JUDGMENT

Through this petition, the Petitioner has impugned Show Cause Notice dated 28.05.2021 on sole ground that the same is time barred under Section 11(5) of the Sales Tax Act, 1990 as the period alleged in the Show Cause Notice is from October, 2014 to September, 2015.Heard learned Counsel for the parties and perused the record. Notice was ordered and in the para-wise comments, the relevant response of the Respondents is as under:- "Notwithstanding the above, the show cause notice dated 28-05-2021 has been issued after obtaining condonation of time limit u/s 74 of the Sales Tax Act, 1990 and Section 32 of the Federal Excise Act, 2005 from the FBR vide order C.No.3(13)ST&FE/Cond/2014/59895-R dated 05-052021. Hence show cause notice is not barred by time.Copy of order C.No. 3(13)ST&FE/Cond/2014/59895-R Annexure "A" dated 05-05-2021." We are afraid the reason assigned for extension of time cannot extend limitation as provided under Section 11 (ibid); whereas the other argume...