Huzaima Bukhari & Dr. Ikramul Haq
Raising the living standard and socio-economic uplift of industrial workers is the cornerstone of the Government policy, which is being achieved by providing the basic and other social amenities of life to workers in the country.WWF has been playing vital and progressive role in providing various important services to the industrial workers. WWF has established many housing schemes for workers throughout the country and development works of new schemes are under progress. In medical sector, WWF has established hospitals and dispensaries in the areas of workers’ concentration. As for the education sector, primary to higher secondary level educational and training institutions have been established and being run all over the country. WWF also awards fully funded scholarships to the talented children of industrial workers. A number of other welfare activities such as marriage grant and death grant are also being run by WWF—Syed Zulfiqar Abbas Bukhari, Special Assistant to Prime Minister / Minister of State
It is settled law and an express command of the Constitution that the law enunciated by the august Supreme Court becomes binding precedent for all forums of the country. All the executive and judicial authorities and forums are constitutionally obliged to implement the orders of and the principles and law laid down by the Supreme Court. Even if a review is pending against a judgment the same shall be binding unless it has been reviewed and a different conclusion is reached by the august Supreme Court. A judgment of the apex Court would have due effect and deference if it decides a question of law or is passed on the basis of law and/or enunciates a principle of law—Khan Gul Khan and others versus Daraz Khan [2010 SCMR 539], Muhammad Tariq Badr and another versus National Bank of Pakistan and others [2013 SCMR 314], Sindh High Court Bar Association through its Secretary and others versus FOP through M/O Law and Justice, Islamabad and others [PLD 2009 SC 879], Commissioner Income Tax versus Habib Bank Ltd. ANZ and Grindlays Bank” [2015 PTD 619], Pakistan Telecommunication Employees Trust (PTET) through M.D. Islamabad and others versus Mohammad Arif and others [2015 SCMR 1472] and Nazir Ahmed and others versus The State and others [PLD 2014 SC 241]
On October 10, 2018, the Federal Minister for Inter Provincial Coordination, Dr Fehmida Mirza chaired a meeting on resolution of post-18th amendment, issues of Employees Old Age Benefits Institute and Workers Welfare Fund. Minister for Overseas Pakistanis & Human Resource Development, Syed Zulfiqar Bukhari, also attended the meeting, in which representatives of Employer’ Federation of Pakistan and Pakistan Workers Federation from the provinces and Islamabad attended the meeting and discussed, in detail, the issues faced by the Workers Welfare Fund and Employees’ Old-age Benefits Institution (EOBI) after the 18th Amendment.
“We are not against devolution or provincial autonomy but we need the welfare of our workers,” they asserted. They highlighted the view that social security net should not be distributed among the states; rather it should be managed through the centre and implemented by the provinces. The trans-provincial fund, assets, institutions and the programs run by EOBI and Workers Welfare Fund (WWF) are difficult to be divided among the provinces. Besides, the migration of the workers would be a big challenge, if the subject considered is to be devolved, the welfare of the workers would be affected, the Federal Minister said that the workers are the main stakeholders in this and the due importance must be given to their view point as well.
She directed the participants to formulate their strategy and submit their point of view in a documented form, adding: “We believe in cooperative federalism, we need to strengthen each other, the government is committed to devise a mechanism based on consensus, to ensure the welfare of the workers.” The representative of workers thanked the Minister for providing them with the opportunity to bring forward their view point, while the next meeting in this regard will be scheduled soon”.
It is obvious the Minister for Inter Provincial Coordination was not even aware of the fact that since 2006, amendments made in various labour laws to broaden their scope were struck down by the Supreme Court in its order of November 10, 2016 reported as Workers Welfare Funds m/o Human Resources Development, Islamabad through Secretary and others v East Pakistan Chrome Tannery (Pvt.) Ltd through its GM (Finance), Lahore etc. and others[(2016) 114 TAX 385 (S.C. Pak.)] and till today no remedial measures have been taken to retrieve losses caused to the Funds established under these laws for the welfare of millions.
