This is a technical amendment to facilitate the addition of new clauses.

Clause (q) disallows 10% of expenditure attributable to purchases from persons who do not possess an NTN (National Tax Number).

• In the case of agricultural produce, this applies only if purchased through a middleman.
• The FBR may exempt certain persons or classes via official notification.

50% of expenditure shall be disallowed if payment of more than Rs. 200,000 is made in cash or non-digital means against a single invoice, regardless of the number of transactions in that invoice.

The intent is to encourage digital payments and documentation of the economy.

• Cash-based businesses will face compliance issues.
• Digital transactions will become necessary.
• Audit risk may increase significantly.

Example: A textile manufacturer sells goods and receives Rs. 300,000 in cash under a single invoice. Clause (s) will apply, and 50% of the related expense will be disallowed.

Critical View: In a manufacturing unit, expenses are pooled and not allocated invoice-wise (e.g., utilities, salaries, raw materials). Therefore, determining the cost attributable to a single invoice is impractical. Even FBR officers will be unable to determine correct disallowances without arbitrary estimations.

This clause is vague, operationally difficult, and prone to legal challenges.