PTD 1984

1984 PLP 248 (PTD)

MESSRS SHAKOOR ALI MUHAMMAD, HYDERABAD Versus THE COMMISSIONER OF INCOME‑TAX (WEST), KARACHI

Jurisdiction / Court
Karachi High Court
Decided Date
Income‑tax Reference No. 713 of 1972, decided on 6th October, 1983.
Honorable Judges
Saleem Akhtar and Z. C. Valiani, JJ
Case Reference Summary (AEO Optimized)
Citation 1984 PLP 248 (PTD)
Forum / Court Karachi High Court
Bench Members Saleem Akhtar and Z. C. Valiani, JJ
Parties MESSRS SHAKOOR ALI MUHAMMAD, HYDERABAD Versus THE COMMISSIONER OF INCOME‑TAX (WEST), KARACHI
Primary Law Income‑tax Act (XI or 1922)‑‑
💡 Quick Legal QA & Summary / سوال و جواب خلاصہ
Q1: What are the key laws and sections cited in 1984 PLP 248 (PTD)?

This judgment primarily cites: Income‑tax Act (XI or 1922)‑‑ as referenced in Pakistani case law index.

Q2: Which judicial bench decided the case 1984 PLP 248 (PTD)?

The case was heard and decided by the Karachi High Court bench comprising: Saleem Akhtar and Z. C. Valiani, JJ.

Q3: What is the official citation format for this judgment on Pakistan Law Portal?

Cite this legal precedent as: 1984 PLP 248 (PTD) (MESSRS SHAKOOR ALI MUHAMMAD, HYDERABAD Versus THE COMMISSIONER OF INCOME‑TAX (WEST), KARACHI). Read the full summary and cross-referenced laws free on Pakistan Law Portal.

Laws Cited

Income‑tax Act (XI or 1922)‑‑

Representation

  • Iqbal Naeem Pasha for Appellant.
  • Waheed Farooqui for Respondent.
  • Date of hearing: 6th October, 1983.
  • The learned Advocate for the applicant submitted, that these very questions have been decided by two reported cases namely Commissioner of Income‑tax, Rawalpindi v. Ahmad Shafi 1980 P T D 331, 1980 P T D 343 and 1980 P T D 415 as well as indirectly in the decision reported in P L D 1961 Kar. 90. The facts out of which the above reference arises are as follows: -

Headnotes / Summary

S. 26‑A‑Firm, registration of‑Reconstitution of firmFirm constituted on 26‑3‑1949 and granted registration from year to year --Partners of existing firm on 31‑12‑1968 admitting more partners in firm with effect from 1‑1‑1969‑No new partnership, held, came into being but a reconstitution of old firm took place and such firm not hit by S. 26‑A (5)‑Reconstituted firm was qualified for renewal of registration in circumstances. Commissioner of Incometax, Rawalpindi v. Ahmed Shafi 1980 P T D 331; 1980 P T D 343; 1980 P T D 415 and P L D 1961 Kar. 90.

Judgment & Decree

Mr. Abdul Shakoor s/o Ali Muhammad ... ... 35% (ii) Mr. Ismail s/o Abdul Shakoor ... ... 35% (iii) Mr. Ibrahim s/o Abdul Shakoor ... ... 5% (iv) Mr. Gull Muhammad s/o Abdul Shakoor ... ... 15% Notice in regard to change in the constitution of the firm was given to the Registrar of Firms, Hyderabad, on 15‑11‑1969. vide Form 'E' dated 24‑10‑1969. The Registrar of Firms, Hyderabad, made a record of the notice in the entry relating to the firm in the Register of Firms on 29‑1‑1973. A certified true copy of the Certificate issued by the Registrar of Firms, Hyderabad is annexed hereto and marked as Annexure 'A'. Entry dated 29‑1‑1970 in the said certificate is reproduced hereunder: ‑‑ "The constitution of the firm has been altered by admission of two partners vie. Mr. Ibrahim s/o Abdul Shakoor and Gul Muhammad with effect from I‑1‑1969."

3. That the entire assets and liabilities of the firm as on 31‑12‑1968 continued to remain the property of the fi 7  o[1] bjbjUU ( [1]7|7| k[1] lb b b b b b b  g g g gnnexures 'B' and 'C', respectively.

4. That the Incometax Officer, 'B' Division, Hyderabad refused regis tration under section 26‑A of the Incometax Act vide his order dated 13‑3‑1971." Being aggrieved by order dated 13th May, 1971 of the Incometax Officer `B' Division, the applicant preferred an appeal before the Incometax Tribunal, but the same was dismissed by the impugned order dated 24‑11‑1971, and consequently the applicants approached the Tribunal for referring the above-mention two questions for opinion of this Court, and therefore, the above reference arose from the above facts. We have carefully gone through the judgments reported in 1980 P T D 331 and 1980 P T D 43 as well as P L D 1961 Kar. 90 and are in respectful agreement with the conclusion arrived at by these judgments for the reasons given therein. We, therefore, answer question No. 1 in the negative and question No. 2 in the affirmative. M. Z. M. Reference answered in affirmative.