Watermark
Appellate Tribunal Inland Revenue 2012 Income Tax Ordinance (XLIX of 2001)--- ---Ss. 70, 69, 25, 18(1)(d), 120, 122(5) & 122(9)

2012 PTD 206

Receipt of income--- Pre-commencement expenditure---
Messrs LAFARGE PAKISTAN CEMENT LTD., ISLAMABAD
Appellant
VS
C.I.R., L.T.U., ISLAMABAD
Respondent

Case Laws / Head Notes / Paras

--Recouped expenditure---Tax year 2005---Receipt of income---Pre-commencement expenditure---Income Tax Return, Annexure IIB, IIB & IIC---Waiver of interest and penal charges---Taxpayer contended that department had taxed the reversal of interest and penal charges under the head 'income from business ignoring the fact that these financial expenses were 'pre-commencement expenses' in terms of S.25 of the Income Tax Ordinance, 2001 and the company had already accounted such reversal as for claiming amortization of pre-commencement expenses for the first time in tax year 2007---Validity---Expenses incurred during the pre-commencement period were to be amortized in the subsequent years after the commencement of production, but the waiver of interest meant that such expense was not incurred-...