Category: Taxation

Stay updated on taxation news, tax laws, FBR policies, compliance, audits, income tax, sales tax, and fiscal developments in Pakistan.

  • FBR defines fair market value of immovable properties, motor vehicles

    FBR defines fair market value of immovable properties, motor vehicles

    KARACHI: Federal Board of Revenue (FBR) has defined fair market value of immovable properties and motor vehicles in case of undeclared assets identified.

    FBR officials said that the valuation of immovable property for the purposes of section 111 of Income Tax Ordinance, 2001 related to undisclosed assets shall be taken to be-

    (a) the fair market value of immovable property shall be the value notified by the Board under sub-section (4) of section 68, in respect of area or areas specified in the said notifications;

    (b) if the fair market value of any immovable property of any area or areas has not been determined by the Board in the notification referred to in sub-section (4) of section 68, the fair market value of such immovable property shall be deemed to be the value fixed by the District Officer (Revenue) or provincial or any other authority authorized in this behalf for the purposes of stamp duty; and

    (c) in the case of agricultural land, the value shall be equal to the average sale price of the sales recorded in the revenue record of the estate in which the land is situated for the relevant period or time;

    (d) if in a case sale price recorded in the instrument of sale of any property is higher than the fair market value as determined under clauses (a), (b) and (c), the applicable price shall be higher of the two; and

    (e) in the case of sale price of any auctioned property or the fair market value as determined under clauses (a), (b) and (c), the higher price shall be applicable.

    (2) For the purposes of section 111 and subject to sub-rule (2), the value of motor cars and jeeps shall be determined in the following manner, namely:-

    (a) the value of the new imported car or jeep shall be the C.I.F. value of such car or the jeep, as the case may be, plus the amount of all charges, customs-duty, sales tax, levies, octroi fees and other duties and taxes leviable thereon and the costs incurred till its registration;

    (b) the value of a new car or jeep purchased from the manufacturer or assembler or dealer in Pakistan, shall be the price paid by the purchaser, including the amount of all charges, customs-duty, sales tax and other taxes, levies, octroi, fees and all other duties and taxes leviable thereon and the costs incurred till its registration;

    (c) the value of used car or jeep imported into Pakistan shall be the import price adopted by the customs authorities for the purposes of levy of customs-duty plus freight, insurance and all other charges, sales tax, levies octroi, fees and other duties and taxes leviable thereon and the costs incurred till its registration;

    (d) the value of a car or jeep specified in clause (a), (b) and (c) at the time of its acquisition shall be the value computed in the manner specified in the clause (a), (b) or (c), as the case may be, as reduced by a sum equal to ten percent of the said clause for each successive year, upto a maximum of five years; or

    (e) the value of a used car or jeep purchased by an assessee locally shall be taken to be the original cost of the car or the jeep determined in the manner specified in clause (a), (b) or (c), as the case may be, as reduced by an amount equal to ten percent for every year following the year in which it was imported or purchased from a manufacturer.

    (3) In no case shall the value be determined at an amount less than fifty percent of the value determined in accordance with clause (a), (b) or (c) or the purchase price whichever is more.

    (4) For the purposes of section 61, the value of any property donated to a non-profit organization shall be determined in the following manner, namely:-

    (a) the value of articles or goods imported into Pakistan shall be the value determined for the purposes of levy of customs duty and the amount of such duty and sales tax, levies, fees, octroi and other duties, taxes or charges leviable thereon and paid by the donor;

    (b) the value of articles and goods manufactured in Pakistan shall be the price as recorded in the purchase vouchers and the taxes, levies and charges leviable thereon and paid by the donor;

    (c) the value of articles and goods which have been previously used in Pakistan and in respect of which depreciation has been allowed, the written down value, on the relevant date as determined by the Commissioner;

    (d) the value of a motor vehicle shall be the value as determined in accordance with rule; and

    (e) the value of articles or goods other than those specified above, shall be the fair market value as determined by the Commissioner.

  • FBR notifies transfer, postings of BS-20 Customs officers

    FBR notifies transfer, postings of BS-20 Customs officers

    ISLAMABAD: Federal Board of Revenue (FBR) on Tuesday notified transfers and postings of Pakistan Customs Service (PCS) officers in BS-20 with immediate effect and until further orders.

