ORDER

This reference application in terms of section 133 of the Income Tax Ordinance, 2001 (the"Ordinance") emanates from the order dated 28.04.2025, whereby the Appellate Tribunal Inland Revenue (Division Bench-II), Islamabad (the"Appellate Tribunal") proceeded to dispose of appeals of the applicant being not maintainable. 2. Learned counsel for the Respondent, at the very outset, objected to maintainability of this reference application on the ground that the appeals filed by the applicant was maintainable before the"Appellate Tribunal"in view of second proviso to sub-section 2 of Section 134A of the"Ordinance".3. We have heard the counsel for the parties and perused the record.4. Second proviso to sub-section 2 of Section 134A of the"Ordinance"reads as under:"Provided further that SOE may file an appeal to the Appellate Tribunal or a reference to the High Court or a petition for leave to appeal to Supreme Court, as the case may be, where sub-section (11) is applicable". The above sai...