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PTD 2025 Sindh High Court

2025 P T D 10

SURFACTANT CHEMICAL COMPANY (PVT.) LTD. through Authorized Officer Versus FEDERATION OF PAKISTAN through Secretary, Ministry of Finance, Islamabad and 5 others
Decided Date: Constitutional Petitions Nos.D-4002 of 2019 along with C.P. No.6074 of 2021 and 774 and 2385 of 2002, decided on 12th September, 2024.
Summary: — S. 19 — Sales Tax Act (VII of 1990), Sixth Sched., Cl. 133 — Notifications SRO 65(I)/2006 dated 05-06-2006 and SRO 474(I)/2016 dated 27-06-2016 — Tax exemption — Two HS Codes — Applicability — Petitioner / importer claimed exemption from levy of cu...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

PETER C/o Messrs PETER & CO. Versus COMMISSIONER INLAND REVENUE, RTO, ISLAMABAD
Decided Date: I.T.A. No.158/IB of 2018, decided on 28th April, 2025.
Summary: — Ss.172(3)(a), 172(3)(b), 172(3)(c), 172(3)(d), 172(3)(e), 172(3)(f) & 223 — Non-resident person — Authorized / statutory representative of taxpayer, role of — Scope — A non-resident company conducted business through a branch office in Pakistan , w...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs DERA TONIGHT, MAKKI RESIDENCY, OLPER ROAD, ROHRI, DISTRICT SUKKUR Versus COMMISSIONER (APPEALS-II), SINDH REVENUE BOARD, KARACHI and another
Decided Date: Appeal No.AT-101 of 2024, decided on 8th October, 2024.
Summary: — S. 24 & Second Sched. — Sindh Sales Tax on Services Rules, 2011, R. 42(1)(a) — Constitution of Pakistan, Arts. 5 & 18 — "Restaurant services" — Registration, requirement of — Fundamental rights of taxpayer — Scope — Article 18 of the Constitution p...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs DATA RICE MILLS, INDUSTRIAL AREA, MIANWALI ROAD, QUAIDABAD KHUSHAB Versus COMMISSIONER INLAND REVENUE (WITHHOLDING ZONE), RTO, SARGODHA
Decided Date: I.T.A. No.722/IB of 2024, decided on 16th January, 2025.
Summary: — Ss. 122, 153, 161 & 233 and First Sched., Pt. IV, Division II — Payments made for expenses incurred by Taxpayer — With-holding/recovery of tax — Reported expenses — Changing by the Assessing Officer — Powers — Scope — Whether the adjudicating offic...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

COMMISSIONER INLAND REVENUE, ZONE-I, LTO, KARACHI Versus PAKISTAN STATE OIL COMPANY LIMITED, KARACHI
Decided Date: S.T.A. No.436/KB of 2019, decided on 30th May, 2025.
Summary: — Ss. 2(37) &11(5) — Supply of oil products by Oil Marketing Company (Pakistan State Oil Company Limited /PSO) — Price Differential Claim ('PDC') receipts — Non-payment of sales tax, allegation of — Tax fraud, claim of — Scope — Issuance of Show-Caus...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs LASTING KNITS C/O MUHAMMAD USMAN (LATE) Versus COMMISSIONER INLAND REVENUE, RTO, LAHORE
Decided Date: S.T.A. No.2517/LB of 2023, decided on 4th September, 2025.
Summary: — S. 53 — Death of Registered Person (individual) — Legal heirs not impleaded by Tax Authorities — Assessment order passed against dead person — Legality — Whether an assessment order is valid against a dead person? — Held: Any type of proceedings in...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

WARTSILA PAKISTAN (PVT.) LTD. Versus COMMISSIONER INLAND REVENUE, LTO, LAHORE
Decided Date: I.T.A. No.2941/LB of 2024, decided on 5th May, 2025.
Summary: — Ss. 4C, 4C(2), clause (i), 154 & 233 — "Commission" income — Super tax, chargeability of — Scope — Appellant( taxpayer/company), accruing foreign indent commission, filed income tax return for tax year 2023 which, upon scrutiny, revealed that the t...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs PAKISTAN RAILWAYS, LAHORE Versus The COMMISSIONER INLAND REVENUE, LEGAL ZONE, CTO, LAHORE
Decided Date: S.T.A. No.1977/LB of 2022, decided on 22nd August, 2025.
Summary: — S. 3 — Federal Excise Act (VII of 2005), S. 12 & Preamble — Constitution of Pakistan , Art. 264 — General Clauses Act (X of 1897), S. 6 — Central Excise Act, 1944, repeal of — Federal Excise Act, 2005, enactment of — Saving clause in the Federal Ex...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib) 1448

Messrs NISHAT CHUNIAN LTD. and another Versus COMMISSIONER INLAND REVENUE, LTU, LAHORE and another
Decided Date: I.T.As. Nos. 2106/LB and 1978/LB of 2016, decided on 2nd June, 2025.
Summary: — S. 65B as inserted vide Finance Act, 2010 and subsequently amended through Finance Act, 2012 — Tax credit for investment — Words "extension" and "expansion", addition of — Retrospective effect — Scope — Beneficial legislation — Scope — Plea of the ...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

ABDUL ALEEM KHAN FOUNDATION Versus COMMISIONER INLAND REVENUE, CTO, LAHORE
Decided Date: I.T.A. No. 2880/LB of 2023, decided on 20th December, 2025.
Summary: — Ss. 2(36)(c), 100C, 122(1) & 122(4) — Income Tax Rules, 2002, Rr. 211 to 217 — Societies Registration Act (XXI of 1860), Preamble — Non-Profit Organization — Tax credit, claim of — Restrictions / conditions — Scope — Appellant-taxpayer / NPO (havin...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

