Legal experts seek clarification on blanket exemption

Legal experts have sought clarification whether blanket exemption has been announced through amnesty scheme vide SRO.333(I)/2011 to the amounts credited in the books of accounts maintained up to June 30, 2011, by the sellers suppliers, service providers to sales tax zero-rated taxpayers of five export sectors.
It is learnt here on Tuesday that the Federal Board of Revenue (FBR) has received a presentation on the amnesty granted under SRO.333(I)/2011 from a Lahore-based tax lawyer Waheed Shahzad Butt. According to the notification, SRO.333(I)/2011 has applied reduced rate of one percent withholding tax on local sales supplies and services provided or rendered to the existing registered taxpayers of five zero-rated sectors including textile, carpets, leather, footwear, surgical and sports goods.
The provisions of clause (a) of sub-section (1) of section 111 of Income Tax Ordinance shall not apply to the amounts credited in the books of accounts maintained for the period ending on the 30th June 2011, by the sellers suppliers, service providers to the categories of sales tax zero-rated taxpayers and provisions of sub-clauses (a) and (b) of the SRO.333(I)/2011 shall be applicable only to the cases of sellers, suppliers, service providers of the above mentioned categories of sales tax zero-rated taxpayers, who are already registered and to those taxpayers who get themselves registered by June 30, 2011," the FBR added.
The legal expert has asked the FBR to explain whether under sub-clause (b) of newly inserted clause 45A through SRO.333(I)/2011, a blanket exemption from the provision of Section 111(1) (a) of the Income Tax Ordinance, 2001 has been allowed to sellers, suppliers, service providers mentioned in the SRO?
Secondly, whether the sellers, suppliers, service providers mentioned in the said SRO are allowed to credit any amount in their books of accounts without paying any taxes, when neither any condition nor any limit has been prescribed under sub-clauses a & b of the notification?
Thirdly, whether to claim the benefits under sub-clause (b) of clause 45A, a single transaction with the category of taxpayers of sales tax zero rated shall be sufficient proof? Fourthly, whether the amount credited by such persons in their books of accounts up to June 30, 2011 shall be treated as income exempt from income tax in the hands of existing and new taxpayers falls under the category of sellers, suppliers, service providers mentioned in the said SRO?
Fifthly, whether any amount credited by such persons in their books of accounts prior to issuance of SRO 333(I)/2011 shall be exempt from the provisions of section 111(1)(a) of the Income Tax Ordinance, 2001?, Shahzad Butt added. Under the SRO.333(I)/2011, the rate of deduction of withholding tax under clauses (a) and (b) of sub-section (1) of section 153 shall be one percent on local sales, supplies and services provided or rendered to the following categories of sales tax zero-rated taxpayers covering textile and articles thereof; carpets; leather and articles thereof including artificial leather footwear; surgical goods and sports goods.