JUDGMENT

In this bunch of petitions common questions of law are involved such as:(i) whether the impugned notices are without jurisdiction, ultra vires and barred by time under the scheme offered by the Income Tax Ordinance, 2001 (the Ordinance) and(ii) what is the effect of special tax year vis-à-vis financial year of which the approval was accorded under section 74(5) of the Ordinance to all the petitioners. 2. We have heard learned counsel for the petitioners as well as the respondents and perused material available on record.3. "Tax years" are envisaged under Part-II, Section 74 of the Ordinance 2001. It caters for a normal tax year comprising of 12 consecutive months ending 30th June hence starting point is ascertainable along with Special Tax Year which is also computation of 12 consecutive months to applicant's choice, which shall be denoted by a calendar year in which the said date falls.4. All the petitioners were accorded the subject approval of "special tax year" under section ...