The Supreme Court held in [(2016) 114 TAX 385 (S.C. Pak.)] as under:
“2. The facts pertaining to these matters are broadly divided into three categories for ease of reference. The first set of facts are that Sections 2 and 4 of the Worker Welfare Ordinance, 1971 (Ordinance of 1971) were amended by Section 12 of the Finance Act of 2006 and subsequently by Section 8 of the Finance Act of 2008 which broadened the scope of the obligation on industrial establishments to contribute towards the Workers’ Welfare Fund established under Section 3 of the Ordinance of 1971. The said amendments (and notices demanding enhanced payment by virtue of the amendments) were challenged through writ petitions before various High Courts of the country. It is pertinent to mention that there are divergent views of the learned High Courts on this question. The view of the learned Lahore High Court in the judgment dated 19.8.2011 reported as East Pakistan Chrome Tannery (Pvt.) Ltd Vs. Federation of Pakistan and others (2012) 105 TAX 81 (H.C. Lah.) = (2011 PTD 2643) is that the levy in question was a fee and not a tax, therefore the amendments made by the Finance Acts of 2006 and 2008 to the Ordinance of 1971 could not have been lawfully brought through a money bill, rather should have been brought through the regular legislative procedure under the Constitution. The learned Peshawar High Court, vide judgment dated 29.5.2014, followed suit. Subsequently the learned Peshawar High Court disposed of numerous tax references on the basis of this decision, against which the appeals are before us. We would like to point out at the very outset that as regards those cases in which the revenue authorities/collecting agencies have assailed the judgment of the learned Peshawar High Court, although no rights of the collecting agencies have been affected as their job is to merely collect contributions for the Workers’ Welfare Fund, we are nevertheless deciding those cases as well keeping in view the importance of the matter and the conflicting judgments impugned before us. There is a contrary view of the Full Bench of the learned High Court of Sindh expressed in the judgment dated 1.3.2013 reported as Shahbaz Garments (Pvt.) Ltd Vs. Pakistan through Secretary Ministry of Finance, Revenue Division, Islamabad and others (2013) 107 TAX 89 (H.C. Kar.) = (PLD 2013 Kar 449) (Full Bench judgment) to the effect that the levy in question was a tax and not a fee, therefore the amendments made by the Finance Acts of 2006 and 2008 to the Ordinance of 1971 were lawfully brought through a money bill. The aforementioned judgments have been challenged by the parties before us.
3. The second set of facts are that various provisions of the Employees Old Age Benefits Act, 1976 (Act of 1976) pertaining to contributions to be made there under were amended by Section 9 of the Finance Act of 2008 effectively widening the scope of the obligation on employers to contribute towards the Employees’ Old-Age Benefits Fund established under Section 17 of the Act of 1976. These amendments were challenged through constitution petitions before the learned High Court of Sindh which, through its judgment dated 3.10.2012 reported as Soneri Bank Limited through Jaffar Ali Khan and others Vs. Federation of Pakistan through Secretary Law and Justice Division, Pak Secretariat, Islamabad and others (2013 PLC 134), held that the levy in question was a fee and not a tax, therefore the amendments made by the Finance Act of 2008 to the Act of 1976 could not have been lawfully brought through a money bill.
4. The third set of facts are that various provisions of the Workmen Compensation Act, 1923, the West Pakistan Industrial and Commercial Employees (Standing Orders) Ordinance, 1968 (Ordinance of 1968), the Companies’ Profit Workers’ Participation Act, 1968 (Act of 1968), the Minimum Wages for Unskilled Workers Ordinance, 1969 (Ordinance of 1969) and the Act of 1976 were amended through the Finance Act of 2007 which amendment(s) in effect broadened the scope of the obligation of the employers in the respective statutes (the obligation(s) in each statute shall be discussed during the course of the opinion). These amendments were challenged through a constitution petition before the learned High Court of Sindh which, through its judgment dated 26.2.2011, held that the changes sought to be made by amendments through the Finance Act of 2007 did not fall within the purview of Article 73(2) of the Constitution, hence, the said amendments could not have been lawfully brought through a money bill. All the aforementioned judgments have been challenged before us.
Sections 2 and 4 of the Workers Welfare Ordinance, 1971 were amended by the Finance Act of 2006 and subsequently by the Finance Act of 2008 to broaden the scope of the obligation on industrial establishments to contribute towards the Workers’ Welfare Fund, established under Section 3 of the Ordinance of 1971. These amendments were declared ultra vires Constitution by Lahore High Court in East Pakistan Chrome Tannery (Pvt.) Ltd v Federation of Pakistan and others (2012) 105 TAX 81 (H.C. Lah.). This order was endorsed in 2016 by the Supreme Court in order cited above. Theissue was whether WWFis a fee or tax. The Supreme Court said it was ‘fee’ and not ‘tax’ and, therefore, the amendments made by the Finance Acts of 2006 and 2008 as Money Bill were unlawful.
