Supreme Court of India
2025
THLN 174
2025 PTD 180 | 2025 SCMR 1
Laws Cited
Sales Tax Act, 1990
Sections
7(1), 10 & 66

The COMMISSIONER INLAND REVENUE, LEGAL ZONE, LARGE TAXPAYERS OFFICE, LAHORE and another

VS

Messrs MAYFAIR SPINNING MILLS LTD

Petitioner(s) by: Ch. Muhammad Zafar Iqbal, Advocate Supreme Court assisted by Muhammad Abdul Hassan, Advocate (in C.A. No.947 of 2002) Muhammad Siddique Mirza, Advocate Supreme Court (in C.As. Nos.980-982 of 2007). Raja Muhammad Iqbal, Advocate Supreme Court (in C.A. No.224 of 2010 and C.P. No. 246 of 2009).
Respondent(s) by: Salman Akram Raja, Advocate Supreme Court along with Malik Ahsan Mahmood, Advocate Supreme Court and Malik Ghulam Sabir, Advocate High Court (in C.A. No. 947 of 2002). Dr. Muhammad Farough Naseem, Advocate Supreme Court (via video link from Karachi) Syed Naveed Amjad Andrabi, Advocate Supreme Court (in C.A. No.224 of 2010). Nemo (in C.A. No.246 of 2009). Malik Javed Iqbal Wains, Additional Attorney General for Pakistan for the Federation of Pakistan. Zubair Khan, Additional Commissioner, CTO, Lahore (via video link from Lahore) for the Department. Date of hearing: 2nd October, 2024.
Present: Yahya Afridi, Syed Hasan Azhar Rizvi and Shahid Waheed, JJ
JUDGMENT

YAHYA AFRIDI, J:--- Through this judgment, we will dispose of all the listed appeals and the petition, as they involve a common issue that was decided by the Lahore High Court and is impugned before this Court in one of the appeals, namely The Commissioner Inland Revenue, Lahore v. Mayfair Spinning Mills Ltd. (C.A. No. 947/2002). Since the said decision of the Lahore High Court was followed by the Sindh High Court, whose judgments have also been challenged before this Court in other appeals and the petition, it is appropriate to first decide Mayfair Spinning Mills Ltd. (supra). The decision rendered therein shall also apply to the resolution of the other appeals and the petition arising from the judgments of the Sindh High Court.The Commissioner Inland Revenue v. Mayfair Spinning Mills Ltd. Factual Background2.                Messrs Mayfair Spinning Mills Ltd. ("the respondent-taxpayer"), a manufacturer of cotto...