    Following officers have been transferred and posted:

    01. Abdul Qadir Memon (Pakistan Customs Service/BS-20) has been transferred and posted as Collector, Collectorate of Customs, (Appeals), Karachi from the post of Chief, Federal Board of Revenue (HQ), Islamabad.

    02. Ms. Seema Raza Bokhari (Pakistan Customs Service/BS-20), who is currently posted as Collector, Model Customs Collectorate, Islamabad has been given look after charge of Collector, Model Customs Collectorate of Gilgit-Baltistan in addition to her own duties.

    03. Muhammad Junaid Jalil Khan (Pakistan Customs Service/BS-20) has been transferred and posted as Collector, Collectorate of Customs, (Appeals), Islamabad from the post of Chief, Federal Board of Revenue (Hq), Islamabad.

    04. Dr. Tahir Qureshi (Pakistan Customs Service/BS-20) has been transferred and posted as Collector, Model Customs Collectorate, Gwadar from the post of Collector, Model Customs Collectorate, Gilgit-Baltistan.

    05. Muhammad Jamil Nasir Khan (Pakistan Customs Service/BS-20) has been transferred and posted as Collector, Model Customs Collectorate of Appraisement and Facilitation (West), Karachi from the post of Chief, Federal Board of Revenue (Hq), Islamabad.

    06. Imran Ahmad Ch. (Pakistan Customs Service/BS-20) is currently posted as Director, Directorate of Post Clearance Audit(North), Islamabad. The officer will also look after the charge of Director, Directorate of Internal Audit-North (Customs), Islamabad.

    07. Ms. Azmat Tahira (Pakistan Customs Service/BS-20) has been transferred and posted as Collector, Model Customs Collectorate (AIIA), Lahore from the post of Director, Directorate of Internal Audit-North (customs), Islamabad.

    08. Basit Maqsood Abbasi (Pakistan Customs Service/BS-20 has been transferred and posted as Collector Model Customs Collectorate of Enforcement and Compliance, Lahore from the post of Collector, Model Customs Collectorate (AIIA), Lahore.

    The FBR said that the officers who are drawing performance allowance prior to issuance of this notification shall continue to draw this allowance on the new place of posting.

  • FBR starts enforcing NTN displaying at business premises

    FBR starts enforcing NTN displaying at business premises

    KARACHI: Federal Board of Revenue (FBR) has started enforcement dive to ensure displaying National Tax Number (NTN) at place of business.

    Sources in FBR said on Tuesday that the tax offices had started campaign to ensure displaying of NTN at place of the business.

    The tax authorities will imposed penalty of around Rs5000 on persons who fail to display the NTN at the place of business as required under Income Tax Ordinance, 2001.

    Section 181C of Income Tax Ordinance, 2001 explains the displaying of National Tax Number.

    Every person deriving income from business chargeable to tax, who has been issued a National Tax Number, shall display his National Tax Number at a conspicuous place at every place of his business.

  • FBR, Iranian customs sign agreement for electronic data exchange

    FBR, Iranian customs sign agreement for electronic data exchange

    ISLAMABAD: Federal Board of Revenue (FBR) and Iranian Customs authorities on Monday signed an agreement for Electronic Exchange of Data.

    The signing ceremony was chaired by Member (Customs-Policy/Operation), FBR Muhammad Javed Ghani, and subsequently presided over by the acting Chairperson, FBR, Nausheen Javaid Amjad.

    The Customs Mutual Assistance Agreement was signed between the Government of the Islamic Republic of Iran and the Islamic Republic of Pakistan on March 04, 2004.

    In light of the said agreement, it was felt imperative by FBR to make progress on a number of important areas for protecting economic interests of Pakistan involved in bilateral trade between Iran and Pakistan.

    Under the agreement, it was decided to finalize of the MoU on Electronic Data Exchange between Pakistan Customs and Iran Customs.

    It was also emphasized to exchange values or documents on real time basis in case of the goods to be imported or exported and to roll-out a fully automated clearance system having advance information about goods and passengers at Taftan – Mirjaveh Border stations (as a pilot project) and at other border stations in a phased manner.

    To this effect, the Iranian customs authorities were approached and meetings were held on February 18-20, 2019 and October 16-17, 2019.

    In the last meeting, on October 16-17, 2019 milestones were achieved and consensus was developed on the areas as listed in above Para.