Through the Finance Act 2008, various provisions of the Employees Old Age Benefits Act, 1976 pertaining to contributions to be made thereunder, were also amended widening the scope of obligation on employers to contribute towards the Employees’ Old-Age Benefits Fund established under Section 17 of the Act of 1976. These amendments were challenged through constitution petitions before the Sindh High Court which, through its judgment dated 3.10.2012 reported as Soneri Bank Limited through Jaffar Ali Khan and others v Federation of Pakistan through Secretary Law and Justice Division, Pak Secretariat, Islamabad and others(2013 PLC 134), held that the levy was a fee and not a tax, therefore, the amendments made by the Finance Act of 2008 could not have been lawfully brought about through a Money Bill. This view of Sindh High Court was also upheld by the Supreme Court.
Through the Finance Act of 2007 various provisions of the Workmen Compensation Act, 1923, the West Pakistan Industrial and Commercial Employees (Standing Orders) Ordinance, 1968, the Companies’ Profit Workers’ Participation Act, 1968, the Minimum Wages for Unskilled Workers Ordinance, 1969 and the Act of 1976 were amended through the Finance Act of 2007 to broaden the scope of the obligation of the employers in the respective statutes. These amendments were challenged before the High Court of Sindh which, through its judgment dated 26.2.2011, held that the amendments through the Finance Act of 2007 not falling within the purview of Article 73(2) of the Constitution could not have been lawfully inserted through Money Bill. The judgments of Lahore and Sindh High Courts were challenged in the Supreme Court that upheld the same in (2016) 114 TAX 385 (S.C. Pak.)] with the conclusion: “There may very well be certain levies/contributions that do not fall within the purview of Article 73(3) but still do not qualify the test of Article 73(2) and therefore cannot be introduced by way of a Money Bill, and instead have to follow the regular legislative procedure………….”.
The above shows the sheer incompetence of our governments and parliamentarians that they could not distinguish which laws are to be presented as Money Bill and which one should go to both the Houses. The beneficial amendments made wrongly in labour laws for the working classes over a decade back have not been corrected by Pakistan People Party (PPP) and Pakistan Muslim League (Nawaz) during the “Decade of Democracy” [2008-18] and by the coalition government of Pakistan Tehreek-i-Insaf (PTI) since coming into power in August 2018.
It can be termed as the worst expression of callousness towards the labourers. All the parties during election claims claim to be champions of the cause of the downtrodden but in reality this is merely for lip service. The PMLN and PPP got ten years to rectify the mistake pointed out by the courts but they remained unmoved. The same apathy is demonstrated by the PTI Government. This confirms that when the matter comes to welfare of the workers, our legislators are totally insensitive but when issue is of raising their own salaries, laws are passed within a few minutes in the Senate and National Assembly. They did not bother that their lapse has affected over half a million pensioners under EOBI and some five million workers of various categories including women, registered for contributions.
It is high time that the Government of PTI should come to the rescue of the affectees by curative amendment or supporting the review petition pending in the above cited case.
The better course is that Dr. Fehmida Mirza, in consultation with Ministry of Law should get a Bill prepared in the light of observations of the Supreme Court in the above cited case and ensure retrieval of lost contributions retrospectively that is from 2006. No party in National Assembly and Senate is going to oppose this Bill or will get exposed as anti-labourer. Recovery of money and its settlement between federal government and provinces can be settled by Ministry of Inter Provincial Coordination under Article 144 of the Constitution.
The curative amendment will bring billions in the national kitty for providing pension, decent housing, free education and health facilities etc. for the beneficiaries of welfare laws. The PTI Government is looking for money for such objectives, not knowing that billions are lying unpaid with industrial undertakings/employers.
The legislators have failed to take note of the fact that any provincial assembly, (in Khyber Pakhtunkhwa, PTI has two thirds majority and in Punjab and Baluchistan has coalition governments) by a resolution under Article 144 of the Constitution can ask National Assembly, to enact laws for welfare of workers and social security of citizens. The funds would go into National Fund to provide all workers and citizens wherever residing. It is strange that the Law Ministry even did not give this advice even after judgement of Supreme Court on Article 149 of the Constitution in Suo Muto Case 1 of 2020.
