JUDGMENT:

SHAHID KARIM, JUSTICE:---This judgment will also decide connected reference application ITR No.45067 of 2023 which relates to tax year 2014. For that tax year, the Commissioner Inland Revenue (Appeals) decided the appeal against the applicant which was affirmed by the Appellate Tribunal Inland Revenue. For the tax year 2015 which is the subject matter of ITR No.72345 of 2023, the CIR (A) taking a contrary view decided the issue engaged in favour of the applicant in the following terms:�7.9 The arguments of the AR heard, record perused and ground of appeal and impugned order is consulted. In view of the above referred facts/ submissions of the case and provisions of law, I find myself in agreement with the submissions made by the learned AR. The learned Additional Commissioner Inland Revenue was not justified in charging the minimum tax on turnover that do not pertains to the appellant and is being offered for tax by the respective Distribution Companies. The minimum tax u/ s 113 of the...