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COMMISSIONER INLAND REVENUE, ZONE-I, REGIONAL TAX OFFICE, SIALKOT vs WHITE GOLD STEEL MILLS, S — 2025 SCMR 1521 SUPREME-COURT

Case information

Citation
2025 SCMR 1521 SUPREME-COURT
Court
Supreme Court of Pakistan
Year
2025
Reporter
SCMR
Parties
COMMISSIONER INLAND REVENUE, ZONE-I, REGIONAL TAX OFFICE, SIALKOT vs WHITE GOLD STEEL MILLS, S
Provisions referred to
S. 221

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-I, REGIONAL TAX OFFICE, SIALKOT VS WHITE GOLD STEEL MILLS, S.I.E. DASKA S. 221(1)---Deemed assessment---Scope---Deemed assessment order is nothing other than the transmutation by legal fiction of the return created as a matter of fact by taxpayer into assessment order of Commissioner as a matter of law---Very use of deeming provision meant ipso facto that it does not fall in the category of orders that are both as a matter of fact and of law the creation of Commissioner---Any mistake in return, made as a matter of fact by taxpayer, cannot become [at any rate for purposes of section 221(1)] as a matter of law, the mistake of the Commissioner such that he can amend the deemed assessment order by rectifying it---Between taxpayer and Commissioner the mistake always lays where, and by whom, in fact it was made, i.e., the taxpayer.

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