ORDER:

On 28.02.2017 Additional Commissioner Enf-III of PRA, Lahore issued show cause notice to M/s Pakistan State Oil Company Ltd. (The Appellant). In the show cause notice the appellant was treated as a withholding agent in terms of Rule 2 of PSTS (Withholding) Rules 2015. The notice further stated that during the period from July 2015 to June 2016, the appellant recei ved taxable services from various commission agents and that under sections 14 and 19 of the PSTSA, 2012 (The Act) read with Rules 4, 5, 6, and 13 of Rules ibid, the appellant was legally bound to withhold/deduct and deposit the due amount of sales tax on services but failed to comply with the statutory obligations. Detail of the services were as under. Sr.No.Service CategoryIncome Tax Withheld @ 12%TotalCommissionPaidPST Payable1.Commission agents (Sr.No.42 to 2nd Schedule)1,693,676,805/-14,113,973,375/-2,258,235,740/-The show-cause notice charged the appellant with the violation of different provisions of The Act, as m...