    In furtherance of the subject matter, the Islamic Republic of Iran Customs Administration (IRICA) nominated, the Director General of Information Technology Department Mrs. Haideh Bagheripour to come over to Pakistan for signing the MoU on behalf of her Customs Administration.

    While welcoming the distinguished guests from Iran Customs, the Chairperson, FBR, Nausheen Javaid Amjad stated that implementation of this MoU will have a number of benefits for both Iran Customs and Federal Board of Revenue such as availability of advance information about values, descriptions and quality of the goods to be imported into Pakistan from Iran and reduced costs on clearance of goods at the borders. Moreover, accurate valuation of the imported goods will lead to realization of greater revenues, she said.

    Member (Customs-Policy), Muhammad Javed Ghani, while speaking on the occasion, warmly welcomed the esteemed guests from Iran Customs on their visit to Pakistan.

    He said the proposed cooperation through the Memorandum of Understanding would go a long way in fostering a long-term relationship between both customs administrations and would enable them to successfully cope with the challenges that they were facing.

    According to him, implementation of this MoU would ensure optimum trade facilitation through quick examination /assessment of the imported goods and more transparency and lesser human interface.

    He assured Iran customs of full cooperation from Pakistan Customs on any area pertaining to mutual assistance and collaboration.

    Ambassador of Iran in Pakistan, Mohammad Ali Hosseini, was also present on the occasion.
    He has conveyed felicitations to all the present officers of Federal Board of Revenue and appreciated both customs administrations for working untiringly to reach the consensus on the provisions of MoU and, finally, converging to sign it.

    He expressed his pleasure over the fact that there were a number of important areas wherein both customs administrations could work together in the best interests of Iran and Pakistan.

    After signing of MoU, the instrument was exchanged between relevant officers of Iran Customs and Federal Board of Revenue.

  • SRB probes foreign transactions of goods carrier, suspends sales tax registration

    SRB probes foreign transactions of goods carrier, suspends sales tax registration

    KARACHI: Sindh Revenue Board (SRB) has launched investigation into identifying source of foreign transactions by a goods carrier company. Further the SRB suspended the sales tax registration of the company for filing untrue monthly statement.

    The SRB on Monday said that it had suspended sales tax registration of M/s. 3 Unicorns Private Limited for concealing facts in its monthly statements.

    The SRB said that available records of the company revealed that it had declared foreign income of around Rs37 million (in its income tax return) for the tax periods from July 2016 to June 2017, and has received consideration of Rs109 million for the tax periods from July 2016 up to February 2019 in his business bank account maintained under the title of ‘3 Unicorns Pvt Ltd’ in Bank Al Habib Limited, as declared in his registration profile.

    Furthermore, the official website of the company revealed that the registered person also provides customs brokerage and customs clearance services and transportation services from Karachi to Afghanistan.

    However, t is observed that the registered person has continuously filed Null sales tax return with the SRB during the aforementioned tax periods i.e. July 2016 to February 2019 despite receiving aforementioned huge consideration in his bank account which was voluntarily declared in registration form.

    “The registered person has failed to justify the aforesaid Null declarations and has failed to provide details of sales and purchases till date which shows mala fide intention on part of the registered person towards short payment of SST and violation of Section 8, 9 and 30 of the Act.”

    The SRB said that non-payment of Sindh sales tax and non-filing of true and correct sales tax return within the time and manner prescribed under the law is contravention of provisions of the Act and rules made thereunder.

    Therefore, this notice is being issued under Section 25 of the Act, 2011 to the effect that registration status of M/s. 3 Unicorns Pvt Ltd is hereby temporary suspended with immediate effect, which shall be revoked if he takes remedial actions by February 14, 2020.

    The SRB directed the company to submit copies of complete annual accounts statement for the financial year 2016/2017, 2017/2018 and 2018/2019 with details of sales and purchases.

    The company has been asked to provide details of transactions with sources of amounts received for the tax periods from July 2016 up to January 2020.

    Reconcile all Sindh sales tax dues of the aforementioned tax periods and deposit along with default surcharge. Further, the company also has been directed to provide copies of rent agreements for the periods.

    “In case of non-satisfactory response or failure to take remedial measures as suggested above on or before aforementioned date, further necessary action shall be taken as envisaged under the Act,” the SRB said.

  • FBR notifies transfer, postings of BS-20 IRS officers

    FBR notifies transfer, postings of BS-20 IRS officers

    ISLAMABAD: Federal Board of Revenue (FBR) on Monday notified transfers and postings of senior officers of Inland Revenue Service (IRS) of BS-20 with immediate effect and until further orders.

