071401_20160923_190055.docx - are reflected in the sales...

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Unformatted text preview: are reflected in the sales tax returns. The cost are properly supported by the documentary evidence hence no advance inference can be drawn. The purchases valuing Rs. 28,4 56,330/- were return to M/s. Salim international and Kamil Sons in settlement of their old outstanding liability, copies of the ledger accounts of the parties have already been submitted to vide our letter dated 2510-2013 which contain the NTN and particulars of the parties. This was Income Tax Ordinance, 2001. Further it is submitted that the purchases of the taxpayer are these have been purchased from known and verifiable parties and are supported fully verifiable as by documentary evidence. The name and complete postal addresses along with the N T N ar e a va i la bl e o n the sa l e s t o majorit x returns filed by the tax pany have imported and p ayer, further y of the purchases are imports which the com have also suffered tax under section 148 of the Income Tax Ordinance, 2001. Further payment of local purchases are also from known and verifi able parties a nd pay me nt s t her e o f ha s a l so be e n ma de t hr o ug ba nki n g c ha nne l a nd a l so h bankin suffered tax u/s. 153(1)(a) of the Income Tax Ordinance, 2001. The documentary evidence as desired by you is attached herein above whi that purchases are ch are an ample proof fully supported as a result no adverse inference can be drawn on an amount of Rs. 84,645,467/- to attract the provision of section 111(1)(b) of the Income Tax Ordinance, 2001." UNQUOTE: The reply of the taxpayer was examined. With regard to its claim of imports of the previous tax year shown in current year amounting to Rs. 23,837,327/- the evident provAed in the form of GD's and reconciliation with sales tax returns has been found satisfactory and hence accepted. However, the claim of electricity charges amounting to Rs. 13,501,224/- and Diesel expense amounting to Rs. 5,813,093/- has not been substantiated with evidence in form of copies of bills, vouchers, month wise reconciliation with sales tax returns, etc despite it claim of submission of the same in its reply. Similarly, for claim of purchase returned back to vendors amounting to Rs. 13,037,513/- due to disallowance of input tax by Directorate of I & I, FBR, in the case of Pakistan Traders, the taxpayer's plea that the stock was written off could not be accepted as the purchases has not been provided to reconcile the total amount of purchases claimed in the income tax record and obtain a clear picture of purchases. Furthermore, the disallowance of input tax was made by I & I after the tax year 2011 and accounts made by the taxpayer cannot cater for such changes nor are there any rules to allow the taxpayer to write off any such purchases in the Income Tax record for which input tax has been disallowed by the Revenue Authorities. ...
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