PAYONEER INC., vs FEDERATION OF PAKISTAN through Secretary, Revenue Division, Ministry of Finance, Government of Pakistan, Islamabad S — 2025 SCMR 952 SUPREME-COURT

Case information

Citation: 2025 SCMR 952 SUPREME-COURT
Court: Supreme Court of Pakistan
Year: 2025
Reporter: SCMR
Parties: PAYONEER INC., vs FEDERATION OF PAKISTAN through Secretary, Revenue Division, Ministry of Finance, Government of Pakistan, Islamabad S
Subject matter: Tax & Customs
Provisions referred to: S. 114---C; Income Tax Ordinance

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

PAYONEER INC., VS FEDERATION OF PAKISTAN through Secretary, Revenue Division, Ministry of Finance, Government of Pakistan, Islamabad S. 114---Constitution of Pakistan, Arts. 185(3) & 199---Constitutional jurisdiction---Alternate and efficacious remedy---National Tax Number, issuance of---Tax non-resident, plea of---Petitioner/company was aggrieved of notice issued by tax authorities after issuing National Tax Number---High Court in exercise of Constitutional jurisdiction declined to interfere in the notice issued by authorities---Validity---Registration alone under Income Tax Ordinance, 2001 or issuance of National Tax Number does not qualify as a coercive action against any entity---No prior notice before registration would have made any difference---Supreme Court declined to interfere in judgment of High Court in Constitutional petition, which was directly assailed before Supreme Court without exhausting remedy of Intra Court Appeal---Only under exceptional circumstances, to be adjudged by Supreme Court itself, such indulgence could be extended which did not exist in the present case---Petition for leave to appeal was dismissed and leave to appeal was refused.

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