JUDGMENT

NASIM SIKANDAR, J.-In this reference application under section 133 of the Income Tax Ordinance, 2001 the assessee, a registered firm engaged in business of manufacturing and export of leather garments claims that following questions of law arise out of the impugned order of the Income Tax Appellate Tribunal, Lahore Bench Lahore, dated 9-1-2003:(a) Whether under the facts and circumstances of the case the Tribunal was justified to confirm the addition under section 12(18) of the late Income Tax Ordinance, 1979 treating the business transactions between sister-concerns as loan?(b) Whether under the facts and circumstances of the case the Tribunal was justified to hold that the payments made by sister-concern could not be treated as payments by the assessee, although the Raw Material was given by the assessee to settle this amount?2. Earlier on 23-6-2003 a Division Bench of the Tribunal refused to refer these questions to this Court.3. For the period relevant to the assessment year 1992-9...