 2019. \n \n \n(6) \nThe taxable income arising from additional investment under sub-\nrule (1) shall be determined according to the following formula, namely:- \n \nTable income subject to enhanced rate of tax = A x B/C  \n \nWhere – \n \nA. \nis taxable income of the banking company; \n \nB. \nis mark up income earned from the additional investment for the tax year; \nand  \n \n                                            \n“6B. For the purpose of rule 6, net income from capital gains shall be computed according to the \nfollowing formula, namely: \n(A/C) × B \n \nWhere- \n \n  \nA \n is the total amount of expenditure as per this Schedule; \n \n  \nB \n is the gross amount of capital gains; and \n \n  \nC \n is the gross amount of receipts including capital gains.” \n1New rule (6C) inserted through Finance Act, 2019. \n2 The word “onwards” substituted by the Finance Act, 2021. \n\n\f\nSeventh Schedule ___________ __________________________ \n744 \n \nC. \nis the total of the mark-up income and non-make-up income of the banking \ncompany as per accounts.] \n \n \n1[  ] \n \n2[(6A)  For tax year 3[2023], the taxable income attributable to \ninvestment in the Federal Government securities shall be taxed at the rate \nof— \n  \n(i) \n55% instead of rate provided in Division II of Part I of the First \nschedule if the gross advances  to deposit ratio as on last day \nof the tax year is upto 40%; \n    \n(ii) 49% instead of rate provided in Division II of Part I of the First \nschedule if the gross advances to deposit ratio as on last day \nof the tax year exceeds 40% but does not exceed 50%; and \n    \n(i) \nat the rates provided in Division II of Part I of the First schedule \nif gross advances to deposit ratio as on last day of the tax year \nexceeds 50%. \n \n4[Explanation-I].- For the removal of doubt it is clarified that \nthe tax rate under this sub-rule is applicable to total income \nattributable to total investment in Federal Government \nsecurities. \n \n5[Explanation-2.– For removal of doubt, it is clarified that the \nterm \"gross advances and deposit\" referred to in this sub-rule for the \npurpose of computing gross advances to deposit ratio shall be the \namount of “gross advances and deposit” at the end of the accounting \nperiod and as disclosed in the annual audited accounts:  \n                                            \n1 Sub-rules (6A) inserted by the Finance Act, 2021. \n2 Sub-rules (6A) substituted by the Finance Act, 2022. The substituted sub-rule read as follows: \n   “(6A) \nFor tax year 2022 onwards, the taxable income attributable to investment in the Federal   \nGovernment securities shall be taxed at the rate of—  \n (i)  40% instead of rate provided in Division II of Part I of the First schedule if the assets to \ndeposit ratio as on last day of the tax year is upto 40%;    \n (ii) 37.5% instead of rate provided in Division II of Part I of the First schedule if the assets to \ndeposit ratio as on last day of the tax year exceeds 40% but does not exceed 50%; and   \n (iii) at the rates provided in Division II of Part I of the First schedule if assets to deposit ratio as \non last day of the tax year exceeds 50%.”  \n3 The expression “2022 and onwards” substituted by The Income Tax (Amendment) Act, 2025 (Act No. \nXIII of 2025). \n4 The existing Explanation numbered by The Income Tax (Amendment) Act, 2025 (Act No. XIII of 2025). \n5 The Expression-2 and proviso added by The Income Tax (Amendment) Act, 2025 (Act No. XIII of \n2025). \n\n\f\nSeventh Schedule ___________ __________________________ \n745 \n \n \n \nProvided that from tax year 2025 and onwards profits and gains \nof a banking company shall be subjected to tax rates under Division \nII of Part I to the First Schedule and nothing contained in this sub-\nrule shall apply to compute part or whole of the tax liability of a \nbanking company.] \n1[  ] \n \n2[7A. The provisions of section 113 shall apply to banking companies as they apply \nto any other resident company.] \n \n3[(7B) From tax year 2015 and onwards, income from Dividend and income from \nCapital Gains shall be taxed at the rate specified in Division II of Part I of First \nSchedule. \n \n(7C) For tax year 4[years 2015 5[  ] 6[and onwards] ] the provisions of section 4B \nshall apply to banking companies and shall be taxed at the rate specified in Division \nIIA of Part I of First Schedule 7[:]  ] \n \n8[Provided that brought forward losses, if any, shall be excluded from income \ncomputed under this Schedule for the purpose of section 4B of this Ordinance.]  \n \n9[(7CA) The provisions of section 4C shall apply to the taxpayers under this \nschedule and shall be taxed at the rates specified in Division IIB of Part I of the \nFirst Schedule from tax year 10[2023] onwards.] \n \n11[Explanation. — For removal of doubt it is clarified that the expression “tax year \n2023 onwards”, means that provisions of section 4C are applicable for the tax year \n2023 and for all subsequent tax years.]  \n \n                                            \n1 Rule 7 omitted by the Finance Act, 2008. The omitted rule 7 read as follows: \n“7. \nThe provisions of section 113 shall apply to banking companies as they apply to any other \nresident company.” \n2 Inserted by the Finance Act, 2009. \n3 Sub-rules (7B) and (7C) inserted by the Finance Act, 2010. \n4 The expression “year 2015, 2016 and 2017” substituted by the Finance Act, 2018. \n5 The figure “2020” substituted by “2021” through Finance Act, 2020 dated 30th June, 2020 \n6 The expression “to 2021” substituted by the Finance Act, 2021. Earlier this expression was substituted \nthrough Tax Laws (Amendment) Ordinance, 2021. \n7 Full stop substituted by “colon” though Finance Act, 2019. \n8 New proviso added through Finance Act, 2019.  \n9 Rule (7CA) inserted by the Finance Act, 2022. \n10 The figure “2022” substituted by the Finance Act, 2023.  \n11 Explanation added by the Finance Act, 2024. \n\n\f\nSeventh Schedule ___________ __________________________ \n746 \n \n1[(7CB) The provisions of section 99D shall apply to the taxpayers under this \nSchedule.] \n \n2[7D. Reduced rate of tax on additional advances for micro, small and \nmedium enterprises.- (1) The taxable income 3[ ] arising from additional advances \nto micro, small and medium enterprises, for the tax years 2020 to 2023, shall be \ntaxed at the rate of 20% instead of the rate provided in Division II of Part I of the \nFirst Schedule-  \n \n(2) A banking company shall furnish a certificate from external auditor along \nwith accounts while e-filing return of Income certifying  the amount of such \nadvances made in preceding lax year, additional advance made for the tax year \nand net mark-up earned from such additional advances for the tax year.  \n \n(3) Notwithstanding anything contained in this Ordinance, the Commissioner \nmay require the banking company to furnish details of the advances to micro, small \nand medium enterprises to determine the applicability of the reduced rate of tax.  \n \n(4) For the purposes of this rule, the term ''micro, small and medium \nenterprises\" shall have the same meaning as provided in Prudential Regulations \nissued by the State Bank of Pakistan.  \n \n(5) “Additional advances\" means any average advances disbursed in \naddition to average amount of such advances made in such sector by the bank for \nthe tax year.  \n \n(6) The taxable income arising from additional advances under sub-rule (1) \nshall be determined according to the following formula, namely:- \n \nTaxable income subject to reduced rate of tax = A x B/C  \n \nWhere-  \n \n \nA. \nis taxable income of the banking company;  \n \n \nB  \nis not mark up income earned from such additional advances for the \ntax year as declared in the annual accounts; and \n \n \nC \nis total of the net mark-up and non mark-up income of the banking \ncompany as per accounts.  \n \n7E. Reduced rate of tax on additional advances for low cost housing.- (l) The \ntaxable income arising from additional advances for low cost housing, for the tax \n                                            \n1 Rule (7CB) added by the  Finance Act, 2023.  \n2 Sub-rule (7D, 7E & 7F) inserted by through Finance Supplementary (Second Amendment) Act, 2019 \n3 Words “interest income” omitted through Finance Act, 2019.  \n\n\f\nSeventh Schedule ___________ __________________________ \n747 \n \nyears 2020 to 2023, shall be taxed  at the rate of 20% instead of the rate provided \nin Division II of Part I of the First Schedule1[: \n  \n \nProvided that the taxable income arising from additional advances to Naya \nPakistan Housing and Development Authority for low cost housing schemes shall \nbe taxed at the rate of 10%.] \n \n \n(2) A banking company shall furnish a certificate from external auditor \nalong with accounts while e-filing return of income certifying the amount of such \nadvances made in preceding tax year, additional advance made for the tax year \nand net mark-up earned from such additional advances for the tax year.  \n \n \n(3) Notwithstanding anything contained in this Ordinance, the \nCommissioner may require the banking company to furnish details of the advances \nmade for low cost housing to determine the applicability of the reduced rate of tax.  \n \n \n(4) For the purposes of this rule, the term \"low cost housing\" shall have \nthe same meaning as provided in Prudential Regulations issued by the Stare Bark \nof Pakistan.  \n \n \n(5) \"Additional advances\" means any average advances disbursed in \naddition to average amount of such advances made in such sector by the bank for \nthe tax year 2019.  \n \n \n(6) The taxable income arising from additional advances under sub rule.(1) \nshall be determined according to the following formula. namely:-  \n \n \nTaxable income subject to reduced rate of tax = A x B/C  \n \n \nWhere- \n \n \nA.  \nis taxable income of the banking company;  \n \n \nB.  \nis net mark-up income earned from such additional advances for the \ntax year as declared in the annual accounts; and \n \n \nC.   is total of the net mark-up and non mark-up income of the banking \ncompany as per accounts.  \n \n7F. Reduced rate of tax on additional advances as Farm Credit.-- (1) The \ntaxable income arising from additional advances for Farm Credit in Pakistan for \nthe tax years 2020 to 2023, shall be taxed at the rate of 20% instead of the rate \nprovided in Division II of Part 1 of the First Schedule. \n  \n                                            \n1Full stop substituted by colon thereafter new proviso inserted though Finance Act, 2020 dated 30th \nJune, 2020. \n\n\f\nSeventh Schedule ___________ __________________________ \n748 \n \n \n(2) A banking company shall furnish a certificate from external auditor \nalong with accounts while e-filing return of income certifying the amount of such \nadvances made in preceding tax year, additional advance made for the tax year \nand net mark-up earned from such additional advances for the tax year.  \n \n \n(3) Notwithstanding anything contained in this Ordinance, the \nCommissioner may require the banking company to furnish details of the advances \nmade for Farm Credit to determine the applicability of the reduced rate of tax.  \n \n \n(4) For the purposes of this rule, the term ''Farm Credit\" shall have the \nsame meaning as provided in Prudential Regulations issued by the State Bank of \nPakistan for agriculture financing excluding such advances made to a company as \ndefined in section 80.  \n \n \n(5) \"Additional advances\" means any average advances disbursed in \naddition to average amount of such advances made in such sector by the bank for \nthe tax year 2019.  \n \n \n(6) The taxable income arising from additional advances under sub-rule \n(1) shall be determined according to the following formula namely:-  \n \nTaxable income subject to reduced rate of tax = A x B/C  \n \nWhere- \n \nA. \nis taxable income of the banking company; \n \nB.  is net mark-up income earned from such additional advances for the \ntax year as declared in the annual accounts: and  \n \n \nC.  is total of the net mark-up and non mark-up income of the banking \ncompany as per accounts. \n \n8. \nExemptions—(1) Exemptions and tax concessions under the Second \nSchedule to this Ordinance shall not apply to income of a banking company \ncomputed under this Schedule. \n \n \n1[(1A) The accumulated loss under the head “Income from Business” (not \nbeing speculation business losses) of an amalgamating banking company or \nbanking companies shall be set off or carried forward against the business profits \nand gains of the amalgamated company and vice versa, up to a period of six tax \nyears immediately succeeding the tax year in which the loss was first computed in \nthe case of amalgamated banking company or amalgamating banking company or \ncompanies.] \n \n \n(2) The provisions relating to group relief as contained in section 59B shall \nbe available to the banking companies provided the holding and subsidiary \ncompanies are banking companies. The accounts of the group companies shall be \n                                            \n1Inserted by the Finance Act, 2008. \n\n\f\nSeventh Schedule ___________ __________________________ \n749 \n \naudited by the chartered accountants firm on the panel of auditors of the State \nBank of Pakistan. The surrender and claim of loss would be subject to the approval \nof the State Bank of Pakistan. \n \n \n(3) The holding and subsidiary companies of 100% owned group of \nbanking companies may opt to be taxed as one fiscal unit as per the provisions of \nsection 59AA relating to group taxation subject to the approval of the State Bank \nof Pakistan. \n \n1[(4) Profit on debt and capital gains from Federal Government’s sovereign \ndebt or a sovereign debt instrument shall be exempt from tax chargeable under \nthis Ordinance, derived by any non-resident banking company approved by the \nFederal Government under a sovereign agreement for the purpose of this sub-rule.  \n \n(5) The provisions of sub-rule (6A) of rule 6C shall not apply to a banking \ncompany for tax year 2024.] \n \n2[8A.  Transitional provisions.— (1) Amounts provided for in the tax year 2008 and \nprior to the said tax year for or against irrecoverable or doubtful advances, which were \nneither claimed nor allowed as a tax deductible in any tax year, shall be allowed in the \ntax year in which such advances are actually written off against such provisions, in \naccordance with the provision of section 29 and 29A. \n \n \n(2)  \nAmounts provided for in the tax year 2008 and prior to the said tax \nyear for or against irrecoverable or doubtful advances, which were neither claimed \nnor allowed as a tax deductible in any tax year, which are written back in the tax \nyear 2009 and thereafter in any tax year and credited to the profit and loss account, \nshall be excluded in computing the total income of that tax year under rule 1 of this \nSchedule. \n \n \n(3)  \nThe provisions of this Schedule shall not apply to any asset given or \nacquired on finance lease by a banking company up to the tax year 2008, and \nrecognition of income and deductions in respect of such asset shall be dealt in \naccordance with the provisions of the Ordinance as if this Schedule has not come \ninto force: \n \nProvided that un-absorbed depreciation in respect of such assets shall \nbe allowed to be set-off against the said lease rental income only.] \n \n9. \nProvision of Ordinance to apply— The provisions of the Ordinance not \nspecifically dealt with in the aforesaid rules shall apply, mutatis mutandis, to the \nbanking company. \n \n                                            \n1 Sub-rules (4) and (5) added by the  Finance Act, 2023. Earlier theses sub-rules were added through \nS.R.O Nos. 213(I)/2023 dated 22.02.2023 and 226(I)/2023 dated 27.02.2023.   \n2 Added by the Finance Act, 2010. \n\n\f\nSeventh Schedule ___________ __________________________ \n750 \n \n10. \nThe Federal Government may, from time to time, by notification in the official \nGazette, amend the schedule so as to add any entry therein or modify or omit any \nentry therein. \n \n \n \n \n \n \n \n \n \n \n\n\f\nEighth Schedule ___________ __________________________ \n \n753 \n[THE EIGHTH SCHEDULE \n[Section 100B] \n \nRULES FOR THE COMPUTATION OF CAPITAL GAINS ON  \nLISTED SECURITIES \n \n1. Manner and basis of computation of capital gains and tax thereon.—  (1) \nCapital gains on disposal of listed securities, subject to tax under section 37A, and \nto which section 100B apply, shall be computed and determined under this \nSchedule and tax thereon shall be collected and deposited on behalf of taxpayers \nby NCCPL in the manner prescribed. \n1[(1A) \nCapital gains on disposal of units of open ended mutual funds and \nto which section 100B apply, shall be computed and determined under this \nSchedule and tax thereon shall be collected and deposited by NCCPL in the \nprescribed manner: \nProvided that second and third proviso in Division VII of Part I of the \nFirst Schedule regarding capital gains arising on redemption of securities \nshall continue to apply.] \n2[(1B) Gain or loss arising to persons through trading of future commodity \ncontracts on Pakistan Mercantile Exchange, subject to tax under section 37A and \nto which section 100B apply, shall be computed and determined under this \nSchedule and tax thereon shall be collected and deposited on behalf of taxpayers \nby NCCPL in the manner prescribed.] \n(2) \nFor the purpose of sub-rule (1)3[,(1A) and (IB)], NCCPL shall develop \nan automated system. \n \n \n(3) \nCentral Depository Company of Pakistan Limited shall furnish \ninformation as required by NCCPL for discharging obligations under this \nSchedule4[:]  \n5[Provided that if the said information is not furnished under this sub-\nrule or sub-rule (3A), NCCPL shall forward the details to the Commissioner \nwho shall exercise powers under the Ordinance to enforce furnishing of the \nsaid information including all penalty provisions.]