ORDER

SHAHID WAHEED, JUSTICE:---The unsuccessful taxpayer has brought this appeal by leave of this Court to challenge the opinion recorded by a Division Bench of the Lahore High Court on the reference of the Revenue's questions emanating from the judgment made by the Appellate Tribunal for Inland Revenue (the Tribunal).2. The short question in this appeal concerns the foundation of the proceedings taken out by the Revenue under section 161, read with section 205 of the Income Tax Ordinance, 2001 (the Ordinance). The taxpayer's primary concern centred on a legal principle established by this Court in the case of MCB Bank[1] (the MCB), which governs the application of section 161 of the Ordinance. The taxpayer strongly contended that this principle must be adhered to rigorously and without compromise. The taxpayer argued that any legal proceedings that stray from this foundational safeguard could potentially render any resulting order—declaring it in default of its tax obligations—utterly ...