    The FBR notified transfers and postings of following officers:

    01. Rizwan Ahmed Urfi (Inland Revenue Service/BS-20) has been transferred and posted as Chief, (PAC-DT) Federal Board of Revenue (Hq), Islamabad from the post of Chief, Federal Board of Revenue (Hq), Islamabad.

    02. Sheikh Zahid Masood (Inland Revenue Service/BS-20) has been transferred and posted as Chief, (Enforcement) (IR-Operations Wing) Federal Board of Revenue (Hq), Islamabad from the post of Chief, Federal Board of Revenue (Hq), Islamabad.

    03. Muhammad Asghar Khan Niazi (Inland Revenue Service/BS-20) has been transferred and posted as Commissioner Inland Revenue (Bahawalpur Zone) Regional Tax Office, Bahawalpur from the post of Commissioner-IR, (Rahimyar Khan Zone) Regional Tax Office, Bahawalpur. The officer is assigned the additional charge of the post of CIR (Rahimyar Khan Zone), RTO, Bahawalpur till the posting of a regular incumbent.

    04. Masood Akhtar (Inland Revenue Service/BS-20) has been transferred and posted as Chief, (Legal Wing) Federal Board of Revenue (Hq), Islamabad from the post of Commissioner-IR, (Bahawalpur Zone) Regional Tax Office, Bahawalpur.

    05. Mohy ud Din Ismail (Inland Revenue Service/BS-20) has been transferred and posted as Chief, (ST &FE) (IR-Policy Wing) Federal Board of Revenue (Hq), Islamabad from the post of Chief, (Legal) Federal Board of Revenue (Hq), Islamabad.

    The FBR said that the officers who are drawing performance allowance prior to issuance of this notification shall continue to draw this allowance on the new place of posting.

  • FBR to impose penalty on withholding agent for not submitting taxpayers’ information

    FBR to impose penalty on withholding agent for not submitting taxpayers’ information

    ISLAMABAD: Federal Board of Revenue (FBR) will impose penalty on withholding agents for failure in submitting withholding statement or information of taxpayers for the period July – December 2019.

    The last day for filing withholding statement electronically was January 31, 2020. Most of the withholding agents had filed the statements as per requirement. However, some of them are still non-compliant and will be liable to fine and penalty, FBR sources said on Monday.

    As per Section 182 of Income Tax Ordinance, 2001, where any person fails to furnish a statement as required under Section 115, 165, 165A of 165B within the due date. “Such person shall pay a penalty of Rs5,000 if the person had already paid the tax collected or withheld by him within the due date for payment and the statement is filed within 90 days from the due date for filing the statement and, in all other cases, a penalty of Rs2,500 for each day of default from the due date subject to a minimum penalty of Rs10,000.”

    The FBR officials said that under Section 165 of the Income Tax Ordinance, 2001, every person collecting tax or deducting tax from a payment shall furnish to the commission a biannual statement in the prescribed form setting out:

    (a) the name, Computerized National Identity Card Number, National Tax Number and address of each person from whom tax has been collected under Division II of this Part or Chapter XII or the Tenth Schedule or to whom payments have been made from which tax has been deducted under Division III of this Part or Chapter XII or the Tenth Schedule in each half-year

    (b) the total amount of payments made to a person from which tax has been deducted under Division III of this Part or Chapter XII or the Tenth Schedule in each half-year

    (c) the total amount of tax collected from a person under Division II of this Part or Chapter XII or the Tenth Schedule or deducted from payments made to a person under Division III of this Part or Chapter XII or the Tenth Schedule in each half-year; and

    (d) such other particulars as may be prescribed:

    Provided that every person as provided in sub-section (1) shall be required to file withholding statement even where no withholding tax is collected or deducted during the period.

    Explanation.— For the removal of doubt, it is clarified that this sub-section overrides all conflicting provisions contained in the Protection of Economic Reforms Act, 1992 (XII of 1992), the Banking Companies Ordinance, 1962 (LVII of 1962), the Foreign Exchange Regulation Act, 1947 (VII of 1947) and the regulations made under the State Bank of Pakistan Act, 1956 (XXXIII of 1956), if any, on the subject, in so far as divulgence of information under section 165 is concerned.

