JUDGMENT

MR. JUSTICE BABAR SATTAR.-(1). The petitioner has impugned an order dated 31.05.2017 passed by the President of Pakistan, whereby findings and recommendations of the learned Federal Tax Ombudsman (FTO) dated 20.02.2017 were set-aside on a representation filed by respondent No. 2 (Federal Board of Revenue (FBR).2. The learned counsel for the petitioner submitted that the Assessing Officer of the tax department attached the petitioner's bank accounts almost two years after passage of the assessment order under Section 140 of the Income Tax Ordinance, 2001 (ITO), without serving any tax demand under the assessment order upon the petitioner. The petitioner filed an appeal against demand generated by the tax department and the Commissioner Appeals by order dated 11.11.2016 stayed the recovery of demand in exercise of authority under Section 128(1A) of the ITO. The appeal was subsequently allowed by order dated 28.11.2016 and the Commissioner Appeals observed that, proceedings under Section ...