SPECIAL AUDIT REPORT

ON
INPUT TAX ADJUSTMENT BY
INDEPENDENT POWER PRODUCERS
(IPPs)
FEDERAL BOARD OF REVENUE
(INLAND REVENUE)
AUDIT YEAR 2017-18

AUDITOR-GENERAL OF PAKISTAN
 TABLE OF CONTENTS

Page
ABBREVIATIONS AND ACRONYMS i

PREFACE ii

EXECUTIVE SUMMARY iii

 AUDIT OBJECTIVES v

 SCOPE OF AUDIT vi

 AUDIT METHODOLOGY vi

 RECOMMENDATIONS vii

AUDIT FINDINGS

 DIRECT TAXES 1

 INDIRECT TAXES 14

ANNEXURES 19
 ABBREVIATIONS & ACRONYMS

AGP Auditor-General of Pakistan

ATL Active Taxpayer’s List
CIR Commissioner Inland Revenue
CPR Computerized Payment Receipt
DAC Departmental Accounts Committee
FBR Federal Board of Revenue
FED Federal Excise Duty
FTO Federal Tax Ombudsman/ Federal Treasury Officer
FTR Final Tax Regime
GST General Sales Tax
IRS Inland Revenue Service
KESC Karachi Electric Supply Corporation
LTU Large Taxpayers Unit
NEPRA National Electric Power Regularity Authority
NTN National Tax Number
NTDC National Transmission and Dispatch Company
RTO Regional Tax Office
SRO Statutory Regulatory Order
STGO Sales Tax General Order
STRN Sales Tax Registration Number
WAPDA Water and Power Development Authority
WHT Withholding Tax
WWF Workers Welfare Fund

i
 Preface

The Auditor-General of Pakistan conducts audit subject to Articles 169 and 170
of the Constitution of the Islamic Republic of Pakistan, 1973 read with Sections
8 and 12 of the Auditor-General’s (Functions, Powers and Terms and Conditions
of Service) Ordinance, 2001. The sectoral audit of “Input Tax Adjustment by
Independent Power Producers (IPPs)” was carried out accordingly.

The Directorate General Audit, Inland Revenue Lahore conducted sectoral audit
of “Input Tax Adjustment by Independent Power Producers (IPPs)” during
period from February to May, 2017. During execution of audit program, Sales
Tax and Income Tax assessment record including Income Tax / Sales Tax
returns audited accounts and statements of withholding taxes were scrutinized by
the Audit. The objective of the audit scrutiny was to check whether the due
amount of tax has been paid by the independent power producers after
adjustment of input tax as admissible under the law.

This Special Audit Report is submitted to the President of Pakistan in pursuance

of Article 171 of the Constitution of the Islamic Republic of Pakistan, 1973 for
causing it to be laid before both houses of Majlis-e-Shoora [Parliament].

Javaid Jehangir
Dated: 23 February 2018 Auditor-General of Pakistan

ii
 EXECUTIVE SUMMARY

The Director General Audit Inland Revenue conducted sectoral audit of

taxation issues including “Input Tax Adjustment by Independent Power
Producers (IPPs)” during the period from February to May, 2017. The objective
of the audit scrutiny was to check whether the due amount of tax has been paid
by the independent power producers after adjustment of input tax as admissible
under the law. The audit was conducted in accordance with the INTOSAI
Auditing Standards.
The power sector in Pakistan is a mix of hydel and thermal units
dominated by two vertically integrated public sector utilities that are Water and
Power Development Authority (WAPDA) for all of Pakistan except Karachi, and
the Karachi Electric Supply Corporation (KESC) for the City of Karachi and its,
surrounding areas. There are a number of independent power producers that
contribute significantly in electricity generation in Pakistan. For years, the
matter of balancing Pakistan's supply against the demand for electricity has
remained a largely unresolved matter. Pakistan faces a significant challenge in
revamping its network responsible for the supply of electricity.
Due to an unrealistic power tariff, high inefficiencies, low payment
recovery and the inability of the government to manage its subsidies mechanism
that lead to a serious “circular debt” issue which is becoming a barrier for future
energy sector investment. The economy is badly affected by electricity crisis
with loss of huge capital. The solution to the current crisis lies in energy
conservation at all level in the country. The use of alternate energy such as wind
and solar power could be utilized to immediately reduce the shortages, while
electricity projects from coal and large dam could provide a long-term solution
to the electricity shortage.
Pakistan has been blessed with ample water resources but could store
only 13 percent of the annual flow of its rivers. The hydropower potential in
Pakistan is over 100,000 MW with identified sites of 59000 MW. Hydropower
generation is dependent on hydrological variations and irrigation release
requirements. In early summer, the reservoir levels are generally low and the
turbines operate at relatively low heads with consequently low power output. In

iii
flood season, the reservoir levels are high and large discharge can be passed
through the turbines for maximum power generation. In winter, the irrigation
requirements are low and the discharge for power generation is limited resulting
in lower power output.
It is clear that, both WAPDA and KESC had been plagued with
inefficiencies, poor governance, red-tape, and political interferences since their
inception. Transmission & Distribution losses amounted to 30-40 per cent. This
was as much a result of a lack of adequate investment in the strained
transmission network as of the power thefts by various groups and individuals.
On average, about 20 per cent of dues were not recovered, most of them owed by
other public sector entities. As a result of these inefficiencies, successive
governments injected significant subsidies into them to keep the end consumer
tariff manageable so as to minimize political damage. To counter these chronic
problems and encouraged by the donor agencies like World Bank and Asian
Development Bank, the government embarked on an ambitious power-sector
restructuring with an eventual aim of privatizing the loss-making entities and
moving towards a market-driven electricity sector. Pakistan is a suitable country
for the installation of Hydro, solar and wind power plants and can become an
Asian leader in renewable energy due to its strategic endowments. Rehabilitation
and replacement of the outdated transmission and distribution systems is also
necessary to bridge the gap between supply and demand of electricity across the
country. Improving and increasing ties with future energy rich countries must not
be neglected.
The Government of Pakistan has given exemption to independent power
producers on income from power generation, according to Clause (132) of Part I
of Second Schedule to the Income Tax Ordinance, 2001, profits and gains
derived by a taxpayer from an electric power generation project set up in
Pakistan on or after the 1st day of July, 1988. The exemption under this Clause
shall apply to such project which is:-
(a) owned and managed by a company formed for operating the
said project and registered under the Companies Ordinance,
1984 (XLVII of 1984), and having its registered office in
Pakistan;
(b) not formed by the splitting up, or the reconstruction or