. \n                                            \n1Inserted by the Finance Act, 2016. \n2 Inserted by the Finance Act, 2016. \n3Inserted by the Finance Act, 2016. \n4 Full-stop substituted by the Finance Act, 2016. \n5Added by the Finance Act, 2016. \n\n\f\nEighth Schedule ___________ __________________________ \n752 \n \n1[(3A)The Asset Management Companies, Pakistan Mercantile Exchange \nand any other person shall furnish information when required by NCCPL for \ndischarging obligations under this Schedule.] \n \n(4) \nNCCPL shall issue an annual certificate to the taxpayer on the \nprescribed form in respect of capital gains subject to tax under this Schedule for a \nfinancial year: \nProvided that on the request of a taxpayer or if required by the \nCommissioner, NCCPL shall issue a certificate for a shorter period within a \nfinancial year.  \n \n(5) \nEvery taxpayer shall file the certificate referred to in sub-rule (4) along \nwith the return of income and such certificate shall be conclusive evidence in \nrespect of the income under this Schedule. \n \n(6) \nNCCPL shall furnish to the Board within 2[forty-five] days of the end of \neach quarter, a statement of capital gains and tax computed thereon in that quarter \nin the prescribed manner and format. \n \n(7) \nCapital gains computed under this Schedule shall be chargeable to \ntax at the rate applicable in Division VII of Part I of the First Schedule. \n3[(8) The provisions of section 4B shall apply to the taxpayers under this \nschedule and taxed at the rates specified in Division IIA of Part I of the First \nSchedule.] \n2. Sources of Investment.— (1) Where a person has made any investment in the \nlisted securities, enquiries as to the nature and source of the amount invested shall \nnot be made for any investment made prior to the introduction of this Schedule, \nprovided that — \n(a) \na statement of investments is filed with the Commissioner along with \nthe return of income and wealth statement for tax year 2012 within the \ndue date as provided in section 118 of this Ordinance and in the \nmanners prescribed; and \n(b) \n that the amount remains invested for a period of forty- five days upto \n30th of June 2012, in the manner as may be prescribed. \n \n(2) \nWhere a person has made any investment in the shares of a public \ncompany traded at a registered stock exchange in Pakistan from the date of \ncoming into force of this Schedule till June 30, 2014, enquiries as to the nature and \nsources of amount invested shall not be made provided that — \n \n                                            \n1Inserted by the Finance Act, 2016. \n2The word “thirty” substituted by the Finance Act, 2017. \n3Added by the Finance Act, 2015. \n\n\f\nEighth Schedule ___________ __________________________ \n753 \n \n(a) \nthe amount remains invested for a period of one hundred and twenty \ndays in the manner as may be prescribed ;  \n(b) \ntax on capital gains, if any, has duly been discharged in the manner \nlaid down in this Schedule; and \n(c) \n a statement of investments is filed with the Commissioner along with \nthe return of income and wealth statement for the relevant tax year \nwithin the due date as provided in section 118 of this Ordinance and \nin the manner prescribed. \n \n(3) \nFor the purpose of this rule, amount of investment shall be calculated \nin the prescribed manner, excluding market value of net open sale position in \nfutures and derivatives, if such sale is in a security that constitutes the said \ninvestment. \n3. Certain provisions of this Ordinance not to apply.—  The respective \nprovisions for collection and recovery of tax, advance tax and deduction of tax at \nsource laid down in the Parts IV and V of Chapter X shall not apply on the income \nfrom capital gains subject to tax under this Schedule and these provisions shall \napply in the manner as laid down in the rules made under this Ordinance, except \nwhere the recovery of tax is referred by NCCPL to the Board in terms of rule 6(3). \n4. Payment of tax collected by NCCPL to the Board.— The amount collected \nby NCCPL on behalf of the Board as computed in the manner laid down under this \nSchedule shall be deposited in a separate bank account with National Bank of \nPakistan and the said amount shall be paid to the Board along with interest accrued \nthereon on yearly basis by July 31st next following the financial year in which the \namount was collected. \n1[4A. Computation, collection and payment of tax under section 4C. – In \naddition to capital gains tax, NCCPL shall also compute and collect tax under \nsection 4C at the rates specified in Division IIB of Part I of the First Schedule on \nthe amount of capital gains computed under this Schedule in the manner specified \nin this Schedule and rules made thereunder.] \n5. Persons to whom this Schedule shall not apply.— If a person intends not to \nopt for determination and payment of tax as laid down in this Schedule, he shall \nfile an irrevocable option to NCCPL after obtaining prior approval of the \nCommissioner in the manner prescribed. In such case the provisions of rule 2 shall \nnot apply. \n6. Responsibility and obligation of NCCPL.— (1) Pakistan Revenue Automation \nLimited (PRAL), a company incorporated under the 2[Companies Act, 2017 (XIX of \n2017)] or any other company or firm approved by the Board and any authority \nappointed under section 209 of this Ordinance, not below the level of an Additional \n                                            \n1 Rule 4A inserted by the Finance Act, 2023. \n2 The expression “Companies Ordinance, 1984 (XLVII of 1984)” substituted by the Finance Act, \n2021. \n\n\f\nEighth Schedule ___________ __________________________ \n754 \n \nCommissioner Inland Revenue, shall conduct regular system and procedural \naudits of NCCPL on quarterly basis to verify the implementation of this Schedule \nand rules made under this Ordinance. \n \n(2) \nNCCPL shall implement the recommendations, if any, of the audit \nreport under sub-rule (1), as approved by the Commissioner, and make \nadjustments for short or excessive deductions. However, no penal action shall be \ntaken against NCCPL on account of any error, omission or mistake that has \noccurred from application of the system as audited under sub-rule (1).   \n \n(3) \nNCCPL shall be empowered to refer a particular case for recovery of \ntax to the Board in case NCCPL is unable to recover the amount of tax. \n \n7. Transitional Provisions.— In respect of tax year 2012, for the period \ncommencing from coming  into force of this Schedule till June 30, 2012, the \ncertificate issued by NCCPL under rule 1(4) shall be the basis of capital gains and \ntax thereon for that period.] \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n\n\f\nNinth Schedule – Part I_______ __________________________ \n \n757 \n1[THE NINTH SCHEDULE \n(See section 99A) \n \nNotwithstanding anything contained in this Ordinance or any other law for \nthe time being in force, a trader qualifying under this Schedule shall have the option \nto be assessed including for filing of return, either- \n \n(a) under the provisions of this Ordinance, other than this Schedule; or \n \n(b) under the provision of this Schedule. \n \nPART I \nRULES FOR THE COMPUTATION OF THE TAX PAYABLE ON PROFITS AND \nGAINS OF A TRADER FALLING UNDER SUB-SECTION (1) OF SECTION 99A \n \n1. \nThe tax payable on profits and gains of a trader  falling under sub-\nsection (1) of section 99A in respect of trading activities chargeable under the head \n“income from business” shall be computed in the manner hereinafter provided. \n \n2. \nFor trader qualifying under this Part, working capital for tax year 2015 \nshall not exceed rupees fifty million and tax at the rate of one per cent of the \nworking capital shall be the tax payable on profits and gains from the trading \nactivity. \n \n3. \nFor tax years 2016, 2017 and 2018, trader qualifying under this Part \nand who has paid tax for the tax year 2015 under rule 2 of this Part shall pay tax \nspecified in rule 4 of this Part subject to the following conditions, namely:- \n \n(a) for tax year 2016, the trader shall declare turnover at least three \ntimes of the working capital declared during tax year 2015; and \n \n(b) for tax years 2017 and 2018 the trader shall declare turnover on \nwhich tax paid is at least twenty-five per cent more than the tax paid \nfor the preceding tax year. \n4. \nFor the purpose of rule 3 of this Part, the following shall be tax rate on \nturnover:- \n \n                                            \n1Inserted by the National Assembly Secretariat’s O.M. No.F.22(2)/2016-Legis dated 29.01.2016. \n\n\f\nNinth Schedule – Part II_______ __________________________ \n \n758 \n \nTurnover \nRate \n(1) \n(2) \nWhere turnover does not exceed 50 million \nrupees \n0.2% \nWhere turnover exceeds 50 million rupees but \ndoes not exceeds 250 million rupees \nRs 100,000 plus 0.15% of the \namount exceeding 50 million \nrupees \nWhere turnover exceeds 250 million rupees \nRs 400,000 plus 0.1% of the \namount exceeding 250 million \nrupees \n \n \n \n \n \n \n5. \nTrader qualifying under this Part shall be entitled to take credit of \nimputable income as defined in clause (28A) of section 2, for tax years 2016 to \n2018, in relation to tax paid under rule 3 of this Part for the purpose of section 111. \n \nPART II \n \nRULES FOR THE COMPUTATION OF THE TAX PAYABLE ON PROFITS AND \nGAINS OF A TRADER FALLING UNDER SUB-SECTION (2) OF SECTION 99A \n \n1. \nThe tax payable on profits and gains of a trader  falling under sub-\nsection (2) of section 99A in respect of trading activities chargeable under the head \n“income from business” shall be computed in the manner hereinafter provided. \n \n2. \nFor tax year 2015, the tax payable on profits and gains of a trader \nqualifying under this Part shall be higher of the following: \n \n(a) 25% higher tax than paid for tax year 2014 or for the latest tax \nyear for which return has been filed on the basis of taxable \nincome; \n \n(b) tax on turnover at the rates specified in rule 4 of Part I; or \n \n(c) rupees thirty thousand. \n \n \n3. \nFor tax years 2016 to 2018, the tax payable on profits and gains of a \ntrader qualifying under this Part shall be higher of the following: \n \n(a) 25% higher tax on the basis of taxable income than tax paid for \nthe preceding tax year; or \n \n(b) tax on turnover at the rates specified in rule 4 of Part I. \n \n\n\f\nNinth Schedule – Part III______ __________________________ \n \n759 \n4. \nTrader qualifying under this Part, who has filed return for tax year 2015 \nbefore the due date of filing of return under this Schedule, may file a revised return \nsubject to the condition that the tax paid is higher of the following: \n \n(a) tax as per rule 2 of this Part on the basis of revised return;  \nor \n \n(b) 10% higher tax than the tax paid as per original return. \n \n5. \nFor tax year 2015, the provisions of clause (ba) of sub-section (6) of \nsection 114 shall not apply to a trader who has revised the return under rule 4 of \nthis Part before the due date of filing of return under this Schedule. \n \n6. \nWhere the imputable income as defined in clause (28A) of section 2 \nin relation to tax on turnover at the rates specified in rule 4 of Part I is higher than \nthe taxable income declared, the trader qualifying under this Part may opt to take \nthe credit for the purpose of section 111, of the difference between the said \nimputable income and taxable income, provided that tax at the rate of one per cent \nof the difference is paid along with the return. \n \nPART III \n \nGENERAL PROVISIONS FOR THE TRADERS UNDER PART I AND PART II \n \n1.  \nTraders deriving income other than from trading activities chargeable \nunder the head “income from business” shall not qualify under this Schedule. \n \n2. \nThe provisions of sections 177 and 214C shall not apply to a trader \nqualifying under this Schedule, for tax years 2015 to 2018.  \n \n3. \nTrader qualifying under Part I of this Schedule shall file a return as \nspecified in Form ‘A” to rule 17 of this Part and trader qualifying under Part II of \nthis Schedule shall file a return as prescribed under the Income Tax Rules, 2002. \n \n4. \nA trader qualifying under this Schedule shall not be entitled to claim \nany adjustment of withholding tax collected or deducted under this Ordinance, \nagainst tax payable in respect of profits and gains relating to trading activity. \n5. \nA trader qualifying under this Schedule shall not be entitled to claim \nany adjustment of refund due against tax payable under rule 2 or 3 of Part I or rule \n1, 3, or 4 of Part II. \n6.  \nA trader qualifying under this Schedule shall not be entitled for any tax \ncredit under this Ordinance. \n\n\f\nNinth Schedule – Part III_________________________________ \n758 \n \n7. \nIf a trader fails to furnish a return for any of the tax years 2016, 2017 \nor 2018 after having furnished a return for tax year 2015 shall not qualify under this \nSchedule for any of the tax years 2015 to 2018 notwithstanding the fact that the \nreturn for tax year 2015 stood qualified under this Schedule at the time of furnishing \nof such return and all the provisions of this Ordinance shall apply.  \n8.  \nWhere it is subsequently discovered by the Commissioner that the \ntrader was not eligible to be qualified under this Schedule or became ineligible to \nbe qualified under this Schedule during any time between tax years 2015 to 2018 \ndue to non-payment of tax or filing of return or otherwise, the trader shall be treated \nto have exercised the option to be assessed under the provisions of this \nOrdinance, other than this Schedule and all this provisions of this Ordinance shall \napply accordingly. \n9. \nTax payable under rule 2 or 3 of Part I or rule 1, 3, or 4 of Part II shall \nbe paid in the State Bank of Pakistan or authorized branches of National Bank of \nPakistan and evidence in the form of a copy of computerized tax payment receipt \n(CPR) shall be provided along with the specified or prescribed return, as the case \nmay be, by the due date. \n10. \nA trader qualifying under this Schedule shall not be a prescribed \nperson for the purpose of section 153. \n \n11. \nFor the income relating to trading activity and qualifying under this \nSchedule- \n \n(a) \nthe Commissioner shall be deemed to have made an assessment of \nincome for that tax year and the tax due thereon as equal to those \nrespective amounts computed under rules  2 or 3 of Part I or rule 1, 3, \nor 4 of Part II; and \n \n(b) \nthe specified or prescribed return, as the case may be, shall, for all \npurposes of this Ordinance, be deemed to be an assessment order \nincluding the application of section 120. \n \nExplanation.- For removal of doubt and for the purpose of this rule, it \nis declared that income means taxable income or imputable income \nas the case may be. \n12. \nThe Federal Government may, from time to time, by notification in the \nofficial Gazette, amend the Schedule so as to add any rule therein or modify or \nomit any rule therefrom. \n \n13. \nThe provisions of sub-section (2) of section 116 shall not apply for the \ntax year 2015 to the trader qualifying under this Schedule if the declared income \nfor the year is less than one million rupees. \n \n\n\f\nNinth Schedule – Part III_________________________________ \n759 \n \n14. \nNotwithstanding anything contained in aforesaid rules, a return \nqualifying under this Schedule may be subject to amendment under section 122 \nwhere definite information, as defined in sub-section (8) of section 122, comes into \nthe knowledge or possession of the Commissioner in which case all the provisions \nof the Ordinance shall apply accordingly. \n \n15. \nIn this Schedule,- \n(a) ‘due date’ means the date as specified by the Federal \nGovernment 1[*] for tax year 2015 and for the tax years 2016, 2017 \nand 2018 the date specified in clause (b) of sub-section (2) of \nsection 118. \n \n(b) ‘turnover’ means turnover as defined in clause (a) of sub-section \n(3) of section 113.  \n16. \nPersons convicted under Control of Narcotics Substances Act, 1997 \n(XXV of 1997), Anti-Terrorism Act, 1997 (XXVII of 1997) and Anti-Money \nLaundering Act, 2010 (VII of 2010) shall not be eligible to qualify under this \nSchedule. \n \n17. \nReturn for the trader qualifying under Part I of this Schedule shall be \non Form A as specified below:- \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n                                            \n1Inserted by the notification dated 30.01.2016. \n[“ *Notification \nIn exercise of the powers conferred by sub-rule (a) of Rule 15 of Part III of the Ninth Schedule to \nthe Income Tax Ordinance, the Federal Government, is pleased to specify the due date as twenty \nninth February, 2016 for filing of income tax returns for the tax year 2015 under rule 3 read with \nrule 17 of Part III of the Ninth Schedule to the Income Tax Ordinance, 2001.”] \n\n\f\nNinth Schedule – Part III_________________________________ \n760 \n \n \nForm A \nRETURN FOR TRADER QUALIFYING UNDER PART I OF THE SCHEDULE \nFOR THE TAX YEARS 2015 TO 2018 \n \nName of proprietor/Managing Member of AOP____________________________ \nCNIC: (please attach copy of CNIC)____________________________________ \nBusiness (es) Name & Address(es) ____________________________________     \n________________________________________________________________ \nPhone:______________ Email:__________________ Mobile: ______________ \nResidential Address of the proprietor:        \n________________________________________________________________\n________________________________________________________________ \nName(s) and Residential address(es) of Members of AOP (if applicable)  \n________________________________________________________________\n________________________________________________________________\n________________________________________________________________\n________________________________________________________________\n________________________________________________________________ \n(1) Amount of working capital ________________________________________ \n(2) Tax payable on (1) above (for tax year 2015 only)______________________ \n(3) Total Turnover _________________________________________________ \n(4) Tax payable on (3) above (for tax years 2016, 2017 and 2018 only)________  \n(5) Amount of Tax [(2) or (4)] _________________________________________ \n(6) CPR No: _________________________ Dated: _______________________ \n \n \nDeclaration: \n \nI_____________________________ CNIC No._____________________   in my \ncapacity as self /representative of taxpayer named above, do hereby solemnly \ndeclare that to the best of my knowledge and belief the information given in \nsimplified return is correct and complete in accordance with the provisions of Part \nI of the Ninth Schedule to Income Tax Ordinance, 2001 (XLIX of 2001). \n \nSignature \n: ________________________   \n \nDate  \n: ________________________”] \n \n \n \n \n\n\f\nTenth Schedule _____________ __________________________ \n \n763 \n1[THE TENTH SCHEDULE  \n \n(See section 100BA) \n \nRULES FOR PERSONS NOT APPEARING IN THE ACTIVE TAXPAYERS’ LIST  \n \n1. \nRate of deduction or collection of tax. – Where tax is required to be \ndeducted or collected under any provision of this Ordinance from persons not \nappearing in the active taxpayers’ list, the rate of tax required to be deducted or \ncollected, as the case may be, shall be increased by hundred percent of the rate \nspecified in 2[ ] this Ordinance 3[: \n \nProvided that the tax required to be collected under section 231B \nshall be increased by two hundred percent of the rate specified in First \nSchedule in case of persons not appearing in the active taxpayers’ list: \n \n4[Provided further that the tax required to be collected under section \n236K shall be at the rates set out in the following table, in case of persons \nnot appearing in the active taxpayers‘ list: –   \n \nTABLE \n \nS. No. \nFair Market Value of Immovable Property \nTax Rate \n(1) \n(2) \n(3) \n1 \nWhere the fair market value does not exceed  \nRs. 50 million \n5[10.5%]  \n2 \nWhere the fair market value exceeds Rs. 50 million \nbut does not exceed Rs. 100 million \n6[14.5%] \n \n3 \nWhere the fair market value exceeds Rs. 100 \nmillion \n7[18.5%]: \n \n                                            \n1 New “Tenth Schedule” inserted though Finance Act, 2019. \n2 The expression “the First Schedule to” omitted by the Finance Act, 2024. \n3 The full stop substituted with a colon and two provisos added by the Finance Act, 2022. \n4 The Second Proviso substituted by the Finance Act, 2024. The substituted proviso read as follows: \n“[Provided further that the tax required to be collected under section 236K shall be increased by two \nhundred and fifty percent of the rate specified in Division XVIII of Part IV of the First Schedule in case \nof persons not appearing in the active taxpayers.]” \n5 The expression “12%” substituted by the Finance Act, 2025. \n6 The expression “16%” substituted by the Finance Act, 2025. \n7 The expression “20%” substituted by the Finance Act, 2025. \n\n\f\nTenth Schedule ________________________________________ \n762 \n \nProvided also that the tax required to be collected or deducted, \nunder sections specified in column (2) against transactions specified in \ncolumn (3) shall be at the rates specified in column (4) of the following Table, \nin case of persons not appearing in the active taxpayers‘ list: – \n \n \nS. No. \nSection \nDescription \nTax Rate \n(1) \n(2) \n(3) \n(4) \n1[  \n- \n- \n] \n2 \nSection 236C \nOn \nthe \ngross \namount \nof \nconsideration received on sale or \ntransfer of immovable property \n2[11.5%] \n \n3 \nSection 236G \nOn the gross amount of sale to \ndistributors, \ndealers \nor \nwholesalers other than sale of \nfertilizer. \n2% \n4 \nSection 236H \nOn the gross amount of sale to \nretailers \n2.5%] \n \n \n3[1A. Rate of deduction or collection of tax from persons who are appearing \non active taxpayers’ list but have not filed return by the due date. – Where \ntax is required to be collected in respect of persons appearing on the active \ntaxpays‘ list who have not filed the return by the due date specified in section 118 \nor by the due date as extended under section 119 or 214A, the rate of tax shall be \n–  \n(a) \nas per rates set out in the following Table in case of tax to be collected under \nsection 236C; \n \nS. No. \nGross Amount of Consideration Received \nTax Rate \n(1) \n(2) \n(3) \n1 \nWhere the gross amount of consideration received \ndoes not exceed Rs. 50 million \n4[7.5%] \n \n2 \nWhere the gross amount of consideration received \nexceeds Rs. 50 million but does not exceed  \nRs. 100 million \n5[8.5%] \n \n                                            \n1 S. No. 1 and entries relating thereto in columns (2), (3) and (4) omitted by the Finance Act, 2025. . \nthe omitted S. No. read as follows: \n“1 \nSection 151 \nOn yield or profit on debt \n35%” \n \n2 The expression “10%” substituted by the Finance Act, 2025. \n3 Rule 1A inserted by the Finance Act, 2024. \n4 The expression “6%” substituted by the Finance Act, 2025. \n5 The expression “7%” substituted by the Finance Act, 2025. \n\n\f\nTenth Schedule ________________________________________ \n763 \n \n3 \nWhere the gross amount of consideration received \nexceeds Rs. 100 million \n1[9.5%]: \n \n \n(b) \nas per rates set out in the following Table in case of tax to be collected under \nsection 236K: \n \n \nS. No. \nFair Market Value of Immovable Property \nTax Rate \n(1) \n(2) \n(3) \n1 \nWhere the fair market value does not exceed  \nRs. 50 million \n2[4.5%] \n \n2 \nWhere the fair market value exceeds Rs. 50 million \nbut does not exceed Rs. 100 million \n3[5.5%] \n \n3 \nWhere the fair market value exceeds Rs. 100 \nmillion \n4[6.5%]: \n \n \n \nProvided that the provisions of this rule shall not apply to a person \nwho has filed return by the due date specified in section 118 or by the due \ndate as extended under section 119 or section 214A for all of the last three \ntax years preceding the tax year for which the return has not been filed by \nthe due date specified in section 118 or by the due date as extended under \nsection 119 or 214A.] \n \n2. \nPersons not required to file return or statement. – (1) Where the \nwithholding agent or the person from whom tax is required to be collected or \ndeducted is satisfied that a person not appearing in the active taxpayers’ list was \nnot required to file a return of income under section 114, 5[  ] as the case may be, \nhe shall before collecting or deducting tax under this Ordinance, furnish to \nCommissioner a notice in writing electronically setting out -  \n \n(a) the name, CNIC or NTN and address of the person not appearing in the \nactive taxpayers’ list’ \n \n(b) the nature and amount of the transaction on which tax is required to be \ncollected or deducted; and  \n \n(c) reason on the basis of which it is considered that the person was not \nrequired to file return or statement, as the case may be. \n \n                                            \n1 The expression “8%” substituted by the Finance Act, 2025. \n2 The expression “6%” substituted by the Finance Act, 2025. \n3 The expression “7%” substituted by the Finance Act, 2025. \n4 The expression “8%” substituted by the Finance Act, 2025. \n5 The expressions “or a statement under sub-section (4) of section 115, omitted though Finance Act, \n2020 dated 30th June, 2020  \n\n\f\nTenth Schedule ________________________________________ \n764 \n \n(2) \nThe Commissioner, on receipt of a notice under sub-rule (1), shall \nwithin thirty days pass an order accepting the contention or making the order under \nsub-rule(3). \n \n(3) \nWhere the withholding agent or the person from whom tax is required \nto be collected or deducted has notified the Commissioner under sub-rule(1) and \nthe Commissioner has reasonable grounds to believe that the person not \nappearing in the active taxpayers’ list was required to file return or statement, as \nthe case may be, the Commissioner may, by an order in writing, direct the \nwithholding agent to deduct or collect tax under rule 1: \n \n \nProvided that in case the Commissioner does not pass any order within thirty \ndays or receipt of notice under sub-rule(1), the Commissioner shall be deemed to \nhave accepted the contention under sub-rule (2) and approval shall be treated to \nhave been granted. \n \n3. \nProvisional assessment. (1) Where for a tax year person’s tax has been \ncollected or deducted in accordance with rule 1 and the person fails to file return \nof income 1[ ] for that tax year within the due date provided in section 118 or as \nextended by the Board, the Commissioner shall notwithstanding anything \ncontained in sub-sections (3) and (4) of section 114 2[ ], within sixty days of the \ndue date provided in section 118 or as extended by the Board make a provisional \nassessment of the taxable income of the person and issue a provisional \nassessment order specifying the taxable income assessed and tax due thereon. \n \n(2) \n In making the provisional assessment under sub-rule (1), the \nCommissioner shall impute taxable income on the amount of tax deducted or \ncollected under rule 1 by treating the imputed income as concealed income for the \npurposes of clause (d) of sub-section (1) of section 111: \n \n \nProvided that the provision of section 111 shall be applicable on unexplained \nincome, asset or expenditure in excess of imputed income treated as concealed \nincome under this rule.”   \n \n \n“Explanation.- For the removal of doubt it is clarified that the imputable \nincome so calculated or concealed income so determined shall not absolve the \nperson so assessed, from requirement of filing of wealth statement under sub-\nsection (1) of section 116, the nature and source of amounts subject to deduction \nor collection of tax under section 111, section of audit under section 177 or 214C \nor subsequent amendment of assessment as provided in rule 8 and all the \nprovisions of the Ordinance shall apply.” \n                                            \n1The expressions “or statement, as the case may be, omitted though Finance Act, 2020 dated 30th \nJune, 2020 \n2 The expressions “or sub-section (5) of section 115” omitted through Finance Act, 2020 dated 30th \nJune, 2020 \n\n\f\nTenth Schedule ________________________________________ \n765 \n \n \n4. \nFinalization or abatement of provisional assessment.-(1) The \nprovisional assessment under rule 3, shall be treated as the final assessment order \nafter the expiry of forty-five days from the date of service of order of provisional \nassessment and the provisions of this Ordinance shall apply accordingly. \n \n(2) \nThe provisional assessment shall stand abated and shall be taken be \nassessment finalized under sub-section (1) of section 120 where the returns of \nincome and wealth statement for the relevant tax year and the preceding tax year \nalong with prescribed form, statements or documents are filed by the person within \na period of forty-five days of receipt of provisional assessment order. \n \n(3) \nWhere returns have been filed before provisional assessment or \nunder sub-rule (2), the tax deducted or collected under rule 1 shall be adjustable \nagainst the tax payable in the return filed for the relevant tax year. \n \n5.  Where the provisional assessment has been treated as final assessment under \nsub-rule (1) of rule 4, the Commissioner may within thirty days of the final \nassessment initiate proceedings for imposition of penalties under section 182 on \naccount of non-furnishing and concealment of income. \n \n6. \nFor the purposes of this Schedule, imputed income means- (a) income \nfor individuals and association of persons which have resulted in the amount of tax \ngiven in paragraph (1) of Division I of the First Schedule equal to the tax collected \nor deducted under rule 1 for not appearing in the active taxpayers’ list; or  \n \n \n(b) \nincome for companies which would have resulted in the amount of tax \ngiven in Division II of the First Schedule equal to the tax collected or deducted at \nthe higher rate under rule 1 for not appearing in the active taxpayers’ list. \n \n7. \nWhere the withholding agent fails to furnish in the withholding statement \ncomplete or accurate particulars of persons not appearing on active taxpayers’ list, \nthe Commissioner shall initiate proceedings under sections 182 and 191 against \nthe withholding agent within thirty days of filing of withholding statement under \nsection 165. \n \n8. \nAmendment of assessment.-(1) The Commissioner may amend an \nassessment order where the imputed income is less than the amount on which tax \nwas deducted or collected under rule 1 or on the basis of definite information \nacquired from an audit or otherwise, the Commissioner is satisfied that-  \n \n(a) any income chargeable to tax has escaped assessment; or  \n \n(b) total income has been under-assessed, or assessed at too low a rate, \nor has been the subject of excessive relief or refund; or  \n \n\n\f\nTenth Schedule ________________________________________ \n766 \n \n(c) any amount under a head of income has been misclassified. \n(2) \nNotwithstanding the provisions of sub-rule (1), where a provisional \nassessment has been treated as final assessment or where in response to the \nprovisional assessment, return has been filed within forty-five days or where \nassessment has been amended under sub-rule (1) and the assessment order is \nconsidered erroneous in so far it is prejudicial to the interest of revenue, the \nCommissioner may, after making or causing to be made, such enquiries as he \ndeems necessary, amend the assessment order. \n \n(3) \nFor the purposes of sub-rule (1), “definite information” shall have the \nsame meaning as defined in sub-section (8) of section 122. \n \n9. \nProvisions of Ordinance to apply.- The provisions of this Ordinance not \nspecifically dealt with in the aforesaid rules shall apply, mutatis mutandis, in the \ncase of proceedings against the persons not appearing on active taxpayers’ list. \n \n10. \nThe provisions of this Schedule shall not apply on tax collectible or \ndeductible in case of the following sections:- \n \n(a) tax deducted under section 149; \n \n(b) tax deducted under section 152 other than sub-section 1[(2A)(a),] (2A)(b) \nand (2A)(c) of section 152; \n2[(ba) Tax deducted under clause (5A) of Part II of the Second Schedule read \nwith sub-section (2) of section 152.] \n3[(bb)  tax deducted under sub-section (2) of section 152 to the extent of clause \n(5AA) of Part II.  \n(c) tax collected or deducted under section 154; \n4[(ca) tax collected or deducted under section 154A;] \n5[   ] Omitted \n \n \n(d)  \n                                            \n1 The expressions “(1), (1AA), (2)” substituted by Finance Act, 2020 dated 30th June, 2020  \n2 Clause (ba) inserted through Tax Laws (Second Amendment) Ordinance 2019, dated 26th \nDecember, 2019. \n3 New sub rule (bb) inserted through Finance Act, 2020 dated 30th June, 2020. \n4 New sub-rule (ca) inserted by the Finance Act, 2022. \n5  Clauses (d), (f), (g), (h), (j), (m), (r) and (s) omitted by the Finance Act, 2021. The omitted clauses \nread as follows:           \n(d) \ntax deducted under section 155; \n(f) \ntax deducted under section 231A; \n(g) \ntax deducted under section 231AA; \n(h) \ntax deducted under section 233AA; \n(j) \ntax deducted under section 235A; \n(m) \ntax collected under section 236B; \n(r) \ntax collected under section 236L; \n(s) \ntax collected under section 236P; \n \n\n\f\nTenth Schedule ________________________________________ \n767 \n \n(e) 1[Omitted]                \n \n(f) \nOmitted \n \n(g) Omitted \n \n2[(ga) tax deducted under section 231AB;] \n \n(h) \nOmitted \n \n3[(ha)  tax collected under section 234 during the period starting from the \ndate of commencement of the Tax Laws (Second Amendment) \nOrdinance, 2022 and ending on the 30th day of June, 2023 in respect \nof goods transport and passenger transport vehicle.] \n \n \n(i) tax deducted under section 235; \n \n(j) Omitted \n \n(k) 4[ ]  \n(l) tax collected under section 236; \n \n(m) Omitted \n    \n \n(n) 5[ ]  \n \n \n \n \n \n \n(o) 6[ ]  \n(p) Omitted       \n \n(q) 7[ ]  \n(r) Omitted \n \n(s) Omitted \n \n(t) Omitted  \n \n8[ ] \n                                            \n1 Sub-rule (e), (p) and (t) omitted by the Finance Act, 2022. The omitted sub-rules read as follows:  \n“(e) tax deducted under section 156B; \n   (p) tax deducted under section 236I; \n   (q) tax deducted under section 236Q;” \n \n2 Sub-rule (ga) inserted by the Finance Act, 2023.   \n3 Clause (ha) inserted by the Tax Laws (Amendment) Act, 2023 (XVI of 2023) dated 20.04.2023. Earlier \nthis clause was inserted through Tax Laws (Second Amendment) Ordinance, 2022 (VI of 2022) dated \n23.08.2022. \n4 Sub-rule (k) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted rule read as \nfollows:  (k) tax collected under section 235B;. \n5 Sub-rule (n) omitted though Finance Act, 2020 dated 30th June, 2020 the omitted rule read as \nfollows:  “(n) tax collected under section 236D;” \n6 Sub-rule (o) omitted though Finance Act, 2020 dated 30th June, 2020 the omitted rule read as  \nfollows: “(o) tax collected under section 236F;” \n7 Sub-rule (q) omitted through Finance Act, 2020 dated 30th June, 2020 the omitted rule read as \nfollows: “(q) tax collected under section 236J;” \n \n8 Sub-rules (u),(v),(w) and (x) omitted though Finance Act, 2020 dated 30th June, 2020 the omitted \nrules read as follows : \n(u) tax collected under section 236R; \n(v) tax collected under section 236U; \n\n\f\nTenth Schedule ________________________________________ \n768 \n \n \n1[(y)  tax collected under section 2[37A on disposal of securities acquired \non and from 1st day of July, 2025;] \n \n \n \n \n \n \n                                            \n(w) tax collected under section 236V; \n(x) tax collected under section 236X;”  \n1 New sub-rule (y) inserted by the Finance Act, 2024. \n2 The expression “37A%” substituted by the Finance Act, 2025. \n\n\f\nEleventh Schedule___________ __________________________ \n \n771 \n1[ELEVENTH SCHEDULE \n \n     [See section 100D] \n \nRULES FOR COMPUTATION OF PROFITS AND GAINS OF BUILDERS AND \nDEVELOPERS AND TAX PAYABLE THEREON \n \n1. \nEligibility.