SUI NORTHERN GAS PIPE LINES LIMITED vs COMMISSIONER INLAND REVENUE, LTO, LAHORE S

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SUI NORTHERN GAS PIPE LINES LIMITED VS COMMISSIONER INLAND REVENUE, LTO, LAHORE S. 13, Sixth Schedule, Table-1, Sr. No. 151, sub-serials (a) and (b) & Sr. 152 [as inserted by Finance Act, 2019 vide Circular No.01 of 2019]---Transposition of exemption under SRO 1212(I)/2018/ following rescindment of SROs 888, 889 and 890(1)/2018---Exemption for Federally Administrated Tribal Area / Provincially Administrated Tribal Area (FATA/PATA) area---"Supplies" as given in Serial 151 and phrase "as made till 30 June 2024"---Interpretation---Argument of the Department was that supplies of electricity had been specifically exempted vide Serial No.152 and had the legislature intended to exempt supplies of gas it would have also done so specifically---Validity---Contention of the Department was misconceived as provision envisaged in Serial No.151 was to be seen and interpreted according to its language keeping in view the background and history of the legislation---Federal Government had issued different SROs to facilitate the inhabitants of FATA/PATA to bring them within the constitutional sphere phasewise and by providing exemption on supplies as it existed prior to the 25th Constitutional Amendment and Serial No.151 is a transposition of SRO 1212(I)/2018 (now rescinded) which provided exemption from whole of sales tax by whatever name it was---Further, if the legislature in its wisdom had specifically mentioned in Serial No.152 of Table-I Sixth Schedule exemption on supplies of electricity to all consumers that did not mean that rest of all supplies were excluded from exemption specially in the presence of S.No.151 which dealt with 'supplies' also---Thus, the word "supplies" given in sub-serial (a) was an independent provision and had to operate separately by connecting with phrase "as made till 30 June 2024---Appeal filed by registered person (SNGPL) was allowed, in circumstances.

SUI NORTHERN GAS PIPE LINES LIMITED vs COMMISSIONER INLAND REVENUE, LTO, LAHORE S — 2025 PTD 153 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN

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