iv
 reconstitution, of a business already in existence or by transfer
to a new business of any machinery or plant used in a business
which was being carried on in Pakistan at any time before the
commencement of the new business; and
(c) owned by a company fifty per cent of whose shares are not held
by the Federal Government or Provincial Government or a
Local Government or which is not controlled by the Federal
Government or a Provincial Government or a Local
Government.
Further as per Clause (11A) (V) of part IV of the Second Schedule to the
Income Tax Ordinance, 2001 the provisions of Section 113, regarding Minimum
Tax, shall not apply to, companies, qualifying for exemption under Clause (132)
and Clause (132B) of Part-I of this Schedule, in respect of receipts from sale of
electricity.
It is pertinent to mention here that the government of India having almost
same economic scenario and power crises did not grant exemption from tax to
independent power producers and the said sector is contributing hundreds of
billions rupees to government exchequer. For example as per power purchase
agreement between M/s TATA Energy and Government of India it is agreed that
“the Seller shall bear and promptly pay all statutory taxes, duties, levies
and cess, assessed/ levied on the Seller, contractors or their employees, that are
required to be paid by the Seller as per the Law in relation to the
execution of the Agreement and for supplying power as per the terms of this
Agreement.”
In Pakistan the independent power producers are enjoying exemption due
to the above said exemptions government revenue involving hundreds of billions
has been foregone yet energy crises are rampant in the country i.e. people
suffering from load shedding paying high tariff and taxes.
Audit Objectives
The objectives of Sectoral Audit were to see whether:
 taxpayers computed their annual Income Tax liability as per
provisions of law;

v
  the Department had designed controls and checks over the taxpayers
for apportionment of expenses;
 there was effective enforcement of such controls to deter the tax
payers to file invalid tax returns and avoid tax;
 automation in the department had helped to improve efficiency in
processing of refund cases;
 the Input Tax adjustment of Sales Tax was correctly claimed; and
 taxpayer have apportioned expenses with respect to exempt and
taxable income.
Scope of Audit
This office selected two field offices i.e. LTU Lahore and LTU
Islamabad having jurisdiction over independent power producers. Audit was
confined to examine/desk audit of data/tax profiles/returns made available by the
department.
Audit Methodology
The following methodology was adopted:
 Understanding the system of levy of Sales Tax, Income Tax and
Federal Excise Duty on Independent Power Producers (IPPs)
 Soft / hard data collection
 Desk audit
 Performed analytical procedure on computerized data
 Compliance of relevant statutory provisions of tax laws applicable
thereon
 Evaluated results and implications

vi
Key audit findings
This report includes audit observations of Rs. 10,155.081 million in
respect of Sectoral Audit of Independent Power Producers (Direct/Indirect
Taxes) relating to Inland Revenue for the Years 2014-15 and 2015-16, audited
during February to May, 2017.
The key audit findings were as follows:
 Loss of revenue due to incorrect exemption claimed by power generation
companies - Rs. 1,017.210 million1
 Loss of revenue due to non taxation of recouped expenditure under
Section 70 of the Income Tax Ordinance, 2000 - Rs. 597.137 million2
 Short deduction of tax under section 5A(1) of the Income Tax Ordinance,
2001 - Rs. 1,282.075 million3
 Incorrect pass through / adjustment of withholding tax deduction on
dividend paid by the IPPs - Rs. 414.547 million4
 Inadmissible adjustment of input tax on sales/supplies which are not
attributable towards taxable supplies Rs. 1,253.363 million5
Recommendations
Shortcomings observed during Sectoral Audit of Independent Power
Producers depicted that:
i) There is a need to ensure apportionment of input tax between energy
purchase price and capacity purchase price.
ii) A mechanism should be evolved to avoid short realization of tax due
to concealment of energy sales.
iii) Assessment made by taxpayers needs to be reviewed at appropriate
level to ensure taxation of taxable and exempt income of the
taxpayers.
iv) There is need to evolve a mechanism to check inadmissible
adjustment of input tax not attributable to power generated by the
taxpayers.
1
Para 1.1, 2Para 1.5, 3Para 1.8, 4Para 1.9, 5Para 2.2,

vii
v) There is a need to devise a mechanism to check short filers and
recovery measures need to be taken as envisaged in Section 11 (A) of
Sales Tax Act, 1990.
vi) Penal provisions of the Sales Tax Act, 1990 should be more deterrent
in cases where the taxpayer deliberately claimed incorrect adjustment
of Input Tax.
vii) There is a need to develop and strengthen the internal controls for
proper assessment and realization of government revenue.

viii
1. Direct Taxes
1.1 Loss of revenue due to incorrect exemption claimed by power
generation companies - Rs. 1,017.210 million
According to Clause (11A) (V) of Part-IV of the Second Schedule to the
Income Tax Ordinance, 2001 the provisions of Section 113, “Minimum Tax,
shall not apply to, companies, qualifying for exemption under Clause (132) and
Clause (132B) of Part-I of this Schedule, in respect of receipts from sale of
electricity”.
Section 113 of the Income Tax Ordinance, 2001 provides for levy of
Minimum Tax on resident company, an individual and an association of persons.
This tax is applicable in cases where company suffer loss for the year; the setting
off of a loss of an earlier year; exemption from tax; and the application of credits
or rebates, according to this section “turnover” means, the gross sales or gross
receipts, exclusive of Sales Tax and Federal Excise duty or any trade discounts
shown on invoices, or bills, derived from the sale of goods, and also excluding
any amount taken as deemed income and is assessed as final discharge of the tax
liability for which tax is already paid or payable; the gross fees for the rendering
of services for giving benefits including commissions; except covered by final
discharge of tax liability for which tax is separately paid or payable; the gross
receipts from the execution of contracts; except covered by final discharge of tax
liability for which tax is separately paid or payable
Twenty three taxpayers registered with the two field offices of FBR
derived income from generation of electricity and its supply to WAPDA. The
said companies were exempt from levy of normal tax under Clause 132 part-I of
second Schedule to the Income Tax Ordinance, 2001, the companies were also
exempt from levy of minimum tax under Clause (11A) (V) of part IV of the
Second Schedule to the Income Tax Ordinance, 2001 in respect of “receipts from
sale of electricity” only. Scrutiny of accounts filed with the returns revealed that
the said companies received “capacity purchase price” which was neither supply
of electricity nor exempt under the law, as so much of the turnover which relates
to supply of electricity was exempt under the aforesaid Clauses of second
Schedule to the Ordinance. But the companies incorrectly claimed it exempt
despite the fact that this receipt does not relate to sale of electricity which was
exempt from levy of tax under the Ordinance. As such, incorrect claim of

