Following questions, statedly arising out of order of 20.04.2022 by the Appellate Tribunal Inland Revenue, Multan Bench, Multan (the Tribunal ), are proposed for determination.1. Whether on the facts and circumstances of the case the learned ATIR has failed to appreciate that the profit on redeemable capital on the basis of profit/loss sharing basis is not an admissible expense under any provision of Income Tax Ordinance, 2001?2. Whether on the facts and circumstances of the case the learned ATIR has failed to appreciate that the profit on redeemable capital is not in the nature of interest on borrowed money therefore, no deductible under section 21 of the Income Tax Ordinance, 2001?3. Whether on the facts and circumstances of the case the learned ATIR has failed to appreciate that Participation Term Finance Certificates were issued for redeemable capital under section 120 of the Companies Ordinance, 1984 which are not interest based.2. Tax Year was 2010. Record depicts that the Tribun...
PRESENT:
Asim Hafeez and Abid Hussain Chattha, JJ
Petitioner(s) by: Muhammad Shaukat Qamar.
Respondent(s) by: Muhammad Usman Hadi and Jamil Ahmad Shaikh.
Law: Income Tax Ordinance, 2001
Sections: 21, 109, 151, 122(5A), 122(9), 111, 133(8)
Law: Companies Ordinance, 1984
Sections: 120
Disclaimer / Note: We have reproduced the judgment for facilitation of readers; however, the readers must study the original or certified copy of the above said judgment before referring it in any Court of Law. The judgment as reproduced above is a reported judgment available in law magazines and journals namely: 2026 PTD 419