JUDGMENT

MUHAMMAD JUNAID GHAFFAR, ACTING CHIEF JUSTICE.---Through this Reference Application, the Applicant has impugned Order dated 08.02.2012 passed in I.T.A. No. 35/KB/2011 for tax year 2009 by the Appellate Tribunal Inland Revenue, at Karachi proposing various questions of law; however, vide order dated 30.10.2012, notice was only ordered on the following two questions of law:-1) As to whether in the facts and circumstances of the case the provision of Section 85 of Income Tax Ordinance, 2001 and interest under section 39 of Income Tax Ordinance, 2001 read with Section 108 of Income Tax Ordinance, 2001 on the payment of Rs.15,000,000/- for the purchase of office made to Portlink International Services (Pvt.) Ltd. By the applicant / tax payer company is attracted?2) As to whether in the facts and circumstances of the case, on the salaries and wages amounting to Rs. 825,645/- paid to individuals falling below the prescribed threshold of Rs.15,000/- provision of Section 21(m) of Income Tax Ord...