ORDER

Three connected Tax References were decided by the impugned consolidated judgment dated 16.10.2024 passed by the Peshawar High Court, Peshawar, whereby the petitioner was denied the exemption to pay tax on the income so derived.2. We have heard the learned counsel for the parties and perused the material available on record. The petitioner, being Frontier Constabulary Security Services is a Private Limited Company and derived income by providing security services as its only prime business. The matter pertained to the tax years 2007, 2008 and 2009, wherein the petitioner sought exemption from income tax under sub-clause (2)(i) of clause (58) of Part-I of the Second Schedule to the Income Tax Ordinance, 2001 (hereinafter referred to as ‘the Ordinance'). It is urged that petitioner is wholly owned by Frontier Constabulary Foundation, which itself enjoying exemption from income vide Special Education and Social Welfare Division SRO 205 (I)/86 dated 24.02.1986. Thus, in consequence there...