RAFHAN MAIZE PRODUCTS CO. LIMITED vs THE APPELLATE TRIBUNAL INLAND REVENUE, MULTAN — 2026 SCMR 368 SUPREME-COURT

Case information

Citation: 2026 SCMR 368 SUPREME-COURT
Court: Supreme Court of Pakistan
Year: 2026
Reporter: SCMR
Parties: RAFHAN MAIZE PRODUCTS CO. LIMITED vs THE APPELLATE TRIBUNAL INLAND REVENUE, MULTAN
Subject matter: Tax & Customs
Provisions referred to: S. 3; Sales Tax Act

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

RAFHAN MAIZE PRODUCTS CO. LIMITED VS THE APPELLATE TRIBUNAL INLAND REVENUE, MULTAN. S.3(1a)---Taxable supplies made to an entity whose registration has been suspended / blacklisted---Further tax, levy of---Scope. The petitioner, a subsidiary of a multinational company engaged in the sale of various food products, challenged adverse orders passed against it for alleged failure to pay further tax at the rate of one percent in respect of supplies made to persons treated as unregistered. The Supreme Court held that Section 3(1a) of the Sales Tax Act, 1990 forms part of the charging section of the statute. A charging provision in a fiscal law must be interpreted strictly according to its plain language and no intendment can be imported into it. The statutory requirement for levy of further tax arises only where taxable supplies are made to a person who has not obtained registration. Where the purchaser had in fact obtained registration, the subsequent suspension or blacklisting of that registration did not amount to non-registration. Such subsequent events did not satisfy the statutory condition prescribed by Section 3(1a). The recipient of the supplies was admittedly registered. Therefore, the prerequisite for levy of further tax was fully absent. Suspension or blacklisting without cancellation of registration could not attract the levy of additional tax under Section 3(1a). The Supreme Court set aside the judgment of the High Court, converted the petition for leave into an appeal and allowed the appeal.

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