ORDER:

RAHEEL KAMRAN, JUSTICE:---In this petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973 (Constitution), the petitioner has assailed the recovery made by the Inland Revenue Officer-respondent No.5 from the Bank Accounts maintained by the petitioner at National Bank of Pakistan, Model Town Branch, Lahore and Bank Al-Falah, Shadman Branch, Lahore pursuant to the notice dated 31.05.2024 (erroneously mentioned as 31.05.2023 on account of typographical therein) in purported exercise of authority under Section 140 of the Income Tax Ordinance, 2001 (Ordinance).2. Learned counsel for the petitioner contends that the impugned recovery made under Section 140 of the Ordinance is manifestly in violation of the proviso to subsection (1) of Section 140 of the Ordinance thus without lawful authority and of no legal effect. He maintains that even otherwise recovery could not be effected by the revenue authorities from the petitioner during pendency of its appeal under Sec...