–These rules shall apply to projects undertaken by builders and \ndevelopers under section 100D. \n \n2. \nScope and payment of tax.—(1) Income computed and tax payable \nthereon shall be on Project-by-Project basis which shall be computed and paid at \nthe rates provided in rule 10. \n \n(2) (a) The above-referred rates shall be applicable for  computing tax liability \nfor the project on annual basis. The annual tax liability shall be \nworked out as under: \n \nTax liability as per the rates in rule 10 \nEstimated project life in years \n \n(b) The estimated project life for tax purposes shall not exceed  2[three] \nand a half years: \n \n3[Provided that in case of existing incomplete projects, the \nestimated project life shall be treated as four years maximum from \ntax year 2020 through tax year 2023 and the tax payable shall be \nreduced by the percentage of completion up to the last day of \naccounting period pertaining to tax year 2019 or tax year 2020 as \ndeclared in the registration form.] \n \n4[  ] \n                                            \n1New Eleventh Schedule added through Finance Act, 2020 dated 30th June, 2020. \n2 The word “two” substituted by the Finance Act, 2021. Earlier this substitution was made through \nIncome Tax (Amendment) Ordinance, 2021. \n3 The first proviso substituted by the Finance Act, 2021. Earlier this substitution was made through \nIncome Tax (Amendment) Ordinance, 2021. The substituted proviso read as follows: \n“Provided that in case of existing incomplete projects, the estimated project life shall be treated \nas three years from tax year 2020 through tax year 2022, and the tax payable shall be reduced by \nthe percentage of completion up to the last day of the  accounting period pertaining to tax year 2019 \nas declared in registration form:” \n4 The second proviso omitted by the Finance Act, 2021. Earlier this omission was made through Income \nTax (Amendment) Ordinance, 2021.The omitted proviso read as follows: \nProvided further that tax liability of tax year 2020 shall be paid along with return. \n(b) Year shall include fraction of a year; and \n\n\f\nEleventh Schedule_____________________________________ \n770 \n \n \n3. \nRegistration and filing of return.— (1) A builder or developer shall \nelectronically register a project on Iris through FBR website on or before the 1[31st \nday of December, 2021] through submission of— \n \n(a) \nregistration form as may be prescribed which shall include, inter alia, \ndetails of a member or shareholder of a builder or developer, as the \ncase may be: \n \nProvided that a developer who is also a builder in case of \na project shall submit two separate forms for registration as a \ndeveloper and as a builder 2[: \n \nProvided further that where benefit of sub-section (3) of \nsection 100D is required to be claimed by builder or developer, the \nproject shall be registered latest by 30th day of June, 2021; and] \n \n(b)  \nan irrevocable option to be assessed under this Schedule in respect \nof each project. \n \n(2)  \nA builder or developer availing this scheme shall electronically file a \nreturn of income and wealth statement as may be prescribed accompanied with \nevidence of payment of due tax which shall be taken for all purposes of this \nOrdinance to be an assessment order issued to the taxpayer by the Commissioner \nto the extent of income computed under these rules. \n \n4. \nCertification.—Every builder or developer shall be required to obtain and \nprovide to the Board in the prescribed manner a certificate from approving authority \nor map approving authority or NESPAK, as the case may be, to the following effect, \nnamely:— \n \n(a) ‘total land area’ in square yards; \n \n(b) ‘covered area’ in square feet; \n \n(c) ‘saleable area’ in square feet; and \n \n(d) type (commercial, residential or industrial) of saleable area or the total land \narea, as the case may be. \n \n5. Advance tax.—A builder or developer falling under this scheme shall pay \nadvance tax equal to one-fourth of the tax liability for the year as determined in \naccordance with sub- rule (1) of rule 2 in four equal installments in the manner laid \ndown in section 147. \n \n                                            \n(c) The tax liability so calculated and paid shall be final tax.”. \n1 The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier this \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n2  Semi colon and the word “and” substituted and proviso added by the Finance Act, 2021. Earlier this \nsubstitution and addition was made through Income Tax (Amendment) Ordinance, 2021. \n\n\f\nEleventh Schedule_____________________________________ \n771 \n \n6. \nIncorporation of profits and gains for computation of income.—A \nbuilder or developer opting for taxation under section 100D shall not be allowed to \nincorporate profits and gains accruing from such projects in his books of account \nor wealth statement, as the case may be, in excess of ten times of the tax paid \nunder rule 2: \n \n \nProvided that such builder or developer shall not be allowed to incorporate \nprofits and gains accruing from a low cost housing project as defined in clause (f) \nof rule 9 in excess of ten times of the tax liability under rule 2: \n \n \nProvided further that where profits and gains accruing from a project are in \nexcess of ten times of the tax paid under rule 2, such excess profits and gains shall \nbe incorporated in the books of account or wealth statement, as the case may be, \nand taxed under Part I of the First Schedule 1[: \n \n \nProvided that profits and gains accruing from such projects in excess of ten \ntimes of tax paid under Rule (2) shall be incorporated by paying tax at the rate of \n20% on profits and gains which are in excess of said limit.] \n \n7. \nExemption from withholding of tax under sections 150 and 153.—(1) \nThe provisions of section 153 shall not apply to builders and developers on— \n \n(a) the purchase of building material except steel and cement; \n \n(b) services of plumbing, electrification, shuttering and other similar \nservices other than those provided by companies. \n \n \n(2) The provisions of section 150 shall not apply to payment of dividend \nexempt under sub-section (7) of section 100D. \n \n8. \nRestriction on change in pattern of ownership of a builder or developer \nbefore completion of a project.—Where exemption from the provisions of \nsection 111 has been claimed under sub-section (3) of section 100D, the following \nrestrictions shall apply, namely:— \n \n(a) a shareholder or a partner of a builder or developer shall not be allowed \na change in ownership of an incomplete project except where at least \nfifty percent of the total project cost, as certified by a firm of chartered \naccountants having an ICAP QCR rating of ‘satisfactory’ notified by the \nBoard for this purpose, has been incurred up to the date of change of \nownership;  \n  \n(b) The succession to legal heirs in case of deceased shareholder or a \npartner shall be allowed; \n \n(c)  The additional partners or shareholders in a builder or developer after \n                                            \n1 Full stop substituted and proviso added by the Finance Act, 2021.  \n\n\f\nEleventh Schedule_____________________________________ \n772 \n \nthe 1[30th day of June, 2021] may join but additional partners or \nshareholders shall not be eligible for exemption provided under sub-\nsection (3) of section 100D. \n \n9.  Definitions.—(1) In these rules, unless there is anything repugnant in the \nsubject or context, \n \n(a) “area” means \n \n(i) in case of a builder,— \n \n(a) in case of a commercial or a residential building excluding a house, \nthe saleable area of the building; and \n \n(b) in case of a house, the covered area of house; \n \n \n   (ii) in case of a developer, the total land area of the project; \n \n \n(b) \n“building” means a residential or commercial building or unit thereof; \n \n \n(c) \n“commercial building” includes any building or part thereof which is \nto be used for commercial purposes in accordance with the relevant \nlaws; \n \n \n(d) \n“commencement of project” means,- \n \n(i) \nin case of a construction project, when layout plan is approved \nby the concerned authority; and \n \n(ii) \nin case of a development project, when the development plan \nis approved by the concerned authority: \n \n \n \n \nProvided that where the building or developer has \ntaken all actions and done all things which are required and \nnecessary to procure any approvals but any such approval is \ndelayed beyond a period of 30 days from date of relevant \napplication and the cutoff date of 2[31st day of December, \n2021] is not adhered to by the builder or developer, the Board \nmay provisionally accept commencement of such project on a \ncase to case basis; \n \n \n(e) \n“completion of project” means.- \n                                            \n1  The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier this   \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n2  The expression “31st day of December, 2020” substituted by the Finance Act, 2021. Earlier this  \nsubstitution was made through Income Tax (Amendment) Ordinance, 2021. \n\n\f\nEleventh Schedule_____________________________________ \n773 \n \n \n(i) \nin the case of a builder, the date on which the grey structure is \ncompleted: \n \n  \n \nProvided that such grey structure shall only be considered \nas completed when the roof of the top floor has been laid as per \nthe approved plan;   \n \n \n(ii) \nin the case of a developer, the date on which— \n \n(A) at least 50% of the total plots have been booked in name of \nbuyers; \n \n(B) at least 40% of the sale proceeds have been received; \n \n(C) landscaping has been completed; and \n \n(D) at least 50% of the roads have been laid up to sub-grade \nlevel as certified by the approving authority or NESPAK; \n \n(f) ‘low   cost   housing‟   means   a   housing   scheme   as developed or \napproved by NAPHDA or under the Ehsaas Programme; \n \n(g) “NAPHDA” means Naya Pakistan Housing and Development Authority; \n \n(h) “NESPAK” means National Engineering Services Pakistan (Private) \nLimited; \n \n(i) “residential building” means a building which is not a commercial \nbuilding but does not include buildings used for industrial purposes; \n \n(j) “saleable area” in case of buildings, means saleable area as determined \nby the approving authority or map approving authority or NESPAK under \nthe relevant laws; \n \n(k) “unit” means a self-contained or independent building or part thereof \nincluding houses, apartments, shops, offices, etc. \n \n \n(2) \nAll other expressions used but not defined in these rules shall have \nthe same meaning as assigned to them under this Ordinance. \n \n10. \nRate and computation of tax liability.–(1) The rate of tax under section \n100D shall be computed in accordance with the Table below, namely:— \n \n \n \n \n \n\n\f\nEleventh Schedule_____________________________________ \n774 \n \nTABLE \n \nRate in respect of \n(1) \n(2) \n(3) \n(4) \nArea in \nKarachi, \nLahore \nand Islamabad \nHyderabad, Sukkur, Multan, \nFaisalabad, \nRawalpindi, \nGujranwala, \nSahiwal, \nPeshawar, \nMardan, \nAbbottabad, Quetta \nUrban Areas not specified \nin columns (2) and (3) \nTAX ON BUILDERS \nFOR COMMERCIAL BUILDINGS \nSq. Ft. \n- \n- \n- \nAny size \nRs.250 per Sq. ft \nRs.230 \nper Sq. ft \nRs.210 \nper Sq. ft \nFOR RESIDENTIAL BUILDINGS \nSq. ft. \n- \n- \n- \nupto 3000 \nRs.80 per Sq. ft \nRs.65 per Sq. ft \nRs.50 per Sq. ft \n3000 and above \nRs.125 per Sq. ft \nRs.110 per Sq. ft \nRs.100 per Sq. ft \nTAX ON DEVELOPERS (ENTIRE PROJECT) \nSq. Yds. \n- \n- \n- \nAny size \nRs.150 per Sq. yd \nRs.130 per Sq. yd \nRs.100 per Sq. yd \nFOR DEVELOPMENT OF INDUSTRIAL AREA \nSq. Yds. \n- \n- \n- \nAny size \nRs.20 per Sq. yd \nRs.20 per Sq. yd \nRs.10 per Sq. yd \n \n  \n(2) \nIn case of mixed use buildings having both commercial and residential \nareas, respective rates mentioned above shall apply. \n \n  \n(3)  \nIn case of development of plots and constructing buildings on the \nsame plots as one project, both rates shall apply: \n \n  \nProvided that in the case of ‘low cost housing and all projects developed by \nNAPHDA, the higher rates shall apply. \n \n \n \n \n \n \n \n \n \n \n \n\n\f\nTwelfth Schedule___________ __________________________ \n \n777 \nTHE TWELFTH SCHEDULE \n[See Section148]  \nPART I \n \nPCT CODE \nDESCRIPTION \n(1) \n(2) \n1[07.01  \nPotatoes, fresh or chilled. \n0702.0000  \nTomatoes, fresh or chilled. \n07.03 \nOnions, shallots, garlic, leeks and other alliaceous vegetables, fresh or \nchilled. \n1006.1010 \nSeed for sowing. \n27.01  \nCoal; briquettes, ovoids and similar solid fuels manufactured from coal.] \n2711.1100 \n- - Natural Gas \n3102.1000 \n- Urea, Whether Or Not In Aqueous Solution \n31.04 \nMineral or chemical fertilisers, potassic. \n52.01 \nCotton, not carded or combed. \n52.02 \nCotton waste (including yarn waste and garnetted stock). \n5203.0000 \nCotton, carded or combed. \n71.08 \nGold (including gold plated with platinum) unwrought or in semi- manufactured forms, \nor in powder form. \n2[    ] \n \n84.01 \nNuclear reactors; fuel elements (cartridges), non- irradiated, for nuclear reactors; \nmachinery and apparatus for isotopic separation. \n84.02 \nSteam or other vapour generating boilers (other than central heating hot water boilers \ncapable also of producing low pressure steam); super- heated water boilers. \n84.03 \nCentral heating boilers other than those of heading 84.02. \n84.04 \nAuxiliary plant for use with boilers of heading 84.02 or 84.03 (for example, \neconomisers, super- heaters, soot removers, gas recoverers); condensers for steam \nor other vapour power units. \n84.05 \nProducer gas or water gas generators, with or without their purifiers; acetylene gas \ngenerators and similar water process gas generators, with or without their purifiers. \n84.06 \nSteam turbines and other vapour turbines. \n84.10 \nHydraulic turbines, water wheels, and regulators therefor. \n84.11 \nTurbo- jets, turbo- propellers and other gas turbines. \n84.12 \nOther engines and motors. \n84.16 \nFurnace burners for liquid fuel, for pulverised solid fuel or for gas; mechanical stokers, \nincluding their mechanical grates, mechanical ash dischargers and similar appliances. \n84.17 \nIndustrial or laboratory furnaces and ovens, including incinerators, non- electric. \n                                            \n1  The PCT Codes 07.01, 0702.0000, 07.03, 1006.1010 and 27.01 and entries relating thereto inserted \nby the Finance Act, 2022. \n2  The PCT Code 72.04 and entry relating thereto omitted by the Finance Act, 2022. The omitted PCT \nCode read as follows: \n     \n“72.04 \nFerrous waste and scrap; remelting scrap ingots of iron or steel.” \n \n\n\f\nTwelfth Schedule_____________________________________ \n776 \n \n84.19 \nMachinery, plant or laboratory equipment, whether or not electrically heated \n(excluding furnaces, ovens and other equipment of heading 85.14), for the treatment \nof materials by a process involving a change of temperature such as heating, cooking, \nroasting, distilling, rectifying, sterilising, pasteurising, steaming, drying, evaporating, \nvaporising, condensing or cooling, other than machinery or plant of a kind used for \ndomestic purposes; instantaneous or storage water heaters, non- electric. \n84.20 \nCalendering or other rolling machines, other than for metals or glass, and cylinders \ntherefor. \n84.21 \nCentrifuges, including centrifugal dryers; filtering or purifying machinery and \napparatus, for liquids or gases. \n8422.3000 \n- Machinery for filling, closing, sealing, or labelling bottles, cans, boxes, bags or other \ncontainers; machinery for capsuling bottles, jars, tubes and similar containers; \nmachinery for aerating beverages \n8422.4000 \n- Other packing or wrapping machinery (including heat- shrink wrapping machinery) \n84.23 \n(Except \n8423.1000) \nWeighing machinery (excluding balances of a sensitivity of 5 cg or better), including \nweight operated counting or checking machines; weighing machine weights of all \nkinds. \n84.26 \nShips’ derricks; cranes, including cable cranes; mobile lifting frames, straddle carriers \nand works trucks fitted with a crane. \n84.27 \nFork- lift trucks; other works trucks fitted with lifting or handling equipment. \n84.28 (Except \n8428.1010 and \n8428.4000) \nOther lifting, handling, loading or unloading machinery (for example, lifts, \nescalators, conveyors, teleferics). \n84.29 \nSelf- propelled bulldozers, angledozers, graders, levellers, scrapers, \nmechanical shovels, excavators, shovel loaders, tamping machines and road \nrollers. \n \n84.30 \nOther moving, grading, levelling, scraping, excavating, tamping, compacting, \nextracting or boring machinery, for earth, minerals or ores; pile- drivers and pile- \nextractors; snow- ploughs and snow- blowers. \n84.31 \nParts suitable for use solely or principally with the machinery of headings 84.25 \nto 84.30. \n84.32 \nAgricultural, horticultural or forestry machinery for soil preparation or cultivation; \nlawn or sports- ground rollers. \n84.33 (Except \n8433.1100 and \n8433.1900) \nHarvesting or threshing machinery, including straw or fodder balers; grass or \nhay mowers; machines for cleaning, sorting or grading eggs, fruit or other \nagricultural \nproduce, other than machinery of heading 84.37. \n84.34 \nMilking machines and dairy machinery. \n84.35 \nPresses, crushers and similar machinery used in the manufacture of wine, \ncider, fruit juices or similar beverages. \n \n84.36 \nOther agricultural, horticultural, forestry, poultry- keeping or bee- keeping \nmachinery, including germination plant fitted with mechanical or thermal \nequipment; poultry incubators and brooders. \n \n84.37 \nMachines for cleaning, sorting or grading seed, grain or dried leguminous \nvegetables; machinery used in the milling industry or for the working of cereals \nor dried leguminous vegetables, other than farm- type machinery. \n \n84.38 \nMachinery, not specified or included elsewhere in this Chapter, for the industrial \npreparation or manufacture of food or drink, other than machinery for