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FAZAL PAPER MILLS (PVT.) LIMITED vs FEDERATION OF PAKISTAN Ss — 2026 PTD 458 LAHORE-HIGH-COURT-LAHORE

Case information

Citation
2026 PTD 458 LAHORE-HIGH-COURT-LAHORE
Court
Lahore High Court
Year
2026
Reporter
PTD
Parties
FAZAL PAPER MILLS (PVT.) LIMITED vs FEDERATION OF PAKISTAN Ss
Subject matter
Tax & Customs
Provisions referred to
S. 177; S. 122; 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

FAZAL PAPER MILLS (PVT.) LIMITED VS FEDERATION OF PAKISTAN Ss.122(9), 177(1), 214-C & Second Schedule, Part IV, Clause 72B---Constitution of Pakistan, Art. 199---Constitutional petition---Petitioner / taxpayer assailed notice selecting its case for audit---Validity---Notice under S. 177(6) of Income Tax Ordinance, 2001 was issued on 20-05-2017, as the audit was to be conducted within the financial year---Completion of audit lingered due to failing of petitioner/taxpayer to convey concerns, as required under S. 177(6) of Income Tax Ordinance, 2001---No concerns were raised to the audit except a plea that it should be completed by 30-06-2017---No such construction could be attributed to S.177(6) of Income Tax Ordinance, 2001 which manifested and envisaged that concerns were invited on audit report---Taxpayer had no objections regarding conduct of audit and preparation of report thereby---Proceedings for audit concluded for all intent and purposes, and stage to amend assessment of the latest tax year had triggered and authorities issued notice under Ss. 122(9) & 111(1) of Income Tax Ordinance, 2001---No objection was raised by petitioner / taxpayer that the notice was beyond limitation provided in S.122 of Income Tax Ordinance, 2001---Petitioner / taxpayer failed to explain as to why response to notice dated 17-09-2021 was not filed and instead Constitutional petition was instituted---High Court in exercise of Constitution jurisdiction declined to interfere in the matter as there was no jurisdictional defect in issuance of notice dated 17-09-2021 and petitioner/taxpayer lacked cooperation / facilitation, to raise concerns to the audit report---Constitutional petition was dismissed in circumstances.

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