JUDGMENT

Inaam Ameen Minhas, J.--Through the instant writ petition, the petitioner assails the condonation letter dated 16.01.2025 ("Impugned Condonation") granted by Respondent No. 2(i)/Member IR (Operations) under Section 214-A of the Income Tax Ordinance, 2001 ("Ordinance") whereby the period of limitation prescribed by the second proviso to Section 177(1) of the Ordinance was enlarged. The petitioners also seek declaration that the respondents/Federal Board of Revenue ("FBR") cannot enlarge the period of limitation prescribed by the second proviso to Section 177(1) of the Ordinance and that the audit proceedings under Section 177 pertaining to Tax Year 2019 is time barred. Lastly, the petitioners seek the interpretation of Section 214-A of the Ordinance.2. The facts of the instant petition, in brief, are that the petitioner having special tax year was selected for audit under Section 177 of the Ordinance, for the period from 01.01.2018 to 31.12.2018 ("Tax Year 2019"), by Commissioner Inland...