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COMMISSIONER INLAND REVENUE, LAHORE vs ATTA CABLES (PVT — 2024 PTD 321 SUPREME-COURT

Case information

Citation
2024 PTD 321 SUPREME-COURT
Court
Supreme Court of Pakistan
Year
2024
Reporter
PTD
Parties
COMMISSIONER INLAND REVENUE, LAHORE vs ATTA CABLES (PVT
Subject matter
Tax & Customs
Provisions referred to
S. 214D; Income Tax Ordinance

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, LAHORE VS ATTA CABLES (PVT.) LTD., LAHORE S. 214D [since omitted]---automatic selection for audit---Scope---In the ordinary course, and in terms of other provisions of the Income Tax Ordinance, 2001 ('the Ordinance'), selection for audit is not automatic but is a result that comes about after going through various statutory filters, including such as are set out in various circulars issued by the Federal Board of Revenue---Section 214D, inasmuch as it applied automatically (subject to certain exceptions contained in its subsections (3) & (4)) and therefore bypassed the filters otherwise built into the Ordinance before an audit could be undertaken, had therefore to be construed and applied strictly---More particularly, the conditions that had to exist for the section to be attracted had to apply precisely---any deviation or discrepancy, howsoever minor, slight or even inconsequential it may otherwise appear to be would apply, and go, in favor of the taxpayer.

Other judgments reported in 2024 PTD

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