JUDGMENT

1. The Petitioner [Pak Telecom Mobile Limited], has filed the instant Writ Petition under Article 199 of the Constitution of the Islamic Republic of Pakistan, ("Constitution") challenging therein the Notice dated 14.01.2022 ("Impugned Notice") and Letter dated 24.08.2022 ("Impugned Letter") issued by the Commissioner (Audit-II) Inland Revenue ("Respondent No.2").2. The brief facts giving rise to the filing of the instant Writ Petition are that on 14.01.2022,Respondent No. 2 issued the Impugned Notice ostensibly under Section 177 of the Income Tax Ordinance, 2001 ("Ordinance of 2001") wherein it was informed that Respondent No. 2 intends to carry out an audit of the tax year 2018 of the Petitioner, therefore, information listed in the Impugned Notice be provided to Respondent No. 2. In its response dated 01.02.2022 to the Impugned Notice, the Petitioner objected to the maintainability of the Impugned Notice on the grounds that the same amount to passing an order without providing the Pe...