153(4) (Order to grant / refuse reduced rate of withholding on Supplies / Services / Contracts)

(FOR GENERIC EXEMPTION)

Name: PAK ELEKTRON LIMITED Registration 2011386

Address: 17 AZIZ AVENUE CANAL BANK GULBERG V Tax Year : 2022
LAHORE Period : 01-Jul-2021 - 31-Dec-2021
Medium : Online
Contact No: 00923008455770 Due Date : 06-Jul-2021
Valid Upto : 31-Dec-2021
Document 06-Jul-2021

The taxpayer is a Public listed Company and derives income from manufacture and sale of Electrical
capital goods and domestic appliances i.e. Electric Motors, Transformers, switchgears, Energy meters, Air-
conditioners, Refrigerator/ Deep Freezers, Compressors, LED, Washing Machine. Taxpayer has e-filed
return of total income for the tax year 2020 on 04-12-2020 declaring income at Rs.504,983,245/- and
claiming refund at Rs.692,510,713/-. The taxpayer has been maintaining calendar year as special income
year. Accordingly, the period w.e.f. 01-01-2021 to 31-12-2021 relates to tax year 2022. The company has
applied for issuance of exemption certificate under section 153(1)(a)/ 153(1)(c) of the Income Tax
Ordinance, 2001 for the period ending as on 31-12-2021. The updated position of advance tax liability for
the period ending as on 31-12-2021 pertaining to the tax year 2022 and its payments/ adjustment are as
under:

Liability u/s 147 for the period 01-01-2021 to 31-12-2021:

Projection
1) Corporate tax liability
Taxable Income Rs.1,756 (M)
Tax liability @29% Rs. 515 (M)

2) Alternative corporate (ACT)

Accounting profit estimated Rs.2,176 (M)
Tax Rate 17% Rs. 370 (M)

3) Minimum Tax Liability

Turnover Rs.40,000 (M)
Minimum tax rate 1.5% Rs. 500 (M)

Estimated advance tax liability for the tax year 2022

as computed Normal Tax Liability which is higher than others Rs.515 (M)

In view of above chart, tax liability upto 31.12.2021 works out at Rs.515 (M) which has been
discharged as under:

Under Section Period Tax Deducted/verified Remarks

Refund adjusted from
Tax Year 2019 2022 208(M) IT-104 is POF.
Tax deducted on import u/s 148 from 01.01.2021 to 30.06.2021 2022 537.982(M) Verification
sheet from ITMS placed in file
Tax deducted on supplies u/s 153 from 01.01.2021 to 30.06.2021 2022 11.898(M) Verification
sheet from ITMS placed in file
Total Tax 757.88(M)

Description Status Yes/No

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 153(4) (Order to grant / refuse reduced rate of withholding on Supplies / Services / Contracts)
(FOR GENERIC EXEMPTION)

Name: PAK ELEKTRON LIMITED Registration 2011386

Address: 17 AZIZ AVENUE CANAL BANK GULBERG V Tax Year : 2022
LAHORE Period : 01-Jul-2021 - 31-Dec-2021
Medium : Online
Contact No: 00923008455770 Due Date : 06-Jul-2021
Valid Upto : 31-Dec-2021
Document 06-Jul-2021

1 Whether the unit is Industrial Undertaking? Yes

2 Tax Year for which exemption certificate is required is the first year of the business? No
3 Whether due advance tax liability for the tax year is paid? (Detail is tabulatd below as working of
Tax Liability) Yes
4 Is WWF deposited in cash? Tax Years 2014 to 2020 WWF for T.Y 2014 to 2020 not paid in cash.
Recovery has been stayed by the Lahore High Court Lahore in W.P No.4470 of 2021 dated 05.07.2021
5 Are any Arrears of income tax, sales tax and federal excise duty outstanding? No
6 Are all Income Tax Returns (alongwith audited accounts) filed since Tax Year 2014? Yes
7 Are all IT Withholding statements filed since 01.07.2018? Yes
8 Are all Sales Tax Returns filed since June, 2020? Yes

No income tax/sales tax demand is outstanding against the taxpayer. Since the advance
tax liability upto 31.12.2021 has been discharged by the taxpayer, exemption certificate u/s 153(1)(a) [on
supplies of manufactured goods] and u/s 153(1)(c) [on execution of contracts] is issued to the taxpayer till
31.12.2021.

The taxpayer is allowed to make supply of goods manufactured by him without tax deduction under clause
(a) of sub-section (1) of Section 153 of the Income Tax Ordinance, 2001.

Tax already deducted before the issuance of this certificate is not refundable and shall be deposited in the
Government Treasury. This exemption is valid for the period mentioned above only, unless cancelled
earlier.

Withholding Tax
Description Code Rate
Payment for Goods u/s 153(1)(a) @3% 64060006 0 0 0
Payment for Goods u/s 153(1)(a) @4% 64060008 0 0 0
Advance tax on persons remitting amounts abroad through
64151905 0 0 0
credit / debit / prepaid cards u/s 236Y
Payment for Services u/s 153(1)(b) @8% 64060166 0 0 0

Attributes
Attribute Value
Decision Granted / Accepted

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 153(4) (Order to grant / refuse reduced rate of withholding on Supplies / Services / Contracts)
(FOR GENERIC EXEMPTION)

Name: PAK ELEKTRON LIMITED Registration 2011386

Address: 17 AZIZ AVENUE CANAL BANK GULBERG V Tax Year : 2022
LAHORE Period : 01-Jul-2021 - 31-Dec-2021
Medium : Online
Contact No: 00923008455770 Due Date : 06-Jul-2021
Valid Upto : 31-Dec-2021
Document 06-Jul-2021

Attachments
Evidence with 153(4) (Application for reduced rate of APPLICATION FOR ISSUANCE OF EXEMPTION
withholding on Supplies / Services / Contracts) (FOR GENERIC CERTIFICATE US 153(1)(a) and 153 (1)(c) read
EXEMPTION) with section 153(4) valid upto 31-12-2021.PDF

Aftab Alam
Commissioner (Enforcement-I)
Inland Revenue, Zone-II
LTO
LAHORE

This is a generic exemption order, and it does not require any party additions; this order is applicable to all
withholding agents.

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