S. Tax (Total) Flashcards
S. TAX
1
Q
input tax disallowance
A
11 conditions
+
Following goods supplied by Reg. person to unregistered (I/P of reg. shall be disallowed)
- filter rods for cigarettes
- A/C, chilling, humidification PLANTS
- Cranes
- storage tangs, gas separaters, heat exchangers
- artificial filament tow
- polypropylene granules
2
Q
Sec 73 Payment
A
3
Q
Residual Tax Apportionment Rules
A
Chap IV of Sales Tax Rules 2006
4
Q
6th Schedule - Exempt Suplies
A
5
Q
Exempt Goods - Manufacturer vs Other (In house & Pvt Consumption)
A
6
Q
In the case Exempt goods are exported…….Would they be zero rated??
A
Yes - Man
No - Other
7
Q
What is similarity & diff b/w Exempt goods and Zero Rated Goods
A
Tax Zero Rated Exempt
Out put charge?? No No
Input claim?? Yes No
8
Q
ZERO RATING
A
9
Q
What is Retail Price u/S. Tax
A
Manufacturer’s Price @ which goods to be sold to consumers xxx
All duties, charges, taxes xxx
(OTHER THAN SALES TAX) —–
Retail Price XX
*Sales price to general body of customers
**More than one such prices, highest out of them (Board has option to select such zones for highest price)
10
Q
Retail Price sales Tax - 3rd Schedule
A
11
Q
8th Schedule
A
6th
8th
5th (zero rate)
3rd (Retail price by man)
Raw cotton and ginned cotton
Local
Imported – 5%
Plant and machinery
Imported plant, machinery, equipment and apparatus, including capital goods,
not listed in the locally manufactured items,
- BMR - desalination plants, coal firing system, gas processing plants and oil and gas field prospecting.
- Medical by hospitals, etc
- mine construction phase or extraction phase.
- imported for Thar Coal Field
- Initial or BMR -power generation, power transmission and grid stations including under construction projects
- education and research related items imported by technical, training institutes, research institutes, schools, colleges and universities
- marble, granite and gem stone extraction and processing industries
- Solar
- renewable energy technologies or for conservation of energy
- manufacturing LED light
- production of bio-diesel – 5%
- Post-harvest handling and processing – 7%
- poultry sector- 7%
- mine exploration phase – 5%
- Initial & BMR - oil refining (mineral oil, hydro- cracking and other value added petroleum products - 10%
- Milk related plants – 5%
Locally man. To EPZ (Operated by power)
Milk
- Imported milk
- Milk and cream other than retail under brand
- Flavored milk -Other than retail
- Fat filled
- Milk and cream - retail under brand – 10%
- Flavored milk - retail u/brand name – 10%
Milky drinks
Yogurt, cheese, cream, butter, desi ghee, whey
Same like milk
Same like milk – 10%
Poultry cattle seed
Feed
Ingredients of feed – 10%
Temporary export, re-imported
10% (foreign origin goods)
Not zero rated – exception to zero rating
Important - other
TV set top boxes – 5%
Gas/LNG to fertilizer – 5%
Fish feed – 10%
6th
8th
5th (zero rate)
3rd (Retail price by man)
Raw cotton and ginned cotton
Local
Imported – 5%
Plant and machinery
Imported plant, machinery, equipment and apparatus, including capital goods,
not listed in the locally manufactured items,
BMR - desalination plants, coal firing system, gas processing plants and oil and gas field prospecting.
Medical by hospitals, etc
mine construction phase or extraction phase.
