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...
PRESENT:
BABAR SATTAR, JUSTICE
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..
Law: Income Tax Ordinance, 2001
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)
Law: Income Tax Act, 1922
Sections: 18-A,18A(5)
Law: :Punjab Finance Act, 2018
Sections: NEMO
Law: Punjab Finance Act, 2021
Sections: NEMO
Disclaimer / Note: We have reproduced the judgment for facilitation of readers; however, the readers must study the original or certified copy of the above said judgment before referring it in any Court of Law. The judgment as reproduced above is a reported judgment available in law magazines and journals namely: 2025 PTD 1364