    (2) Every prescribed person collecting tax under Division II of this Part or Chapter Xll or the Tenth Schedule or deducting tax under Division III of this Part of Chapter Xll or the Tenth Schedule shall furnish statements under sub-section (l) as per the following schedule, namely:-

    (a) in respect of the half-year ending on the 30th June, on or before the 31st day of July; and

    (b) in respect of the half-year ending on the 31st December, on or before the 31st day of January.

    (2A) Any person who, having furnished statement under sub-section (1) or sub-section (2), discovers any omission or wrong statement therein, may file a revised statement within sixty days of filing of statement under sub-section (1) or sub-section (2), as the case may be.

    (2B) Notwithstanding anything contained in this section, the Commissioner as he deems lit may by notice in writing require any person, collecting or deducting tax under this Ordinance, to furnish a statement for any period specified in the notice within such period of time as may be specified in the notice.

    (3) Board may prescribe a statement requiring any person to furnish information in respect of any transactions in the prescribed form and verified in the prescribed manner.

    (4) A person required to furnish a statement under sub-section (1), may apply in writing, to the Commissioner for an extension of time to furnish the statement after the due date and the Commissioner if satisfied that a reasonable cause exists for non-furnishing of the statement by the due date may, by an order in writing, grant the applicant an extension of time to furnish the statement.

    (5) The Board may make rules relating to electronic furnishing of statements under this section including,-

    (a) mandatory electronic filing of statements; and

    (b) determination of eligibility of the data of such statements and e-intermediaries, etc.

    (6) Every person deducting tax from payment under section 149 shall furnish to the Commissioner an annual statement in the prescribed form and manner.

  • Criminal proceedings to be initiated for taking bribe

    Criminal proceedings to be initiated for taking bribe

    KARACHI: Federal Board of Revenue (FBR) is determined to eliminate corrupt practices in the official matters in Inland Revenue and Pakistan Customs and decided to take action against officials taking bribe or financial benefits for giving favor someone.

    FBR officials told PkRevenue.com that vigilance teams of tax authorities were observing the day to day affairs of field offices and also examining complaints against tax officials regarding their workings.

    In order to effectively check misuse of authority to gain financial benefit, new provisions have been introduced through Finance Act, 2019 in all the relevant statutes to prescribe rules for initiating criminal proceedings against officers and officials of the FBR who deliberately commit acts or fail to act for personal benefits.

    Similar action would also be taken against persons who offer bribes or other financial benefits to the tax employees, the sources said.

    The laws have been introduced through Section 156A Customs Act, 1969, Section 33A Sales Tax Act, 1990 and Section 216A Income Tax Ordinance, 2001 for taking against corrupt practices of officials.

    Under Section 216A of Income Tax Ordinance, Proceedings against authority and persons shall be taken as under.

    (1) Subject to section 227, the Board shall prescribe rules for initiating criminal proceedings against any authority mentioned in section 207 and officer of the Directorates General mentioned in Part II and Part III of Chapter XI including any person subordinate to the aforesaid authorities or officers of the

    Directorates General who willfully and deliberately commits or omits an act which results in undue benefit or advantage to the authority or the officer or official or to any other person.

    (2) Where proceedings under sub-section (1) have been initiated against the authority or officer or official, the Board shall simultaneously intimate the relevant Government agency to initiate criminal proceedings against the person referred to in sub-section (1).

    (3) The proceedings under this section shall be without prejudice to any other liability that the authority or officer or official or the person may incur under any other law for the time being in force.

  • Tax collection from salary of executives, directors jumps up by 85%

    Tax collection from salary of executives, directors jumps up by 85%

    KARACHI: The collection of income tax has registered sharp growth of 85 percent on salary received by executives/directors of companies.

    The unprecedented growth has been witnessed due to changes in salary tax slabs introduced through Finance Act, 2019.

    The collection of income tax has increased to Rs3.1 billion during first seven months (July – January) 2019/2020 as compared with Rs1.667 billion in the same period of the last fiscal year.

    Sources in Large Taxpayers Unit (LTU) Karachi, a collecting office of Federal Board of Revenue (FBR), said that the higher tax rates on the salary income received by executives and directors of companies revised through the Finance Act, 2019 resulted in improved tax revenue under this head.

    They said that the tax slab was increased to 35 percent on the salary income above Rs75 million.

    The tax officials also attributed the increase in tax revenue to effective monitoring and audit of executives /directors of companies.