imported for Thar Coal Field
Initial or BMR -power generation, power transmission and grid stations including under construction projects
education and research related items imported by technical, training institutes, research institutes, schools, colleges and universities
marble, granite and gem stone extraction and processing industries
Solar
renewable energy technologies or for conservation of energy
manufacturing LED light
production of bio-diesel – 5%
Post-harvest handling and processing – 7%
poultry sector- 7%
mine exploration phase – 5%
Initial & BMR - oil refining (mineral oil, hydro- cracking and other value added petroleum products - 10%
Milk related plants – 5%
Locally man. To EPZ (Operated by power)
Milk
Imported milk
Milk and cream other than retail under brand
Flavored milk -Other than retail
Fat filled
Milk and cream - retail under brand – 10%
Flavored milk - retail u/brand name – 10%
Milky drinks
Yogurt, cheese, cream, butter, desi ghee, whey
Same like milk
Same like milk – 10%
Poultry cattle seed
Feed
Ingredients of feed – 10%
Temporary export, re-imported
10% (foreign origin goods)
Not zero rated – exception to zero rating
Important - other
TV set top boxes – 5%
Gas/LNG to fertilizer – 5%
Fish feed – 10%
12
Q
Importers - Types
A
- Commercial Importer
- Manufacturer Importer for In-house consumption
- Service provider for In house consumption
- POL products
13
Q
Importers & Minimum Value Addition Tax - 1
A
14
Q
Commercial Importer Rules
A
15
Q
Commercial Importer Example (No refund only carry forward)
A
16
Q
How can the Min Value Addition Tax paid by Commercial Importer be refunded
A
Never
Any Excess - To be C/F
C/F period not mentioned by law
17
Q
Commercial Importer Return frequency
A
MONTHLY
18
Q
Vehicle Dealer -Special Procedure Concept
A
19
Q
Vehicle Dealer - Special Procedure Rules Summary (6 Points)
A
- All dealers to register (old/new vehicles;comissioned/non-comissioned;local/imported)
- Booking document of man. /imp - particulars of dealer
- Man/Imp delare to comissioner - comission structure
- Invoice - by Man. to Buyer if By Man to Dealer, dealer to issue ST Invoice to customer (delivery cum invoice)
- Adjustment of I/P O/P in the normal manner
- Own amount ST to be charged by dealer
20
Q
P & M IMPORT
A
- Rate= Reduced (10%)
Conditions:
- No compatible local substitute
- If By Reg. Man. for own use
- PDC diff. tax (17-10%) with customs auth.
- Cheque return after 1st ST return after import
- Subs. supply to comm. regime or unreg. person - pay ST at normal rate - 17%
- Subs. supply to registered person - 10%
4.If by Comm. importer
- BG/chequ/pay order/cash diff. tax (17-10%) with customs auth.
- Cheque return after evidence of next supply to a reg. person
- Supply to unreg. person -liability to payment @ full rate
21
Q
Which sales Tax Rate - Timing
A
Time???
22
Q
Which Rate (2) Changes in ST Rate -Imports
A
23
Q
REFUND ON ZERO RATE
A
- In Q, any defult sur., penalty, etc etc under any (tax) law to FBR—–deduct from refund instead of adding to liability
- Any incoming/receipt from FBR for delay in refund(@KIBOR) taxable income u/Income from Other sources
- Within 45 days of return
- Adjustment if d/s+penalty
- Reason to believe - incorrect claim / refund—–proceedings 120D …..inquiry by AC—-Board may extend 9M
- Delay refund @KIBOR/annum (Income from other sources.
24
Q
90% Input Tax Restriction Impact &
Treatment
A
- Lower Profit Margin - Pay 10% of Output to FBR
- Input (Purchases) more than O/P due to reasons
- Overbuying (closing stock)
- Loss
- Not entitled to refund rather paying 10% of O/P to FBR
25
What happens to Un-adjusted Input carried forward (due to 90 pc rest)
Direct Addition to next month's Input?
How long C/F
e.g C/F from Jan to Feb - not to be added to Feb's Input directly
1st calc. claimable I/P of Feb (i.e.after apportionment of Feb)
Procedure in Jan
1. separate perm. disallowance (e.g cash payment, unreg. gifts, assets)
