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

Pakistan | Sales Tax Act, 1990 | Section 36(3), historical text applicable to the proceedings

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

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.

New judgment alerts

Follow this court or legal topic

Receive new judgments and analysis about Supreme Court of Pakistan, Commercial Law by email.

Primary source

Original judgment and official source

This HTML summary does not replace the court record. Use the linked original judgment PDF or official court source to verify the exact text and directions.

Later treatment

Later treatment

Research tools

Use this judgment in your research

Compare judgments

Judgment text is provided for legal research and general information. Verify the official court record before relying on it in proceedings.