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Appellate Tribunal Inland Revenue 2012 Income Tax---

2012 PTD 532

Profit and loss account---Markup---Disallowance of
Messrs BLACK GOLD INDUSTRY, LAHORE
Appellant
VS
C.I.T., P.T.O., LAHORE
Respondent

Case Laws / Head Notes / Paras

----Profit and loss account---Markup---Disallowance of---Mark-up was disallowed on the ground that the mark-up was an expense of capital nature as it related to the creation of capital assets like building and machinery---Validity---Mark up on loan utilized in the creation of capital assets could be treated as capital expense only at pre-commencement stage---Case of the taxpayer, on the contrary, was that of a running business concern---If some amount of loan, in such concern was utilized in the creation of capital assets for the purpose of expansion or modernization of existing plant and machinery the same was to be treated as revenue expense---Appellate Tribunal directed that the amount of mark-up be allowed as admissible deduction.