MUSTAFA AKHUND Versus DCIR, ZONE AEOI, UNIT-4, RANGE-B
Decided Date: I.T.A. No. 1483/KB of 2024, decided on 19th September, 2024.
Summary: — Ss. 111, 116(2), 122 & 176(4) — Wealth statement — Concealment of amount in foreign bank account — Addition made, assailing of — Plea of the appellant (individual taxpayer) is that his late father was a distinguished bureaucrat who, after his stint...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs RUBY STEEL CORPORATION (PVT.) LTD. Versus COMMISSIONER INLAND REVENUE, RTO, LAHORE
Decided Date: S.T.A. No.913/LB of 2024, decided on 26th May, 2025.
Summary: — S.3(1A) — SRO 648(I)/2013 dated 09.07.2013 — SRO 585(I)/2017 dated 01-07-2017 — SRO No.1223(I)/2021 dated 17-09-2021 — Taxable supplies made by steel sector — Unregistered buyers — Levy of further tax, exemption from — Scope — Kind of supplies rela...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

ANEES UR REHMAN Versus COMMISSIONER INLAND REVENUE, RTO, LAHORE
Decided Date: Income Tax Appeal No.4397/LB of 2023, decided on 23rd June, 2025.
Summary: — Ss. 107, 111(1)(b) & 111(4)(a) — Circular No. 05 of 2021 dated 30.08.2021 issued by Federal Board of Revenue — Memorandum No. EPD 30-04-2021-97865, dated 07th May 2021, issued by the State Bank of Pakistan — Non-resident, declaration of income — Do...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

SAEED TAJ DIN, LAHORE Versus COMMISSIONER INLAND REVENUE ZONE RTO, LAHORE
Decided Date: I.T.A. No.3263/LB/2024, decided on 30th August, 2024.
Summary: — Ss. 122(5A) & 236K — Deemed Assessment Order erroneous — Issuance of notices through e-mail and not by post (with acknowledgement due) — Taxpayer (a physician) assailed assessment order recorded by the Additional Commissioner Inland Revenue ('the A...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs POWERLINE TRADING COMPANY, FAISALABAD Versus COMMISSIONER INLAND REVENUE, RTO, FAISALABAD
Decided Date: S.T.A. No.272/LB/2025 and MA (Stay) No.1382/LB/2025, decided on 21st April, 2025.
Summary: — Ss. 2(14), 2(37), 3 & 8 — Tax fraud — Issuance of fake flying invoices — Input tax illegally claimed — Sales tax return, non-submission of — Due tax, non-depositing of — Mere filing of Annex-C without sales tax return — Scope and effect — Plea of t...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs MASOOD AHMED KHAN NIAZI CONTRACTOR, SARGODHA Versus COMMISSIONER INLAND REVENUE, RTO, SARGODHA
Decided Date: S.T.A. No.830/IB/2023, decided on 22nd January, 2025.
Summary: — Ss. 3 & 11 — Concealment/suppression of gross sales of supplies, allegation of — Assessment of sales tax — Basis of income tax returns — Proprietary — Tax, charging of — Essential attributes — Appellant (registered person / a contractor) approached...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs TRADE ZONE INTERNATIONAL, ROHILA MANSION, PESHAWAR Versus COMMISSIONER INLAND REVENUE, RTO, PESHAWAR
Decided Date: S.T.A. No.108/PB of 2018, decided on 21st February, 2023.
Summary: — S. 3 — Authority passing order on date not fixed for hearing — Legality — Order-in-original revealed that the same was made on a date when, admittedly, no hearing date was fixed — An order passed on the date for which no hearing date was fixed was ...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs AMIR MAJEED KHAN NIAZI Versus The DCIR, RTO, SARGODHA
Decided Date: S.T.As. Nos.396/IB and 397/IB of 2024, decided on 27th September, 2024.
Summary: — S. 3 — Tax liability, determination of — Assessment of sales tax returns on the basis of income tax returns — Charging section(s) of law — Applicability — Appellant (being a registered person involved in supply of construction material to Gawadar/ ...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs COCA-COLA EXPORT CORPORATION PAKISTAN through Authorized Representative Versus COMMISSIONER APPEALS, BALOCHISTAN REVENUE AUTHORITY and another
Decided Date: Sales Tax Appeal No.06 of 2024, decided on 26th April, 2024.
Summary: — Ss. 2(115), 2(139), 25 & 27(1) — Company having its branch office in Balochistan already registered with Punjab Revenue Authority (PRA) — Registration of such company with Balochistan Revenue Authority, requirement of — Scope — "Place of Business i...
PTD 2025 Inland Revenue Appellate Tribunal

2025 P T D (Trib

Messrs FAISALABAD ELECTRIC SUPPLY COMPANY LTD., FAISALABAD Versus The COMMISSIONER INLAND REVENUE, LARGE TAXPAYERS' OFFICE, FAISALABAD
Decided Date: S.T.A. No.09/MB/2022, decided on 25th May, 2022.
Summary: — Ss. 8(1)(a), (f), (g), (h) & (i) & 11(2) — Tax credit not allowed — Order passed on ground(s) other than those mentioned / confronted through the Show-Cause Notice — Argument of the Department was that, during scrutiny, it found Registered Person( ...