1
exemption from Minimum Tax resulted in short levy of tax amounting to
Rs. 1,017.210 million.
Management Response

LTU informed that Minimum Tax under Section 113 is not leviable on
payments received by the IPPs against” capacity purchase price”. LTU is
requested to get the stance verified from Audit. In this regard Audit is of the
view that according to Clause (11A) (V) of part IV of the Second Schedule to the
Income Tax Ordinance, 2001 the provisions of Section 113, regarding Minimum
Tax, shall not apply to, companies, qualifying for exemption under Clause (132)
and Clause (132B) of Part-I ibid, in respect of receipts from sale of electricity
and capacity receipts are such receipts against which no electricity is supplied by
the IPPs to WAPDA. Department may also consider the case if any lacuna
exists which causes avoidance of Minimum Tax by IPPs on capacity receipts as
such receipts are not from supply of electricity.

DAC Decision

DAC directed the LTU to get its stance verified from Audit and report
final compliance by 20.02.2018.

Audit Recommendations

 Non-recovery of Minimum Tax may be justified.

 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Department may also consider the case if any lacuna exists which
causes avoidance of Minimum Tax by IPPs.
[Annexure-A]
1.2 Short levy of tax on dividend income under Section 5 of the Income
Tax Ordinance, 2001 - Rs. 156.962 million
According to Section 5 (1) of the Income Tax Ordinance 2001, “a tax
shall be imposed, at the rate specified in Division III of Part I of the First
Schedule, on every person who receives a dividend from a company or treated as
dividend under Clause (19) of Section 2 of the Income Tax Ordinance, 2001. The

2
tax imposed under sub-Section (1) on a person who receives a dividend shall be
computed by applying the relevant rate of tax to the gross amount of the
dividend”.
M/s Altern Energy (NTN-2152266) assessed under the jurisdiction of
LTU Lahore, received dividend income for Tax Years 2015 and 2016. The
taxpayer was required to file statement under Section 115 (4) of the Income Tax
Ordinance, 2001, and pay due tax accordingly but the needful was not done. This
resulted in short levy of tax on dividend income amounting to Rs. 156.962
million.
Management Response
The Audit findings were sent to the Department during Audit in April
2017 but no reply was furnished by the Department.
DAC Decision

DAC meeting was not convened due to non submission of working

papers by the Department.

Audit Recommendations

 Non-recovery of may be justified.

 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
 Department may also consider the case if any lacuna exists which
causes avoidance of tax by IPPs.
[Annexure-B]
1.3 Non deduction of tax on dividend under Section 150 of the Income
Tax Ordinance, 2001 - Rs. 636.129 million
According to Section 150 of the Income Tax Ordinance 2001, “every
person paying a dividend shall deduct tax from the gross amount of the dividend
paid at the rate specified in Division I of Part III of the First Schedule to the
Ordinance. Further as per Section 165 of the Income Tax Ordinance, 2001
every person collecting tax under Division II of this Part or Chapter XII or

3
deducting tax from a payment under Division III shall furnish a monthly
statement to the commissioner in the prescribed format setting out the name,
Computerized National Identity Card Number, National Tax Number and
address of each person from whom tax has been collected”.
Four taxpayers registered with LTU, Lahore paid dividend to its
shareholders for the year ended 30th June, 2016 and 2015. The taxpayers while
making payment of dividend did not deduct and deposit the tax as required
under the law. This resulted in short levy of tax on dividend income amounting
to Rs. 636.129 million.
Management Response

The Audit findings were sent to the Department during audit in April
2017 but no reply was furnished by the Department.

DAC Decision

DAC meeting was not convened due to non submission of working

papers by the Department.

Audit Recommendations

 Non-recovery of tax may be justified.

 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
[Annexure-C]
1.4 Loss of revenue due to non deduction of tax on late payment
surcharge under Section 151 - Rs. 665.346 million
According to Section 151 of the Income Tax Ordinance, 2001 “where a
person pays yield on an account, deposit or a certificate, under the National
Savings Scheme or Post Office Savings Account; or a banking company or
financial institution pays any profit on a debt, being an account or deposit
maintained with the company or institution; the payer of the profit shall deduct
tax at the rate specified in Division IA of Part III of the First Schedule from the

4
gross amount of the yield or profit paid as reduced by the amount of Zakat, if
any, paid by the recipient under the Zakat and Ushr Ordinance, 1980 (XVII of
1980), at the time the profit is paid to the recipient”.
Eighteen taxpayers registered with the two field offices of FBR paid
interest on account of late payment surcharge. The taxpayers were required to
deduct and deposit tax while making payment to the recipient. But the needful
was not done. It is pertinent to mention here that Islamabad High Court (IHC) in
the case of M/s Hub Power Company Limited, a parallel company, decided the
case against the said company on the issue of taxation of late payment interest
(LPI), as it was in the nature of interest on late payments made by the taxpayers.
This resulted in short recovery of tax amounting to Rs. 665.346 million
Management Response
Department contested the para that tax is not deductible on late payment
surcharge. Audit is of the view that late payment surcharge is in the nature of
interest hence, tax is leviable on such payments. It is pertinent to mention here
that Islamabad High Court (IHC) in the case of M/s Hub Power Company
Limited, a parallel company, decided the case against the said company on the
issue of taxation of late payment interest (LPI). Hence, Department is requested
to reconsider the case under intimation to Audit.
DAC Decision

DAC directed the Department to get its stance verified from Audit and
report final compliance by 20.02.2018.

Audit Recommendations

 Non-recovery of tax may be justified.

