JUDGMENT

Through this constitutional petition filed under Article 199 of the Constitution of Islamic Republic of Pakistan (Constitution), the petitioner has brought a challenge to the order dated 09.02.2023 (Impugned Order) passed under section 74 of the Sales Tax Act, 1990 (Act, 1990) read with section 43(2) of the Federal Excise Act, 2005 (Act, 2005). A collateral challenge is also laid to show cause notices bearing No.LTO/ST/U-3/R-II/23/8809 & No.LTO/ST/U-3/R-II/23/8808, both issued on 23.05.2023 (the "Show Cause Notices") on the premise that since Show Cause Notices are a direct and inseparable offshoot of the Impugned Order, therefore, the same cannot sustain if the Impugned Order falls to the ground due to inherent and palpable defect of jurisdiction.2. Learned counsel for the petitioner while laying confrontal attack to the vires of the Impugned Order has argued that the Impugned Order is not sustainable on any standards of Principles of Administration of Justice as the same is witho...