2026
THLN 7964
2026 PTD 192
Laws Cited
Income Tax Ordinance, 2001 | Income Tax Recovery Rules, 2002. | Constitution of Pakistan, 1973
Sections
140 ,140(1), 137(2) | Rule 210C(3) | 10A, 14

Commissioner Inland Revenue (Legal), Islamabad (in CPLA.3578/2024) Commissioner Inland Revenue (Zone-IV), Islamabad (in CPLA.4598/2024) …Petitioner(s) (in both cases)

VS

Pakistan LNG Limited and others (in CPLA.3578/2024) Serene Air (Pvt) Limited and others (in CPLA.4598/2024) …Respondent(s) (in

Petitioner(s) by: Ms. Asma Hamid, ASC (in both cases) Dr. Ishtiaq, Director General (Law)
Respondent(s) by: Mr. Jehanzeb Awan, ASC (in CPLA.3578/2024)
Present: Mr. Justice Munib Akhtar Mrs. Justice Ayesha A. Malik Mr. Justice Shahid Waheed
JUDGMENT

These Civil Petitions are directed against judgment dated 16.04.2024 in CPLA No.3578 of 2024 and order dated 24.06.2024 in CPLA No.4598 of 2024, which relies upon the judgement dated 16.04.2024, whereby both the intra court appeals filed by the Petitioners were dismissed by the Islamabad High Court Islamabad (High Court). 2. The Respondent in CPLA No.3578 of 2024 is Pakistan LNG Limited whose income tax return for the year 2020 was amended in terms of order dated 15.03.2021 under Section 122(5A) of the Income Tax Ordinance, 2001 (Ordinance), raising a demand ofRs.2,928,517,260/- for recovery of tax due. On the same date, notice under Section 137(2) of the Ordinance was issued informing the taxpayer of the amount due. The Respondent challenged the amended assessment order before the Commissioner Inland Revenue (Appeals) (CIR Appeals) which appeal was decided on 09.03.2022 and subsequently uploaded on the web portal of the FBR (i.e., IRIS) at 3:28 pm.[1]On the same date, at 4:00 pm,...