JUDGMENT

Through this Constitutional Petition, the petitioner has challenged the issuance of Show-Cause Notice No.Adj-II/Coll/SCN-312/DIT-KHI/Seizure-Cum-Cont-Rep/190-Appg-I / Saba Intl/2018 dated 10.04.2018 ("Show-Cause Notice") by Respondent No.2, seeking a declaration that it was issued illegally and without jurisdiction.2. The succinct facts leading to the captioned petition are that the petitioner is a manufacturer, importer, and exporter of textiles registered in accordance with Section 14 of the Sales Tax Act, 1990. It is claimed that, as a manufacturer, importer, and exporter of textiles, the petitioner is entitled to avail the benefit of the concessionary rate of sales tax under SRO-1125(I)/2011 dated 31.12.2011 for the determination of its sales tax and income tax liabilities. The memorandum of the petition alleges that Respondent No.2 issued the impugned Show-Cause Notice to the petitioner based on a contravention report prepared by Respondent No.3 following the seizure of two consig...