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SHAHNAWAZ (PVT.) LTD. versus PAKISTAN THROUGH THE SECRETARY MINISTRY OF FINANCE GOVERNMENT OF PAKISTAN, ISLAMABAD


Sections 120, 177 [such as the Finance Act (I of 2009) and the Finance (Amendment) Ordinance (XXII of 2009)], 174 (3) and 214 C [such as the Finance Act (XVI of 2010)] of the Sales Tax Act ( VIII 1991), Article 25 of the Constitution of Pakistan and Article 199 of the Constitution of Pakistan for a comprehensive income tax for tax year 2008 and selection of cases by computer belt 11 12 2009 for sales tax audit to be valid will be separate unit of each tax year. The Tax Ordinance, 2001 applies in a special way with respect to each tax year, because the next day, on the last day of the tax year, the income tax audit cannot be performed without a record under which the taxpayer Section 143 (3) of the tax year must be maintained for some years the Income Tax Ordinance, 2001. In relation to the tax year 2008, Section 177 of the Ordinance was to be applied as it was on 1 7 2008 and, on the basis of this, the taxpayer could have been selected for Audit Section 177 as was 1 7 2008. On the 12th of 2009, when the computer ballot was held, taxpayers had acquired an exclusive right to know how to be selected for a particular year's audit, with the taxpayers only with a permanent right Could have been selected for audit. The applicant for tax year 2008 was similar in section 177 and then the option of selecting taxpayers to audit individual classes individually and individually 1 7 was not available in 2008 in the Federal Board of Revenue. There was no legal authority under 177. The selection of the taxpayer by computer belt for the tax year 2008 audit was incorporated on 1 7 2010 by Section 214C Finance Act 2010 of the Income Tax Ordinance 2001 and it was 1 7

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