Lahore High Court
2025
THLN 6425
2025 PTD 502 | 2025 PLJ 56
Laws Cited
Income Tax Ordinance, 2001
Sections
122(5A),122(9),177,177(7)

HONDA ATLAS CARS (PAKISTAN) LIMITED

VS

FEDERAL BOARD OF REVENUE AND OTHERS

Petitioner(s) by: M/s. Waqas Ahmad Mir, Hammad Hussain and Ali Hussain Gillani, Advocates (in W.P. No. 38459 of 2021). Mr. Basharat Ali Awan, Advocate (in W.P. No. 49337 of 2021).
Respondent(s) by: Syed Zain-ul-Abedeen Advocate FBR (in W.P. No. 49337 of 2021). Mr. Ahmed Pervaiz Advocate FBR (in W.P. No. 38459 of 2021). Mr. Sheraz Zaka Assistant Attorney General.
Present: SHAMS MEHMOOD MIRZA, J.
ORDER

This order shall decide the present writ petition as well as connected Writ Petitions No. 49337 of 2021 which deal with similar legal issues.2. For the purposes of this order only the facts of the present case shall be stated.3. The petitioner has called into question notices dated 27.05.2021 and 28.05.2021 through which it has been selected for audit for the tax years 2017, 2018, 2019 and 2020 in terms of Section 177 of the Income Tax Ordinance, 2001 (the Ordinance).4. In order to support the grounds agitated in this petition, it is submitted that a number of notices were issued to the petitioner under Section 122(5A) read with Section 122(9) of the Ordinance for the tax years 2017 to 2019 on which orders were passed, and the cases are now pending before the appellate forums. It is, however, conceded that such is not the case with respect to the tax year 2020. The petitioner also referred to circular dated 05.10.2009 issued by the Federal Board of Revenue holding that a case shall be ...