MADINA STEEL MILLS vs FEDERATION OF PAKISTAN through Secretary, Revenue Division / Chairman, FBR, Islamabad ar

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MADINA STEEL MILLS VS FEDERATION OF PAKISTAN through Secretary, Revenue Division / Chairman, FBR, Islamabad art. 25---Maxim 'ubieadem ratio, ibi idem jus'---applicability---Where there is same reason, there is same law---Justice demands consistent treatment of similarly situated individuals. Citation Name: 2025 PTD 780 LAHORE-HIGH-COURT-LAHOREBookmark this Case MADINA STEEL MILLS VS FEDERATION OF PAKISTAN through Secretary, Revenue Division / Chairman, FBR, Islamabad Ss. 21 & 73---Sales Tax Rules, 2006, R. 12---Constitution of Pakistan, Art. 25---Constitutional petition---Principle of legitimate expectation---Applicability---De-registration, blacklisting and suspension of registration---Equal treatment of law---Petitioner / registered person was aggrieved of suspension of its registration number, despite providing documents including payment evidence under S. 73 of Sales Tax Act, 1990, and transportation records---Plea raised by petitioner / registered person was that in a similar situation registration of another company was restored---Validity---When tax authorities treat similarly situated taxpayers differently, particularly in assessment or adjustment of tax liabilities, such conduct may amount to a violation of guarantee provided under Art. 25 of the Constitution---Disparate treatment accorded to petitioner / registered person, as compared to other company, raised serious Constitutional concerns---If both taxpayers were placed in substantially similar circumstances, yet received materially different treatment from tax authorities, such inconsistency could reflect arbitrary and discriminatory exercise of administrative discretion, thereby undermining the rule of law---Administrative discretion must be exercised fairly, consistently and without arbitrariness or caprice---Principle of legitimate expectation further reinforced such notion, as taxpayers in comparable circumstances reasonably expected similar treatment from revenue authorities---High Court set aside order passed by authorities against petitioner / registered person as the same was illegal, and without lawful authority---High Court directed tax authorities to extend similar treatment to petitioner / registered person which was given to the other similarly placed entity---Constitutional petition was allowed accordingly. Citation Name: 2025 PTD 780 LAHORE-HIGH-COURT-LAHOREBookmark this Case MADINA STEEL MILLS VS FEDERATION OF PAKISTAN through Secretary, Revenue Division / Chairman, FBR, Islamabad actus curiae neminem gravabit---Meaning---an act of Court or any authority must not cause prejudice to any individual. Citation Name: 2025 PTD 780 LAHORE-HIGH-COURT-LAHOREBookmark this Case MADINA STEEL MILLS VS FEDERATION OF PAKISTAN through Secretary, Revenue Division / Chairman, FBR, Islamabad Discretion, exercise of---Scope---Exercise of discretion must be grounded in reason and fairness.

MADINA STEEL MILLS vs FEDERATION OF PAKISTAN through Secretary, Revenue Division / Chairman, FBR, Islamabad art — 2025 PTD 780 LAHORE-HIGH-COURT-LAHORE

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