JUDGMENT:

SHAHID KARIM, JUSTICE:-This judgment will decide a cluster of Intra Court Appeals (Appendix-I) brought by the Income Tax Department / Federal Board of Revenue (FBR) and (Appendix-II) brought by the private parties to challenge the judgment passed by a learned Single Judge of this Court in W.P No.52559 of 2022 and a large number of connected constitutional petitions which were decided by the same judgment (The Impugned Judgment). At the centre of controversy is the provisions of Section 7E in Chapter II (Section 7E) with the caption �charge of tax� in the Income Tax Ordinance, 2001 (The 2001 Ordinance) which was inserted by the Finance Act, 2022. The petitioners before the learned Single Judge (respondents in these ICAs) contended that section 7E is ultra vires the Constitution of Islamic Republic of Pakistan, 1973 (The Constitution) and beyond the powers of the National Assembly to promulgate as an impost of tax. In conclusion, the learned Single Judge held that:27. For what has been d...