CFAP – 05Advanced Taxation[Trainer: Fawad Hassan – ACA]

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Dos and Don’ts1. Referring too many books2. Optimize Memory Utilization3. Improvise Retrieval Ability4. First understand “The Big Picture” – Taxation Framework/Mechanism5. Then “Zoom In” for details

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Expectations1. Understanding of Taxation Laws2. Application of Understanding

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SyllabusGrid Weighting Last 8 years’ Average

Income Tax 50-55 59Sales Tax 30-35 28Faderal Excise Law 10-15 12Professional values, ethics and attitude 5-10 1Details

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Revenue Collection

Exchequ

er(Fede

ral Conso

lidated Fu

nd)

Inflows

Outflows

Income TaxCVTWWF

Sales TaxFED

Custom Duty

DeficitLoans & GrantsCapital Receipts

Revenue Receipts

Non Tax Receipts

Tax Receipts

Other Taxes

FBR TaxesIndirect Tax

Direct Tax

External Receipts

Internal Receipts

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Income Tax6 Basic Questions1. Tax Year

2. Type of Person3. Residential Status4. Tax Regime5. Geographical Source of Income6. Apportionment of Deductions

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1. Tax Year [S-74]Time Bracket

Normal Tax Year (NTY)

End date is other than 30th JuneEnd date is 30thJune

Time period of less than 12 monthsTime period of 12 months

Transitional Tax Year (TTY)Special Tax Year (STY)Denoted by Calendar Year relevant to NTY in which Year end falls

Denoted by Calendar Year in which NTY endsDenoted by Calendar Year relevant to NTY in which Year end falls

FBR has authority to prescribe STYTTY occurs because of change in TY from NTY to STY or vice versa

TTY is the period between TY end date of last tax year and commencement date of next TY

Industry Special Tax Year SRO RefSugar Manufacturing 1st October - 30th September 134(R)/68,July 31,1968

Rice Exporter 1st January - 31st December 367(I) /74,January 14,1974Insurance 1st January - 31st December 878 (I) /95,August 30,1995

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Change in Tax YearNTY STY STY - 1 STY - 2STY NTY

Tax Payer will give an application in writing to Commissioner of Income Tax (CIT)CIT is convinced that compelling need exists

Not ConvincedGive tax payer an opportunity of being heard in person

Not Convinced1) issue rejection orders2) record reasons of rejection in order

Tax Payer may file review application to FBR & decision of FBR shall be final

Grant Permission through an order in writing

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Tax Year PracticeDetermine the tax year in respect of each accounting periods mentioned below:

a) 1.09.2015 to 31.08.2016b) 01.04.2016 to 30.06.2016c) 1.01.2016 to 31.12.2016d) 1.04.2016 to 31.03.2017e) 1.05.2016 to 30.04.2017f) 1.07.2016 to 30.06.2017

STYTTYSTYSTYSTYNTY

TY 2017TY 2016TY 2017TY 2017TY 2017TY 2017

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2. Type of Persona) Tax Payer [S-2(66)]b) Person [S-80]

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a) Tax Payer [S-2(66)]Any person or representative of person who;i. Derives an amount chargeable to taxii. Is required to collect/deduct taxiii. is required to furnish return of incomeiv. is required to pay taxunder Income Tax Ordinance 2001

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b) Person [S-80]Following shall be treated as person;i. Individualii. Company formed in Pakistan or elsewhereiii. AOP formed in Pakistan or elsewhereiv. Federal governmentv. Foreign governmentvi. Political subdivision of foreign governmentvii. Public International Organization

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Company means followingi. Company as defined in Companies Ordinance 1984ii. Body Corporate formed by or under any law in force in Pakistaniii. Modarabaiv. body incorporated by or under any law of country outside Pakistan relating to incorporation of companiesv. cooperative society, finance society or any other societyvi. non-profit organizationvii. Trustviii. foreign association declared by FBR to be a companyix. Provincial Governmentx. Local Governmentxi. Small company as defined in Section -2

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Association of Persons includes followingi. Firm (means relation between persons who have agreed to share profits of business carried on by all or any one of them acting for all)ii. Hindu Undivided Familyiii. Artificial Juridical Personiv. Any body of persons formed under foreign lawAnd does not include “Company”

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3. Residential Statusa) Resident Individualb) Resident Companyc) Resident AOP

