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ARY COMMUNICATION LIMITED vs FEDERAL BOARD OF REVENUE S — 2026 PTD 721 KARACHI-HIGH-COURT-SINDH

Case information

Citation
2026 PTD 721 KARACHI-HIGH-COURT-SINDH
Court
Sindh High Court
Year
2026
Reporter
PTD
Parties
ARY COMMUNICATION LIMITED vs FEDERAL BOARD OF REVENUE S
Subject matter
Tax & Customs
Provisions referred to
S. 177---S; S. 177; 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

ARY COMMUNICATION LIMITED VS FEDERAL BOARD OF REVENUE S.177---Selection for audit, assailing of---Suit filed before High Court in its original jurisdiction---Maintainability---Audit proceedings---Scope---Present suit essentially seeks to assail selection for audit notices, under S. 177 of the Income Tax Ordinance, 2001, ostensibly predicated upon such specified reasons which has already been disapproved---Once a taxpayer is selected for audit and till such audit is completed the taxpayer is provided ample and multiple opportunities at every step to defend his position, support his returns and offer explanations for the information provided and entries made in the tax returns---Even if adiscrepancy is discovered taxpayer should be provided yet another opportunity to explain his position before his assessment would be revised---Such selection is not per se illegal---A mere notice seeking information is not necessarily adversarial and would not ipso facto give rise to an actionable cause---Audit proceedings provides a forum and opportunity for consideration of any reservation of the plaintiffs---If any adverse order is passed in pursuance thereof the same would be appealable---Default by the plaintiff in submitting to the statutory hierarchy can not be demonstrated to denude the statutory forum of its jurisdiction; or confer the same upon the High Court on original jurisdiction---Plaintiff (taxpayer having been selected for audit failed to demonstrate an actionable cause of action---Plaint was rejected, in circumstances.

Other judgments reported in 2026 PTD

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