Supreme Court in the case of Messers Sui Southern Gas Ltd & Others v Federation of Pakistan & Other 2018 SCMR 802 has extensively elucidated that the post-Eighteenth Amendment position vis-à-vis legislative competence of federation and federating units as under:
“We are in agreement with the observation made by the learned High Court that though in a Federal system, provincial autonomy means capacity of a province to govern itself without interference from the Federal Government or the Federal legislature, but as the Provincial legislature does not possess extra-territorial legislative authority i.e. it cannot legislate regarding the establishments operating beyond the territorial boundaries of that province”.
The above pronouncement of the Supreme Court is not restricted to any particular law and covers all laws. It is binding under Article 189 of the Constitution. Through democratic process vide Article 144/147 of the Constitution, all laws related to workers and social security can be federalised.
Significant pro-labour reforms were introduced by the Government of Zulfikar Ali Bhutto as early as in 1972 in the wake of threadbare discussions at a Tripartite Labour Conference held at Islamabad. Many laws were introduced and steps were taken to guarantee to the workers their long overdue fundamental rights of freedom of association and collective bargaining, and assurance of greater security of service, representation in management, group-insurance, old age pension, free education for children and housing and medical facilities etc. Some beneficial laws, for example, Workers Welfare Fund Ordinance, 1971, framed by Pakistan People Party and later amended from time to time by various governments, after the Eighteenth Constitution Amendment (18th Amendment), are is disarray—partly because of contradictory judgements of the higher courts and party because of inactions on the part of federal and provincial legislators to provide remedial actions highlighted in judicial pronouncements.
No doubt the final decision of the Supreme Court created confusion, problems and controversies which require the provincial Governments (as now labour is the provincial subject by virtue of 18th Amendment) to move fast and take proper legislative steps to correct the situation created by the Federal Government through Finance Acts in violation of the Constitution of Pakistan. The courts are bound to give decisions only according to the law and the Constitution.
In view of the Supreme Court judgement, the possibility of employers instituting petitions before courts claiming arrears of contributions/ payments made in excess cannot be ruled out. It also provides opportunity to provincial governments to restore to the workers benefits lost on account of judgement dated Feb 26, 2011 of the Sindh High Court, by following the correct legislative process. In this respect, the federal government will also be required to transfer funds generated under the Companies Profits (Workers’ Participation) Fund Act, 1968 )WPPF) and the Workers’ Welfare Fund Ordinance, 1971 to the respective provincial governments, as per devolution principles.
The Lahore High Court held that the “impugned amendments introduced in WWF Ordinance through Finance Acts, 2006 and 2008 are unconstitutional and therefore struck down”. The discussion above that the subject contributions/payments do not constitute a tax is sufficient to hold that any amendments to the provisions of the Ordinance of 1971, the Act of 1976, the Act of 1923, the Ordinance of 1968, the Act of 1968 and the Ordinance of 1969 could not have been lawfully made through a Money Bill, i.e. the Finance Acts of 2006 and 2008, as the amendments did not fall within the purview of the provisions of Article 73(2) of the Constitution
The Supreme Court’s verdict of November 10, 2016 by which all the Ordinances in respect of Employees Old-age Benefits Institution Act 1976, Workers Welfare Fund Ordinance, 1971 and Ordinance 1968 etc were annulled as unlawful. The apex court held that no amendment was legally made after the contributions in question were declared as fee and not tax. Hence the application of those amendments would cease unless further legislation is made through the parliament.
At the time of decision by Supreme Court, there are approximately 0.5 million pensioners under EOBI and some five million workers of various categories including women were registered for contributions.
The biggest handicap of the EOBI is that it is mostly headed and run by the officers appointed by the Federal Government who usually have little or no background of the working in a workers welfare institution. One of the outgoing Chairmen, Zafar Iqbal Gondal, was found in gross financial irregularities during PPP rule and is remained in jail while the just transferred Saleh Muhammad Farooqi worked part time as he was a favourite of Prime Minister also worked as Chairman of implementation of Green bus project of Karachi. Race is on for replacing him and a number of candidates of the federal bureaucracy have always been vying for the coveted post.
Interestingly an official Raja Faizul Hasan Faiz who was labour adviser during PPP rule advised the institution on making amendments to deprive the poor private sector workers of their rights through Finance Bills and instead of being reprimanded for the same, he was elevated to legal consultant in Federal Ombudsman’s cell.
There is an inbuilt anomaly in the EOBI in working out contributions of the concerned organization along with the incumbent as well as pensions as it has adopted the minimum wage as benchmark as against the old age pensioners of the government whose contributions are worked out on basis of their progressive salary slabs and their pensions are paid according to their last pay. By this the private organizations’ workers who are working in different categories from lowest to the highest slabs are paid the same lowest rated pensions which make it meaningless for the higher salaried men and women.