the \nextraction or preparation of animal or fixed vegetable fats or oils. \n84.39 \nMachinery for making pulp of fibrous cellulosic material or for making or \nfinishing paper or paperboard. \n84.40 \nBook- binding machinery, including book- sewing machines. \n84.41 \nOther machinery for making up paper pulp, paper or paperboard, including \ncutting machines of all kinds. \n\n\f\nTwelfth Schedule_____________________________________ \n777 \n \n \n84.42 \nMachinery, apparatus and equipment (other than the machines of headings \n84.56 to 84.65), for preparing or making plates, cylinders or other printing \ncomponents; plates, cylinders and other printing components; plates, cylinders \nand lithographic stones, prepared for printing purposes (for example, planed, \ngrained or polished). \n8443.1100 \nOffset printing machinery, reel-fed \n8443.1200 \nOffset printing machinery, sheet-fed, office type (using sheets with one side not \nexceeding 22 cm and the other side not exceeding 36 cm in the unfolded state) \n8443.1300 \nOther offset printing machinery \n8443.1400 \nLetterpress printing machinery, reel fed, excluding flexographic printing \n8443.1500 \nLetterpress printing machinery, other than reel fed, excluding flexographic \nprinting \n8443.1600 \n- Flexographic printing machinery \n8443.1700 \nGravure printing machinery \n8443.1910 \nHot stamping machines \n8443.1920 \nLabel printing/embossing machines \n8443.1930 \nFlat bed printing presses \n8443.1940 \nProof presses \n8443.1951 \nOn cotton textile \n8443.1959 \nOther \n8443.1990 \nOther \n8444.0000 \nMachines for extruding, drawing, texturing or cutting man- made textile \nmaterials. \n \n84.45 \nMachines for preparing textile fibres; spinning, doubling or twisting machines \nand other machinery for producing textile yarns; textile reeling or winding \n(including weft- winding) machines and machines for preparing textile yarns for \nuse on the machines of heading 84.46 or 84.47. \n84.46 \nWeaving machines (looms). \n84.47 \nKnitting machines, stitch- bonding machines and machines for making gimped \nyarn, tulle, lace, embroidery, trimmings, braid or net and machines for tufting. \n \n \n84.48 \nAuxiliary machinery for use with machines of heading 84.44, 84.45, 84.46 or \n84.47 (for example, dobbies, Jacquards, automatic stop motions, shuttle \nchanging mechanisms); parts and accessories suitable for use solely or \nprincipally with the machines of this heading or of heading 84.44, 84.45, 84.46 \nor 84.47 (for example, spindles and spindle flyers, card clothing, combs, \nextruding nipples, shuttles, healds \nand heald- frames, hosiery needles). \n8449.0000 \nMachinery for the manufacture or finishing of felt or nonwovens in the piece or \nin shapes, including machinery for making felt hats; blocks for making hats. \n \n \n84.51 \nMachinery (other than machines of heading 84.50) for washing, cleaning, \nwringing, drying, ironing, pressing (including fusing presses), bleaching, dyeing, \ndressing, finishing, coating or impregnating textile yarns, fabrics or made up \ntextile articles and machines for applying the paste to the base fabric or other \nsupport used in the manufacture of floor coverings such as linoleum; machines \nfor reeling, unreeling, \nfolding, cutting or pinking textile fabrics. \n \n84.53 \nMachinery for preparing, tanning or working hides, skins or leather or for \nmaking or repairing footwear or other articles of hides, skins or leather, other \nthan sewing machines. \n84.54 \nConverters, ladles, ingot moulds and casting machines, of a kind used in \nmetallurgy or in metal foundries. \n84.55 \nMetal- rolling mills and rolls therefor. \n \n84.56 \nMachine- tools for working any material by removal of material, by laser or other \nlight or photon beam, ultrasonic, electro- discharge, electro- chemical, electron \n\n\f\nTwelfth Schedule_____________________________________ \n778 \n \nbeam, ionic- beam or plasma arc processes; water- jet cutting machines. \n84.57 \nMachining centres, unit construction machines (single station) and multi- station \ntransfer machines, for working metal. \n84.58 \nLathes (including turning centres) for removing metal. \n \n84.59 \nMachine- tools (including way- type unit head machines) for drilling, boring, \nmilling, threading or tapping by removing metal, other than lathes (including \nturning centres) of heading 84.58. \n \n84.60 \nMachine- tools for deburring, sharpening, grinding, honing, lapping, polishing or \notherwise finishing metal or cermets by means of grinding stones, abrasives or \npolishing products, other than gear cutting, gear grinding or gear finishing \nmachines of heading 84.61. \n \n84.61 \nMachine- tools for planing, shaping, slotting, broaching, gear cutting, gear \ngrinding or gear finishing, sawing, cutting- off and other machine- tools working \nby removing metal or cermets, not elsewhere specified or included. \n \n84.62 \nMachine- tools (including presses) for working metal by forging, hammering or \ndie- stamping; machine- tools (including presses) for working metal by bending, \nfolding, \nstraightening, flattening, shearing, punching or notching; presses for working \nmetal or metal carbides, not specified above. \n84.63 \nOther machine- tools for working metal or cermets, without removing material. \n84.64 \nMachine- tools for working stone, ceramics, concrete, asbestos- cement or like \nmineral materials or for cold working glass. \n \n84.68 \nMachinery and apparatus for soldering, brazing or welding, whether or not \ncapable of cutting, other than those of heading 85.15; gas- operated surface \ntempering machines and appliances. \n \n \n84.74 \nMachinery for sorting, screening, separating, washing, crushing, grinding, \nmixing or kneading earth, stone, ores or other mineral substances, in solid \n(including powder or paste) form; machinery for agglomerating, shaping or \nmoulding solid mineral fuels, ceramic paste, unhardened cements, plastering \nmaterials or other mineral products in powder or paste form; machines for \nforming foundry moulds of sand. \n84.75 \nMachines for assembling electric or electronic lamps, tubes or valves or \nflashbulbs, in glass envelopes; machines for manufacturing or hot working glass \nor glassware. \n84.77 \nMachinery for working rubber or plastics or for the manufacture of products from \nthese materials, not specified or included elsewhere in this Chapter. \n84.78 \nMachinery for preparing or making up tobacco, not specified or included \nelsewhere in this Chapter. \n84.79 (Except \n8479.8960 and \n8479.8990) \nMachines and mechanical appliances having individual functions, not specified \nor included elsewhere in this Chapter. \n84.80 \nMoulding boxes for metal foundry; mould bases; moulding patterns; moulds for \nmetal (other than ingot moulds), metal carbides, glass, mineral materials, \nrubber or plastics. \n \n84.86 \nMachines and apparatus of a kind used solely or principally for the manufacture \nof semiconductor boules or wafers, semiconductor devices, electronic \nintegrated circuits or flat panel displays; machines and apparatus specified in \nNote 9 (c) to this Chapter; parts and accessories. \n8501.3300 \nOf an output exceeding 75 kW but not exceeding 375 kW \n8501.3400 \nOf an output exceeding 375 kW \n8502.1190 \nOther \n8502.1200 \nOf an output exceeding 75 kVA but not exceeding 375 kVA \n8502.3100 \nWind-powered \n8502.3900 \nOther \n8503.0090 \nOther \n\n\f\nTwelfth Schedule_____________________________________ \n779 \n \n8504.2100 \nHaving a power handling capacity not exceeding 650 kVA \n8504.2200 \nHaving a power handling capacity exceeding 650 kVA but not exceeding 10,000 \nkVA \n8504.2300 \nHaving a power handling capacity exceeding 10,000 kVA \n8504.3400 \nHaving a power handling capacity exceeding 500 kVA \n8504.5000 \nOther inductors \n \n85.14 \nIndustrial or laboratory electric furnaces and ovens (including those functioning \nby induction or dielectric loss); other industrial or laboratory equipment for the \nheat treatment of materials by induction or dielectric loss. \n \n85.15 \nElectric (including electrically heated gas), laser or other light or photon beam, \nultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or \nwelding machines and apparatus, whether or not capable of cutting; electric \nmachines and apparatus for hot spraying of metals or cermets. \n8543.3000 \n- Machines and apparatus for electroplating, electrolysis or electrophoresis \n85.45 (Except \n8545.1100 and \n8545.9020) \nCarbon electrodes, carbon brushes, lamp carbons, battery carbons and other \narticles of graphite or other carbon, with or without metal, of a kind used for \nelectrical \npurposes. \n85.46 \nElectrical insulators of any material. \n \n \n85.47 \nInsulating fittings for electrical machines, appliances or equipment, being fittings \nwholly of insulating material apart from any minor components of metal (for \nexample, threaded sockets) incorporated during moulding solely for purposes of \nassembly, \nother than insulators of heading 85.46; electrical conduit tubing and joints \ntherefor, of base metal lined with insulating material. \n89052000 \n- Floating Or Submersible Drilling Or Production Platforms \n \nPart II \n \nPCT CODE \nDESCRIPTION \n(1) \n(2) \n05.05 \nSkins and other parts of birds, with their feathers or down, feathers and parts of \nfeathers (whether or not with trimmed edges) and down, not further worked than \ncleaned, disinfected or treated for preservation; powder and waste of feathers or parts \nof feathers. \n05.06 \nBones and horn- cores, unworked, defatted, simply prepared (but not cut to shape), \ntreated with acid or degelatinised; powder and waste of these products. \n05.07 \nIvory, tortoise- shell, whalebone and whalebone hair, horns, antlers, hooves, nails, \nclaws and beaks, unworked or simply prepared but not cut to shape; powder and \nwaste of these products. \n05.08 \nCoral and similar materials, unworked or simply prepared but not otherwise worked; \nshells of molluscs, crustaceans or echinoderms and cuttle- bone, unworked or simply \nprepared but not cut to shape, powder and waste thereof. \n0510.0000 \nAmbergris, castoreum, civet and musk; cantharides; bile, whether or not dried; glands \nand other animal products used in the preparation of pharmaceutical products, fresh, \nchilled, frozen or otherwise provisionally preserved. \n05.11 \nAnimal products not elsewhere specified or included; dead animals of Chapter 1 or 3, \nunfit for human consumption. \n\n\f\nTwelfth Schedule_____________________________________ \n780 \n \n1[    ] \n \n[   ] \n \n[   ] \n \n07.04 \nCabbages, cauliflowers, kohlrabi, kale and similar edible brassicas, fresh or chilled. \n07.05 \nLettuce (Lactuca sativa) and chicory (Cichorium spp.), fresh or chilled. \n07.06 \nCarrots, turnips, salad beetroot, salsify, celeriac, radishes and similar edible roots, \nfresh or chilled. \n0707.0000 \nCucumbers and gherkins fresh or chilled. \n07.08 \nLeguminous vegetables, shelled or unshelled, fresh or chilled. \n07.11 \nVegetables provisionally preserved (for example, by sulphur dioxide gas, in brine, in \nsulphur water or in other preservative solutions), but unsuitable in that state for \nimmediate consumption. \n07.13 \nDried leguminous vegetables, shelled, whether or not skinned or split. \n10.02 \nRye. \n10.03 \nBarley. \n10.04 \nOats. \n10.05 \nMaize (corn). \n[   ] \n \n11.08 \nStarches; inulin. \n12.01 \nSoya beans, whether or not broken. \n12.05 \nRape or colza seeds, whether or not broken. \n1206.0000 \nSunflower seeds, whether or not broken. \n12.07 \nOther oil seeds and oleaginous fruits, whether or not broken. \n12.09 \nSeeds, fruit and spores, of a kind used for sowing. \n12.10 \nHop cones, fresh or dried, whether or not ground, powdered or in the form of pellets; \nlupulin. \n12.11 \nPlants and parts of plants (including seeds and fruits), of a kind used primarily in \nperfumery, in pharmacy or for insecticidal, fungicidal or similar purposes, fresh, \nchilled, frozen or dried, whether or not cut, crushed or powdered. \n15.02 \nFats of bovine animals, sheep or goats, other than those of heading 15.03. \n15.07 \nSoya- bean oil and its fractions, whether or not refined, but not chemically modified. \n15.11 \nPalm oil and its fractions, whether or not refined, but not chemically modified. \n \n \n1518.0000 \nAnimal or vegetable fats and oils and their fractions, boiled, oxidised, \ndehydrated, sulphurised, blown, polymerised by heat in vacuum or in inert gas \nor otherwise chemically modified, excluding those of heading 15.16; inedible \nmixtures or preparations of animal or vegetable fats or oils or of fractions of \ndifferent fats or oils of \nthis Chapter, not elsewhere specified or included. \n18.03 \nCocoa paste, whether or not defatted. \n                                            \n1  The PCT Codes 07.01, 0702.000, 07.03, 1006.1010 and 27.01 and entries relating thereto omitted \nby the Finance Act, 2022. The omitted PCT Codes read as follows:     \n“07.01 \nPotatoes, fresh or chilled. \n0702.0000 \nTomatoes, fresh or chilled. \n07.03 \nOnions, shallots, garlic, leeks and other alliaceous vegetables, fresh or chilled. \n1006.1010 \nSeed for sowing \n27.01 \nCoal; briquettes, ovoids and similar solid fuels manufactured from coal.” \n \n     \n \n\n\f\nTwelfth Schedule_____________________________________ \n781 \n \n \n23.06 \nOil- cake and other solid residues, whether or not ground or in the form of \npellets, resulting from the extraction of vegetable fats or oils, other than those of \nheading 23.04 or 23.05. \n2502.0000 \nUnroasted iron pyrites. \n2503.0000 \nSulphur of all kinds, other than sublimed sulphur, precipitated sulphur and \ncolloidal sulphur. \n25.04 \nNatural graphite. \n25.05 \nNatural sands of all kinds, whether or not coloured, other than metal bearing \nsands of chapter 26. \n \n25.06 \nQuartz (other than natural sands); quartzite, whether or not roughly trimmed or \nmerely cut, by sawing or otherwise, into blocks or slabs of a rectangular \n(including square) shape. \n2507.0000 \nKaolin and other kaolinic clays,whether or not calcined. \n25.08 \nOther clays (not including expanded clays of heading 68.06), andalusite, \nkyanite and sillimanite, whether or not calcined; mullite; chamotte or dinas \nearths. \n2509.0000 \nChalk. \n25.10 \nNatural calcium phosphates, natural aluminium calcium phosphates and \nphosphatic chalk. \n25.11 \nNatural barium sulphate (barytes); natural barium carbonate (witherite), whether \nor not calcined, other than barium oxide of heading 28.16. \n2512.0000 \nSiliceous fossil meals (for example, kieselguhr, tripolite and diatomite) and \nsimilar siliceous earths, whether or not calcined, of an apparent specific gravity \nof 1 or less. \n25.13 \nPumice stone; emery; natural corundum, natural garnet and other natural \nabrasives, whether or not heat- treated. \n2514.0000 \nSlate, whether or not roughly trimmed or merely cut, by sawing or otherwise, \ninto blocks or slabs of a rectangular (including square) shape. \n \n25.18 \nDolomite, whether or not calcined or sintered, including dolomite roughly \ntrimmed or merely cut, by sawing or otherwise, into blocks or slabs of a \nrectangular (including square) shape; dolomite ramming mix. \n \n25.19 \nNatural magnesium carbonate (magnesite); fused magnesia; dead- burned \n(sintered) magnesia, whether or not containing small quantities of other oxides \nadded before sintering; other magnesium oxide, whether or not pure. \n25.20 \nGypsum; anhydrite; plasters (consisting of calcined gypsum or calcium \nsulphate) whether or not coloured, with or without small quantities of \naccelerators or retarders. \n2521.0000 \nLimestone flux; limestone and other calcareous stone, of a kind used for the \nmanufacture of lime or cement. \n25.25 \nMica, including splittings; mica waste. \n \n2528.0000 \nNatural borates and concentrates thereof (whether or not calcined), but not \nincluding borates separated from natural brine; natural boric acid containing not \nmore than 85 \n% of H3BO3 calculated on the dry weight. \n25.29 \nFeldspar; leucite; nepheline and nepheline syenite; fluorspar. \n25.30 \nMineral substances not elsewhere specified or included. \n26.01 \nIron ores and concentrates, including roasted iron pyrites. \n \n2602.0000 \nManganese ores and concentrates, Including ferruginous manganese ores and \nconcentrates with a manganese content of 20 % or more, calculated on the dry \nweight. \n2603.0000 \nCopper ores and concentrates. \n2604.0000 \nNickel ores and concentrates. \n2605.0000 \nCobalt ores and concentrates. \n\n\f\nTwelfth Schedule_____________________________________ \n782 \n \n2606.0000 \nAluminium ores and concentrates. \n2607.0000 \nLead ores and concentrates. \n2608.0000 \nZinc ores and concentrates. \n2609.0000 \nTin ores and concentrates. \n2610.0000 \nChromium ores and concentrates. \n2611.0000 \nTungsten ores and concentrates. \n26.12 \nUranium or thorium ores and concentrates. \n26.13 \nMolybdenum ores and concentrates. \n2614.0000 \nTitanium ores and concentrates. \n26.15 \nNiobium, tantalum, vanadium or zirconium ores and concentrates. \n26.16 \nPrecious metal ores and concentrates. \n26.17 \nOther ores and concentrates. \n2618.0000 \nGranulated slag (slag sand) from the manufacture of iron or steel. \n2619.0000 \nSlag, dross (other than granulated slag), scalings and other waste from the \nmanufacture of iron or steel. \n26.20 \nSlag, ash and residues (other than from the manufacture of iron or steel) \ncontaining metals, arsenic or their compounds. \n[   ] \n \n27.02 \nLignite, whether or not agglomerated, excluding jet. \n2703.0000 \nPeat (including peat litter), whether or not agglomerated. \n27.04 \nCoke and semi- coke of coal, of lignite or of peat, whether or not agglomerated; \nretort carbon. \n2705.0000 \nCoal gas, water gas, producer gas and similar gases, other than petroleum \ngases and other gaseous hydrocarbons. \n \n27.07 \nOils and other products of the distillation of high temperature coal tar; similar \nproducts \nin which the weight of the aromatic constituents exceeds that of the non- \naromatic constituents. \n27.08 \nPitch and pitch coke, obtained from coal tar or from other mineral