COMMISSIONER INLAND REVENUE, ZONE-IV, REGIONAL TAX OFFICE, LAHORE vs UNIQUE CYCLE INDUSTRY S — 2024 PTD 158 LAHORE-HIGH-COURT-LAHORE

Case information

Citation: 2024 PTD 158 LAHORE-HIGH-COURT-LAHORE
Court: Lahore High Court
Year: 2024
Reporter: PTD
Parties: COMMISSIONER INLAND REVENUE, ZONE-IV, REGIONAL TAX OFFICE, LAHORE vs UNIQUE CYCLE INDUSTRY S
Subject matter: Tax & Customs
Provisions referred to: S. 133

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

COMMISSIONER INLAND REVENUE, ZONE-IV, REGIONAL TAX OFFICE, LAHORE VS UNIQUE CYCLE INDUSTRY S.133 (1)---Notification SRO No.670(I)/2013, dated 18-7-2013---Reference---Concessions, grant of---Principle---Input/output ratios of manufacturer---Determination---Dispute was with regard to grant of concession under Notification SRO No. 670(I)/2013 dated 18-7-2013---Validity---Reading of Notification SRO No.670(I)/2013 dated 18-7-2013 in bits and pieces would contravene the intent and purpose of statutory instrument, which purpose was grant of concession but subject to scrutiny regarding determination of input/output ratios of manufacturer---Strict adherence to requirements of Notification SRO No.670(I)/2013, dated 18-7-2013 would ensure supply of completely assembled bicycles and not the sale of parts of bicycles---This was the mischief sought to be addressed by introducing statutory instrument---Harmonious reading of subject matter conditions would ensure enforcement of Notification SRO No.670(I)/2013, dated 18-7-2013 in letter and spirit and lawful gaining of advantages / concessions extended thereunder---High Court set aside the order and remanded the matter to Appellate Tribunal Inland Revenue which had decided the matter on erroneous construction of subject matter conditions---High Court directed Appellate Tribunal Inland Revenue to decide appeal of respondent / registered person afresh upon reading conditions (i) and (ii) of Notification SRO No.670(I)/2013, dated 18-7-2013, conjunctively and not disjunctively---Reference was allowed accordingly.

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