JUDGMENT:

AGHA FAISAL, JUSTICE:---The issue before us was the withdrawal of exemption from taxation in respect of inter-corporate dividends. It was the petitioners' case that the exemption ought to perpetuate ad infinitum, notwithstanding the omission thereof in the statute. The respondents disagreed and argued that the exemption remained valid during its tenancy on the statute book and under no stretch of interpretation could it be construed to perpetuate infinitely, especially since the same had consciously been omitted from the statute.The present petitions were advocated to the remit delineated supra2 and dismissed vide short order, announced in Court at the conclusion of the final hearing on 28.02.2023. These are the reasons for our short order.Factual context2. The benefit of group relief was introduced into the Income Tax Ordinance, 2001 ("Ordinance") by insertion of section 59B3 ("59B") therein, vide the Finance Act, 2004. Through successive amendments the scope of the provision was vari...