tars. \n2709.0000 \nPetroleum oils and oils obtained from bituminous minerals, crude \n28.03 \nCarbon (carbon blacks and other forms of carbon not elsewhere specified or \nincluded). \n28.04 \nHydrogen, rare gases and other non- metals. \n28.05 \nAlkali or alkaline- earth metals; rare- earth metals, scandium and yttrium, \nwhether or not intermixed or inter- alloyed; mercury. \n28.08 \nNitric acid; sulphonitric acids. \n28.09 \nDiphosphorus pentaoxide; phosphoric acid; polyphosphoric acids, whether or \nnot chemically defined. \n28.11 \nOther inorganic acids and other inorganic oxygen compounds of non- metals. \n28.14 \nAmmonia, anhydrous or in aqueous solution. \n28.15 \nSodium hydroxide (caustic soda); potassium hydroxide (caustic potash); \nperoxides of sodium or potassium. \n2817.0000 \nZinc oxide; zinc peroxide. \n28.18 \nArtificial corundum, whether or not chemically defined; aluminium oxide; \naluminium hydroxide. \n28.19 \nChromium oxides and hydroxides. \n28.20 \nManganese oxides. \n28.21 \nIron oxides and hydroxides; earth colours containing 70 % or more by weight of \ncombined iron evaluated as Fe2O3. \n2822.0000 \nCobalt oxides and hydroxides; commercial cobalt oxides. \n28.23 \nTitanium oxides. \n\n\f\nTwelfth Schedule_____________________________________ \n783 \n \n28.24 \nLead oxides; red lead and orange lead. \n28.25 \nHydrazine and hydroxylamine and their inorganic salts; other inorganic bases; \nother metal oxides, hydroxides and peroxides. \n28.26 \nFluorides; fluorosilicates, fluoroaluminates and other complex fluorine salts. \n28.27 \nChlorides, chloride oxides and chloride hydroxides; bromides and bromide \noxides; iodides and iodide oxides. \n28.28 \nHypochlorites; commercial calcium hypochlorite; chlorites; hypobromites. \n28.29 \nChlorates and perchlorates; bromates and perbromates; iodates and \nperiodates. \n28.30 \nSulphides; polysulphides, whether or not chemically defined. \n28.31 \nDithionites and sulphoxylates. \n28.32 \nSulphites; thiosulphates. \n28.33 \nSulphates; alums; peroxosulphates (persulphates). \n28.34 \nNitrites; nitrates. \n28.35 \nPhosphinates(hypophosphites), phosphonates (phosphites) and phosphates; \npolyphosphates, whether or not chemically defined. \n28.36 \nCarbonates;peroxocarbonates (percarbonates); commercial ammonium \ncarbonate containing ammonium carbamate. \n28.39 \nSilicates; commercial alkali metal silicates. \n28.40 \nBorates; peroxoborates (perborates). \n28.41 \nSalts of oxometallic or peroxometallic acids. \n28.42 \nOther salts of inorganic acids or peroxoacids (including aluminosilicates \nwhether or not chemically defined), other than azides. \n28.43 \nColloidal precious metals; inorganic or organic compounds of precious metals, \nwhether or not chemically defined; amalgams of precious metals. \n \n28.44 \nRadioactive chemical elements and radioactive isotopes (including the fissile or \nfertile \nchemical elements and isotopes) and their compounds; mixtures and residues \ncontaining these products. \n28.45 \nIsotopes other than those of heading 28.44; compounds, inorganic or organic, \nof such isotopes, whether or not chemically defined. \n28.46 \nCompounds, inorganic or organic, of rare- earth metals, of yttrium or of \nscandium or of mixtures of these metals. \n28.49 \nCarbides, whether or not chemically defined. \n2850.0000 \nHydrides, nitrides, azides, silicides and borides, whether or not chemically \ndefined, other than compounds which are also carbides of heading 28.49. \n28.52 \nInorganic or organic compounds of mercury, whether or not chemically defined, \nexcluding amalgams. \n \n28.53 \nPhosphides, whether or not chemically defined, excluding ferrophosphorus; \nother inorganic compounds (including distilled or conductivity water and water \nof similar \npurity); liquid air (whether or not rare gases have been removed); compressed \nair; amalgams, other than amalgams of precious metals. \n29.01 \nAcyclic hydrocarbons. \n29.02 \nCyclic hydrocarbons. \n29.03 \nHalogenated derivatives of hydrocarbons. \n29.04 \nSulphonated, nitrated or nitrosated derivatives of hydrocarbons, whether or not \nhalogenated. \n29.05 \nAcyclic alcohols and their halogenated, sulphonated, nitrated or nitrosated \nderivatives. \n29.06 \nCyclic alcohols and their halogenated, sulphonated, nitrated or nitrosated \nderivatives. \n\n\f\nTwelfth Schedule_____________________________________ \n784 \n \n29.07 \nPhenols; phenol- alcohols. \n29.08 \nHalogenated, sulphonated, nitrated or nitrosated derivatives of phenols or \nphenol- alcohols. \n \n29.09 \nEthers, ether- alcohols, ether- phenols, ether- alcohol- phenols, alcohol \nperoxides, ether peroxides, ketone peroxides (whether or not chemically \ndefined), and their halogenated, sulphonated, nitrated or nitrosated derivatives. \n29.10 \nEpoxides, epoxyalcohols, epoxyphenols and epoxyethers, with a three- \nmembered ring, and their halogenated, sulphonated, nitrated or nitrosated \nderivatives. \n2911.0000 \nAcetals and hemiacetals, whether or not with other oxygen function, and their \nhalogenated, sulphonated, nitrated or nitrosated derivatives. \n29.12 \nAldehydes, whether or not with other oxygen function; cyclic polymers of \naldehydes; paraformaldehyde. \n2913.0000 \nHalogenated, sulphonated, nitrated or nitrosated derivatives of products of \nheading 29.12. \n29.14 \nKetones and quinones, whether or not with other oxygen function, and their \nhalogenated, sulphonated, nitrated or nitrosated derivatives. \n29.15 \nSaturated acyclic monocarboxylic acids and their anhydrides, halides, \nperoxides and peroxyacids; their halogenated, sulphonated, nitrated or \nnitrosated derivatives. \n \n29.16 \nUnsaturated acyclic monocarboxylic acids, cyclic monocarboxylic acids, their \nanhydrides, halides, peroxides and peroxyacids; their halogenated, \nsulphonated, nitrated or nitrosated derivatives. \n29.17 \nPolycarboxylic acids, their anhydrides, halides, peroxides and peroxyacids; \ntheir halogenated, sulphonated, nitrated or nitrosated derivatives. \n \n29.18 \nCarboxylic acids with additional oxygen function and their anhydrides, halides, \nperoxides and peroxyacids; their halogenated, sulphonated, nitrated or \nnitrosated derivatives. \n29.19 \nPhosphoric esters and their salts, including lactophosphates; their halogenated, \nsulphonated, nitrated or nitrosated derivatives. \n29.20 \nEsters of other inorganic acids of non- metals (excluding esters of hydrogen \nhalides) and their salts; their halogenated, sulphonated, nitrated or nitrosated \nderivatives. \n29.21 \nAmine- function compounds. \n29.22 \nOxygen- function amino- compounds. \n29.23 \nQuaternary ammonium salts and hydroxides; lecithins and other \nphosphoaminolipids, whether or not chemicallydefined. \n29.24 \nCarboxyamide- function compounds; amide- function compounds of carbonic \nacid. \n29.25 \nCarboxyimide- function compounds (including saccharin and its salts) and \nimine- function compounds. \n29.26 \nNitrile- function compounds. \n29.27 \nDiazo- , azo- or azoxy- compounds. \n29.28 \nOrganic derivatives of hydrazine or of hydroxylamine. \n29.29 \nCompounds with other nitrogen function. \n29.30 \nOrgano- sulphur compounds. \n29.31 \nOther organo- inorganic compounds. \n29.32 \nHeterocyclic compounds with oxygen hetero- atom(s) only. \n29.33 \nHeterocyclic compounds with nitrogen hetero- atom(s) only. \n29.34 \nNucleic acids and their salts, whether or not chemically defined; other \nheterocyclic compounds. \n29.35 \nSulphonamides. \n \nProvitamins and vitamins, natural or reproduced by synthesis (including natural \n\n\f\nTwelfth Schedule_____________________________________ \n785 \n \n29.36 \nconcentrates), derivatives thereof used primarily as vitamins, and intermixtures \nof the foregoing, whether or not in any solvent. \n \n29.37 \nHormones, prostaglandins, thromboxanes and leukotrienes, natural or \nreproduced by \nsynthesis; derivatives and structural analogues thereof, including chain \nmodified polypeptides, used primarily as hormones. \n29.38 \nGlycosides, natural or reproduced by synthesis, and their salts, ethers, esters \nand other derivatives. \n29.39 \nAlkaloids, natural or reproduced by synthesis, and their salts, ethers, esters and \nother derivatives. \n29.41 \nAntibiotics. \n2942.0000 \nOther organic compounds. \n \n30.01 \nGlands and other organs for organo- therapeutic uses, dried, whether or not \npowdered; extracts of glands or other organs or of their secretions for organo- \ntherapeutic uses; heparin and its salts; other human or animal substances \nprepared for therapeutic or prophylactic uses, not elsewhere specified or \nincluded. \n31.02 (except \n3102.1000) \nMineral or chemical fertilisers, nitrogenous. \n31.03 \nMineral or chemical fertilisers, phosphatic. \n \n31.05 \nMineral or chemical fertilisers containing two or three of the fertilising elements \nnitrogen, phosphorus and potassium; other fertilisers; goods of this Chapter in \ntablets or similar forms or in packages of a gross weight not exceeding 10 kg. \n32.01 \nTanning extracts of vegetable origin; tannins and their salts, ethers, esters and \nother derivatives. \n \n32.02 \nSynthetic organic tanning \nsubstances; inorganic tanning substances; tanning \npreparations, whether or not containing natural tanning substances; enzymatic \npreparations for pre- tanning. \n1[3204.1100 \nDisperse Dyes And Preparations Based Thereon \n3204.1200 \nAcid dyes, whether or not premetallised, and preparations based \nthereon; mordant dyes and preparations based thereon \n3204.1300 \nBasic dyes and preparations based thereon \n3204.1400 \nDirect Dyes And Preparations Based Thereon \n3204.1510 \nIndigo Blue \n3204.1590 \nOther Vat dyes (including those usable in that state as pigments) and \npreparations based thereon: \n3204.1600 \nReactive Dyes And Preparations Based Thereon \n \nPigments and preparations based thereon: \n3204.1710 \n(a) Powdered \n3204.1720 \n(b) Liquid \n3204.1790 \n(c) Other \n3204.1910 \nDyes, Sulphur \n3204.1990 \nDyes, Synthetic \n3204.2000 \nSynthetic Organic Products Of A Kind Used As Fluorescent Brightening \nAgents \n3204.9000 \nOther Synthetic organic colouring matter \n3206.1900 \nPigments and preparations based on titanium dioxide] \n                                            \n1 The PCT Codes 3204.1100, 3204.1200, 3204.1300, 3204.1400, 3204.1510, 3204.1590, 3204.1600, \n3204.1710, 3204.171, 03204.1790, 3204.1910, 3204.1990, 3204.2000, 3204.9000, 3206.1900 and \nentry relating thereto in column (2) inserted through S.R.O.1240(I)/2020 dated 20.11.2020. \n\n\f\nTwelfth Schedule_____________________________________ \n786 \n \n32.14 \n \nGlaziers’ putty, grafting putty, resin cements, caulking compounds and other \nmastics; \npainters’ fillings; non- refractory surfacing preparations for facades, indoor \nwalls, floors, ceilings or the like. \n \n33.02 \nMixtures of odoriferous substances and mixtures (including alcoholic solutions) \nwith a basis of one or more of these substances, of a kind used as raw \nmaterials in industry; \nother preparations based on odoriferous substances, of a kind used for the \nmanufacture of beverages. \n1 [3402.1220 \nCationic surface active agents \n3402.1300 \nNon-ionic surface active agents \n3402.9000 \nSurface active preparations and cleaning preparations excluding \ndetergents] \n \n \n34.03 \nLubricating preparations (including cutting- oil preparations, bolt or nut release \npreparations, anti- rust or anti- corrosion preparations and mould release \npreparations, based on lubricants) and preparations of a kind used for the oil or \ngrease treatment of textile materials, leather, furskins or other materials, but \nexcluding \npreparations containing, as basic constituents, 70 % or more by weight of \npetroleum oils or of oils obtained from bituminous minerals. \n2 [3404.9090 \nOther artificial waxes] \n3504.0000 \nPeptones and their derivatives; other protein substances and their derivatives, \nnot elsewhere specified or included; hide powder, whether or not chromed. \n35.05 \nDextrins and other modified starches (for example, pre- gelatinised or esterified \nstarches); glues based on starches, or on dextrins or other modified starches. \n3 [3506.9110 \n3506.9190 \nHot melt adhesive \n3507.9000 \nEnzymes] \n37.02 \nPhotographic film in rolls, sensitised, unexposed, of any material other than \npaper, paperboard or textiles; instant print film in rolls, sensitised, unexposed. \n37.03 \nPhotographic paper, paperboard and textiles, sensitised, unexposed. \n3704.0000 \nPhotographic plates, film, paper, paperboard and textiles, exposed but not \ndeveloped. \n3705.0000 \nPhotographic plates and film, exposed and developed, other than \ncinematographic film. \n \n37.07 \nChemical preparations for photographic uses (other than varnishes, glues, \nadhesives \nand similar preparations); unmixed products for photographic uses, put up in \nmeasured portions or put up for retail sale in a form ready for use. \n38.01 \nArtificial graphite; colloidal or semi- colloidal graphite; preparations based on \ngraphite or other carbon in the form of pastes, blocks, plates or other semi- \nmanufactures. \n3803.0000 \nTall oil, whether or not refined. \n                                            \n1 The PCT Codes 3402.1220, 3402.1300, 3402.9000 and entry relating thereto in column (2) inserted \nthrough S.R.O.1240(I)/2020 dated 20.11.2020. \n2 The PCT Code 3404.9090 and entry relating thereto in column (2) inserted through \nS.R.O.1240(I)/2020 dated 20.11.2020. \n3 The PCT Codes 3506.9110, 3506.9190, 3507.9000 and entry relating thereto in column (2) inserted \nthrough S.R.O.1240(I)/2020 dated 20.11.2020. \n\n\f\nTwelfth Schedule_____________________________________ \n787 \n \n3804.0000 \nResidual lyes from the manufacture of wood pulp, whether or not concentrated, \ndesugared or chemically treated, including lignin sulphonates, but excluding tall oil of \nheading 38.03. \n38.06 \nRosin and resin acids, and derivatives thereof; rosin spirit and rosin oils; run gums. \n38.09 \nFinishing agents, dye carriers to accelerate the dyeing or fixing of dyestuffs and other \nproducts and preparations (for example, dressings and mordants), of a kind used in \nthe textile, paper, leather or like industries, not elsewhere specified or included. \n38.10 \nPickling preparations for metal surfaces; fluxes and other auxiliary preparations for \nsoldering, brazing or welding; soldering, brazing or welding powders and pastes \nconsisting of metal and other materials; preparations of a kind used as cores or \ncoatings for welding electrodes or rods. \n38.12 \nPrepared rubber accelerators; compound plasticisers for rubber or plastics, not \nelsewhere specified or included; anti- oxidising preparations and other compound \nstabilisers for rubber or plastics. \n38.15 \nReaction initiators, reaction accelerators and catalytic preparations, not elsewhere \nspecified or included. \n3816.0000 \nRefractory cements, mortars, concretes and similar compositions, other than products \nof heading 38.01. \n3817.0000 \nMixed alkylbenzenes and mixed alkylnaphthalenes, other than those of heading 27. \n07 or 29. 02. \n3818.0000 \nChemical elements doped for use in electronics, in the form of discs, wafers or \nsimilar forms; chemical compounds doped for use in electronics. \n3821.0000 \nPrepared culture media for the development or maintenance of micro- organisms \n(including viruses and the like) or of plant, human or animal cells \n38.23 \nIndustrial monocarboxylic fatty acids; acid oils from refining; industrial fatty alcohols. \n38.24 \nPrepared binders for foundry moulds or cores; chemical products and preparations of \nthe chemical or allied industries (including those consisting of mixtures of natural \nproducts), not elsewhere specified or included. \n39.01 \nPolymers of ethylene, in primary forms. \n39.02 \nPolymers of propylene or of other olefins, in primary forms. \n39.03 \nPolymers of styrene, in primary forms. \n39.04 \nPolymers of vinyl chloride or of other halogenated olefins, in primary forms. \n1 [3905.3000 \nPolymers in vinyl alchol \n3906.9030 \nOther acrylic polymers] \n39.07 \nPolyacetals, other polyethers and epoxide resins, in primary forms; polycarbonates, \nalkyd resins, polyallyl esters and other polyesters, in primary forms. \n39.08 \nPolyamides in primary forms. \n3910.0000 \nSilicones in primary forms. \n39.11 \nPetroleum resins, coumarone- indene resins, polyterpenes, polysulphides, \npolysulphones and other products specified in Note 3 to this Chapter, not elsewhere \nspecified or included, in primary forms. \n39.12 \nCellulose and its chemical derivatives, not elsewhere specified or included, in primary \nforms. \n2 [3912.2010 \nCellulose Nitrates Nonplasticised \n                                            \n1 The PCT Codes 3905.3000, 3906.9030 and entry relating thereto in column (2) inserted through \nS.R.O.1240(I)/2020 dated 20.11.2020. \n2 The PCT Codes 3912.2010, 3912.2090, 3912.3100 and entry relating thereto in column (2) inserted \nthrough S.R.O.1240(I)/2020 dated 20.11.2020. \n\n\f\nTwelfth Schedule_____________________________________ \n788 \n \n3912.2090 \nOther cellulose Nitrates \n3912.3100 \nCarboxymethylcellulose And Its Salts] \n39.14 \nIon- exchangers based on polymers of headings 39.01 to 39.13, in primary forms. \n1[3919.9020   \n- - - PVC electric insulation tapes in logs exceeding 100 cm.] \n40.01 \nNatural rubber, balata, gutta- percha, guayule, chicle and similar natural gums, in \nprimary forms or in plates, sheets or strip. \n40.02 \nSynthetic rubber and factice derived from oils, in primary forms or in plates, sheets or \nstrip; mixtures of any product of heading 40.01 with any product of this heading, in \nprimary forms or in plates, sheets or strip. \n4003.0000 \nReclaimed rubber in primary forms or in plates, sheets or strip. \n40.04 \nWaste, parings and scrap of rubber (other than hard rubber) and powders and \ngranules obtained therefrom. \n40.05 \nCompounded rubber, unvulcanised, in primary forms or in plates, sheets or strip. \n41.01 \nRaw hides and skins of bovine (including buffalo) or equine animals (fresh, or salted, \ndried, limed, pickled or otherwise preserved, but not tanned, parchment- dressed or \nfurther prepared), whether or not dehaired or split. \n41.02 \nRaw skins of sheep or lambs (fresh, or salted, dried, limed, pickled or otherwise \npreserved, but not tanned, parchment- dressed or further prepared), whether or not \nwith wool on or split, other than those excluded by Note 1 (c) to this Chapter. \n41.03 \nOther raw hides and skins (fresh, or salted, dried, limed, pickled or otherwise \npreserved, but not tanned, parchment- dressed or further prepared), whether or not \ndehaired or split, other than those excluded by Note 1 (b) or 1 (c) to this Chapter. \n41.04 \nTanned or crust hides and skins of bovine (including buffalo) or equine animals, \nwithout hair on, whether or not split, but not further prepared. \n41.05 \nTanned or crust skins of sheep or lambs, without wool on, whether or not split, but not \nfurther prepared. \n41.06 \nTanned or crust hides and skins of other animals, without wool or hair on, whether or \nnot split, but not further prepared. \n41.07 \nLeather further prepared after tanning or crusting, including parchment- dressed \nleather, of bovine (including buffalo) or equine animals, without hair on, whether or not \nsplit, other than leather of heading 41. 