Supreme Court of Pakistan
2025
THLN 3887
2025 PTD 837
Laws Cited
Income Tax Ordinance, 2001 | Limitation Act, 1908 | Constitution of Pakistan, 1973
Sections
133,122(5), 111, 122C, 114 | 5, 3 | 185(3)

M/s Muhammad Faisal Prop, F.A. Traders, Lahore

VS

Commissioner Inland Revenue, Zone-II, RTO-II, Lahore

Petitioner(s) by: Hassan Kamran Bashir, Advocate Supreme Court
Respondent(s) by: Mrs. Kausar Parveen, Advocate Supreme Court and Dr. Ishtiaq Ahmed Khan, DG (Law) FBR
Present: Mr. Justice Yahya Afridi, CJ Mr. Justice Irfan Saadat Khan
JUDGMENT

The instant leave petition has been filed against the order passed by the Lahore High Court, Lahore in ITR No. 41034 of 2017, dated27.02.2024.2. Briefly stated, the facts of the case are, that the petitioner, an individual, is the Proprietor of F.A Traders and derives income as a dealer/distributor of the biscuits manufactured by M/S Ismail Industries Limited (hereinafter referred to as 'M/S Ismail'). The proceedings were initiated by the Assessing Authority (hereinafter referred to as 'AA'), against the petitioner on the basis of an information received from M/S Ismail that the petitioner has made purchases of Rss 21,033,395/-, which had not been disclosed by him in respect of the tax year 2013. Thereafter, notice under section 114 of the Income Tax Ordinance,2001 (hereinafter referred to as 'The Ordinance) was issued by the AA to the petitioner, which remained un-complied with. Subsequently, a show cause notice, under section 122C of the Ordinance was issued, which also remained un-c...