64B.
Tax credit for employment generation by 123
manufacturers
64C. Omitted by Finance Act, 2021 125
64D. Tax credit for point of sale machine 125
65. Miscellaneous provisions relating to tax credits 125
65A. Omitted by the Finance Act, 2017 126
65B. Tax credit for investment 127
65C. Omitted by the Finance Act, 2021 128
65D. Omitted by the Finance Act, 2021 129
65E. Tax credit for industrial undertakings established 130
before the first day of July, 2011
65F. Tax credit for certain persons 132
65G. Tax credit for specified industrial undertakings 133
65H. Omitted by the Finance Act, 2022. 133
CHAPTER-IV
COMMON RULES
PART I
GENERAL
66. Income of joint owners 135
67. Apportionment of deductions 135
68. Fair market value 136
69. Receipt of income 137
70. Recouped expenditure 137
71. Currency conversion 137
72. Cessation of source of income 137
73. Rules to prevent double derivation and double 138
deductions
PART II
TAX YEAR
74. Tax year 139
PART III
ASSETS
75. Disposal and acquisition of assets 141
75A. Purchase of assets through banking channel 141
76. Cost 142
77. Consideration received 143
78. Non-arm's length transactions 144
79. Non-recognition rules 144
CHAPTER V
PROVISIONS GOVERNING PERSONS
PART I
CENTRAL CONCEPTS
Division I
Persons
80. Person 146
Division II
Resident and Non-resident Persons
81. Resident and non-resident persons 148
82. Resident individual 148
83. Resident company 149
84. Resident association of persons 149
Division III
Associates
85. Associates 149
PART II
INDIVIDUALS
Division I
Taxation of Individuals
86. Principle of taxation of individuals 152
87. Deceased individuals 152
Division II
Provisions Relating to Averaging
88. An individual as a member of an association of 153
persons
88A. Omitted by Finance Act, 2014 153
89. Authors 153
Division III
Income Splitting
90. Transfers of assets 154
91. Income of a minor child 155
PART III
ASSOCIATIONS OF PERSONS
92. Principles of taxation of associations of persons 156
93. Omitted by the Finance Act, 2007. 157
PART IV
COMPANIES
94. Principles of taxation of companies 157
95. Disposal of business by individual to wholly-owned 158
company
96. Disposal of business by association of persons to 159
wholly-owned company
97. Disposal of asset between wholly-owned 161
companies
97A. Disposal of asset under a scheme of arrangement 162
and reconstruction.
PART V
COMMON PROVISIONS APPLICABLE TO
ASSOCIATIONS OF PERSONS AND
COMPANIES
98. Change in control of an entity 164
PART VA
TAX LIABILITY IN CERTAIN CASES
98A. Change in the constitution of an association of 165
persons
98B. Discontinuance of business or dissolution of an 165
association of persons
98C. Succession to business, otherwise than on death 165
CHAPTER-VI
SPECIAL INDUSTRIES
PART I
INSURANCE BUSINESS
99. Special provisions relating to insurance business 167
99A. Special provisions relating to payment of tax 167
through electricity connections
99B. Special procedure for small traders and 169
shopkeepers
99C. Special procedure for certain persons 169
99D. Additional tax on certain income, profits and gains. 169
PART II
OIL, NATURAL GAS AND OTHER MINERAL
DEPOSITS
100. Special provisions relating to the production of oil 171
and natural gas, and exploration and extraction of
other mineral deposits
100A. Special provisions relating to banking business. 171
100B. Special provision relating to capital gain tax. 172
100BA. Special provisions relating to persons not appearing 172
in active taxpayers’ list.
100C. Tax credit for certain persons 173
100D. Special provisions relating to builders and 177
developers
100E. Special provisions relating to small and medium 184
enterprises
100F Omitted by the Finance Act, 2022 184
CHAPTER VII
INTERNATIONAL
PART I
GEOGRAPHICAL SOURCE OF INCOME
101. Geographical source of income 187
101A Gain on disposal of assets outside Pakistan 192
PART II
TAXATION OF FOREIGN-SOURCE INCOME OF
RESIDENTS
102. Foreign source salary of resident individuals 195
103. Foreign tax credit 195
104. Foreign losses 196
PART III
TAXATION OF NON-RESIDENTS
105. Taxation of a permanent establishment in Pakistan 197
of a non-resident person
106. Thin capitalization 198
106A. Restriction on deduction of profit on debt payable 200
to associated enterprise
PART IV
AGREEMENTS FOR THE AVOIDANCE OF
DOUBLE TAXATION AND
PREVENTION OF FISCAL EVASION
107. Agreements for the avoidance of double taxation 203
and prevention of fiscal evasion
CHAPTER VIII
ANTI-AVOIDANCE
108. Transactions between associates 205
108A. Report from independent chartered accountant or 206
cost and management accountant
108B. Transactions under dealership arrangements 206
109. Recharacterisation of income and deductions 207
109A Controlled foreign company. 208
110. Salary paid by private companies 210
111. Unexplained income or assets 211
112. Liability in respect of certain security transactions 213
CHAPTER IX
MINIMUM TAX
113. Minimum tax on the income of certain persons. 214
113A. Omitted by the Finance Act, 2016 217
113B. Omitted by the Finance Act, 2016 217
113C. Alternative Corporate Tax 218
CHAPTER X
PROCEDURE
PART I
RETURNS
114. Return of income 221
114A. Business bank account 228
114B. Powers to enforce filing of returns. 229
115. Persons not required to furnish a return of income 230
116. Wealth statement 231
116A Foreign income and assets statement 233
117. Notice of discontinued business 234
118. Method of furnishing returns and other documents 235
119. Extension of time for furnishing returns and other 237
documents
PART II
ASSESSMENTS
120. Assessments 239
120A. Omitted by Finance Act, 2013 242
120B. Restriction of proceedings 242
121. Best judgment assessment 242
122. Amendment of assessments 244
122A. Revision by the Commissioner 248
122B. Revision by the Chief Commissioner 249
122C. Omitted by the Finance Act, 2017 249
122D. Agreed assessment in certain cases 250
123. Provisional assessment in certain cases 251
124. Assessment giving effect to an order 251
124A. Powers of tax authorities to modify orders, etc. 253
125. Assessment in relation to disputed property 254
126. Evidence of assessment 254
