ORDER

MR. JUSTICE SYED MANSOOR ALI SHAH:---.---(1). These cases pertain to the tax period: February 2016 to December 2017. The facts are that due to certain reasons the respondent taxpayers filed late income tax return, as a consequence a penalty under Section 33(1) and (5) as well as additional surcharge under Section 34 of the Sales Tax Act, 1990, (‘Act, 1990') was imposed on them through the assessment order 13.06.2016. The respondent taxpayer filed an appeal against the said assessment order, which was allowed dated 09.09.2016, holding that the taxpayer is not liable to pay the penalty or the additional surcharge as failure to pay was not "willful". The same view was upheld by the Tribunal vide its judgment dated 05.01.2018 and through the impugned judgment of the Sindh High Court dated 06.05.2022.2. Learned counsel for the petitioner submits that the High Court and the forums below have failed to appreciate that the amendment was brought about in Section 34 of the Act, 1990, through F...