ORDER

This Reference Application has been filed by Pakistan International Airlines Corporation against order dated 29.06.2017 passed by the Appellate Tribunal Inland Revenue, Karachi in FE No. 22/KB/2014. PIAC is a State Owned Enterprise in terms of State Owned Enterprises (Governance and Operation) Act, 2023 and pursuant to Section 38 of Federal Excise Act, 2005 read with 134A of the Income Tax Ordinance, 2001 a mechanism has been provided for State Owned Enterprises ("SOE") to approach FBR in respect of adverse orders passed by the Inland Revenue Department. The most significant and the relevant amendment made, which in our view is fully applicable to the present Applicant, is that now it ismandatoryfor SOE to go for ADR, whereas the limit of Rs. 50 Million is also not applicable.When confronted as to the above provision Counsel for PIAC / Applicant, submits that instructions are awaited. Whereas,Respondent's Counsel submits that even the Honourable Supreme Court has referred the matters f...