2. Apportion b/w exempt, zero, other.......exempt separate, zero for refund appl.blance other is claimable.
3. Make two portions Fixed Assets & Other
4. Apply 90% rest _w.r.t - others_. (No restriction of 90% for Fixed Assets)
4. C/F to Feb
5. In Feb perform steps_1-3_ and calc claimable I/P tax; add C/Forwarded claimable of Jan
6. Apply 90% test to Other than Fixed Assets(Jan C/F+Feb claimable) - C/F excess
26
How long to C/F unadjusted claimable I/P
Reason - overbuying/closing stock - Automatic adjustment once sold in coming months
Reasong - low profit margins - 180D - Application & Procedure
27
90% Restriction & Fixed Assets
* Fixed Asset ? Machinery & Fiscal Cash Register
* 90% restriction does not apply
* Make two portions of Input......FA & Others
* Apportion
* First deduct _others_ and apply 90% test
* Then deduct FA I/P (Liability may be reduced less than 10%)
28
Input Tax Restriction (90%)
Q & A
29
Exceptions to 90% restriction
OR
Dedcution of Input from Out without any restriction
Indurty Specific - Person Type
Persons
* Distributor
* Wholesale-cum retailer (_Not_ wholesaler)
* Zero rate supplier - _whole entity_ (zero rate:local ration 50.01:49.9) i.e. no 90% restriction for local supply even
* Zero rate supplier - _Zero rate only_ (zero rate:local ration 49.9:50.01) i.e. 90% restriction for local supply
* Comm. Imp. - _whole entity_ (zero rate:local ration 50.01:49.9) i.e. no 90% restriction for local supply even
* Comm. Imp. - _Zero rate only_ (zero rate:local ration 49.9:50.01) i.e. 90% restriction for local supply
* subject to reduced rates u/_SRO 1125 of 2011_
_In the exam Q - calculate ratio of local and comm. and/or zero rate_
Industry (Elect, gasoil marketing, refineries, fertilizer, edible oil, telecom)
30
Difference between Wholesaler - Distributor - Wholesaler-cum-distributor
Key Important Points
* No restriction (90%) for Dist & wholesale-cum Ret. but restriction (90%) for wholesaler.
* _Minimum margin for W/S 10%_ - otherwise C/F & _Cash flow remain invested/stuck_
* Dist vs wholesaler ---------Area specific & comission
* wholesale cum retailer ----Import, supply to both wholesale & retail
31
Sales Tax Withholding Agents
* GOVERNMENT (Fed, Prov, Autonomous bodies e.g NEPRA NAB PCP, public sector org)
* COMPANIES
* AOP - Exporter only (_not zero arted)_
* Individual - Exporter only (_not zero arted)_
32
SALES TAX WITHHELD treatment (add/deduct)
Exam Q
Deduct -from Liability if our deducted (Exam Q mentions withholding BUYER details e.g Co, exporter, etc etc)
Add -to (bottom) Liability based upon Exam Q details supply made to e.g Co, exporter, etc etc)
33
ST Withholding Rates
* What does unregistered means........LIABLE to be regsitered (therefore cottage industry does not fall in category)
* Supply to Unregistered??
* Supply to Registered Wholesaler, dealer
* Supply to Registered Importer
* Supply to Registered Man.
34
Withholding Tax % to be applied to which amount??
Registered person?
Unregistered Person?
Unregistered Person ---------- Value of taxable SUPPLY
Registered Person-----Amount of Sales Tax
35
When to Deposit ST Withheld
Alongwith the return of ST of the _period inwhich the purchase has been made_
_IRRESPECTIVE_ whether PAYMENT MADE or NOT
36
100% W/H ST Deduction
* _Advertisement_ Services
* from Service Provider in Pakistan or Abroad
37
Exceptions to WH ST deductions
1. 3rd Schedule
2. Commercial import supplies (where comm. importer have paid Value added tax)
3. Utilities (Elect, gas, phone
4. Specific supplies (pertroleum prod, vegetable ghee, cooking oil
38
Definitions - Goods (What is subject to ST)
3 itesm
* Immovable (Land/build)........No ST
* Movable - Actionable claims (A/R, Prom. Note, etc------No ST
* Movable -Others (Movable)-----Subject to ST
{Diff b/w Share & Stock.....Singular Plural)
39
Definitions - Input Tax
Local Supply (Accrual)
+
Import (Paid)
+
_FED_ (in VAT mode, manuf/services)
+
Provincial ST on services (courier,clearing,forwarding)
+
AJK ST paid
40
Definitions - Manufacture or Produce
PRACTICALLY WHEN MACHINES ARE INVOLVED
* Conversion
* Changed / Reshaped / capable of being used differently (DVD, wood----duster)
* incidental process (Toll manuf.)
* printing/pub/lith/engrav
* assembling/mix/cut/dilut/bottl/packag/repackag
41
Definition- Manfacturere / Producer
Engaged in Man/Prod
+
Toll Man. which is like service provider (i.e. Man. whether or not RM owned).....Toll Man (u/ITO services; u/ST manuf)
+
Holder/user of patent, other prop rights
+
Assignee/trustee/liquidator (Manf. during) in bankruptcy/liquidacy who disposes off assets in bankruptcy
42
Definitions - Supply
Check examples from book also
* Sale
* _Transfer_ of right to ownership (exchange, gifts)
* Manufacturer _USES_ own goods
* Pvt use
* Non-biz use (to employees)
* In-house consumption (components in manuf) [exempt supply if final goods are taxable.
