Supreme Court of Pakistan
Commissioner Inland Revenue, Legal Zone, Corporate Tax Office (CTO), Lahore v M/s Makerwal Collieries Limited
Published on this website
Civil Appeal No. 1693 of 2021
Citation: Order dated 18 August 2026; approved for reporting; reporter citation not stated in supplied copy
Background
Background
The Supreme Court held that the statutory adjudication period runs afresh from remand, dismissing the tax Department’s appeal against an order made years too late.
Legal questions
Legal questions
Does remand for fresh sales-tax adjudication remove the statutory deadline, preserve an original-notice clock, or begin a fresh statutory period?
Court holding
What the Court decided
When the original order is set aside and fresh adjudication is directed, the section 36(3) period is reckoned afresh from remand, subject to lawful statutory extension or exclusion. Remand does not create unlimited time.
Final outcome
Final outcome
Department appeal dismissed; fresh order dated 31 December 2005 held time-barred after remand dated 10 March 2001; Tribunal and Lahore High Court limitation conclusion upheld.
Practical effect
What the decision means in practice
Department appeal dismissed; fresh order dated 31 December 2005 held time-barred after remand dated 10 March 2001; Tribunal and Lahore High Court limitation conclusion upheld.
This summary states the immediate effect recorded in the decision. The original judgment and the facts of the particular case remain controlling.
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Later treatment
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Related article
Related article
The Supreme Court held that the statutory adjudication period runs afresh from remand, dismissing the tax Department’s appeal against an order made years too late.
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