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a) Resident Individual [S-82]i. Not based on Nationalityii. Based on Physical Presence in Pakistaniii. Government servant posted abroad will be treated as resident, irrespective of his physical stay in Pakistaniv. Counting of days shall be made in accordance with Rule-14 of Income Tax Rules, 2002

0 – 182 days 183 days or moreNon Resident Resident

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Rule-14 of Income Tax Rules, 2002Days not to be counted Days to be counted

i. Day or part of day in Pakistan solely by reason of being in transit between two different places outside PakistanPart of a day shall be counted as a whole day in following cases;i. Day of arrival in Pakistanii. Day of departure from Pakistaniii. Public Holidayiv. Leave, including sick leavev. Holiday spent in Pakistan before, during or after activity in Pakistanvi. Day when activity was interrupted due to Strike, lockout, delay in receipt of supplies

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b) Resident Company [S-83]i. Company incorporated in Pakistanii. Provincial Governmentiii. Local Governmentiv. Company incorporated outside Pakistan

ResidentNo further condition required

Residentif, Control and Management of affairs situated wholly in Pakistan at any time in a Tax Year

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b) Resident AOP [S-84]Resident if, Control and Management of affairs situated wholly or partly in Pakistan at any time in a Tax Year

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Residential Status Practicei. Mr. Raza is working as Director Operations in the Ministry of Tourism. On 15 July 2016 he was posted to Pakistan Embassy inItaly for two years.ii. Anderson LLC was incorporated as limited liability Company in UK. The control and management of its affairs was situatedwholly in Pakistan. However, with effect from 01 November 2016, the entire management and control was shifted to UK.iii. On 01 February 2017, Mr. Sameel was sent to Pakistan by his UK based company to work on a special project. He left Pakistanon 23 August 2017.iv. BBL is a non-listed public company incorporated under the Companies Ordinance, 1984. All the shareholders of the companyare individuals. The control and management of affairs of the company during the year was outside Pakistan.v. Mr. Salman a property dealer in USA came to Pakistan on 01 February 2016. During his stay upto 02 August 2016 in Pakistan, he remained in Peshawar upto 30 June 2016 and thereafter till his departure from Pakistan, in Quetta. Assume that Commissioner has granted him permission to use calendar year as special tax year. vi. Peshawar LLC (PLLC) was incorporated as a limited liability company in UAE. PLLC has 5 directors out of which 2 are involved in management, the rest of them were situated in UAE. The 2 directors control the affairs of the company from Pakistan.

Resident

Resident

Non ResidentResident

Resident

Resident

Federal Govt Employee

Control & Mngt in wholly in Pak any time in TYStay less than 180 days

Company incorporated in PakTotal stay 184 days

Control & Mngt in wholly in Pak any time in TY

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4. Tax RegimesHeads of IncomeSalary Income

Property IncomeBusiness IncomeCapital GainsIncome from Other SourcesTotal Income- Deductible AllowancesTaxable IncomeRate from 1st ScheduleTax Imposed/Chargeable- Tax CreditsTax Payable- Withholding Tax/Adv TaxIncome Tax Demand/Refund

Normal Tax Reg. Separate Block Final Tax Reg Minimum Tax Reg1010101010

10%

50

(2)

(10)

1

40

4(1)3

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5. Geographical Source of Incomea) Pakistan Source Income [S-2(40) & 101]b) Foreign Source Income [S-2(27) & 101(16)]

Resident Non ResidentPakistan Source Income Taxable TaxableForeign Source Income Taxable Not Taxable

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6. Apportionment of Deductions [S-67 & Rule 13]Apportionment of Deductions [S-67]Any expenditure/deduction/allowance that relates with following shall be apportioned on reasonable basis:a) derivation of income under more than one head of incomeb) derivation of taxable income and income under Final Tax Regimec) derivation of income under any head of income and for any other purpose

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6. Apportionment of Deductions [S-67 & Rule 13]Apportionment of Expenditures Deductions and Allowances [Rule-13]Clearly Allocable to an Income Not clearly Allocable to an Income

deductible/chargeable against that particular income Apportion on basis of following formula:Common Exp x Gross Receipts of a class of income/Gross Receipts of all classes of incomeClass of Income may include following:Salary IncomeIncome from PropertyIncome from Business (Speculative/Non Speculative)Capital GainsOther SourcesSeparate Block of IncomeExempt IncomeIncome under FTR

