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SUI NORTHERN GAS PIPE LINES LIMITED vs COMMISSIONER INLAND REVENUE, LTO, LAHORE Sixth Schedule, Table-1, Sr — 2025 PTD 153 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN

Case information

Citation
2025 PTD 153 INLAND REVENUE APPELLATE TRIBUNAL OF PAKISTAN
Year
2025
Reporter
PTD
Parties
SUI NORTHERN GAS PIPE LINES LIMITED vs COMMISSIONER INLAND REVENUE, LTO, LAHORE Sixth Schedule, Table-1, Sr
Subject matter
Tax & Customs
Provisions referred to
Finance Act; Sales Tax Act

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

SUI NORTHERN GAS PIPE LINES LIMITED VS COMMISSIONER INLAND REVENUE, LTO, LAHORE Sixth Schedule, Table-1, Sr. No. 151, sub-serials (a) and (b) [as inserted by Finance Act, 2019, vide Circular No.01 of 2019]---Transposition of exemption under SRO 1212(1)/2018/ following rescindment of SROs 888, 889 and 890(I)/2018---Exemption for Federally Administrated Tribal Area /Provincially Administrated Tribal (FATA/PATA)---The underlined word "Further"---Argument of the Department was that if both sub-serials were read disjunctively it would mean that all kind of supplies were exempt from tax which was against the intent of Legislature---Circular No.01 issued by FBR, while giving explanation for reasons of insertion of S.No.151, clarified that Sr.No.151 was added and it was a transposition of exemption under SRO 1212(I)/2018; it was explained that in transposed form, it allowed further exemption on imports of industrial input including plant and machinery imported by industrial units located within tribal areas---The underlined word "further" was of much relevance, which meant exemption on imports was also granted in addition to exemptions already available under SRO 1212(I)/2018 with respect to supplies within tribal areas---Under the said SRO the Federal Government provided exemption from whole of sales tax by whatever name called as levied under Sales Tax Act, 1990---Hence, the argument of the Department was misconceived---Intent of the legislature was manifestly clear that it decided to continue the concession of exemption on sales tax as on supplies till 30th June 2024 in order to provide some breathing space to the inhabitants of FATA/PATA to merge them into the constitutional state---Appeal filed by registered person (SNGPL) was allowed, in circumstances.

Other judgments reported in 2025 PTD

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