A.   BACKGROUND (BG): This refers to the KQU 3484 for ---------.25 Tax item 2 about -------------------------------

B.   EXECUTIVE SUMMARY: The petitioner-------------Limited Legal Counsel contested the Revocation of an Exemption Certificate, arguing it was issued by the Commissioner under Section 153(4) and can only be revoked by a higher authority (Chief Commissioner under Section 122(b)).

The prior notice for cancellation was deemed unreasonable as it was only one day. SHC suspended Revocation other till the next hearing is scheduled for  ------------.25.

C.   DETAILS 

1.   General

Further to KQU 3502 of --------------, being an important matter, we would inform you about ----------------------------------------- (Attachment 3232.1) in the ensuing paragraph, with emphasis in bold for quick reading.

2.   Learned Legal Counsel for Petitioner submissions

2.1  It is contended, inter alia, by Learned Counsel for the Petitioner that the Engro challenged the Revocation order dated 27.7.25 of the Exemption Certificate earlier granted under Section 153(4) of the ITO, 2001.

2.2  The Exemption Certificate was issued by the Commissioner after applying his mind and exercising powers under Section 153(4) on Application made by the Petitioner Company. Such Certificate cannot be revoked by the same Authority, but can be revoked by the higher Authority, that is, the Chief Commissioner in terms of Section 122(b).

2.3  Moreover, Prior Notice before cancellation was that only one day time is given to submit the Reply, which is unreasonable, although the said Notice was replied to.

3.   SHC Deliberations and Interim order 

Contention prima facie appears to be correct in view of the above statutory provision.

Hence, Issued Notices to the Respondents and the Learned DAG by all modes except publication, including Electronic mode for 12.8.25, as per Roster.

Till the next date of hearing on 12.8.25, the impugned Revocation Order is suspended.

4.  Way Forward

We will keep you posted of any update as soon as it comes to our knowledge, keeping in yours and ours time constraints.

D.   FURTHER DETAILS & SERVICES 

Should you require any clarification or explanations in respect of the above or otherwise, or require Income Tax, Federal & Provincial Sales Tax or Withholding Tax Advisory, Statement or Return Filing or Review services, or related accounting matters like the above, please feel free to email us.

Best regards for Here & Hereafter
Asif S Kasbati (FCA, FCMA & LLB)

Managing Partner 

Kasbati & Co (1400+ Tax, Levies, Companies, Economy, Inflation, HR, Banking, Finance, etc

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