Before the 18th Amendment in the Constitution of Islamic Republic of Pakistan (“the Constitution”) in April 2010, the Federal Board of Revenue (FBR) had the legal power to collect WWF and WPPF from across the country. After the amendment, the powers were, however, devolved to the provinces and presently the provincial governments are allowed to collect WPPF. Sindh is the first province to introduce a legislation to collect WPPF and get the Act of 2015 enacted. It is followed by the Punjab through Punjab Workers Welfare Fund of 2019.
According to the order by Sindh High Court (SHC), the Sindh Companies Profits (Workers’ Participation) Act of 2015 will apply to all trans-provincial companies employing a total of 100 or more workers at any time of the year, and operating across the country irrespective of the regional location of their registrations.
Of the payment made by a company’s total profits, only such percentage of the distributive profits as is proportionate to firm’s workforce in Sindh will go to the WPPF, no matter the number of its workers in the province is below or more than 100.
Sindh WPPF Act 2015 applies to all the companies in the province regardless of where their registered office or industrial premises are located. So, if a company’s registered office is in Lahore and its manufacturing premises are in Peshawar but if it has any kind of presence in Sindh, the Act of 2015 allows the province to collect the levy.
SHC also removed a confusion of applicability of rates under the WPPF. In its order, the court said the purpose of WPPF was the welfare of labour and there were no problems applying it to all the workers of a company throughout Pakistan. It retained this character on the commencement of the Constitution and up to the 18th Amendment (from 1973 to 2010).
“The Act thereafter ‘fractured’ into provincial legislation and was then replaced by the Sindh Act,” the court order said.
The Sindh WPPF Act 2015 legally binds companies to make a proportionate distribution of 5 percent of their profits to their workers in the province. The five percent of profits will be calculated on the total profits of the company and not just those arising out of its operations from Sindh.
The Sind Revenue Board (SRB) official said the provincial revenue authority was mandated to collect the amount from corporate and industrial units operating within the jurisdiction of the province or their offices or officers working in any other province or within the jurisdiction of the Federal Government.
The consolidation and rationalization of the laws relating to labour welfare and social insurance however will require further policy decision in as much as to whether labour welfare and social insurance institutions like EOBI, PESSI’s, WWF etc. will be federalized, provincialised or disinvested. Despite criticism from certain quarters these welfare organizations have played an important role in providing to the labour a suitable social safety net and so these are required to be kept in place but should also be further strengthened. What is needed is to introduce a comprehensive social insurance and social security scheme for the society at large on the lines such schemes are in vogue in other welfare states. It would in any way be desirable to ensure that restructuring of labour laws does not create any problem for the industry. Restructuring should, therefore, be gradual, fully considered and rationally done.
Technology is undergoing a rapid change. Pressure of globalization is increasing day by day. Investor has his own priorities. Management style is changing. Unions are expected to play more constructive role. There are indigenous needs. There are external pressures due to international commitments. Communication is increasing. Industrial relation systems of the world are undergoing change. Out-dated labour laws, multiple in number, ought to undergo considerable change to resolve genuine problems of workers and the industry. The government’s current Labour Policy and its commitment to the consolidation, simplification and rationalization of labour laws is very timely.
The following are some of the suggestions:
* Law on industrial relations has already been thoroughly revised in consultation with all stakeholders. What is required is to invoke its bipartite and participative character more vigorously to foster trust relationship between employers and employees.
* The law on wages should state determination of wage system by the organization concerned in consultation with workers or through collective bargaining. The government power should better remain confined to fixation of wages of workers in small and unorganized sector. Authority must, however, be appointed to ensure timely payment of wages without any unauthorized deductions.
*The law on conditions of employment should apply to all employment sectors laying down minimum standards and basic principles to deal with employment matters. The right to determine service benefits should rest with the organization concerned according to its objective conditions and economic viability.
* The Factories Act, the Mines Act, the Shops and Establishment Ordinance, the Railways Act (Chapter VI-A),the Workmen Compensation Act and every law with relevant provisions be consolidated in the shape of a generic law to be named as law on occupational safety and health which should apply to all economic sectors. General principles and standards should be laid down in the enacting part and industry-wise regulations should be appended according to their needs and requirements. The appointment of judicial authority to award compensation in case of accidents and deaths should also be provided in the same law. This law should be fully in conformity with international labour standards. It would be advisable for Pakistan to ratify ILO Convention 155 in this regard. The subject of occupational safety and health needs to be given the highest priority to improve working environment and ensure safe working conditions in industry in Pakistan.
