SUMMARY

1. Admitted Violations:o Appellant filed Annex-C (showing supplies + output tax) but never filed sales tax return for Tax Period 03/2021. o No tax deposited despite declaring output tax → Buyers illegally claimed input tax credits.2. Contradictory Defense Rejected:o Appellant's claim of "inadvertent error" (before tribunal) vs. "system error" (before CIR-A)deemed false and willful.o No evidence of genuine transactions (invoices produced were "paper transactions").3. Tax Fraud Established: o Actions fall under Section 2(37) (tax fraud):"Issuing fake invoices to facilitate illegal input tax adjustments without actual supplies/tax payment." o Violates Sections 8(1)(ca), 23, 26 (non-filing/non-payment) and 73 (fraudulent documentation).4. Legal Consequences:o Output tax demand (Rs. 2.99M) upheld as liability arose from fraudulent Annex-C. o 100% penalty justified due to deliberate fraud. o Stay application dismissed – No prima facie case. ________________________________________Critica...