 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
 Department may also consider the case if any lacuna exists which
causes avoidance of tax by IPPs.
[Annexure-D]

5
1.5 Loss of revenue due to non taxation of recouped expenditure under
Section 70 of the Income Tax Ordinance, 2000 - Rs. 597.137 million
Section 70 of the Income Tax Ordinance, 2001 provides for taxation of
recouped expenditure. According to the Section “where a person has been
allowed a deduction for any expenditure or loss incurred in a tax year in the
computation of the person’s income chargeable to tax under a head of income
and, subsequently, the person has received, in cash or in kind, any amount in
respect of such expenditure or loss, the amount so received shall be included in
the income chargeable under that head for the tax year in which it is received”.
Four taxpayers assessed under the jurisdiction of two field offices of FBR
received insurance claims during the Tax Years 2015 and 2016. Insurance claims
are not income derived from sale of electricity the taxpayers were required to
declare the said recoupment under Section 39 of the Income Tax Ordinance
2001, as other income. But the needful was not done. This resulted in short-levy
of tax amounting to Rs. 597.137 million.
Management Response
The Department contested that recouped expenditure is not taxable.
Departmental contention is not acceptable. Audit is of the view that recouped
expenditure i.e. insurance claim is taxable under Section 70 of the Income Tax
Ordinance, 2001 as such income is not derived from supply of electricity hence,
taxable under the law. Department is requested to reconsider the case as
insurance claim received by the company is taxable as other income.
DAC Decision

DAC directed the Department to get its stance verified from Audit and
report final compliance by 20.02.2018.
Audit Recommendations
 Non-recovery of tax may be justified.
 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
[Annexure-E]

6
1.6 Excessive assessment of loss / Potential tax effect due to claim of
provisions inadmissible u/s 34 of the Income Tax Ordinance, 2001
- Rs. 1,973.689 million
According to Section 34 (1) of the Income Tax Ordinance 2001, “a
person accounting for income chargeable to tax under the head ‘Income from
Business’ on an accrual basis shall derive income when it is due to the person
and shall incur expenditure when it is payable by the person. Further as per sub
Section (3) of Section 34 an amount shall be payable by a person when all the
events that determine liability have occurred and the amount of the liability can
be determined with reasonable accuracy”.
Two taxpayers registered with the two field offices of FBR claimed
provisions for liquidated damages during Tax Years 2015 and 2016. Provisions
claimed by the tax payer were inadmissible as per law, because said expenses
were provisions only and not actual expenses incurred by the taxpayers. As such,
claim of inadmissible expenses resulted in excess assessment of loss and
consequent potential tax effect of Rs. 1,973.689 million.
Management Response

The Department replied that show cause notice had been issued to the
taxpayers but assessment proceeding were not yet finalized.

DAC Decision
DAC directed the Department to get its stance verified from Audit and
report final compliance by 20.02.2018.
Audit Recommendations
 Non-recovery of tax may be justified.
 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
[Annexure-F]

7
1.7 Loss of revenue due to non taxation of income from other sources
under Section 39 of the Income Tax Ordinance, 2001 - Rs. 1,117.562
million
According to Section 39 (1) read with Section 70 of the Income Tax
Ordinance, 2001 “income of every kind received by a person in a tax year, if it is
not included in any other head, other than income exempt from tax under this
Ordinance, shall be chargeable to tax in that year under the head “Income from
Other Sources”.
Nine taxpayers assessed under the jurisdiction of two field formations of
FBR received other income such as interest on late payment surcharge,
liquidated damages which is also in the nature of interest on delayed payment by
NTDC etc. but tax was not charged as per law. Further, a taxpayer M/s Attock
Gen Limited NTN-2904414 also received Worker’s Profit Participation Fund
amounting to Rs.265.652 million as “pass through item” which is in the nature of
recoupment of expenses incurred during Tax Years 2015 and 2016. The said
recoupment is taxable as it is not attributable to income from electricity. The
above said receipts were taxable being other income but the needful was not
done by the Department. This resulted in short recovery of tax amounting to
Rs. 1,117.562 million.
Management Response
The Department contested the para. Departmental contention is not
acceptable. Audit is of the view that income from other sources is such income
which is not income from electricity hence, taxable under Section 39 of the
Income Tax Ordinance, 2001. Department is requested to reconsider the case.
DAC Decision
DAC directed the Department to get its stance verified from Audit and
report final compliance by 20.02.2018.
Audit Recommendations
 Non-recovery of tax may be justified.
 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
[Annexure-G]

8
1.8 Short deduction of tax under Section 5A(1) of the Income Tax
Ordinance, 2001 - Rs. 1,282.075 million
According to Section 5A (1) of the Income Tax Ordinance, 2001 “a tax
shall be imposed at the rate of ten percent, on every public company other than a
scheduled bank or a modaraba, that derives profits for a tax year but does not
distribute cash dividends within six months of the end of the said tax year or
distributes dividends to such an extent that its reserves, after such distribution,
are in excess of hundred percent of its paid up capital, so much of its reserves as
exceed hundred per cent of its paid up capital shall be treated as income of the
said company. Provided that for Tax Year 2015, cash dividends may be
distributed before the due date mentioned in sub-Section (2) of Section 118, for
filing of return for Tax Year 2015”.
M/s Kot Addu Power Company, Limited bearing NTN-0708010
assessed under the jurisdiction of Large Taxpayers Unit, Lahore had
accumulated un-appropriated profit amounting to Rs. 21,708,105,000 against
paid up capital of Rs. 8,802,532,000 as on 30.06.2016. According to the
provisions of Section 5A (1) so much of the reserves which exceeds hundred per
cent of the capital are deemed income which is taxable @ 10 per cent. The
taxpayer while filing Income Tax return did not pay tax on such reserves which
resulted in short levy of tax amounting to Rs. 1,282.075 million
Management Response

The Audit findings were sent to the Department during Audit in April
2017 but no reply was furnished by the Department.

DAC Decision

DAC meeting was not convened due to non submission of working

papers by the Department.
Audit Recommendations
 Non-recovery of tax may be justified.
 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.

