ORDER

MUHAMMAD TAUQIR AFZAL MALIK (JUDICIAL MEMBER).-This is an appeal by the assessee, a public limited company, who has challenged the action taken by IAC under section 66A vide order, dated 12-4-2000.2. They have called in question that the order passed by DCIT was neither erroneous nor prejudicial to the interest of Revenue, hence there were no legal or factual grounds for amending the original order.That the expenses claimed by the assessee-Company cannot be allocated to income which was exempt from tax i.e. capital gains from the sale of shares of the quoted companies under clause (116) to Second Schedule to Income Tax Ordinance, 1979 as held in a number of cases by the learned High Court as well as learned ITAT.That the administrative and other expenses and interest cannot be allocated to income which is exempt from tax and taxable income.That without prejudice to the above grounds of appeal, section 28 of the Ordinance states that while computing the income under the head capital gai...