Income Tax Appellate Tribunal
2006
THLN 1162
2006 PTD 882 | (2005) 92 TAX 1
Laws Cited
Income Tax Ordinance, 1979 | Income Tax Rules, 1982 | Banking Companies Ordinance, 1962
Sections
23,23(vii),24,24(i) | 20 | 25,25(a),25(3),25(4),25(6),83,84

VS

Petitioner(s) by: Iqbal Naeem Pasha and Nadeem Ahmed Dawoodi
Respondent(s) by: Muhammad Farid, Legal Advisor, Ali Hasnain, D.R. and Javed Iqbal Rana, D.R.
Present: S. HASAN IMAM, JUDICIAL MEMBER S.A. MINAM, JAFRI, ACCOUNTANT MEMBER
ORDER

The assessee a non-resident Banking Company, in this appeal pertaining to assessment year 1985-86, has taken following objections to the impugned order, dated 22-8-1987:--"That the learned CIT(A) has erred in:(i) remanding the case to the learned ITO regarding disallowance of specific provision for bad/doubtful debts amounting to Rs.742,652;(ii) confirming the disallowance of specific provision for "loss on account of frauds" amounting to Rs.159,695;(iii) confirming the order regarding disallowance of expenditure of Rs.730,215 on "leave fair assistance";(iv) confirming the disallowance of Rs.292,182 as "proportionate head office charges" by invoking Rule 20 of the Income Tax Ordinance, 1979;(v) confirming disallowances of penal interest aggregating to Rs.330,158;(vi) confirming the order treating gain of Rs.60,050 realized on Government securities as revenue gain, and(vii) confirming the disallowance of bifurcated interest expenses of Rs.1,439,616".DISALLOWANCE FOR SPECIFIC PROVISION F...