Pakistan Source IncomeForeign Source Income

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6. Apportionment of Deductions [Rule 13]a) Gross receipts are net of Sales Tax & Federal Excise Dutyb) Nature and source of each class of income shall be considered for allocationc) Above allocation shall be certified by CA or CMAd) In case accounts are not required to be audited then certificate shall be obtained for basis of allocation. The said certificate is required to be accepted by CIR who shall accept it only if variation in allocation from these rules is not more than 10%e) In certain transactions where net gains, brokerage, commission or other income is taken, than Gross Profits shall be taken as Gross Receipts

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a) Total Income [S-10]b) Taxable Income [S-9]c) Heads of Income [S-11]d) Tax on Taxable Income [S-4]

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Final Tax RegimeAdvance Tax Tax at SourceSection 169

[S-148] Imports[S-148A] Local Purchase of Cooking Oil & Vegetable Ghee[S-234A] CNG Stations

[S-151] Profit on debt[S-152] Payments to Non Residents[S-153] Payment of Goods, Services or Contracts[S-154] Exports[S-156] Prizes & Winnings[S-156A] Petroleum Products[S-233] Brokerage & Commission

[S-152A] Payment for Foreign Produced Commercials[S-236A] Advance Tax at the time of sale by Auction[S-236M] Bonus Shares issued by Companies Quoted on Stock Exchange[S-236N] Bonus Shares issued by Companies not Quoted on Stock Exchange[S-236Q] Payment to Residents for use of Machinery & Equipment[S-236S] Dividend in Specie

Others

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[S-148] ImportsFinal Tax Regime

• Collector of Customs shall collect ADVANCE TAX on imports @ 1st Schedule, Part-II at the time and in the manner, custom duty is paid• Above tax on Imports shall be :

Adjustable Tax in following cases:i. Import of Raw Material, Plant & Machinery, Equipment & Parts by Industrial Undertaking for its own useii. Import of Fertilizer by Manufacturer of Fertilizeriii. Import of Motor Vehicle in CBU condition by Manufacturer of Motor Vehiclesiv. Imports by Large Import Housev. Import of Foreign Produced Film for viewing and screening

Minimum Tax in following cases:i. Import of Edible Oil [including crude oil imported as raw material of manufacture of ghee or cooking oil]ii. Import of Packing Material

Final Tax in following cases:i. Import of ship by ship breakerii. Any other imports not mentioned earlier

• have paid-up capital of exceeding Rs.250 million;• have imports exceeding Rs.500 million;• own total assets exceeding Rs.350 million at the close of the TY;• is single object company;• maintain computerized records of imports and sale of goods;

• maintain a system for issuance of 100% cash receipts on sales;• present accounts for tax audit every year;• is registered under the Sales Tax Act, 1990 and• make sales of industrial raw material of manufacturer registered under the Sales Tax Act,1990

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[S-148A] Local Purchase of Cooking Oil or Vegetable GheeFinal Tax Regime

• Purchase of locally produced edible oil by Manufacturer of Cooking Oil or Vegetable Ghee shall be charged to tax at following rate:

2% of Purchase of locally produced edible oil • Above tax shall be final tax in respect of income accruing from locally produced edible oil

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[S-234A] CNG StationFinal Tax Regime

Person preparing Gas consumption bill

Charge tax @ 1st Sched, Part-III, Div-VIB

CNG StationBill

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[S-151] Profit on DebtFinal Tax Regime

Payer of POD Deduct tax @1st Sched, Part-III, Div-IA

Gross POD X- Zakat (X)

X• Account• Deposit• Certificate• Post Office Savings Account• Account• Deposit• Security issued by FG/PG/LG• Bond• Debenture• Certificate• Security• Instrument of any kind

of National Saving Scheme

with any Bank/Financial Institution

Issued by:Banking CoFinancial InstitutionCompany as defined in Co. Ord. 1984Body Corporate formed under any Law

To any Resident Person

To any Resident Person other than Financial Institution

Tax deduction shall not be made from Profit on Debt on Loan Agreement between borrower and Banking Company OR Financial InstitutionTax deducted under Section 151, shall be ADJUSTABLE against tax liability calculated under Section 7B, which will be calculated @ 1st Sched, Part-I, Div-IIIA on Gross Amount of Profit on DebtTax Liability under Section 7B, shall be Final TaxSection 7B is not applicable on Company, therefore Profit on Debt received by Company shall be taxed under Normal Tax Regime and tax deducted under section 151 shall be adjustable

