Law: Constitution of Pakistan, 1973

Section: 4,10A

Law: Income Tax Ordinance, 2001

Section: 138,138(1),140

(a) Constitution of Pakistan---Art.4--Protection of law--Act not prohibited in law--Scope-- Constitution and body of statutory laws under it, aim to protect citizens and prohibit the State from treating citizens in manner that is not backed by law--Such requirement has to be understood in a context wherein a citizen is at liberty to do what he/she is not prohibited by law from doing--Functionaries of State can only interfere with his/her life, liberty, body, reputation or property where they are authorized by law to interfere in such manner as prescribed by law.� (b) Constitution of Pakistan--Part II, Chap I, Arts. 4, 10-A--Fundamental rights--Principles of natural justice--Scope--Principles of natural justice have been regarded as a fundamental rights of a citizen-- Principles of natural justice are understood to include right of a citizen to a hearing and right to be heard by an impartial Tribunal-- Independence of judiciary is recognized as a salient feature of the Constitution and right to access to justice includes right to have ones civil entitlements and obligations adjudicated by a Tribunal or Court that is a neutral arbiter of law-- Importance of such rights was formally recognized when Art. 10-A of the Constitution was introduced in the Constitution by 18th Constitutional Amendment to afford a textual basis to such rights. Mehram Ali and others v. Federation of Pakistan and others PLD 1998 SC 1445; Messrs Pak-Saudi Fertilizers Limited v. Federation of Pakistan and others 2002 PTD Kar. 679; Brothers Textile Mills Limited v. Federation of Pakistan through Secretary and 03 others 2003 PTD Lah. 2834; Z.N. Exports Private Limited v. Collector of Sales Tax 2003 PTD 1746; Sun-Rise Bottling Company Private Limited through Chief Executive v. Federation of Pakistan and 4 others 2006 PTD 535 and Commissioner of Income Tax and others v. Messrs Media Network and others 2006 PTD 2502 rel. (c) Income Tax Ordinance (XLIX of 2001)---Ss. 138, 140--Constitution of Pakistan, Art. 199--Constitutional petition--Tax liability, recovery of--Time frame to fulfill liability--Legality of Issuing a Second Notice under Section 138 for Tax Year 2025: Analysis and…