Tax Book 2023

(Ben LeoJzBdje) #1

Income Tax Authorities Chapter- 19


The Directorate-General of Research and Development shall consist of a Director General and as
many Directors, Additional Directors, Deputy Directors, Assistant Directors and such other officers as
the Board may, by notification in the official Gazette, appoint.

The Board may, by notification in the official Gazette, specify the functions, jurisdiction and powers of
the Directorate-General of Research and Development.


  1. Directorate-General of Broadening of Tax Base [U/s 230D]


The Directorate-General of Broadening of Tax Base shall consist of a Director-General and as many
Directors, Additional Directors, Deputy Directors, Assistant Directors and such other officers as the
Board may, by notification in the official Gazette, appoint.
The Board may, by notification in the official Gazette, specify the functions, jurisdiction and powers of
the Directorate General of Broadening of Tax Base.


  1. Directorate-General of International Tax Operations [U/s 230E]


1) The Directorate General of international Tax Operations shall consist of a Director General and as
many Directors, Additional Directors, Deputy Directors, Assistant Directors and such other officers
as the board may, by notification in the official Gazette, appoint.
2) The Board may, by notification in the official Gazette,
(a) specify the functions and jurisdiction of the Directorate General and its officers; and
(b) confer the powers of authorities specified in section 207 upon the Directorate General and its
officers.
3) The functions and powers of the Directorate General of International Tax Operations shall include
but not limited to-
a. receive and send information from other jurisdictions under spontaneous, automatic and on
demand exchange of information under exchange of information agreements;
b. levy and recover tax by passing an assessment order under section I23(1A) in case of
undeclared off-shore assets and incomes;
c. receive, transmit and exchange country reports to the jurisdictions that are parties to
international by country agreements with Pakistan; and
d. conduct transfer pricing audit in cases selected for such audit by the Director General of
international Tax Operations.
4) The Board may, by notification in the official Gazette, specify the criteria for selection of the taxpayer
for transfer pricing audit. Explanation- For the removal of doubt, it is clarified that transfer pricing
audit refers to the audit for determination of transfer price at arm's length in transactions between
associates and is independent tax audit under section 177 and 2l4C which is audit of the income tax
affairs of the taxpayer.
Explanation- For the removal of doubt, it is clarified that transfer pricing audit refers to the
audit for determination of transfer price at arm's length in transactions between associates and
is independent tax audit under section 177 and 2l4C which is audit of the income tax affairs of the
taxpayer.
5) Transfer pricing audit of cases selected under clause (d) of sub-section (3) shall be conducted as
per procedure given in section 177 and all the provisions of the Ordinance, except the first
proviso to sub-section (1), sub-section (6A), (10) and (14) of section 177, shall apply accordingly.
6) Nothing contained in this section shall prevent the CIR from determination of transfer price at arm’s
length in transactions between associates while conducting audit of income tax affairs of a taxpayer
under section 177 or 214C or during proceedings under section 122.


  1. Directorate-General of Special Initiative [U/s 230G]


(1) The Directorate General of Special Initiative shall consist of a Director General and as
many Directors, Additional Directors, Deputy Directors, Assistant Directors and such other officers as
the Board may, by notification in the official Gazette, appoint.

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