| Citation(s) |
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| 2025 SLG 5406 2025 SLD 5406 = 2025 LHC 7211 = 2026 PTCL 350 |
STR No. 9011 of 2021
PRESENT; (Hassan Nawaz Makhdoom) Judge (Khalid Ishaq) Judge
Date of Hearing: 04.11.2025 Applicant by: In STR Nos. 9011 & 49639 of 2021 M/s. Umair Ahmad and Haris Irfan, Advocates In STR No. 16313 of 2024 Mr. Yasir Islam Chaudhary, Advocate In STR No. 63693 of 2024 Ms. Humera Bashir, Advocate
Respondents by: For Federation of Pakistan in all cases Mirza Nasar Ahmad, Additional Attorney General alongwith Mr. Asad Ali Bajwa, Deputy Attorney General & Mr. Shakil A. Pasha, Assistant Attorney General For CIR/FBR In STR No. 9011 of 2021 Barrister Ahmed Pervaiz and Barrister Ahad Asif For CIR/FBR in STR No. 49639 of 2021 Mr. Muhammad Yahya Johar, Advocate In STR No. 16313 of 2024 M/s. Hashim Aslam Butt, Ahmad Yar Khan, Muhammad Irfan & Muhammad Umer Shahzad, Advocates
Quaid-e-Azam Thermal Power Private Limited
VERSUS
Appellate Tribunal Inland Revenue and 3 others
Law: Sales Tax Act, 1990
Section: 7,8, 2(14)(d), 8(1)(h)
Law: Punjab Sales Tax on Services (Recovery) Rules 2012
Section: 2(38)
Summary of the Judgment
This judgment by Justice Khalid Ishaq of the High Court decides multiple Sales Tax References (STRs) involving a dispute over input tax adjustment claimed by the taxpayer under the Sales Tax Act, 1990.
The taxpayer constructed a 1180 MW RLNG-based power plant at Bhikki, Sheikhupura through an Engineering, Procurement and Construction (EPC) agreement with HEI-HRL Joint Venture, which was registered with the Punjab Revenue Authority under the Punjab Sales Tax on Services Act, 2012. The Joint Venture charged provincial sales tax on construction services, which the taxpayer paid and then claimed as input tax adjustment against its output tax on electricity supply.
The tax department disallowed the adjustment of PKR 986,088,811, arguing that: