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Recharacterization of income and deductions

Recharacterization of income and deductions legal meaning, translation and judicial precedents.

Meaning & Judicial Interpretation: (اردو مفہوم اور قانونی تشریح)

2013 PTD 116 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN Judicial Precedent
Ss.99, 109, 67, 177 & Fourth Sched., Rr.6A & 5(b)Insurance businessTaxable income, computation ofRecharacterization of income and deductionsExemption of capital gains from sale of shares

Application of other provisions of the Income Tax Ordinance, 2001 in computation of taxable income of an insurance company assessable under S.99 of the Income Tax Ordinance, 2001 read with Fourth Schedule to the Income Tax Ordinance, 2001

Validity

High Court disapproved invocation of S.67 of the Income Tax Ordinance, 2001 to the insurance company holding that S.99 of the Income Tax Ordinance, 2001 read with the Fourth Schedule to the Income Tax Ordinance, 2001 were special provisions applicable to insurance company and general provisions of the Income Tax Ordinance, 2001 were not to be applied in case of insurance companies

Provisions of S.109 of the Income Tax Ordinance, 2001 were not applicable to the taxpayer being a general insurance company assessable under S.99 of the Income Tax Ordinance, 2001 read with the Fourth Schedule of the Income Tax Ordinance, 2001.

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Precedents & Case Laws citing "Recharacterization of income and deductions"

PTD 2026
I.T.R. No.53 of 2022, decided on 18th November, 2025.

2026 P T D 419

COMMISSIONER INLAND REVENUE, LEGAL ZONE, LTO, MULTAN Versus Messrs AL-HILAL INDUSTRIES (PVT.) LTD.

Court: Lahore High Court (Multan Bench)
PTD 2020
Tax Reference Applications Nos.127 to 131 of 2011, decided on 13th May, 2020.

2020 P T D 1252

COMMISSIONER INLAND REVENUE, LEGAL DIVISION, REGIONAL TAX OFFICE, ISLAMABAD Versus Messrs PAK STEEL RE-ROLLING MILLS

Court: Islamabad High Court
PTD 2013
I.T.As. Nos.108/KB and 247/KB of 2011, decided on 8th October, 2012.

2013 P T D (Trib

Messrs IGI INSURANCE LIMITED, KARACHI and another Versus C.I.R., AUDIT DIVISION II, L.T.U., KARACHI and another

Court: Inland Revenue Appellate Tribunal of Pakistan
PTD 2017
I.T.A. No.293/KB of 2012, decided on 31st October, 2013.

2017 P T D (Trib

Messrs CRESOX (PVT.) LTD. Versus C.I.R., ZONE-IV, LTU, KARACHI

Court: Inland Revenue Appellate Tribunal
SCMR 2022
Decided on 17th June, 2022.

2022 S C M R 1958

ATTORNEY GENERAL OF CANADA — Appellant Versus COLLINS FAMILY TRUST and another — Respondents

Court: Supreme Court of Canada*
PTD 2018
I.T.R.A. No.6 of 2013, decided on 18th April, 2017.

2018 P T D 114

COMMISSIONER INLAND REVENUE, ZONE-III Versus Messrs IGI INSURANCE COMPANY LTD.

Court: Sindh