14. \n4112.0000 \nLeather further prepared after tanning or crusting, including parchment- dressed \nleather, of sheep or lamb, without wool on, whether or not split, other than leather of \nheading 41.14. \n41.13 \nLeather further prepared after tanning or crusting, including parchment- dressed \nleather, of other animals, without wool or hair on, whether or not split, other than \nleather of heading 41. 14. \n41.14 \nChamois (including combination chamois) leather; patent leather and patent \nlaminated leather; metallised leather. \n41.15 \nComposition leather with a basis of leather or leather fibre, in slabs, sheets or strip, \nwhether or not in rolls; parings and other waste of leather or of composition leather, \nnot suitable for the manufacture of leather articles; leather dust, powder and flour. \n42.05 (Except \n4205.0090) \nOther articles of leather or of composition leather. \n43.01 \nRaw furskins (including heads,tails, paws and other pieces or cuttings, suitable for \nfurriers’ use), other than raw hides and skins of heading 41.01, 41.02 or 41.03. \n                                            \n1  The PCT Code 3919.9020 and entry relating thereto inserted by the Finance Act, 2022. \n\n\f\nTwelfth Schedule_____________________________________ \n789 \n \n43.02 \nTanned or dressed furskins (including heads, tails, paws and other pieces or \ncuttings), unassembled, or assembled (without the addition of other materials) other \nthan those of heading 43.03. \n44.01 \nFuel wood, in logs, in billets, in twigs, in faggots or in similar forms; wood in chips or \nparticles; sawdust and wood waste and scrap, whether or not agglomerated in logs, \nbriquettes, pellets or similar forms. \n44.02 \nWood charcoal (including shell or nut charcoal), whether or not agglomerated. \n44.03 \nWood in the rough, whether or not stripped of bark or sapwood, or roughly squared. \n44.04 \nHoopwood; split poles; piles, pickets and stakes of wood, pointed but not sawn \nlengthwise; wooden sticks, roughly trimmed but not turned, bent or otherwise worked, \nsuitable for the manufacture of walking- sticks, umbrellas, tool handles or the \nlike;chipwood and the like. \n4405.0000 \nWood wool; wood flour. \n44.06 \nRailway or tramway sleepers (cross- ties) of wood. \n1 [4407.1100 \nOf Pine (Pinus Spp.) \n4407.1200 \nOf Fir (Abies Spp.) And Spruce (Picea Spp.) \n4407.1900 \nOther - Coniferous: \n4407.2100 \nMahogany (Swietenia Spp.) \n4407.2200 \nVirola, Imbuia And Balsa \n4407.2500 \nDark Red Meranti, Light Red Meranti And MerantiBakau \n4407.2600 \nWhite Lauan, White Meranti, White Seraya, Yellow Meranti And Alan \n4407.2700 \nSapelli \n4407.2900 \nOther - Of tropical wood: \n4407.9100 \nOf Oak (Quercus Spp.) \n4407.9200 \nOf Beech (Fagus Spp. ) \n4407.9300 \nOf Maple (Acer Spp.) \n4407.9500 \nOf Ash (Fraxinus Spp.) \n4407.9700 \nOf Poplar And Aspen (Populus Spp.) \n4407.9900 \nWood sawn or chipped lengthwise, sliced or peeled, whether or not \nplanned, sanded or end-jointed, of a thickness exceeding 6mm. – \nOther] \n4701.0000 \nMechanical wood pulp. \n4702.0000 \nChemical wood pulp, dissolving grades. \n47.03 \nChemical wood pulp, soda or sulphate, other than dissolving grades. \n47.04 \nChemical wood pulp, sulphite, other than dissolving grades. \n4705.0000 \nWood pulp obtained by a combination of mechanical and chemical pulping processes. \n47.06 \nPulps of fibres derived from recovered (waste and scrap) paper or paperboard or of \nother fibrous cellulosic material. \n47.07 \nRecovered (waste and scrap) paper or paperboard. \n48.04 \nUncoated kraft paper and paperboard, in rolls or sheets, other than that of heading \n48.02 or 48.03. \n48.10 \nPaper and paperboard, coated on one or both sides with kaolin (China clay) or other \ninorganic substances, with or without a binder, and with no other coating, whether or \nnot surface- coloured, surface- decorated or printed, in rolls or rectangular (including \nsquare) sheets, of any size. \n                                            \n1 The PCT Codes 4407.1100, 4407.1200, 4407.1900, 4407.2100, 4407.2200, 4407.2500, 4407.2600, \n4407.2700, 4407.2900, 4407.9100, 4407.9200, 4407.9300, 4407.9500, 4407.9700, 4407.9900 and \nentry relating thereto in column (2) inserted through S.R.O.1240(I)/2020 dated 20.11.2020. \n\n\f\nTwelfth Schedule_____________________________________ \n790 \n \n48.13 \nCigarette paper, whether or not cut to size or in the form of booklets or tubes. \n48.22 \nBobbins, spools, cops and similar supports of paper pulp, paper or paperboard \n(whether or not perforated or hardened). \n4823.9040 \n- - - Double Side Adhesive Tapes \n5001.0000 \nSilk- worm cocoons suitable for reeling. \n5002.0000 \nRaw silk (not thrown). \n5003.0000 \nSilk waste (including cocoons unsuitable for reeling, yarn waste and garnetted stock). \n5004.0000 \nSilk yarn (other than yarn spun from silk waste) not put up for retail sale. \n5005.0000 \nYarn spun from silk waste, not put up for retail sale. \n51.01 \nWool, not carded or combed. \n51.02 \nFine or coarse animal hair, not carded or combed. \n51.03 \nWaste of wool or of fine or coarse animal hair, including yarn waste but excluding \ngarnetted stock. \n5104.0000 \nGarnetted stock of wool or of fine or coarse animal hair. \n51.05 \nWool and fine or coarse animal hair, carded or combed (including combed wool in \nfragments). \n51.06 \nYarn of carded wool, not put up for retail sale. \n51.07 \nYarn of combed wool, not put up for retail sale. \n51.08 \nYarn of fine animal hair (carded or combed), not put up for retail sale. \n52.05 \nCotton yarn (other than sewing thread), containing 85 % or more by weight of cotton, \nnot put up for retail sale. \n52.06 \nCotton yarn (other than sewing thread), containing less than 85 % by weight of cotton, \nnot put up for retail sale. \n53.01 \nFlax, raw or processed but not spun; flax tow and waste (including yarn waste and \ngarnetted stock). \n53.02 \nTrue hemp (Cannabis sativa L.), raw or processed but not spun; tow and \nwaste of true hemp (including yarn waste and garnetted stock). \n53.03 \nJute and other textile bast fibres (excluding flax, true hemp and ramie), raw or \nprocessed but not spun; tow and wastes of these fibres (including yarn waste and \ngarnetted stock). \n53.05 \nCoconut, abaca (Manila hemp or Musa textilis Nee), ramie and other vegetable \ntextile \nfibres, not elsewhere specified or included, raw or processed but not spun; tow, noils \nand waste of these fibres (including yarn waste and garnetted stock). \n53.06 \nFlax yarn. \n53.07 \nYarn of jute or of other textile bast fibres of heading 53.03. \n54.02 \nSynthetic filament yarn (other than sewing thread), not put up for retail sale, including \nsynthetic monofilament of less than 67 decitex. \n1 [5403.3100 \nViscose Rayon, Untwisted Or With A Twist Not Exceeding 120 Turns \nPer Metre \n5403.3910 \nCuprammonium Rayon] \n55.01 \nSynthetic filament tow. \n55.02 \nArtificial filament tow. \n55.03 \nSynthetic staple fibres, not carded, combed or otherwise processed for spinning. \n                                            \n1 The PCT Codes 5403.3100, 5403.3910 and entry relating thereto in column (2) inserted through \nS.R.O.1240(I)/2020 dated 20.11.2020. \n\n\f\nTwelfth Schedule_____________________________________ \n791 \n \n 1 [5403.2010 \nSynthetic staple fibres, not carded, combed or otherwise] \n55.04 \nArtificial staple fibres, not carded, combed or otherwise processed for spinning. \n55.05 \nWaste (including noils, yarn waste and garnetted stock) of man- made fibres. \n55.06 \nSynthetic staple fibres, carded, combed or otherwise processed for spinning. \n5507.0000 \nArtificial staple fibres, carded, combed or otherwise processed for spinning. \n55.08 \nSewing thread of man- made staple fibres, whether or not put up for retail sale. \n55.09 \nYarn (other than sewing thread) of synthetic staple fibres, not put up for retail sale. \n55.10 \nYarn (other than sewing thread) of artificial staple fibres, not put up for retail sale. \n55.11 \nYarn (other than sewing thread) of man- made staple fibres, put up for retail sale. \n55.12 \nWoven fabrics of synthetic staple fibres, containing 85 % or more by weight of \nsynthetic staple fibres. \n55.13 \nWoven fabrics of synthetic staple fibres, containing less than 85 % by weight of such \nfibres, mixed mainly or solely with cotton, of a weight not exceeding 170 g/m2. \n55.14 \nWoven fabrics of synthetic staple fibres, containing less than 85 % by weight of such \nfibres, mixed mainly or solely with cotton, of a weight exceeding 170 g/m2. \n55.15 \nOther woven fabrics of synthetic staple fibres. \n55.16 \nWoven fabrics of artificial staple fibres. \n56.01 \nWadding of textile materials and articles thereof; textile fibres, not exceeding 5 mm in \nlength (flock), textile dust and mill neps. \n56.08 \nKnotted netting of twine, cordage or rope; made up fishing nets and other made up \nnets, of textile materials. \n59.02 \nTyre cord fabric of high tenacity yarn of nylon or other polyamides, polyesters or \nviscose rayon. \n63.10 \nUsed or new rags, scrap twine, cordage, rope and cables and worn out articles of \ntwine, cordage, rope or cables, of textile materials. \n68.15 \nArticles of stone or of other mineral substances (including carbon fibres, articles of \ncarbon fibres and articles of peat), not elsewhere specified or included. \n70.02 \nGlass in balls (other than microspheres of heading 70.18), rods or tubes, unworked. \n71.05 \nDust and powder of natural or synthetic precious or semi- precious stones. \n72.01 \nPig iron and, spiegeleisen in pigs, blocks or other primary form. \n72.02 \nFerro- alloys. \n72.03 \nFerrous products obtained by direct reduction of iron ore and other spongy ferrous \nproducts, in lumps, pellets or similar forms; iron having a minimum purity by weight of \n99.94 %, In lumps, pellets or similar forms. \n2[72.04 \nFerrous waste and scrap; remelting scrap ingots of iron or steel.] \n72.05 \nGranules and powders, of pig iron, spiegeleisen, iron or steel. \n72.06 \nIron and non- alloy steel in ingots or other primary forms (excluding iron of heading \n72.03). \n72.08 \nFlat- rolled products of iron or non- alloy steel, of a width of 600 mm or more, hot- \nrolled, not clad, plated or coated. \n72.09 \nFlat- rolled products of iron or non- alloy steel, of a width of 600 mm or more, cold- \nrolled (cold- reduced), not clad, plated or coated. \n72.10 \nFlat- rolled products of iron or non- alloy steel, of a width of 600 mm or more, clad, \nplated or coated. \n                                            \n1 The PCT Code 5503.2010 and entry relating thereto in column (2) inserted through \nS.R.O.1240(I)/2020 dated 20.11.2020. \n2  The PCT Code 72.04 and entry relating thereto inserted by the Finance Act, 2022. \n\n\f\nTwelfth Schedule_____________________________________ \n792 \n \n72.11 \nFlat- rolled products of iron or non- alloy steel, of a width of less than 600 mm, not \nclad, plated or coated. \n72.12 \nFlat- rolled products of iron or non- alloy steel, of a width of less than 600 mm, clad, \nplated or coated. \n72173010 \nOf A Kind Used In Manufacture Of Pneumatic Tyres(Bead Wire) \n72.18 \nStainless steel in ingots or other primary forms; semi- finished products of stainless \nsteel. \n72.19 \nFlat- rolled products of stainless steel, of a width of 600 mm or more. \n72.20 \nFlat- rolled products of stainless steel, of a width of less than 600 mm. \n72.25 \nFlat- rolled products of other alloy steel, of a width of 600 mm or more. \n72.26 \nFlat- rolled products of other alloy steel, of a width of less than 600 mm. \n72.27 \nBars and rods, hot- rolled, in irregularly wound coils, of other alloy steel. \n7315.1920 \nOther For Motor Cars And Vehicles \n7401.0000 \nCopper mattes; cement copper (precipitated copper). \n7402.0000 \nUnrefined copper; copper anodes for electrolytic refining. \n74.03 \nRefined copper and copper alloys, unwrought. \n74.04 \nCopper waste and scrap. \n7405.0000 \nMaster alloys of copper. \n74.06 \nCopper powders and flakes. \n74.07 \nCopper bars, rods and profiles. \n74.08 \nCopper wire. \n74.09 \nCopper plates, sheets and strip, of a thickness exceeding 0.15 mm. \n74.10 \nCopper foil (whether or not printed or backed with paper, paperboard, plastics or \nsimilar backing materials), of a thickness (excluding any backing) not exceeding 0.15 \nmm. \n74.11 \nCopper tubes and pipes. \n7413.0000 \nStranded wire, cables, plaited bands and the like, of copper, not electrically insulated. \n75.01 \nNickel mattes, nickel oxide sinters and other intermediate products of nickel \nmetallurgy. \n75.02 \nUnwrought nickel. \n7503.0000 \nNickel waste and scrap. \n7504.0000 \nNickel powders and flakes. \n75.05 \nNickel bars, rods, profiles and wire. \n75.06 \nNickel plates, sheets, strip and foil. \n76.01 \nUnwrought aluminium. \n76.02 \nAluminium waste or scrap. \n76.03 \nAluminium powders and flakes. \n76.06 \nAluminium plates, sheets and strip, of a thickness exceeding 0.2 mm. \n76071100 \nRolled But Not Further Worked \n76.08 \nAluminium tubes and pipes. \n78.01 \nUnwrought lead. \n7802.0000 \nLead waste and scrap. \n78.04 \nLead plates, sheets, strip and foil; lead powders and flakes. \n79.01 \nUnwrought zinc. \n7902.0000 \nZinc waste and scrap. \n79.03 \nZinc dust, powders and flakes. \n79.04 \nZinc bars, rods, profiles and wire. \n79.07 \nOther articles of zinc. \n\n\f\nTwelfth Schedule_____________________________________ \n793 \n \n80.01 \nUnwrought tin. \n8002.0000 \nTin waste and scrap. \n8003.0000 \nTin bars, rods, profiles and wire \n81.01 \nTungsten (wolfram) and articles thereof, including waste and scrap. \n81.02 \nMolybdenum and articles thereof, including waste and scrap. \n81.03 \nTantalum and articles thereof, including waste and scrap. \n81.04 \nMagnesium and articles thereof, including waste and scrap. \n81.05 \nCobalt mattes and other intermediate products of cobalt metallurgy; cobalt and \narticles thereof, including waste and scrap. \n8106.0000 \nBismuth and articles thereof, including waste and scrap. \n81.07 \nCadmium and articles thereof, including waste and scrap. \n81.08 \nTitanium and articles thereof, including waste and scrap. \n81.09 \nZirconium and articles thereof, including waste and scrap. \n81.10 \nAntimony and articles thereof, including waste and scrap. \n8111.0000 \nManganese and articles thereof, including waste and scrap. \n81.12 \nBeryllium, chromium, germanium, vanadium, gallium, hafnium, indium, niobium \n(columbium), rhenium and thallium, and articles of these metals, including waste and \nscrap. \n8113.0000 \nCermets and articles thereof, including waste and scrap. \n83.09 \nStoppers, caps and lids (including crown corks, screw caps and pouring stoppers), \ncapsules for bottles, threaded bungs, bung covers, seals and other packing \naccessories, of base metal. \n83.11 \nWire, rods, tubes, plates, electrodes and similar products, of base metal or of metal \ncarbides, coated or cored with flux material, of a kind used for soldering, brazing, \nwelding or deposition of metal or of metal carbides; wire and rods, of agglomerated \nbase metal powder, used for metal spraying. \n84.07 \nSpark- ignition reciprocating or rotary internal combustion piston engines. \n84.08 \nCompression- ignition internal combustion piston engines (diesel or semi- diesel \nengines). \n84.09 \nParts suitable for use solely or principally with the engines of heading 84.07 or 84.08. \n8414.1000 \nVacuum pumps \n8414.3010 \nUsed with HCFC and non-CFC gases \n8414.9010 \nOf machines of heading 8414.1000 and 8414.3010 \n84.65 \nMachine- tools (including machines for nailing, stapling, glueing or otherwise \nassembling) for working wood, cork, bone, hard rubber, hard plastics or similar hard \nmaterials. \n84.66 \nParts and accessories suitable for use solely or principally with the machines of \nheadings 84.56 to 84.65, including work or tool holders, self- opening dieheads, \ndividing heads and other special attachments for the machines; tool holders for any \ntype of tool for working in the hand. \n84.67 \nTools for working in the hand, pneumatic, hydraulic or with self- contained electric or \nnon- electric motor. \n8479.8990 \nOther \n84.82 \nBall or roller bearings. \n84.84 \nGaskets and similar joints of metal sheeting combined with other material or of two or \nmore layers of metal; sets or assortments of gaskets and similar joints, dissimilar in \ncomposition, put up in pouches, envelopes or similar packings; mechanical seals. \n8501.1000 \nMotors of an output not exceeding 37.5 W \n8501.2000 \nUniversal AC/DC motors of an output exceeding 37.5 W \n\n\f\nTwelfth Schedule_____________________________________ \n794 \n \n8501.3110 \nPhotovoltaic generators consisting of panels of photocells combined with other \napparatus \n8501.4010 \nOf an output not exceeding 60 watts \n8501.4090 \nOther \n8501.5120 \nAC clutch motors for industrial sewing machine \n8501.5310 \nOf an output exceeding 75 kW but not exceeding 375 kW (500 HP) \n85.03 \n(except \n8503.0090) \nParts suitable