09-26-2011, 03:58 PM
I have not gone through the relevant SROs. Just sharing general legal position. We have to apply such law as was in force at the time of its application. So until October SRO 603 was in force and you must comply with it.
Unless there is some express provision that dispense with the operation of SRO 603 from the date of its issuance, or later SRO is made duly retrospective in its operation, operation of SRO 603 would not stop.
However, in executive field, apart from legal situation, practice and policy also counts. Some times FBR as an undeclared policy dispense with the strict enforcement of some rule or provision. For example s.164 requires production of copies of challans along with the deduction certificate but in practice only certificate is being issued. Further, accountants, lawyers are required to maintain certain books of accounts however in practice FBR has just avoided to enforce this rule.
So, you may check with the peers involve in similar matters or from someone in FBR about how serious is FBR in monitoring compliance of SRO 603 for threee months (July to September 2009) regarding categories specified by you.
Unless there is some express provision that dispense with the operation of SRO 603 from the date of its issuance, or later SRO is made duly retrospective in its operation, operation of SRO 603 would not stop.
However, in executive field, apart from legal situation, practice and policy also counts. Some times FBR as an undeclared policy dispense with the strict enforcement of some rule or provision. For example s.164 requires production of copies of challans along with the deduction certificate but in practice only certificate is being issued. Further, accountants, lawyers are required to maintain certain books of accounts however in practice FBR has just avoided to enforce this rule.
So, you may check with the peers involve in similar matters or from someone in FBR about how serious is FBR in monitoring compliance of SRO 603 for threee months (July to September 2009) regarding categories specified by you.
