Supreme Court of Pakistan
2025
THLN 4378
2025 PTD 823 | (2025) 131 TAX 676 | 2025 SCMR 952
Laws Cited
Income Tax Ordinance, 2001 | Constitution of Pakistan, 1973
Sections
114, 176, 114(4) | 185(3), 199

M/s Payoneer Inc., through its authorized officer.

VS

Federation of Pakistan through Secretary, Revenue Division, M/o Finance, Govt. of Pakistan, Islamabad and others.

Petitioner(s) by: Mr. Jahanzeb Awan, ASC.
Respondent(s) by: Mr. Imtiaz Ahmed, ASC. Syed Rifaqat Hussain Shah, AOR.
Present: Mr. Justice Yahya Afridi, CJ Mr. Justice Muhammad Shafi Siddiqui Mr. Justice Shakeel Ahmad
ORDER

This petition for leave to appeal arises out of a judgment dated 20.06.2024 passed in Writ Petition No.1670 of 2021.2. The petitioner being a non-resident entity engaged in transaction(s) based on the Home Remittance Agreement signed with the Mobilink Microfinance Bank Limited involving transfer of money from customers located outside Pakistan to the beneficiaries in Pakistan. On 11.11.2020 in terms of section 176 of the Income Tax Ordinance, 20011 (hereinafter referred176.Notice to obtain information or evidence.(1) The Commissioner may, by notice in writing, require any person, whether or not liable for tax under thisOrdinance – (a) to furnish to the Commissioner or an authorised officer, any information relevant to any tax leviable under this Ordinance or to fulfill any obligation under any agreement with foreign government or governments or tax jurisdiction, as specified in the notice; or] (b) to attend at the time and place designated in the notice for the purpose of b...