Law: Income Tax Ordinance, 2001

Section: 124, 161, 205

APPELLATE TRIBUNAL INLAND REVENUE, LAHORE BENCH, LAHORE. ITA No.522/LB/2026 (Tax Year 2017) NTN No.9020019 M/s.  Water and Sanitation Agency, Gulberg-II,  Lahore.                                   ….Appellant V e r s u s The Commissioner Inland Revenue, LTO, Faisalabad.                                       ….Respondent Appellant By:           Mr. M. Ali Raza Naseem, Advocate Respondent By:        Mr. Imran Saeed, DR Date of Hearing:     19.02.2026 Date of Order:        19.02.2026 O r d e r Nasir Mahmud (Member) : This appeal has been preferred against the order dated 26.01.2026 passed by the learned Commissioner Inland Revenue (Appeals) (“CIR(A)”), who was seized of an appeal arising out of an order passed under sections 124, 161, and 205 of the Income Tax Ordinance, 2001 (“the Ordinance”), and who concluded the appeal in the following terms:–  “I have examined the case record, verbal arguments as well as facts of the case, it is observed that a second appeal is pending adjudication before the Honorable Appellate Tribunal Inland Revenue (ATIR). It is a settled principle of law that when the matter is sub judice before a higher appellate forum, the lower authorities are required to exercise judicial restraint and avoid parallel proceedings which may result in multiplicity of litigation and conflicting decisions. Furthermore, the record reflects that the impugned order was framed without affording the appellant a proper opportunity of being heard, in violation of the principles of natural justice and in disregard of the explicit directions of the learned CIR (Appeals). The alleged non-service of notice and the lapse of…