    They said that previously directors of companies avoid taxes by taking advantage of tax laws.

    The salary income has been explained in section 12 of Income Tax Ordinance, 2001.

    Salary.— (1) Any salary received by an employee in a tax year, other than salary that is exempt from tax under this Ordinance, shall be chargeable to tax in that year under the head “Salary”.

    (2) Salary means any amount received by an employee from any employment, whether of a revenue or capital nature, including —

    (a) any pay, wages or other remuneration provided to an employee, including leave pay, payment in lieu of leave, overtime payment, bonus, commission, fees, gratuity or work condition supplements (such as for unpleasant or dangerous working conditions);

    (b) any perquisite, whether convertible to money or not;

    (c) the amount of any allowance provided by an employer to an employee including a cost of living, subsistence, rent, utilities, education, entertainment or travel allowance, but shall not include any allowance solely expended in the performance of the employee’s duties of employment;

    (d) the amount of any expenditure incurred by an employee that is paid or reimbursed by the employer, other than expenditure incurred on behalf of the employer in the performance of the employee’s duties of employment;

    (e) the amount of any profits in lieu of, or in addition to, salary or wages, including any amount received —

    (i) as consideration for a person’s agreement to enter into an employment relationship;

    (ii) as consideration for an employee’s agreement to any conditions of employment or any changes to the employee’s conditions of employment;

    (iii) on termination of employment, whether paid voluntarily or under an agreement, including any compensation for redundancy or loss of employment and golden handshake payments;

    (iv) from a provident or other fund, to the extent to which the amount is not a repayment of contributions made by the employee to the fund in respect of which the employee was not entitled to a deduction; and

    (v) as consideration for an employee’s agreement to a restrictive covenant in respect of any past, present or prospective employment;

    (f) any pension or annuity, or any supplement to a pension or annuity; and

    (g) any amount chargeable to tax as “Salary” under section 14.

    (3) Where an employer agrees to pay the tax chargeable on an employee’s salary, the amount of the employee’s income chargeable under the head “Salary” shall be grossed up by the amount of tax payable by the employer.

    (4) No deduction shall be allowed for any expenditure incurred by an employee in deriving amounts chargeable to tax under the head “Salary”.

    (5) For the purposes of this Ordinance, an amount or perquisite shall be treated as received by an employee from any employment regardless of whether the amount or perquisite is paid or provided —

    (a) by the employee’s employer, an associate of the employer, or by a third party under an arrangement with the employer or an associate of the employer;

    (b) by a past employer or a prospective employer; or

    (c) to the employee or to an associate of the employee or to a third party under an agreement with the employee or an associate of the employee.

  • No claim of compensation against customs officials

    No claim of compensation against customs officials

    KARACHI: An owner of goods has not entitled for claiming compensation from customs officials for any damage done during lawful detention.

    Customs officials said that in case any consignment is detained lawfully and during detention any damage occurred to the goods unintentionally then the owner of goods cannot claim compensation for such damage.

    They said that Section 216 of Customs Act, 1969 explained as:

    Section 216: No compensation for loss or injury except on proof of neglect or willful act

    No owner of goods shall be entitled to claim from any officer of customs compensation for the loss of such goods or for damage done to them at any time while they remain or are lawfully detained in any custom-house, customs area, wharf or landing place under the charge of any officer of custom, unless it be proved that such loss or damage was occasioned by gross negligence or willful act of such officer.

    Section 214: Remission of duty and payment of compensation to the owner in certain cases

    Where, on prosecution by the owner of any goods, an officer of customs is convicted of an offence connected with the removal of such goods from the warehouse without payment of duty, the whole of the duty on such goods shall be remitted, and, the Collector of Customs, shall, in accordance with the rules, pay to the owner due compensation for the damage caused to the owner by such offence.

    Section 215: Service of order, decision, etc

    Any order or decision passed or any summons or notice issued under this Act shall be served-

    (a) by tendering the order, decision, summons or notice or sending it by registered post or the courier service or by any other mode of transmission subject to acknowledgement receipt to the person for whom it is intended or to his agent; or

    (b) if the order, decision, summons or notice cannot be served in any manner provided in clause (a), by affixing it on the notice board of the custom-house; or

    (c) in case of electronic orders, decisions, notices or summons, when these have been sent to the recipient from the Customs Computerized System.