SAMMAN GHEE MILLS (PVT.) LTD. vs FEDERAL BOARD OF REVENUE S — 2023 PTD 1704 LAHORE-HIGH-COURT-LAHORE

Case information

Citation: 2023 PTD 1704 LAHORE-HIGH-COURT-LAHORE
Court: Lahore High Court
Year: 2023
Reporter: PTD
Parties: SAMMAN GHEE MILLS (PVT.) LTD. vs FEDERAL BOARD OF REVENUE S
Subject matter: Tax & Customs
Provisions referred to: S. 177---; S. 177

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

SAMMAN GHEE MILLS (PVT.) LTD. VS FEDERAL BOARD OF REVENUE S. 177---audit---Collective audit of several years---Scope---Petitioner assailed the notices issued by department whereby it was selected for income tax audit for the years 2016, 2018, 2019 and 2020---Contention of petitioner was that a taxpayer once selected for audit for a particular tax year could not be selected again without giving reasonable cause and that the audit selection in terms of S. 177 of the four years was arbitrary, illegal and unlawful based on guess work---Validity---appellant was selected under S. 177(1) and reasons for its selection for audit were duly and briefly mentioned therein---Powers of Commissioner qua issuance of impugned notices were not ambiguous in any manner rather were in the letter of the law---There was nothing in S. 177 that could bar the Commissioner to issue impugned notices and conduct audit for one or more periods which come within the period of six years---appeal was dismissed.

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