Islamabad High Court
2025
THLN 2588
2025 PTD 1364
Laws Cited
Income Tax Ordinance, 2001 | Income Tax Act, 1922 | :Punjab Finance Act, 2018 | Punjab Finance Act, 2021
Sections
2(63),4,4(1),4(6),114,120,122,122(5A),137,137(2),138,138(1),140,147,147(1),147(1)(d),147(2),147(4),147(4A),147(4B),147(5),147(5A),147(5B),147(6),147(7),147(10),205(1A) | 18-A,18A(5) | NEMO | NEMO

M/S PAKISTAN TELECOMMUNICATION AUTHORITY THROUGH ITS DIRECTOR (BUDGET & ACCOUNTS)

VS

. FEDERATION OF PAKISTAN FOR THE PURPOSE OF SERVICE THROUGH CHAIRMAN FEDERAL BOARD OF REVENUE, ISLAMABAD & OTHERS

Petitioner(s) by: Ch. Naeem ul Haq, Ch. Imran ul Haq and Ch. Faheem ul Haq, Advocates.
Respondent(s) by: Mr. Osama Shahid, Advocate for the Tax Department in Writ Petition No.181 of 2019. Mr. Ghulam Qasim Bhatti, Advocate for the Tax Department in Writ Petition No.4497 & 4558 of 2022. Mr. Aqeel Akhtar Raja and Raja Muhammad Jawad Arslan, Assistant Attorney General.
Present: BABAR SATTAR, JUSTICE
JUDGMENT

Through this judgment, this Court will decide the afore-titled Writ Petitions as they involve interpretation of Section 147 of the Income Tax Ordinance, 2001 ("2001 Ordinance"), even though the relevant facts are distinct in each case and will be addressed accordingly.Relevant Factual Background2. In Writ Petition No.181 of 2019 the petitioner has impugned a notice dated 27.12.2018 issued under Section 147 of the 2001 Ordinance, and a notice dated 27.12.2018 issued under Section 140 of the 2001 Ordinance pursuant to which a recovery was coercively affected from the bank account of the petitioner maintained with the National Bank of Pakistan.3. Pursuant to notice dated 27.12.2018 the Tax Department put the petitioner on notice that it had not discharged its obligation to pay advance tax in accordance with the liability calculated pursuant to the formula provided under Section 147(4) of the 2001 Ordinance. It was the petitioner's contention that it filed an estimate in terms of Section 1...