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• Rules extra levy can’t be applied if primary capital gains tax is zero

• Notes that administrative circulars can’t override law; cites FCC ruling limiting scope of super tax

• Dismisses FBR claim that wealth overrides tax exemptions

RAWALPINDI: The Lahore High Court has ruled that a super tax under Section 4C of the Income Tax Ordinance of 2001 cannot be imposed on capital gains arising from the sale of inherited immovable property where the gain itself carries a zero percent tax rate.