Lahore High Court
2026
THLN 2530
2026 PTD 419
Laws Cited
Income Tax Ordinance, 2001 | Companies Ordinance, 1984
Sections
21, 109, 151, 122(5A), 122(9), 111, 133(8) | 120

COMMISSIONER INLAND REVENUE, LEGAL ZONE, LTO, MULTAN

VS

Messrs AL-HILAL INDUSTRIES (PVT.) LTD.

Petitioner(s) by: Muhammad Shaukat Qamar
Respondent(s) by: Muhammad Usman Hadi and Jamil Ahmad Shaikh
Present: Asim Hafeez and Abid Hussain Chattha, JJ
ORDER

Following questions, statedly arising out of order of 20.04.2022 by the Appellate Tribunal Inland Revenue, Multan Bench, Multan (the Tribunal ), are proposed for determination.1. Whether on the facts and circumstances of the case the learned ATIR has failed to appreciate that the profit on redeemable capital on the basis of profit/loss sharing basis is not an admissible expense under any provision of Income Tax Ordinance, 2001?2. Whether on the facts and circumstances of the case the learned ATIR has failed to appreciate that the profit on redeemable capital is not in the nature of interest on borrowed money therefore, no deductible under section 21 of the Income Tax Ordinance, 2001?3. Whether on the facts and circumstances of the case the learned ATIR has failed to appreciate that Participation Term Finance Certificates were issued for redeemable capital under section 120 of the Companies Ordinance, 1984 which are not interest based.2. Tax Year was 2010. Record depicts that the Tribun...