9
1.9 Incorrect pass through/adjustment of withholding tax deduction on
dividend paid by the IPPs to associated company-Rs. 414.547 million
According to Section 150 of the Income Tax Ordinance 2001, “every
person paying a dividend shall deduct tax from the gross amount of the dividend
paid at the rate specified in Division I of Part III of the First Schedule to the
Ordinance. Further, as per NEPRA amended decision dated 14th December 2009,
vide Para 10.1 pass through item shall be payable by the power purchaser to the
company (IPP) on the basis of the actual costs reasonable incurred by the
company to satisfy the requirements of the power purchase agreement or to the
extent that the company is obligated pursuant to the Laws of Pakistan to make
payment for such pass through items”.
M/s Atlas Power Limited NTN (2878470) assessed under the jurisdiction
of the Chief Commissioner Inland Revenue, Large Taxpayers Unit, Lahore, paid
dividend amounting to Rs. 1,777,500,000 vide statement of cash flow as on
30.06.2016 to its share holders M/s Shirazi Investments (Private) Limited, a
company holding 401 million ordinary shares of Rs.10 each during the period
under consideration. The taxpayer while making payment of dividend deducted
withholding tax on dividend accumulating to Rs. 414,547,000 and claimed it
pass through item which is inadmissible as withholding tax is not actual costs
reasonably incurred by the company, rather it is a tax which is payable by the
investor M/s Shiraze Investments (Pvt) Limited and never payable by the
taxpayer i.e. IPP. The incorrect pass through of withholding tax by IIP to
WAPDA accumulating to Rs. 414.547 million is not justifiable as per terms of
power purchase agreement, as the said agreement covers only such payment
which are reasonably incurred by the IPPs.
Management Response

The Audit findings were sent to the Department during audit in April
2017 but no reply was furnished by the Department.

DAC Decision

DAC meeting was not convened due to non submission of working

papers by the Department.

10
Audit Recommendations
 Non-recovery of tax may be justified.
 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
1.10 Short deduction of tax amounting to Rs. 79.602 million under Section
153 (1) (b) of the Income Tax Ordinance 2001
According to Section 153 (1) (b) of the Income Tax Ordinance, 2001
“every prescribed person making a payment in full or part including a payment
by way of advance to a resident person or permanent establishment in Pakistan
of a non resident person for rendering of providing of services shall at the time of
making of payment, deduct tax from the gross amount payable at the rate
specified in Division III of the First Schedule”.
M/s Altern Energy Limited NTN-2152266 assessed under the jurisdiction
of Large Taxpayers Unit, Lahore made payment on account of “fee for
operations and maintenance contracts” amounting to Rs. 1,030,222,000 for Tax
Years 2016, vide note 21 to the audited accounts as on 30.06.2016. The tax
deductible @ 8% on such payment was Rs. 82,417,760 whereas, taxpayer
deducted tax amounting to Rs. 2,815,051 only under Section 153 (1) (b) of the
Income Tax Ordinance, 2001. This resulted in short levy of tax on services
amounting to Rs. 79.602 million.
Management Response

The Audit findings were sent to the Department during audit in April
2017 but no reply was furnished by the Department.

DAC Decision

DAC meeting was not convened due to non submission of working

papers by the Department.
Audit Recommendations
 Non-recovery of tax may be justified.

11
  Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
1.11 Excess assessment of refund amounting to Rs. 28.818 million due to
excess claim of tax deduction u/s 151 of the Income Tax Ordinance
2001
As per Section 151 of the Income Tax Ordinance 2001, “where a banking
company or financial institution pays any profit on a debt, being an account or
deposit maintained with the company or institution; the payer of the profit shall
deduct tax at the rate specified in Division IA of Part III of the First Schedule
from the gross amount of the yield or profit paid as reduced by the amount of
Zakat, if any, paid by the recipient under the Zakat and Ushr Ordinance, 1980
(XVII of 1980), at the time the profit is paid to the recipient”.
M/s Uch-II Power (Pvt) Ltd. assessed under the jurisdiction of Large
Taxpayers Unit, Islamabad derived income from power generation and claimed
refund on account of profit on debt amounting to Rs. 34,161,931 for Tax Year
2015. Scrutiny of audited accounts revealed that the taxpayer declared income
amounting to Rs.53,439,000 on account profit on debt vide note 22 to the audited
accounts filed for the Tax Year 2015, where tax deductable @ 10% accumulates
to Rs. 5,343,900 only. As such, excess tax deduction was claimed by the
taxpayer amounting to Rs. 28.818 million.
Management Response
The Department replied that Show Cause Notice has been issued to the
taxpayer but assessment proceedings were not yet finalized.
DAC Decision
DAC directed the Department to get its stance verified from Audit and
report final compliance by 20.02.2018.
Audit Recommendations
 Non-recovery of tax may be justified.
 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.

12
  Loss of government revenue be made good under intimation to Audit.
(AO No.01)
1.12 Loss of revenue/income escaped assessment due to incorrect
apportionment of taxable income - Rs. 180.651 million
According to Section 67 (1) of the Income Tax Ordinance 2001, “where
an expenditure relate to the derivation of more than one head of income; or
derivation of income comprising of taxable income and any class of income to
which sub-Sections (4) and (5) of Section 4 apply, or the derivation of income
chargeable to tax under a head of income and to some other purpose, the
expenditure shall be apportioned on any reasonable basis taking account of the
relative nature and size of the activities to which the amount relates”.
M/s Hub Power Company Limited, (NTN-0800595) assessed under the
jurisdiction of the Large Taxpayers Unit, Islamabad, derived income from
generation and transmission of electricity which is exempt from tax and also
earned other income which is chargeable to tax under the normal tax regime
during tax year 2015 and 2016. Audit observed that taxpayer incorrectly
apportion interest income and gain on sale of assets towards exempt income. As
such, so much of the income which has been apportioned towards exempt
income escaped assessment with consequent loss of revenue amounting to
Rs. 180.651 million.
Management Response
The Department replied that Show Cause Notice has been issued to the
taxpayer but assessment proceedings were not yet finalized.
DAC Decision
DAC directed the Department to finalize the assessment proceedings and
report final compliance by 20.02.2018.
Audit Recommendations
 Non-recovery of tax may be justified.
 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
[Annexure-H]