* Disposal _to satisfy debt_ (goods as consideration)
* Auction _to satisfy debt_ (goods as consideration).......s.tax, in this case, belongs to owner of goods as bank, etc are acting on behalf
* _Stock in trade (not yet sold, charge o/p tax) De-registration_ (stock immidiately held before)
* _Stock in trade (not yet sold, charge o/p tax) Change in Reg_. (stock immidiately held before) category e.g. retailer changes shop from mall to outside, etc
* Goods owned/belonging to others, transfer of same to owner - _Toll Manuf.-_ Manufacture of goods belonging to others
43
Definitions - Supply (Diff. between Hire Purchase - Lease - Installment Sales)
What is supply in these cases & are they subject to ST
* Installment sales - Goods (ownership) transferred .....payment in installments---Normal sales
* Hire Purchase (lease but not by an entity established under leasing related laws) - mentioned separately as title is not transferred at the time of sales.....transfer happens at the end of contract/arrangement
* Leasing and Hire Purchase arrangements are same, Title is not transferred hence not supply; however leasing biz is under separte laws/rules related to leasing business - not included in the definition of supply specifially as for Hire Purchase
so supply not supply not subject to ST (i.e. not in the definition of supply)
Installment sales - Supply & Subject to ST
Hire Purchase - Supply and specifically included in the definition of supply.
Leasing - Not Supply and not subject to ST
44
Definitions - Taxable Supply
Taxable Supply (other thn exempt)
+
Taxable Activity
45
Definition - Taxable Activity
* Biz/Trade/Man
* Supply of goods
* Supply of services
* Supply of goods & services both
* One off
* anything done during commencement and termination of economic activity
EXCLUSIONS:
* Employment
* Private recreational pursuit or hobby
Restaurant vs Silani Center (Charity Org) - both making food
If both provide free food to needy.......Restaurant's provision of free supply is taxable activity as the business is commercial activity while silani is not comm. activity
46
What are _taxable goods and services_
What is Taxable supply
Goods --- ALL except exempt
Services ----- Specified only
Conclusion: any x goods taxable - yes (if they are not exempt)
teaching services taxable - NO as not sepcified in law
Taxable supply: Supply of _taxable goods_ including zero rated excluding exempt
47
Definitions - Tax Fraction
How much is ST if Value including ST is "X"
%of ST divided by (% of ST+100%) x value including ST
Figs in fraction
48
Definitions - Time of Supply
1. Delivered
2. Notified (set aside and informed)
3. Paid (means if advance paid, whether notified, delivered or not: separate document advance payment receipt like ST Invoice)
4. Associate - made available (Advance is not supply)
5. Hire Purchase - Date of Agreement (Advance & Delivery irrelevant)
important as EFFECTS AMOUNT OF O/P in return..........O/P in Jan-Jan's return
Delivered - Notified - Paid whichever is earlier
49
Definitions (Value of Supply related)
What are discounts shown on Invoice
A. Invoice - @net of discount value
1. Normal _trade_ discount
2. _Quantity_ discount
1. Different levels of disc wrt quantum
2. free items for certain quantity purchased e.g 4+1=5 (20%)
3. _Cash Purchase_ discount
B. Invoice - not net of discount value/disc _not shown on Invoice_
1. _Early Payment_
C. _3rd schedule_ items - _No concept_ of discount
50
Definitions -Value of Supply
* Normal (Consid+all taxes excl. ST)
* By FBR (higher of actual or FBR i.e. FBR value 'll be considered min. value) - locally produced coal SRO 532 11062000
* Net of discount _if_ shown _on Invoice_ (i.e. other than early payment and 3rd schedule) and discount i_n conformity with normal biz practice_. [Net of disc. value means ST to be applied to Net of disc. value e.g gross 100, net of disc. 97: ST on 97]
* Freight/delivery charges receoverable from receipient - (FBR circular letter dtd 22-4-99, consideration is for supply and not for bare goods) Supplier's Own vehicles Vale= Value+freight/delivery
value of goods 100;freight 5....value of supply=105
If on hire transport Co. shall directly invoice in receipient's name
* Consideration in Kind (partial or full) - Open mkt price
* Installment price (including mark up) - open mkt price (i.e. mark up not subject to ST, as mark up represents longer credit compared with short credit)
* Imported Goods - VoS=Value+customs+FED (while value for Adv tax: Value+customs+FED+ST)
* Exempt Goods for Toll Manuf. - Mkt price excl ST
* Undervalued (reason to believe) - comissioner report to FBR, FBR valuation committee (Sales Tax Deptt+Trade Assoc. Rep)- Value by Committee.
