Law: Sales Tax Act, 1990

Section: 2(18),11,21,21(4),25,25AA,25(1),25(2),30 ,30A,30B,30C,30D,30DD,30E,30(1)(j),30(2) ,30(3),30(4),31,32,33,34,36,38,38A,38B,4 5A,72B

Law: Federal Board of Revenue Act, 2007

Section: 3,4(e),4(i),4(k),4(1)(e),5,5(1)(f)

Law: Customs Act, 1969

Section: 3A

(a) Interpretation of statutes---.--- ---.---- Purposive approach ---.---Concept and Scope---.---Purposive interpretation was based on the concept of purpose and purpose was a normative concept that the law constructed---.---Concept of purposive interpretation rested on the straightforward premise that law was enacted to fulfill a purpose and laws were presumed to be valid, and the Legislature did not commit a mistake and did not waste its words. Foreword to Harvard Law Review 2002; Pepper v. Hart, (1993) 1 All ER 42, 50; Gadoon Textile Mills v. WAPDA 1997 SCMR 641, 829; Lord Roskill in Anderson v. Ryan, (1985) 2 All ER 355, 359 and Attorney-General v. Prince Ernest Augustus of Hanover (1957) A.C. 436 at 473 rel. (b) Sales Tax Act (VII of 1990)---.--- ---.----Ss. 30, 30A, 30E, 32 2(18)---.---Federal Board of Revenue Act (IV of 2007), Ss. 3, 5 4(e), 4(i) 4(k)---.---FBR S.R.O.No. 116(I)/2015 dated 09.02.2015---.---Powers and functions of the Federal Board of Revenue---.---Officer of Inland Revenue---.---Directorate General (Intelligence and Investigation), Inland Revenue---.---Powers and functions of the Directorate under the Sales Tax Act, 1990---.---Petitioners impugned S.R.O. No. 116(I)/2015 dated 09.02.2015 issued by the Federal Board of Revenue ( FBR ) whereby Directorate General of Intelligence and Investigation ( DG(II) ) was setup and officers for the same were notified---.---Contention of petitioners, inter alia, was that under Ss. 30 30A of the Sales Tax Act, 1990, impugned S.R.O. could not confer powers to the said officers prior to their declaration as officers under S. 30E of the Sales Tax Act, 1990 and that the impugned S.R.O. conferred powers on the said officers beyond remit of authority of such officers under the law---.---Validity---.---Impugned S.R.O. presupposed appointment of employees of officers to DG (II), and its effect was to appoint officers of FBR as officers of Inland Revenue with any other designation and when a transfer was made of an officer of the Inland Revenue within meaning of S. 30 of the Sales Tax Act, 1990 to any attached department of the FBR, no need arose for designating such officer as officer of Inland Revenue---.---FBR…