JUDGMENT

The questions for determination in this reference are as follows: Whether an Appellate Tribunal has the authority to remand a case in a time-barred appeal under subsection (5) of section 127 of the Income Tax Ordinance? Whether the service of an order through electronic means can be considered equivalent to personal service or service through registered post as stipulated in clauses (a) and (b) of sub-section (1) of section 218 of the Ordinance?The petitioner has filed this Tax Reference under Section 133 of the Income Tax Ordinance, 2001 ("Ordinance"), seeking thisCourt's opinion on questions of law arising from the order of theAppellate Tribunal Inland Revenue, Peshawar Bench (Special Bench Peshawar), dated 11.02.2022 ("Tribunal"). Briefly stated, the respondent/ taxpayer derives income from the sale of garments under the name R-Sheen Peshawar. The Officer Inland Revenue('COIR"), through a notice dated 23.10.2019 issued under Rule44(4) of the Income Tax Rules, 2002 ("Rules"), read wi...