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Not Applicable

FTR

Company

Tax Imposed Final Tax

NTR

Other CasesSection 7BCompany

Tax deducted at source

Section 151

Other Cases

Not Final Tax

Final Tax

Separate Taxation

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[S-152] Payments to Non ResidentsFinal Tax Regime

Every person while making payment to Non Resident for

Contract of[S-152(1A)]

Advertising Services by Non Resident Media Person relaying from outside Pakistan[S-152(1AAA)]

Insurance/Reinsurance Premium[S-152(1AA)]Advertisement Services rendered by TV Satellite Channel

ConstructionAssemblyInstallation in PakistanSupervisory activity in relation to above

premium should not be taxable income of PE of Non Resident

Deduct tax @ 1st Sched, Part-III, Div-IIFinal Tax

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[S-153] Payments for Goods, Services, ContractsFinal Tax Regime

Every Prescribed Person while making payment to Resident shall deduct tax @ 1st Sched, Part-III, Div-III for payment on account of following

Final Tax

Goods[S-153(1)(a)]

Other CasesListed CompanyCompany(being manufacturer) OthersSports PersonListed Company

Other than for sale of goods or services

Contracts[S-153(1)(c)]

Services[S-153(1)(b)]

Minimum TaxAdjustable Tax

Section 153(2): Exporter/Export House making payment to Resident Person OR PE of Non Resident for services of stitching, dying, printing, embroidery, washing, sizing and weaving shalldeduct tax @ 1st Sched, Part-III, Div-IV ResidentPENR

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[S-154] ExportsFinal Tax Regime

Indirect ExporterIndirect ExporterExporter Indenting Commission AgentDirect ExporterDirect ExporterFromDirect ExporterBankExport Processing Zone Authority

Authorized Dealer in ForexCollector of CustomsAuthorized Dealer in ForexBy

Payment of GoodsRealization of ProceedsTime of Export Realization of Forex ProceedsTime of ExportRealization of Forex

ProceedsTime[S-154(3B)][S-154(3)][S-154(3A)] [S-154(2)][S-154(3C)][S-154(1)]

Tax Collection

Rate 1st Sched, Part-III, Div-IV

Tax deducted/collected above shall be Final Tax, however, a person may opt not to be subject to final taxation. In case of availing such option, the above taxes shall be treated as minimum tax

In Land Back-to-back letter of credit Firm contract Forex Pak Rupees (i.e., exports without Form "E")

Sales made to Direct exporter through Export Proceeds Realizable inIndirect Exporter Direct Exporter

Yes NoExport of Goods by Industrial Undertaking in Export Processing Zone Commission on Exports

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[S-156] Prizes & WinningsFinal Tax Regime

Every person paying following shall deduct/collect tax @ 1st Sched, Part-III, Div-VI• Prize Bond• Winning from raffle• Lottery• Prize on a quize• Sale promotion prize by a company• Cross word puzzleTax shall be deducted from gross amount, in case of cash prize ORon fair market value, in case of prize in kindTax collected/deducted shall be Final Tax

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[S-156A] Petroleum ProductsFinal Tax Regime

Every person selling petroleum products to petrol pump operator shall deduct tax ondiscount or commission allowed to petrol pump operatorat the rate mentioned in 1st Sched, Part-III, Div-VIATax deducted shall be Final Tax

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[S-233] Brokerage & CommissionFinal Tax Regime

Principal AgentBrokerage / Commission

Faderal Govt,Provincial Govt,Local Govt,Company,AOP formed under any LawDeduct tax @1st Sched, Part-IV, Div-II

Tax deducted shall be Final TaxIf agent has retained any commission or brokerage from amount remitted to principal, such amount shall be deemed to have beenpaid by principal to the agent and tax thereon shall be collected by principal from agent.