13
2. Indirect Taxes
2.1 Non-recovery of Federal Excise Duty on franchised services under
Section 3 of Federal Excise Act, 2005 - Rs. 542.308 million

According to Section 3 of Federal Excise Act, 2005, “there shall be

levied and collected in such manner as may be prescribed duties of excise on,
goods produced or manufactured in Pakistan; goods imported into Pakistan; and
on such goods as the Federal Government may specify, by notification in the
official Gazette, except the goods and services specified in the First Schedule.”
Further as per sub Section (12a) of Section 2 “franchise” means an
authority given by a franchiser under which the franchisee is contractually or
otherwise granted any right to produce, manufacture, sell or trade in or do any
other business activity in respect of goods or to provide service or to undertake
any process identified with franchiser against a fee or consideration including
royalty or technical fee, whether or not a trade mark, service mark ,trade name,
logo, brand name or any such representation or symbol, as the case may be, is
involved;”
Four taxpayers registered with the two field offices of FBR paid
Operations & Management Fee (O&M), as evident from the Audit accounts filed
with the Income Tax returns. It was noticed that Federal Excise Duty on payment
of said expense was not levied and recovered by the Department. This resulted in
loss of Rs. 542.308 million.
Management Response
The Department replied that Show Cause Notices have been issued but
adjudication proceedings were yet not finalized.

DAC Decision
DAC meeting was not convened due to non submission of working
papers by the Department.
Audit Recommendations
 Non-recovery of tax may be justified.

14
  Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
[Annexure-I]
2.2 Inadmissible adjustment of input tax on sales/supplies which are not
attributable towards taxable supplies - Rs. 1,253.363 million
According to Rule 13 [3] of Sales Tax Special Procedure Rules, 2007 for
IPPs read with Section 8 [2] of the Sales Tax Act 1990, “the value of supply
shall be the amount received by such IPP or, as the case may be, on account of
Energy Purchase Price only and any amount in excess of Energy Purchase Price
received on account of Capacity Purchase Price, Energy Price Premium, Excess
Bonus, Supplemental Charges, etc., shall not be deemed as a component of the
value of supply; if a registered person deals in taxable and non-taxable supplies,
he can reclaim only such proportion of the input tax as is attributable to taxable
supplies in such manner as may be specified by the Board”.
Five taxpayers registered with the two field offices of FBR claimed credit
of input tax paid on purchase against sales which are not attributable towards
taxable supplies [energy purchase price] without making apportionment of input
tax as required under the law. The lapse resulted in inadmissible adjustment of
input tax of Rs. 1,253.362 million.
Management Response
The Department replied that Show Cause Notices have been issued but
adjudication proceedings were yet not finalized.
DAC Decision
DAC meeting was not convened due to non submission of working
papers by the Department.
Audit Recommendations
 Non-recovery of tax may be justified.
 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
[Annexure-J]

15
2.3 Short realization of Sales Tax due to Inadmissible adjustment of
Input Tax - Rs 10.580 million
According to Section 8(1) of the Sales Tax Act 1990, read with SRO
490(I)/2004 dated 12th June 2004, as amended by SRO 450(I)/2013 dated 27th
May, 2013, “a registered person shall not be entitled to reclaim or deduct input
tax paid on the goods or services used or to be used for any purpose other than
for taxable supplies made or to be made by him, goods used in, or permanently
attached to, immoveable property, such as building and construction materials,
paints, electrical and sanitary fittings, pipes, wires and cables, vehicles, parts of
such vehicles, electrical and gas appliances but excluding such goods acquired
for sale or re-sale or for direct use in the production or manufacture of taxable
goods”.
Eight taxpayers registered with two field offices of FBR claimed credit of
input tax paid on purchase of furniture, cable and wires etc. items which were
not allowed as per law ibid. Neither the system checked such inadmissible
adjustment while filing of Sales Tax return nor did the Department detect the
irregularity. The lapse resulted in short-realization of tax due to inadmissible
adjustment of Input Tax of Rs. 10.580 million.
Management Response

The Department replied that Show Cause Notices have been issued but
adjudication proceedings were yet not finalized.

DAC Decision

DAC meeting was not convened due to non submission of working

papers by the Department.

Audit Recommendations

 Non-recovery of tax may be justified.

 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
[Annexure-K]

16
2.4 Short realization of Sales Tax due to Suppression of sales amounting
to Rs. 199.102 million
According to Section 3(1) of the Sales Tax Act 1990, “subject to the
provisions of this Act, there shall be charged, levied and paid a tax known as
Sales Tax at the rate of seventeen percent of value of taxable supplies made by
a registered person in the course or furtherance of any taxable activity carried on
by him”.
Five taxpayers falling under the jurisdiction of Large Taxpayers Unit
Lahore revealed that the registered persons made taxable supply of electricity to
NTDC/WAPDA for the period 2014-16. Comparison of energy sales shown in
final accounts and Sales Tax returns revealed that taxpayers shown more sales in
final accounts/Income Tax returns than in the Sales Tax returns meaning there by
that the taxpayers suppressed sales in Sales Tax returns. The lapse resulted in
short realization of tax due to suppression of sales Rs 199.102 million.
Management Response

The Department replied that Show Cause Notices have been issued but
adjudication proceedings were yet not finalized.

DAC Decision
DAC meeting was not convened due to non submission of working
papers by the Department.
Audit Recommendations

 Non-recovery of tax may be justified.