* Between associates - higher of normal or mkt
51
Definition - Output Tax
Supply made (sales)
+
FED (in VAT mode) on manuf/services
+
Prov. ST on services rendered
52
Definitions -Registered Person
Registered
+
Liable to be registered
(such person 'll not be entitled to benifits available to registered)
(Impact: A Manuf. where comissioner considers TO above 5M and this limit crossed since last 5-6 months, they 'll consider this manuf. as back-dated registered and require o/p related to last 5-6 months' sales however 'll not allow input claim against this o/p as not entitled to any benifit as not registered)
[Power misusage risk]
53
Definitions- Tax Fraud
Knowingly, Dishonestly, Fraudulently
1. Act/Omission with intention (contravention to law)
1. understate tax lib two periods
2. Overstate tax credit/refund
2. making Taxable supply w/out registration
3. Falsifying ST Invoices
54
Definitions-Tax Invoice
1. Serially No.
2. Supplier - Name, Address-NTN
3. Recepient - Name, Address-NTN
4. Desc. of goods
5. Qt. of goods
6. Value excl. tax
7. Tax
8. Value Incl. Tax
* Invoice can be sent electronically b/w registered persons (i.e. both registered)
* one invoice for one supply
55
Definitions - Advance Receipt Procedure
ST Order 1 of 2006
_INPUT_ CAN NOT BE CLAIMED IF NOT ISSUED AS PER PRESCRIBED FORMAT AND RULES
Rules:
1. Charge ST on Advance Received; Include in O/P for return in the period reecived.
2. Invoice - "Advance Payment Receipt" - Serially Number - Format - Tax
3. Later When actual supply no tax related to previous; Mention related receipt number and date on Invoice
4. Later supply cancelled, value changes
1. issue credit not for adjustment
2. Adjust O/P in return of the month adjustments happens (no time limit, if tax already deposited related to advance)
56
Supply Parts Under Warranty
Charge ST or not
57
Free Additional Promotional Items
Charge ST or not
1. General Rule: Free supply is taxable
2. However This can be taken as Qt Discount, so ST on net value e.g 2+1 ST on Value of 2 [if in confirmity w/normal biz practice]
3. if items relate to 3rd schedule (e.g fruit juices) - no concept of ST, ST on retail price
58
Debit & Credit Note
* When
* Types: Sales Return, Purchase Return:?
* Max Time for Adjustment: ?
* Who to Make
* Particulars
* Where Supplier Reg. Receipient Unreg??
* where such goods are sub. resupplied
* If goods (returned) were returned being unfit e.g. expiry date & destroyed
* When?
1. Cancellation
2. Return
3. CHANGE in nature
4. CHANGE in value
5. other such events
* Credit Note, Debit Note
* 180D (may be extended for special reasons;comissioner)
* Both Parties to make for a particular supply
* Name & NTN of both;Original ST Inv- No. date,qt,value,amount;reason for issuance;sign&seal;qt being returned;original revised&diff.
* adj. only by supplier through Cr
* ST in normal way
* No I/P; No O/P------Goods to be destroyed u/supervision of ST Deptt.
59
* Return
1. Normal
2. Reg-Unreg.
3. _Unfit_ supply (This case is not due difference in required specifications: Example of this case may be that returned goods can not be resold/resupplied e.g due to expiry date, etc)
* Subsequest _Destroy_; e.g fire in warehouse, etc (LHC decision Mayfair Spinning Mills, PTCL2002 CL 115)
* _Wastage_ of RM during Manuf. (1989 circular FBR)
of Goods
* Return
1. Issue DR/CR both (reduce from O/P & I/P)
2. Reg. to issue DR/CR only
3. (This case is not due difference in required specifications) No I/P or O/P by _seller_ i.e. _Both IPOP_ of seller(receipient off course 'll reverse I/P):destroy in presence of ST deptt.
* I/P can be claimed
* Wastage
1. not saleable - I/P can be claimed
2. saleable - By product - chargeable to ST
practically wastage issue is debateable as verifiable or not?