for use solely or principally with the machines of heading 85.01 or \n85.02. \n1[8504.3100 \nSMD Inductors for LED Bulb and Lights. \n8504.4090 \nConstant Current Power Supply of LED Lights and Bulbs.] \n8504.9010 \nOn load-tape changer for power transformers \n8504.9020 \nBushings for power transformers \n8504.9030 \nOf machines of heading 8504.4090 \n8504.9040 \nToroidal cores and strips \n8504.9090 \nOther \n85.05 \nElectro- magnets; permanent magnets and articles intended to become permanent \nmagnets after magnetisation; electro- magnetic or permanent magnet chucks, clamps \nand similar holding devices; electro- magnetic couplings, clutches and brakes; \nelectro- magnetic lifting heads. \n85.11 \nElectrical ignition or starting equipment of a kind used for spark- ignition or \ncompression- ignition internal combustion engines (for example, ignition magnetos, \nmagneto- dynamos, ignition coils, sparking plugs and glow plugs, starter motors); \ngenerators (for example, dynamos, alternators) and cut- outs of a kind used in \nconjunction with such engines. \n85.12 \nElectrical lighting or signalling equipment (excluding articles of heading 85.39), \nwindscreen wipers, defrosters and demisters, of a kind used for cycles or motor \nvehicles. \n8528.7213 \nIn CKD/SKD condition \n85.29 \nParts suitable for use solely or principally with the apparatus of headings 85.25 to \n85.28. \n2[8532.2200 \nElectrical Capacitors Aluminum Electrolytic for LED Bulbs and Lights.] \n85.33 \nElectrical resistors (including rheostats and potentiometers), other than heating \nresistors. \n8534.0000 \nPrinted circuits. \n85.35 \nElectrical apparatus for switching or protecting electrical circuits, or for making \nconnections to or in electrical circuits (for example, switches, fuses, lightning \narresters, voltage limiters, surge suppressors, plugs and other connectors, junction \nboxes), for a voltage exceeding 1,000 volts. \n85.37 \nBoards, panels, consoles, desks, cabinets and other bases, equipped with two or \nmore apparatus of heading 85.35 or 85.36, for electric control or the distribution of \nelectricity, including those incorporating instruments or apparatus of Chapter 90, and \nnumerical control apparatus, other than switching apparatus of heading 85.17. \n85.38 \nParts suitable for use solely or principally with the apparatus of heading 85.35, 85.36 \nor 85.37. \n                                            \n1  The PCT Codes 8504.3100 and 8504.4090 and entries relating thereto inserted by the Finance Act, \n2022. \n2  The PCT Code 8532.2200 and entry relating thereto inserted by the Finance Act, 2022. \n\n\f\nTwelfth Schedule_____________________________________ \n795 \n \n1[8539.9020 \nBase Cap for all Kinds of LED Bulbs. \n8539.9090 \nBare or Stuffed Metal Clad Printed Circuit Boards (MCPCB) for all kinds \nof LED Bulbs. \n8539.9090 \nHousing/Shell, Shell Cover and Base Cap for all Kinds of LED Bulbs.] \n85.40 \nThermionic, cold cathode or photo- cathode valves and tubes (for example, vacuum \nor vapour or gas filled valves and tubes, mercury arc rectifying valves and tubes, \ncathode- ray tubes, television camera tubes). \n85.41 \nDiodes, transistors and similar semi- conductor devices; photosensitive \nsemiconductor devices, including photovoltaic cells whether or not assembled in \nmodules or made up into panels; light-emitting diodes(LED); mounted piezo- electric \ncrystals. \n85.42 \nElectronic integrated circuits. \n8545.1100 \nOf A Kind Used For Furnaces \n8545.9020 \nFor dry battery cells \n85.48 \nWaste and scrap of primary cells, primary batteries and electric accumulators; spent \nprimary cells, spent primary batteries and spent electric accumulators; electrical parts \nof machinery or apparatus, not specified or included elsewhere in this Chapter. \n8701.2010 \nComponents For The Assembly / Manufacture Of Road Tractors For Semi-Trailers \n(Prime Movers), In Any Kit Form, Of Less Than 280 Hp \n8701.2030 \nComponents For The Assembly / Manufacture Of Road Tractors For Semi-Trailers \n(Prime Movers), In Any Kit Form, Of 280 Hp And Above \n8702.1010 \nComponents For Assembly / Manufacture Of Vehicles, In Any Kit Form \n8703.2111 \nComponents For The Assembly/ Manufacture Of Vehicles, In Any Kit Form Excluding \nThose Of Headings 8703.2113 And 8703.2115 \n8703.2112 \nComponents For The Assembly / Manufacture Of Mini Van Type Vehicles, In Any Kit \nForm \n8703.2114 \nComponents For The Assembly/ Manufacture Of Auto Rickshaws, In Any Kit Form \n8703.2191 \nComponents For The Assembly / Manufacture Of Vehicles, In Any Kit Form \nExcluding Those Of Heading 8703.2193 And 8703.2195 \n8703.2194 \nComponents For The Assembly / Manufacture Of Mini Van, In Any Kit Form \n8703.2210 \nComponents For The Assembly / Manufacture Of Vehicles, In Any Kit Form \nExcluding Those Of Heading 8703.2240 \n8703.2311 \nComponents For The Assembly / Manufacture Of Vehicles, In Any Kit Form \n8703.2321 \nComponents For The Assembly / Manufacture Of Vehicles, In Any Kit Form \nExcluding Of Heading 8703.2323 \n8703.2322 \nComponents For The Assembly / Manufacture Of Sport Utility Vehicles 4X4, In Any \nKit Form \n8703.3310 \nComponents For The Industrial Assembly/ Manufacture Of Vehicles, In Any Kit Form \n8704.1010 \nComponents For Assembly/ Manufacture Of Dump Trucks Designed For Off-Highway \nUse \n8704.2110 \nComponents For The Assembly / Manufacture Of Vehicles, In Any Kit Form \n8704.2211 \nComponents For The Assembly / Manufacture Of Vehicles, In Any Kit Form \n8704.2291 \nComponents For The Assembly / Manufacture Of Vehicles, In Any Kit Form \n8704.2310 \nComponents For The Assembly / Manufacture Of Vehicles, In Any Kit Form \n                                            \n1  The PCT Codes 8539.9020, 8539.9090 & 8539.9090 and entries relating thereto inserted by the \nFinance Act, 2022. \n\n\f\nTwelfth Schedule_____________________________________ \n796 \n \n8704.3110 \nComponents For The Assembly / Manufacture, In Any Kit Form Excluding Those Of \nHeading 8704.3130 And 8704.3150 \n8704.3120 \nComponents For The Assembly / Manufacture Of Mini Cargo Van, In Any Kit Form \n8704.3140 \nComponents For The Assembly / Manufacture Of 3-Wheeler Cargo Loader, In Any \nKit Form \n8711.2010 \nComponents For The Assembly / Manufacture Of Vehicles, In Any Kit Form \n8908.0000 \nVessels and other floating structures for breaking up. \n90.32 \nAutomatic regulating or controlling instruments and apparatus. \n1[9001.9000 \nLenses for LED Bulbs and Lights.] \n91.04 \nInstrument panel clocks and clocks of a similar type for vehicles, aircraft, spacecraft \nor vessels. \n9107.0000 \nTime switches with clock or watch movement or with synchronous motor. \n9401.9010 \nSeat Parts Made Of Foam, Head/Arm Rests And Seat Frames For Motor Cars Of \nHeading 87.03 And Vehicles Of Sub-Headings 8703.2113, 8703.2115, 8703.2193, \n8703.2195, 8703.2240, \n9401.9030 \nOther For Motor Cars And Vehicles \n2[9405.1090 \nHousing/Shell, Shell Cover and Base Cap for all Kinds of LED Lights. \n9405.9900 \nBare or Stuffed Metal Clad Printed Circuit Boards (MCPCB) for all kinds \nof LED Lights.] \n96.06 \nButtons, press- fasteners, snap- fasteners and press- studs, button moulds and other \nparts of these articles; button blanks. \n96.07 \nSlide fasteners and parts thereof. \n \nPart III \n \nPCT \nCODE \nDESCRIPTION \n(1) \n(2) \nRespective \nheadings \nGoods not specifically mentioned in Part I or II. \n \n \n \n \n \n \n \n \n \n \n                                            \n1  The PCT Code 9001.9000 and entry relating thereto inserted by the Finance Act, 2022. \n2  The PCT Codes 9405.1090 & 9405.9900 and entries relating thereto inserted by the Finance Act, \n2022. \n\n\f\nThirteenth Schedule__________ __________________________ \n \n797 \n1[THE THIRTEENTH SCHEDULE  \n (See section 61) \n \nS. No. \nName \n(1) \n(2) \n1.  any Sports Board or institution recognised by the Federal Government for the \npurposes of promoting, controlling or regulating any sport or game. \n2.  The Citizens Foundation. \n3.  Fund for Promotion of Science and Technology in Pakistan. \n4.  Fund for Retarded and Handicapped Children. \n5.  National Trust Fund for The Disabled. \n6.  Fund for Development of Mazaar of Hazarat Burn i Imam. \n7.  Rabita-e-lslami's Project for printing copies of the Holy Quran. \n8.  Fatimid Foundation, Karachi. \n9.  Al-Shifa Trust. \n10.  Society for the Promotion of Engineering Sciences and Technology in Pakistan. \n11.  Citizens-Police Liaison Committee, Central Reporting Cell, Sindh Governor House, \nKarachi. \n12.  ICIC Foundation.  \n13.  National Management Foundation. \n14.  Endowment Fund of the institutions of the Agha Khan Development Network \n(Pakistan listed in Schedule 1 of the Accord and Protocol, dated November 13, \n1994, executed between the Government of the Islamic Republic of Pakistan and \nAgha Khan Development Network. \n15.  Shaheed Zulfigar Ali Bhutto Memorial Awards Society. \n16.  Iqbal Memorial fund. \n17.  Cancer Research Foundation of Pakistan, Lahore. , \n18.  Shaukat Khanum Memorial Trust, Lahore. \n19.  Christian Memorial Hospital, Sialkot. \n20.  National Museums, National Libraries and Monuments or institutions declared to be \nNational Heritage by the Federal Government. \n21.  Mumtaz Bakhtawar Memorial Trust Hospital, Lahore.  \n22.  Kashmir Fund for Rehabilitation of Kashmir Refugees and Freedom Fighters. \n23.  Institutions of the Agha Khan Development Network (Pakistan) listed in \nSchedule 1 of the Accord and Protocol, dated November 13, 1994, executed \nbetween the Government of the Islamic Republic of Pakistan and Agha Khan \nDevelopment Network. \n24.  Azad Kashmir President's Mujahid Fund,1972. \n25.  National Institute of Cardiovascular Diseases, (Pakistan) Karachi. \n26.  Businessmen Hospital Trust, Lahore. \n27.  Premier Trust Hospital, Mardan. \n28.  Faisal Shaheed Memorial Hospital Trust, Gujranwala. \n                                            \n1 The Thirteenth Schedule added by the Finance Act, 2021. Earlier this amendment was made through Tax Laws \n(Second  Amendment) Ordinance, 2021. \n\n\f\nThirteenth Schedule____________________________________ \n798 \n \n29.  Khair-un-Nisa Hospital Foundation, Lahore. \n30.  Sind and Balochistan Advocates' Benevolent Fund. \n31.  Rashid Minhas Memorial Hospital Fund. \n32.  Any relief or welfare fund established by the Federal Government. \n33.  Mohatta Palace Gallery Trust. \n34.  Bagh-e-Quaid-e-Azam project, Karachi. \n35.  Any amount donated for Tameer-e-Karachi Fund. \n36.  Pakistan Red Cres-cent Society. \n37.  Sank of Commerce and Credit International Foundation for Advancement of \nScience and Technology. \n38.  Federal Board of Revenue Foundation. \n39.  The Indus Hospital, Karachi. \n40.  Pakistan Sweet Homes Angels and Fairies Place. \n41.  Al-Shifa Trust Eye Hospital. \n42.  Aziz Tabba Foundation. \n43.  Sindh Institute of Urology and Transplantation, SIUT Trust and Society for the \nWelfare of SIUT. \n44.  Sharif Trust. \n45.  The Kidney Centre Post Graduate Institute. \n46.  Pakistan Disabled Foundation. \n47.  Sardar Trust Eye Hospital, Lahore. \n48.  Supreme Court of Pakistan — Diamer Bhasha & Mohmand Dams — Fund. \n49.  Layton Rahmatullah Benevolent Trust (LRBT). \n50.  Akhuwat. \n51.  The Prime Minister's COVIE)-19 Pandemic Relief Fund-2020. \n52.  Ghulam Ishaq Khan Institute of Engineering Sciences and Technology (GIKI). \n53.  Lahore University of Management Sciences. \n54.  Dawat-e-Hadiya, Karachi. \n55.  Baitussalam Welfare Trust. \n56.  Patients' Aid Foundation. \n57.  Alkhidmat Foundation. \n58.  Alamqir Welfare Trust International. \n59.  Prime Minister's Special Fund for victims of terrorism. \n60.  Chief Ministers(Punjab) Relief Fund for Internally Displaced Persons (1DPs) of KPK. \n61.  Prime Ministers Flood Relief Fund 2010 and Provincial Chief Ministers Relief Funds \nfor victims of flood 2010. \n62.  Waqf for Research on Islamic History, Art and Culture, Istanbul. \n    1[63. \nAll entities mentioned in Table-I of clause (66) of Part-I of the Second Schedule of \nthe Ordinance.]  \n                                            \n1  The S. No 63 and entry relating thereto in column (2) inserted by the Finance Act, 2022. \n\n\f\nThirteenth Schedule____________________________________ \n799 \n \n   1 [64. \nThe Prime Minister's Relief Fund for Flood, Earthquake and Other Calamities with \neffect on and from the 5th August, 2022. \n     65. \nFilm and Drama Finance Fund.] \n \n  \n \n  \nProvided that the Federal Government shall have the power to add, amend or omit \nany entry in this Schedule.\n                                            \n1  S. Nos. 64 and 65 and entry relating thereto in column (2) added by the Finance Act, 2023. Earlier \nthese serial numbers were added through S.R.O. Nos. 1634(I)/2022 dated 30.08.2023 and \n212(I)/2023 dated 22.02.2023 respectively. \n\n\f\nFourteenth Schedule _________ __________________________ \n \n800 \n1[FOURTEENTH SCHEDULE \n(See section 100E) \n \nRULES FOR COMPUTATION OF PROFIT AND GAINS FOR SMALL \nAND MEDIUM ENTERPRISES \n \n1. \nApplication.- These rules shall apply to small and medium enterprises as defined in \nClause (59A) of Section 2 of the Ordinance. \n \n2. \nRegistration.- Small and medium enterprise shall be required to register with FBR on \nits Iris web portal or Small and Medium Enterprises Development Authority on its SME \nregistration portal   (SMERP). \n \n3. \nCategories and tax rates.- There shall be following two categories of small and \nmedium enterprises and tax on their taxable income shall be computed at the tax rates \ngiven in the table below, namely:- \n \nSr. No. \nCategory \nTurnover \nRates \n(1) \n(2) \n(3) \n(4) \n 1. \nCategory-1 \nWhere annual business turnover \ndoes not exceed Rupees 100 million \n7.5% of taxable \nincome  \n 2. \nCategory-2 \nWhere annual turnover exceeds \nRupees 100 Million but does not \nexceed Rupees 250 Million   \n15% of taxable \nincome  \n \n \n4. \nOption for Final Tax Regime.- (1) The small and medium enterprises may opt for \ntaxation under final tax regime at the rates given in the table below: \n \nSr. No. Category \nTurnover \nRates \n(1) \n(2) \n(3) \n(4) \n 1. \nCategory-1 \nWhere annual business turnover does \nnot exceed Rupees 100 million \n0.25% of gross \nturnover   \n 2. \nCategory-2 \nWhere \nannual \nbusiness \nturnover \nexceeds Rupees 100 million but does \nnot exceed Rupees 250 million   \n0.5% \nof \ngross \nturnover   \n \n \n(2) \nOption under sub-rule (1) of this rule shall be exercised at the time of filing of \nreturn of income and option once exercised shall be irrevocable for three tax years. \n \n(3) \nThe provisions of section 177 and 214C shall not apply to SME who opts for \ntaxation under sub-rule (1) of this rule. \n  \n                                            \n1 The Fourteenth Schedule added by the Finance Act, 2021.  \n\n\f\nFourteenth Schedule__________________________________ \n801 \n \n5. \nAudit.- (1) SMEs who opt for taxation under normal law under rule 3 may be selected \nfor tax audit through risk based parametric computer ballot under section 214C of the \nOrdinance if its tax to turnover ratio is below tax rates given in rule 4 of these rules. \n \n(2) \nThe cases selected under sub-rule (1) of this rule shall not exceed 5% of the \ntotal population of SMEs whose tax to turnover ratio is below tax rates given in rule 4 of \nthese rules.  \n \n6. \nExports.- The export proceeds of SMEs shall be subject to tax as per  rates prescribed \nin Rule (4) under final tax regime.”; \n \n7. \nExclusion from Minimum Tax on Turnover.- The provisions of section 113 of the \nOrdinance shall not apply to SMEs. \n \n8. \nTax on Supply of Goods.-The tax deductible under clause (a) of sub-section (1) of \nsection 153 shall not be minimum tax where payments are received on sale or supply \nof goods by SMEs. \n \n9. \nProvisions of Ordinance to apply.- The other provisions of the Ordinance shall apply \nmutatis mutandis to the SMEs.] \n\n\f\nFifteenth Schedule _________ __________________________ \n \n802 \n1[The Fifteenth Schedule \n[See section 114C] \nThreshold for Economic Transactions \n \nFor the purposes of section 114C of the Ordinance, the threshold of the economic \ntransactions specified herein, to be applied in respect of ineligible persons shall be \ndetermined as follows \n \nS. No. Transaction \nreference  \nDescription \nTransaction \nvalue \nspecification  \nThreshold \nlimitation \nfor \nineligibility \n(1) \n(2) \n(3) \n(4) \n(5) \n1. \n114C(1)(a) \nIn relation to an application \nfor booking, purchase or \nregistration \nof \nmotor \nvehicle. \nThe \ninvoice \nvalue for locally \nmanufactured \nvehicle; or the \nimport value as \nassessed by the \nCustoms \nAuthority \ninclusive of all \napplicable taxes, \nduties, \nlevies \nand charge. \nExceeding \nseven \nmillion \nrupees.  \n2. \n114C(1)(b) \nIn relation to an application \nfor registering, recording or \nattesting transfer of any \nimmoveable property   \nFair \nMarket \nValue as defined \nin clause (22AA) \nof section 2 of \nthe Ordinance \nExceeding \none \nhundred \nmillion \nrupees. \n3. \n114C(1)(c) \nIn relation to the investment \nin \nsecurities, \ndebt \nsecurities, units of mutual \nfunds or money market \ninstruments subject to the \ncondition \nthat \nthe \ninvestment amount up to \nrupees fifty million shall be \nnew investment in any \nfinancial \nyear \nexcluding \nreinvestment \neither \nby \nAcquisition cost \nof securities or \ndebt \nsecurities \nor unit of mutual \nfunds or money \nmarket \ninstruments \nExceeding \nfifty  million \nrupees”; \n                                            \n1 Fifteenth Schedule inserted by the Finance Act, 2025. \n\n\f\nFifteenth Schedule__________________________________ \n803 \n \nliquidation of similar type of \nsecurities \nand \nor \nreinvestment \nof \nreturns \nearned on already held \nsecurities \n4. \n114C(1)(d) \nAnnual \ncash \nwithdrawal \nlimit \n- \nOne \nhundred \nmillion \nrupees in all \nbank \naccounts \nheld by an \nindividual. \n \n \n**** \n \n","passage_offset_convention":"zero-based Unicode code points and UTF8 bytes; end 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