SUMMIT BANK LTD. vs PROVINCE OF SINDH S — 2022 PTD 1279 KARACHI-HIGH-COURT-SINDH

Case information

Citation: 2022 PTD 1279 KARACHI-HIGH-COURT-SINDH
Court: Sindh High Court
Year: 2022
Reporter: PTD
Parties: SUMMIT BANK LTD. vs PROVINCE OF SINDH S
Subject matter: Tax & Customs
Provisions referred to: S. 23---; S. 23

Fields are extracted from the reported citation and judgment text. Where a detail is not stated in the record, it is not shown.

Judgment text as reported

SUMMIT BANK LTD. VS PROVINCE OF SINDH S.23---assessment of tax---Show-cause notice---Limitation---Scope---Petitioners assailed show-cause notices on the ground that the notices were time-barred for the reason that they were to be governed by the limitation period of 5 years applicable to them when the respective monthly sales tax returns were filed and that subsequent amendment in S.23 whereby limitation period was enhanced to 8 years was applicable only on sales tax returns filed on or after the date of amendment of law---Validity---When the amendment in S. 23 was introduced, the original limitation period in respect of all the petitioners had not expired---Had the enhancement in limitation not been brought in S.23, petitioners could have been issued show-cause notices by the department---In such a situation, it was neither a case of past and closed transaction nor of accrual of any vested right in favour of petitioners---Constitutional petitions were dismissed.

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