60
Delivery of Goods to Insurance Company against insurance claim constitutes a taxable supply
Destruction of goods (totally0 an dsubsequent compensation by Insurance Company does not constitute Supply (as per definition of supply)
* Not sale
* not done in the normal course of biz
* Payment (by ins. Co.) is compen. for loss and not payment/consid. for delivery of goods.
61
Refund Procedure
CORPORATE ENTITY
Furnishing Audited FS
If
Input not settled through C/F
Refund claim - Time Limit (not claimed in the relevant tax period)
* Furnish
1. statement duly certified by auditors+
2. Annual audited FS showing i/p\>90% of O/P
* Refund on yearly basis in 2nd month following the end of Co's fin. year
Auditor guily-refer ICAP council for disciplinary action
Refund claim - Time Limit (not claimed in the relevant tax period) - _within 1 YEAR_
62
Goods - Registered can not supply to Registered
Consequence: Input of Registered shall be _disallowed, even he purchased/procured supply from registered_
_OR_
_Prohibited supplies for Registered Person_
Sec 8(6) SRO 488 of 2004
Following goods supplied by Reg. person to unregistered (I/P of unreg. shall be disallowed)
1. filter rods for cigarettes
2. A/C, chilling, humidification PLANTS
3. Cranes
4. storage tangs, gas separaters, heat exchangers
5. artificial filament tow
6. polypropylene granules
Does not apply to supply to end user, govt, etc
63
Input claim related to
STOCK PURCHASED before Registration (Sec 59)
* complete Registration Within
1. 30D - local
2. 90D - Import
3. Stock verfiable
4. Stock unsold
CLAIM on UNSOLD/UNUSED stock
64
VALUE ADDITION ------SEC 7A
NOT PRACTICALLY IMPLEMENTED
Charge tax on value addition only.......specially important where RM/input supply is exempt and FG/output taxable
Currently where Input supply is exempt no tax on purchase but taxed when output/sales
65
* What is TOLL MANUFACTURING
* CHARGEABILITY OF TAX
1. SRO 1125 items
2. RM & FG Both exempt (e.g Pharmaceuticals)
3. Both RM & FG taxable
4. RM exempt, FG Taxable (e.g RM: Red Chilli, FG: Red Chilli Powder is exempt u/Sr16 Tbl1 6th Sch)
* Compare diff b/w Cat. 3 & Cat. 4
* Is vendor manufacturer or service provider in Toll Manuf.
* What is value of supply
* How 'll the toll manuf. of 3rd schedule items be treated
* What about Toll Manuf. of zero rated items
* RM supplied to vendor by Principal;FG returned to Pincipal by vendor
*
1. 3% on conversion charges
2. NO ST
3. ST on _conversion charges_
4. ST on market value of _total supply (_as per _definition_ of _value of suppl)_
* Vendor is manuf. as per Mauf. defi.
* Conversion charges
* 3rd schedule items Toll manuf. under the ame principle. Vendor ST on conv. charges while manufacturer on retail price.
* Toll Manuf. of zero rated items - in same way as zero rated items
66
Sale of Taxable Business (Activity)
or
Transfer of ownership
1. From Reg. person to Unreg. Person
2. From Reg. person to Reg. Person
1. On Stock (i.e. possession of taxable supply)- Reg. person shall account for and pay ST (otherwise transferee shall have to pay.
2. By Transferee
67
Excess Tax Collection
Sec 3B
1. What is excess
2. If incidence passed on to consumer
3. IF incidence not passed on
1. Not collectable or collected (excess output) mistakenly
2. Deposit with Govt. (no claim of refund wrt this amount shall be acceptable)
3. Return to payer (however proof of incidence shall be with the collector)
68
SALES TAX - JOINT & SEVERAL LIABILITY
OF
REGISTERED PERSONS
IN
THE SUPPLY CHAIN
WHERE ST IS UNPAID
CONDITIONS
* BURDEN OF PROOF RESTS WITH FBR
* REG. PURCHASES FROM REG
* IN KNOWLEGE / HAS RESONABLE GROUNDS
* CURRENT/PREVIOUS/SUBSEQUESNT SUPPLY
* ST WILL REMAIN UNPAID
* BOTH (HAVING KNOWLEDGE & SUPPLYING AND RECEIVER) - JOINTLY AND SEVERALY LIABLE FOR UNPAID TAX
* BOARD MAY EXEMPT
