JUDGMENT

This Civil Petition is directed against order dated 31.01.2024 passed by the Lahore High Court, Lahore (High Court) whereby the income tax reference filed by the Petitioner-Commissioner Inland Revenue was dismissed. 2. The basic contention of the counsel for the Petitioner is that Section 2(36) read with Section 100C of the Income Tax Ordinance, 2002 (theOrdinance) read with SRO No.754 (I)/2016 dated 15.08.2016 (the SRO) was misconstrued by the High Court. The taxpayer is a welfare society and the relevant tax year is 2019. The taxpayer filed their return on 26.12.2019 after which a show cause notice was issued on 12.02.2021 under Section 122(9) read with Section 122(5A) of the Ordinance stating therein that the taxpayer was not entitled to tax credit as they had not obtained the relevant approval required under Section 2(36) of the Ordinance given that the validity of their existing approval dated 05.06.2007 expired in the year 2010 in terms of the SRO. The assessment order dated...