* Instead of having a law on human resource development (HRD), which being a vast subject does not fit to the consolidation of certain labour laws in this regard, it would be proper to re-enact the law relating to apprenticeship to meet the present day requirements.
* An enabling provision must be laid down in the law regarding conditions of employment requiring also companies, firms and industries to evolve their labour welfare and social insurance systems in consultation with their workers organizations. It would ultimately help to deal appropriately with laws relating to labour welfare and social security.
* Consolidation should be carried meaningfully by re-enacting laws coherently. The out-dated laws and the laws, which have lost their utility or usefulness, be repealed.
*Credit goes to the Musharraf for breaking the ice in bringing a comprehensive labour policy after about thirty years, with the promise to restructure labour legislation on sound footings to meet not only the present time needs but also the challenges of globalization and changing technologies. The Ministry of Labour deserves appreciation for a job that has been accomplished. The late Omar Asghar Khan, the former Federal Labour Minister, was able to prepare a way for the Labour Policy by holding 24th PTCL after 13 years and patronizing and supervising the initiatives of the ministry in this regard. His devotion to the cause of labour was unprecedented. A package of labour reforms announced during his time (April 30, 2001) was a prerequisite to the current labour policy.
In the Industrial Relations Act, 2013 both the sectors’ workforces come under the definition of workers, but no rules of business have been chalked out to enable them to have their trade unions registered under the law.
Ms. Huzaima Bukhari, Advocate High Court and Visiting Faculty at Lahore University of Management Sciences (LUMS), is author of numerous books and articles on Pakistani tax laws. She is editor of Taxation and partner of Huzaima & Ikram, a leading law firm of Pakistan. From 1984 to 2003, she was associated with Civil Services of Pakistan. Since 1989, she has been teaching tax laws at various institutions including government-run training institutes in Lahore. She specialises in the areas of international tax laws, corporate and commercial laws. She is review editor for many publications of Amsterdam-based International Bureau of Fiscal Documentation (IBFD) and contributes regularly to their journals. She has to her credit over 1500 articles on issues of public importance, printed in various journals, magazines and newspapers at home and abroad.She has also coauthored with Dr. Ikramul Haq many books that include Pakistan: Enigma of Taxation, Towards Flat, Low-rate, Broad and Predictable Taxes, Law & Practice of Income Tax, Law , Practice of Sales Tax, Law and Practice of Corporate Law, Law & Practice of Federal Excise, Law & Practice of Sales Tax on Services, Federal Tax Laws of Pakistan, Provincial Tax Laws, Practical Handbook of Income Tax, Tax Laws of Pakistan, Principles of Income Tax with Glossary andMaster Tax Guide, Income Tax Digest 1886-2011 (with judicial analysis). She regularly writes columns for Pakistani newspapers and has contributed over 1500 articles on issues of public finance, taxation, economy and on various social issues in various journals, magazines and newspapers at home and abroad.
Dr. Ikramul Haq, Advocate Supreme Court, specialises in constitutional, corporate and tax laws. He established Huzaima & Ikram in 1996 and is presently its chief partner as well as partner in Huzaima Ikram & Ijaz. He studied journalism, English literature and law. He is Chief Editor of Taxation andVisiting Faculty at Lahore University of Management Sciences (LUMS).
He has also coauthored with Huzaima Bukhari many books that include Pakistan: Enigma of Taxation, Towards Flat, Low-rate, Broad and Predictable Taxes, Law & Practice of Income Tax, Law , Practice of Sales Tax, Law and Practice of Corporate Law, Law & Practice of Federal Excise, Law & Practice of Sales Tax on Services, Federal Tax Laws of Pakistan, Provincial Tax Laws, Practical Handbook of Income Tax, Tax Laws of Pakistan, Principles of Income Tax with Glossary andMaster Tax Guide, Income Tax Digest 1886-2011 (with judicial analysis). He is author of Commentary on Avoidance of Double Taxation Agreements signed by Pakistan, Pakistan: From Hash to Heroin, its sequelPakistan: Drug-trap to Debt-trap and Practical Handbook of Income Tax. He regularly writes columns for many Pakistani newspapers and international journals and has contributed over 2500 articles on a variety of issues of public interest, printed in various journals, magazines and newspapers at home and abroad.