JUDGMENT

MR. JUSTICE MUHAMMAD SAJID MEHMOOD SETHI:---.---(1). Through instant Reference Application under Section 47 of the Sales Tax Act, 1990 ("the Act of 1990") read with Section 133(1) of the Income Tax Ordinance, 2001 ("the Ordinance of 2001"), following questions of law, asserted to have arisen out of impugned order dated 20.08.2024, passed by learned Appellate Tribunal Inland Revenue, Lahore Bench, Lahore, have been pressed and argued for our opinion:-(1) Whether on the facts and in the circumstances of the case, the Appellate Tribunal Inland Revenue has tailed to pass a just, fair, proper, reasoned and speaking order, as required under Section 24A of the General Clauses Act, 1897? If so:i. Whether such a non-speaking order is not sustainable in the eye of law?(2) Whether on the facts and in the circumstances of the case, the Appellate Tribunal Inland Revenue has erred in law and fact both, while travelling beyond the allegation voiced and raised in the show cause notice and in the sheer...