Appellate Tribunal Inland Revenue
2025
THLN 1001
2025 THLN 1001
Laws Cited
Income Tax Ordinance, 2001
Sections
131(1), 120(1)(b)

M/s Fauji Fertilizer Company Limited; Sona Tower 156 The Mall Rawalpindi. NTN:1435809-3

VS

The Commissioner Inland Revenue

Petitioner(s) by: Mr. Rashid Qureshi, FCA
Respondent(s) by: Mr. Osama Shahid, L.A. Assisted by Mr. Muhammad Fiaz Hussain, DR Date of hearing: 18.12.2024 Date of order:,08.01.2025
Present: (M. M. AKRAM) JUDICIAL MEMBER Sd/-- -SD- (IMRAN LATIF MINHAS) ACCOUNTANT MEMBER
ORDER

M. M. AKRAM (JUDICIAL MEMBER): The appellant taxpayer has filed the titled appeal challenging the Order-in-Appeal No. 304/2023, dated January 20, 2023, issued by the Commissioner of Inland Revenue (Appeals-I), Large Taxpayers Office (LTO), Islamabad. This appeal pertains to the tax year 2018 and was filed under Section 131(1) of the Income Tax Ordinance, 2001 (�the Ordinance�), based on the grounds outlined in the memorandum of appeal.2.    The relevant facts culled out from the record indicate that the appellant, a publicly listed company engaged in the manufacturing, importing, purchasing, and marketing of fertilizers and chemicals across Pakistan, filed its return of total income for the tax year 2018. This return constituted a deemed assessment finalized under Section 120(1)(b) of the Ordinance. Upon examination, the Additional Commissioner Inland Revenue (Add CIR) identified the deemed assessment as erroneous and prejudicial to the interest of revenue. Conseque...