Case Details

Citation(s)
2025 SLG 1419 2025 SLD 1419
Appellate Tribunal Inland Revenue, Karachi
STA No. 385/KB/2024 (Tax Period Jan 2023 to June 2023) Under Section 11(2) STRNβ€’. 17-50-3200-005-19
Present: MR. AIJAZ AHMED KHAN, MEMBER. MR. SAJJAD AKBAR KHAN, MEMBER
Appellant by Mr. Irshad Alam, Advocate.
Respondent by Malik Khan Khataki DR

M/S. Pakeezah Dyeing & Bleaching, Karachi... ..Appellant

VERSUS

The Commissioner Inland Revenue, Zone-I, CTO, .. Respondent

Law: Sales Tax Act, 1990

Section: 11(2), 73

Law: Sales Tax Rules, 2006

Section: 36

Summary;

This document is an order from the Division Bench-IV of the Appellate Tribunal Inland Revenue, Karachi, concerning an appeal by M/S. Pakeezah Dyeing & Bleaching against an assessment order issued by the Deputy Commissioner Inland Revenue (DCIR) under Section 11(2) of the Sales Tax Act, 1990, for the tax period January to June 20231.

Core Points and Issues

Grounds of Appeal:
The appellant challenged the assessment order on several grounds, mainly alleging procedural and legal flaws in the post-refund audit process, improper application of stock valuation, and non-compliance with relevant rules and sections of the Sales Tax Act and Rules1.

Post-Refund Audit Procedure:
The appellant argued that the post-refund audit was conducted without proper selection criteria or written order from the Commissioner, as required by Rule 36 of the Sales Tax Rules, 2006. They claimed the audit initiation was arbitrary and not in accordance with risk-based computerized selection or a written directive1.

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