| Case ID |
fff34bf8-e2c9-4c6c-94f1-d67ffd12f7c9 |
| Body |
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| Case Number |
I.T.A. No. 4206/LB of 2000 |
| Decision Date |
Oct 29, 2001 |
| Hearing Date |
Aug 25, 2001 |
| Decision |
The appeal was dismissed, upholding the decision that the commercial production commenced in July 1991. The tribunal concluded that, despite the appellant's argument that the production of fully manufactured Auto Wire Harness started in 1993, the production of semi-finished goods in 1991 marked the commencement of commercial production. The exemption period started from July 1991, as the industrial undertaking was considered set up and ready to go into production at that time. |
| Summary |
In this case before the Income Tax Appellate Tribunal, the key issue was the determination of the commencement date for commercial production, which was essential for tax exemption eligibility under the Income Tax Ordinance, 1979. The appellant contended that commercial production, particularly of their fully manufactured product 'Auto Wire Harness', began in 1993. However, the tribunal, referencing previous judgments and clarifications from the Central Board of Revenue, concluded that the production of semi-finished goods in 1991 qualified as the start of commercial production. This decision upheld the Assessing Officer's rectification order, determining that the exemption period commenced in July 1991. Keywords such as 'Income Tax Appellate Tribunal', 'commercial production', 'tax exemption', and 'Auto Wire Harness' are crucial for understanding this case's context. This case highlights the complexities of tax law and the critical role of precise definitions and timelines in determining tax liabilities. |
| Court |
Income Tax Appellate Tribunal
|
| Entities Involved |
Not available
|
| Judges |
Khawaja Farooq Saeed,
Imtiaz Anjum
|
| Lawyers |
Wasim Siddiqui, C.A.,
M. Asif, D.R.
|
| Petitioners |
Not available
|
| Respondents |
Not available
|
| Citations |
2002 SLD 466,
2002 PTD 620,
(2002) 85 TAX 219
|
| Other Citations |
1979 PTD 612,
1998 PTD (Trib.) 3742
|
| Laws Involved |
Income Tax Ordinance, 1979
|
| Sections |
Second Sched
|