 Internal controls may be strengthened to avoid recurrence of such
irregularities in future.
 Loss of government revenue be made good under intimation to Audit.
[Annexure-L]

17
ANNEXURES
 Annexure-A
(Para 1.1)
Statement showing loss of revenue due to incorrect exemption claimed by
Power Generation Companies Rs. 1,017.210 million

Tax payable
Turnover
under
S. Name of taxpayer Tax “capacity Observation
Section 113
No. & NTN Year revenue only” No.
@ 1%
(Rs.)
(Rs.)
LTU Islamabad

1 TNB Liberty Power 2016 2,018,615,000 20,186,150 02

Limited (1424775)

2 -Do- 2015 4,251,280,000 42,512,800 02

3 Halmore Power 2016 4,183,002,662 41,830,026 03

Generation
Company (2678422)

4 -Do- 2015 4,619,236,709 46,192,367 03

5 Attock Gen Limited 2016 3,034,882,000 30,348,820 04

(2904414)

6 -Do- 2015 3,128,168,000 31,281,680 04

7 Fauji Kabirwala 2016 1,261,977,522 12,619,775 08

Power Company
Limited (0787372)

8 -Do- 2015 1,217,228,287 12,172,282 08

9 Foundation Power 2016 3,844,804,595 38,448,045 11

Company (Daharki)
Limited (2803618)

10 -Do- 2015 4,007,831,238 40,078,312 11

11 Rousch (Pakistan) 2016 6,390,552,000 63,905,520 12

Power Limited
(0819027)

12 -Do- 2015 6,329,156,000 63,291,560 12

19
13 Saba Power 2016 1,340,101,000 134,010,100 20
Company (Pvt)
Limited (0657142)

14 -Do- 2015 1,474,680,000 147,468,000 20

15 Orient Power 2016 3,459,393,000 34,593,930 21

Company (Pvt)
Limited (1869185)

16 -Do- 2015 3,552,179,000 35,521,790 21

LTU Lahore

17 M/s Altern Energy 2016 345,906,000 3,459,060 05

Limited (2152266)

18 -Do- 2015 346,472,000 3,464,720 05

19 M/s Atlas Power 2016 4,593,330,000 45,933,300 09

Limited NTN
(2878470)

20 -Do- 2015 4,833,849,000 48,338,490 09

21 M/s Lalpir Power 2016 3,939,104,000 39,391,040 17

Limited NTN-
(0786188)

22 M/s Nishat Chunian 2016 4,342,233,008 43,422,330 18

Power Limited
NTN-(2958445)

23 M/s Pakgen Power 2016 3,873,997,000 38,739,970 22

Limited. NTN-
0786171

Total 1,017,210,067

20
 Annexure-B
(Para 1.2)
Statement showing short levy of tax on dividend income under Section 5 of
the Income Tax Ordinance, 2001 - Rs. 156.962 million

Amount
S. Name of Name of Tax Observation
NTN involved
No. formation taxpayer Year No.
(Rs.)
1 LTU M/s Altern 2152266 2015 61,788,000 02
Lahore Energy Limited
2 -do- -do- 2016 95,173,900 06

Total 156,961,900

Annexure-C
(Para 1.3)

Statement showing non/short deduction of tax on dividend under Section

150 of the Income Tax Ordinance, 2001 - Rs. 1,647.493 million

Amount
S. Name of Name of Tax Observation
NTN involved
No. formation taxpayer Year No.
(Rs.)
1 LTU M/s Altern 2152266 2015 15,854,775 04
Lahore Energy Limited

2 -do- M/s Atlas 2878470 2016 95,718750 11

Power Limited

3 -do- M/s Kot Addu 0708010 2016 518,264,104 13

Power
Company
Limited

4 -do- M/s Pak Gen 0786171 2016 6,292,046 21

Power Limited

Total 636,129,675

21
 Annexure-D
(Para 1.4)

Statement showing loss of revenue due to non deduction of tax on late

payment surcharge under Section 151 - Rs. 665.347 million

Amount of
Tax
S. Name of Amount paid Tax tax short Observation
leviable
No. taxpayer (Rs.) Year levied No
@
(Rs)
LTU Islamabad
1 M/s Rousch 209,827,000 2016 10% 41,853,900 13
2 (Pakistan) 1,256,000 2015 10% 125,600
Power
Limited
NTN-
(0819027)
3 M/s 131,027,023 2016 10% 13,102,702 14
4 Foundation 177,581,110 2015 10% 17,758,111
Power
Company
(Daharki)
Limited
NTN-
(2803618)
5 M/s TNB 50,692,000 2016 10% 5,069,200 18
6 Liberty 778,672,000 2015 10% 77,867,200
7 Power 7,645,000 2016 10% 764,500 19
8 Limited 51,351,000 2015 10% 5,135,100
9 NTN- 3,238,504,000 2014 10% 323,850,400 31
(1424775)
10 M/s Attock 201,733,000 2016 10% 20,173,300 22
11 Gen Limited 221,839,000 2015 10% 22,183,900
NTN-
2904414
12 M/s 489,473,740, 2015 10% 48,947,374 25
Foundation
Power

22
 Company
(Daharki)
Limited
NTN-
(2904414)
13 M/s Halmore 146,928,033 2016 10% 14,692,803 26
Power
Generation
Company
NTN-
(2678422)
LTU Lahore
14 M/s Altern 291,421,000 2015 10% 29,142,100 03
Energy
Limited NTN
(2152266)

15 M/s Kot 261,218,000 2015 10% 26,121,800 15

Addu Power
Company,
Limited
bearing NTN-
0708010
16 -do- 185,589,000 2016 10% 18,558,900 15

Total 665,346,890

23
 Annexure-E
(Para 1.5)

Statement showing loss of revenue due to non taxation of recouped

expenditure under Section 70 of the Income Tax Ordinance, 2001
- Rs. 597.137 million

Amount of
Amount Tax
S. Name of Tax tax short Observation
received leviable
No. Taxpayer Year levied No
(Rs.) @
(Rs.)
LTU Islamabad
1 M/s Rousch 418,539,000 2016 32% 133,932,480 10
(Pakistan)
Power Limited
NTN-(0819027)
2 M/s TNB 484,054,000 2016 32% 154,897,280 30
Liberty Power
Limited NTN-
(1424775)
LTU Lahore

3 M/s Lalpir 2,427,000 2016 32% 776,640 16

Power Limited
NTN-(0786188)

4 -do- 11,033,000 2015 32% 3,530,560 16

5 M/s Pak Gen 950,000,000 2016 32% 304,000,000 20

Power Limited
NTN-(0786171)

Total 597,136,960

24
 Annexure-F
(Para 1.6)

Statement showing potential tax effect/claim of inadmissible expenses

- Rs. 1,973.689 million

Amount
S. Name of Name of Tax Observation
NTN involved
No. formation taxpayer Year No.
(Rs.)
1 LTU M/s TNB 1424775 2015 1,828,119,480 17
Islamabad Liberty
Power
Limited,
2 -do- -do- 2016 142,148,490
3 LTU M/s Altern 2152266 2016 3,421,440 07
Lahore Energy
Limited
Total 1,973,689,410