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[S-152A] Payment for Foreign Produced CommercialsFinal Tax Regime

Any Person Non Resident Person

Tax deducted shall be Final Tax

Foreign produced commercial for advertisementOnTelevision or other media

Direct Payment

Through agent or intermediary

Deduct tax@ 20%From Gross amount

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[S-236A] Advance tax at time of sale by auctionFinal Tax RegimeSellerPurchaserPublic Auction Auction by Tender

Property attached/confiscatedORAwarding of any lease to any personIncluding:lease of the right to collect tollsfees or other leviesBelonging/Not belonging to:GovernmentLocal GovernmentAny authorityCompanyForeign association declared to be a company [S-80(2)(b)(vi)]Foreign contractor/consultant/consortiumCollector of CustomsCommissioner of Inland RevenueAny any other authority

Collect tax@1st Sched, Part-IV, Div-VIIIOn sale price

Final Tax

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[S-236M] Bonus Shares issued by Listed CompaniesFinal Tax Regime

ShareholderListed Company Bonus Shares

Withhold5%Bonus Shares Remaining Shares Pay tax@ 5%Share PriceDay-end price on 1st day of book closure

Collect tax with in 15 days of book closureTax not paid by shareholder

Deposit shares with CDC/prescribed entityDeposit shares with CDC/prescribed entityDispose off shares(pay to CIT - FBR)

Final Tax

Release Shares

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[S-236N] Bonus Shares issued by Un-quoted CompaniesFinal Tax Regime

ShareholderUn-listed Company Bonus Shares

Co. shall pay tax @ 5% Bonus Shares & collect it from Sh.holder Remaining Shares Pay tax@ 5%Share PriceDay-end price on 1st day of book closure

To be paid to FBR with in 15 days of book closureTax not paid by shareholderORShares not collected by shareholder

Company shall dispose off shares(pay to CIT - FBR)

Final Tax

Release Shares

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[S-236Q] Payment to Resident for use of Machinery & EquipmentFinal Tax RegimePrescribed PersonMaking payment to Resident Person

For use/right to useIndustrial/commercial/scientific equipment On account of RENT of machinery

Deduct tax on Gross Amount

1st Sched, Part-IV, Div-XXIII

Final Tax

Prescribed Person has same meaning as defined in Section 153(7)Machinery leased by:- Leasing Co.- Investment bank- Modaraba- Scheduled bank- Development finance Inst.

Agriculture MachineryThis section not applicable on following:

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Separate BlockSeparate Taxation Separate Block

Section 8 [S-5] Tax on Dividends[S-5A] Tax on Undistributed Reserves[S-5AA] Tax on Investment in Sukuks[S-6] Tax on certain payments to Non Residents[S-7] Tax on shipping and air transport income of a non-resident person[S-7A] Tax on shipping of Resident Person[S-7B] Tax on Profit on Debt[S-7C] Tax on Builders[S-7D] Tax on Developers

• To be discussed in relevant Head of Income

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DividendSeparate Block

Company Shareholder

Deduct tax on gross amount @ 1st Sched, Part-III, Div-I

Cash Dividend[S-150] Dividend in specie[S-236S]

Tax deducted will be Adjustable

Pay tax on gross amount @ 1st Sched, Part-I, Div-III

Tax Imposed will be Final Tax[S-5]

Shareholder shall pay Final Tax after adjustment of tax deducted at source

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[S-5A] Undistributed Reserves of Public CompanySeparate Block

Public Company(Other than Scheduled Bank or Modaraba)

50% or more shares held by FG Electric Power Generation Company exempt under 2nd Schedule, Part-I, Clause 132Cash Dividend is paid upto Cash Dividend is paid lower than the limit No Cash dividend paid

40% of Profit after taxOR50% of paid up capitalwhich ever is lessUndistributed Reserves X- Paid up capital (X)

XTreated as Deemed Income

Taxable @ 10%Final Tax on Deemed Income

This section not applicable Includes:• Revenue Reserves• Reserves Created out of profitsDoes not include:• Capital Reserves• Share Premium• Reserves required to be created under any law

Cash dividend must be distributed within 6 months from end of tax year

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Return on SukukSeparate Block

Special Purpose Vehicle Sukuk Holder

Deduct tax on gross amount @ 1st Sched, Part-III, Div-IB

Return on Sukuk[S-150A]

Tax deducted will be Adjustable

Pay tax on gross amount @ 1st Sched, Part-I, Div-IIIB

Tax Imposed will be Final Tax[S-5AA]

Receiver of return shall pay Final Tax after adjustment of tax deducted at source

