COMMISSIONER INLAND REVENUE, (SPECIAL ZONE FOR BUILDERS AND DEVELOPERS) REGIONAL TAX OFFICE, ISLAMABAD vs KHUDADAD HEIGHTS, ISLAMABAD S — 2025 SCMR 716 SUPREME-COURT

Case information

Citation: 2025 SCMR 716 SUPREME-COURT
Court: Supreme Court of Pakistan
Year: 2025
Reporter: SCMR
Parties: COMMISSIONER INLAND REVENUE, (SPECIAL ZONE FOR BUILDERS AND DEVELOPERS) REGIONAL TAX OFFICE, ISLAMABAD vs KHUDADAD HEIGHTS, ISLAMABAD S
Subject matter: Tax & Customs
Provisions referred to: S. 122---C

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, (SPECIAL ZONE FOR BUILDERS AND DEVELOPERS) REGIONAL TAX OFFICE, ISLAMABAD VS KHUDADAD HEIGHTS, ISLAMABAD S.122---Constitution of Pakistan, Art. 185 (3)---Re-assessment---Definite information---Credit entries in bank record---Re-assessment of net worth of respondent/taxpayer was set aside by Appellate Tribunal Inland Revenue and the order was maintained by High Court---Validity---Re-assessment proceedings were triggered on the basis of bank statement of respondent/taxpayer---All transactions in bank account did not necessarily demonstrate income of respondent/taxpayer, unless it was established that statements and/or entries therein had disclosed information of income which was 'definite'---Banking instrument could not be applied as one having 'definite information'---Neither Commissioner nor Appellate Tribunal Inland Revenue and High Court were of the view that all credit entries in statement of account disclosed income of respondent/taxpayer hence it did not constitute 'definite information'---Appellate Tribunal Inland Revenue was the last fact finding forum and such question could neither be raised in reference jurisdiction of High Court nor before Supreme Court---Supreme Court declined to interfere with judgment of High Court---Petition for leave to appeal was dismissed and leave to appeal was refused.

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