JUDGMENT

Muhammad Junaid Ghaffar, J:--- Through all these Petitions, the Petitioners have impugned Notices either under Section 177 or 122 of the Income Tax Ordinance, 2001 (Ordinance) as being unconstitutional, unlawful, and void, ab-initio.2. Learned Counsel for the Petitioners[1] have argued that these notices have been issued under the aforesaid provisions of the Ordinance read with Section 214(D) which according to them was inserted through Finance Act, 2015 and was thereafter, deleted through Finance Act 2018, whereas, after its omission, no further audit proceedings can continue. According to them in view of the judgment passed in Shah Nawaz (Pvt.) Ltd[2] a vested right has accrued to the Petitioners after omission of Section 214D and therefore, the impugned Notices arc without lawful authority. It has been further contended that Section 214-L ibid which was introduced by Finance Supplementary Act, 2018 and a holistic reading of this provision and the omission of Section 214D ibid, suppo...