3rd Pak Int Sukuk Co

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Special Purpose Vehicle

WapdaWapdaFirst SukukCompany Ltd

SukukHolder

Sukuk Certificate

Funds for Purchase of Turbines FundsTitle to Turbines

Lease TurbinesLease Rental Return to Sukuk Holder

Pay Exercise PriceGet Title of Turbines

Redeem Sukuk

Return SukukPurchase Turbines

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Payments to Non ResidentsSeparate BlockPayment to Non Residentfor Pakistan SourceRoyalty OR FFTS Non-Resident

Deduct tax on gross amount @ 1st Sched, Part-I, Div-IV

Payment to Non Resident[S-152(1)]

Tax deducted will be Adjustable

Pay tax on gross amount @ 1st Sched, Part-I, Div-IV

Tax Imposed will be Final Tax[S-6]

This section shall not apply on following:1. Royalty: where property or right giving rise to royalty is effectively connected with PE of Non Resident. Such royalty shall be treated as business income of PE of Non Resident.2. FFTS: where services giving rise to fee are rendered through PE of Non Resident. Such fee shall be treated as business income of PE of Non Resident.3. Royalty or FFTS exempt from tax.

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[S-2(54)] RoyaltyRoyalty means any amount Paid Payable Periodical or lumpsum as consideration for following

(vi)(vii)

supply of any assistance ancillary and subsidiary to any property or right mentioned abovedisposal of any right or property mentioned above

(v) Use or right to use Industrial/commercial/scientific equipment(iv) Supply of Technical/industrial/commercial/scientific Knowledge/skill(iii) receive or right to receive visual image or sound transmitted by

Satellite/CableOptic FiberSimilar technologyin connection with

TelevisionRadioInternet broadcasting

(ii) Use or right to use copyright or a literary, artistic or scientific work includingfilms or video tapes for use in connection with television ortapes in connection with radio broadcastingbut shall not include consideration for sale, distribution or exhibition of cinematograph films

(i) Use or right to use PatentInventionDesignModel

Secret formulaProcessTrade markOther like property/right

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[S-2(23)] FFTSmeans any consideration, whether periodical or lump sum, for rendering :

(b) consideration chargeable under head "Salary"(a) consideration for services in connection with construction, assembly or like project

It does not include following

Including services of technical or other personnel

ManagerialTechnicalConsultancy Services

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[S-7] Tax on Shipping & Air Transport Business of Non-ResidentSeparate Block

Non-Resident owns a ship or aircraft

Tax shall be imposed @ 1st Sched, Part-I, Div-V

Tax Imposed will be Final Tax

On Gross AmountPassengers, live stock, mail, goods embarkedIn Pakistan Outside Pakistan

AmountReceived/ReceivableIn Pakistan P P

Outside Pakistan P O

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[S-7A] Tax on Shipping of Resident PersonSeparate Block

Resident doing shipping business

Ships flying Pakistan Flag

@ 1 US $ per Gross Registered Tonnage

Pay Tonnage Tax

Ships not registered in Pakistan

Pay Tonnage Tax

0.15 US $ per Gross Registered TonnageFor each voyage to Pakistan Subject to maximum of 1 US $ per Gross Registered Tonnage

Exchange rate on following dates shall be applicable:i. In case of Company, 1st December of relevant Tax Yearii. In other cases, 1st September of relevant Tax YearTax paid under this section shall be Final TaxThis section shall not be applicable after 30.06.2020

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[S-7C] Tax on BuildersSeparate Block

Person deriving income from business ofConstruction & Sale of residential/commercial/other building

@ 1st Sched, Part-I, Div-VIIIA

Pay tax on basis of area of building constructed

On business or projects initiated/approved after 01.7.2016

FHR may prescribe following:i. mode/manner for payment/collection of taxii. Authority who will grant approval for computation and payment plan of taxiii. Responsibilities/powers of authorities who will approve/suspend/cancel NOC to sell the property

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[S-7D] Tax on DevelopersSeparate Block

Person deriving income from business ofDevelopment & Sale of residential/commercial/other Plots

@ 1st Sched, Part-I, Div-VIIIB

Pay tax on basis of area of Plot

On business or projects initiated/approved after 01.7.2016

FHR may prescribe following:i. mode/manner for payment/collection of taxii. Authority who will grant approval for computation and payment plan of taxiii. Responsibilities/powers of authorities who will approve/suspend/cancel NOC to sell the property