22. Depreciation.

-
(1) Subject to this section, a person shall be allowed a deduction for the depreciation of the
persons depreciable assets used in the persons business in the tax year.
(2) Subject to
1
[sub-section] (3)
2
[ ], the depreciation deduction for a tax year shall be
computed by applying the rate specified in Part I of the Third Schedule against the
written down value of the asset at the beginning of the year.
(3) Where a depreciable asset is used in a tax year partly in deriving income from business
chargeable to tax and partly for another use, the deduction allowed under this section
for that year shall be restricted to the fair proportional part of the amount that would
be allowed if the asset
3
[was] wholly used to
4
[derive] income from business chargeable
to tax.
5
(4) [Omitted by Finance Act, 2004]
(5) The written down value of a depreciable asset of a person at the beginning of the tax
year shall be
(a) where the asset was acquired in the tax year, the cost of the asset to the
person as reduced by any initial allowance in respect of the asset under section
23; or
(b) in any other case, the cost of the asset to the person as reduced by the total
depreciation deductions (including any initial allowance under section 23)
allowed to the person in respect of the asset in previous tax years.
(6) Where sub-section (3) applies to a depreciable asset for a tax year, the written down
value of the asset shall be computed on the basis that the asset has been solely used to
derive income from business chargeable to tax.
(7) The total deductions allowed to a person during the period of ownership of a
depreciable asset under this section and section 23 shall not exceed the cost of the
asset.
(8) Where, in any tax year, a person disposes of a depreciable asset, no depreciation
deduction shall be allowed under this section for that year and -
(a) if the consideration received exceeds the written down value of the asset at the
time of disposal, the excess shall be chargeable to tax in that year under the
head Income from Business; or

1
Substituted for sub-section by Finance Act, 2005.
2
The word and figure and (4) omitted by the Finance Act, 2004. It has rendered the opening part of sub-
section grammatically incorrect as now it should be Subject to sub-section (3).
3
Substituted for were by Finance Act, 2010.
4
Substituted for derived by Finance Act, 2003.
5
Sub-section (4) Omitted by Finance Act, 2004.


(b) if the consideration received is less than the written down value of the asset at
the time of disposal, the difference shall be allowed as a deduction in computing
the persons income chargeable under the head Income from Business for that
year.
(9) Where sub-section (3) applies, the written down value of the asset for the purposes of
sub-section (8) shall be increased by the amount that is not allowed as a deduction as a
result of the application of sub-section (3).
(10) Where clause (a) of sub-section (13) applies, the
1
consideration received on disposal of
the passenger transport vehicle for the purposes of sub-section (8) shall be computed
according to the following formula
A x B/C
where -
A is the
2
[amount] received on disposal of the vehicle;
B is the amount referred to in clause (a) of sub-section (13); and
C is the actual cost of acquiring the vehicle.
(11) Subject to sub-sections (13) and (14), the rules in Part III of Chapter IV shall apply in
determining the cost and consideration received in respect of a depreciable asset for
the purposes of this section.
3
(12) The depreciation deductions allowed to a leasing company or an investment bank or a
modaraba or a scheduled bank or a development finance institution in respect of assets
owned by the leasing company or an investment bank or a modaraba or a scheduled
bank or a development finance institution and leased to another person shall be
deductible only against the lease rental income derived in respect of such assets.
(13) For the purposes of this section, -
(a) the cost of a depreciable asset being a passenger transport vehicle not plying for
hire shall not exceed
4
[two]
5
[and half] million rupees;

6
[ ]
(b) the cost of immovable property or a structural improvement to immovable
property shall not include the cost of the land;
7
(c) any asset owned by a leasing company or an investment bank or a modaraba or

1
Substituted for the words written down value by Finance Act, 2004.
2
Substituted for the word consideration by Finance Act, 2004.
3
Sub-section (12) substituted by Finance Ordinance, 2002.
4
Substituted one by Finance Act, 2012.
5
Words inserted by Finance Act, 2009.
6
Proviso omitted by Finance Act, 2009. Earlier it was inserted by Finance Act, 2005.
7
Clause (c) substituted by Finance Ordinance, 2002.


a scheduled bank or a development finance institution and leased to another
person is treated as used in the leasing company or the investment bank or the
modaraba or the scheduled bank or the development finance institutions
business; and
(d) where the consideration received on the disposal of immovable property
exceeds the cost of the property, the consideration received shall be treated as
the cost of the property.
(14) Where a depreciable asset that has been used by a person in Pakistan is exported or
transferred out of Pakistan, the person shall be treated as having disposed of the asset
at the time of the export or transfer for a consideration received equal to the cost of the
asset.
(15) In this section, -
depreciable asset means any tangible movable property, immovable property (other
than unimproved land), or structural improvement to immovable property, owned by a
person that -
(a) has a normal useful life exceeding one year;
(b) is likely to lose value as a result of normal wear and tear, or obsolescence; and
(c) is used wholly or partly by the person in deriving income from business
chargeable to tax,
but shall not include any tangible movable property, immovable property, or
structural improvement to immovable property in relation to which a deduction
has been allowed under another section of this Ordinance for the entire cost of
the property or improvement in the tax year in which the property is acquired or
improvement made by the person; and
structural improvement in relation to immovable property, includes any
building, road, driveway, car park, railway line, pipeline, bridge, tunnel, airport
runway, canal, dock, wharf, retaining wall, fence, power lines, water or sewerage
pipes, drainage, landscaping or dam.