Annexure-G
(Para 1.7)

Statement showing loss of revenue due to non taxation of income from other
sources under Section 39 of the Income Tax Ordinance, 2001
- Rs. 1,117.563 million

Amount
Tax Observation
S. No. Name of taxpayer NTN involved
Year No.
(Rs.)
LTU Islamabad
1 M/s Attock Gen 2904414 2016 39,388,480 27
Limited
2 -do- 2015 47,045,790
3 -do- 2016 98,296,960

4 -do- 2015 164,827,080

5 M/s Fauji 0787372 2016 29,016,377 29

Kabirwala Power
Company Limited

25
 6 -do- 2015 42,438,804

7 -do- 2016 4,252,964

8 -do- 2015 2,289,578

9 M/s FFC Energy 3546089 2015 37,051,990 28

Limited
10 M/s TNB Liberty 1424775 2016 71,790,400 32
Power Limited,
11 -do- 2015 240,772,950

12 M/s Halmore 2678422 2016 44,555,373 41

Power Generation
Company Limited
13 -do- 2015 65,647,622

14 M/s Orient Power 1869185 2016 72,271,040 42

Company (Pvt)
Limited
15 -do- 2015 42,652,830

LTU Lahore

16 M/s Altern Energy 2152266 2016 3,306,240 19

Limited

17 M/s Pakgen Power 0786171 2016 31,217,600 24

Limited

18 M/s Lalpir Power 0786188 2014 80,740,820 26

Limited

Total 1,117,562,898

26
 Annexure-H
(Para 1.12)

Statement showing loss of revenue/income escaped assessment due to

incorrect apportionment of taxable income Rs. 180.652 million

Description Amount Observation

(Rs.) No.
Profit on debt declared as per return of income for TAX 32,268,000 39
YEAR 2015 M/s Hub Power Company Limited, (NTN-
0800595)
Add accounting gains on sale of assets 2,654,000
Other income to be included in taxable income 34,922,000
Income incorrectly apportioned towards exempt income 23,975,545
Add accounting gain on sale of assets incorrectly 2,654,000
apportioned
Total other income which escaped assessment 26,629,545
Tax leviable @ 33% / Loss of revenue 8,787,750

Description Amount Observation

(Rs.) No.
Other income declared as per return of including 1,444,497,387 40
profit on debt, accounting gain on sale of assets and
others for Tax Year 2016 M/s Hub Power Company
Limited, (NTN-0800595)
Less dividend to be taxed as separate block of income 904,015,437
as declared by the taxpayer u/s 115 (4)
Balance income to be assessed as other income 540,481,950
Less income offered for tax due to incorrect 3,406,688
apportionment towards exempt income
Balance taxable income to be assessed u/s 39 537,075,262
Tax leviable @ 32% / Loss of revenue 171,864,083

Tax Year 2015 Loss of revenue 8,787,750

Tax Year 2016 Loss of revenue 171,864,083

Total 180,651,833

27
 Annexure-I
(Para 2.1)
Statement showing non recovery of Federal Excise Duty on franchised
services under Section 3 of Federal Excise Act, 2005 - Rs. 542.309 million

Expenses FED
Name of incurred on payable
S. Tax Observation
taxpayer & account of @ 10%
No. period No.
NTN services
(Rs.) (Rs.)
LTU Islamabad
1 M/s The Hub 2014-15 1,301,217,000 130,121,700 05
Power Company
Limited. NTN-
0800595
2 M/s Uch Power-I 2014-15 601,258,000 60,125,800 15
(Pvt) Limited,
NTN- 0657166
3 -do- 2015-16 650,047,000 65,004,700
4 M/s Uch Power- 2014-15 182,564,000 18,256,400 16
II (Pvt) Limited,
NTN- (3239640)
5 -do- 2015-16 252,074,000 25,207,400
LTU Lahore
6 M/s Atlas Power 2014-15 1,583,563,000 158,356,300 10
Limited NTN
(2878470)
7 -do- 2015-16 852,364,000 85,236,400
Total 542,308,700

28
 Annexure-J
(Para 2.2)
Statement showing inadmissible adjustment of Input Tax
- Rs. 1,253.363 million

Inadmissible
Observation
S. No. Name of taxpayer NTN Input Tax
No.
(Rs.)
LTU Islamabad

M/s Halmore Power

1 2678422 762,487,074 34
Generation Co. Ltd.
M/s Foundation Power
2 2803618 194,829,391 35
Co. Ltd.

3 M/s Attock Gen Limited 2904414 198,593,556 38

LTU Lahore
M/s Altern Energy
4 Limited 2152266 223,917 34

M/s Kot Addu Power

5 Company Limited 0708010 97,228,951 30

Total 1,253,362,889

29
 Annexure-K
(Para 2.3)

Statement showing inadmissible Input Tax adjustment - Rs.10.580 million

Inadmissible
Observation
S. No. Name of taxpayer NTN Input Tax
No.
(Rs.)
LTU Islamabad
1 The Hub Power 0800595-6 1,758,339 33
Company Limited
2 FFC Energy Limited 3546089-0 251,404 36

3 Saba Power Company 366,045 37

private Ltd 0657142-5

LTU Lahore
4 Kohinoor Energy Ltd 0656788-6 5,036,095 27

5 Atlas Power Limited 2878470-7 137,193 35

6 Kot Addu Power Co. 0708010-7 2,108,396 29

7 Lalpir Power Ltd. 0786188-5 873,765 36

8 Nishat Power Ltd. 2958448-5 48,870 37

Total 10,580,107

30
 Annexure-L
(Para 2.4)

Statement showing suppression of sales - Rs. 199.102 million

Inadmissible
Observation
S. No. Name of taxpayer NTN Input Tax
No.
(Rs.)
1 M/s Kohinoor Energy 0656788-8 19,053,210 28
Limited
2 M/s Lalpir Power 0786188-5 36,012,195 31
Limited
3 M/s Nishat Chunian 2958445-7 43,451,994 32
Limited
4 M/s Pakgen Power 0786171-7 64,864,174 33
Limited
5 M/s Atlas Power 2878470-7 18,487,960 38
Limited
6 M/s Nishat Power 2958448-5 17,232,599 39
Limited
Total 199,102,131

31