I. BACKGROUND (BG)

(1) This refers to the related Important TLQCs in trail, blue, italic and double Line (a) 3433 of 2.2.26 about 4B & 4C Recovery measures, its Economic impact and PTBA recommendations (b) 3431 of 1.2.26 about FCCP Short Order: Sections 4B/4C Super Tax almost intra vires Constitution details (2) More relevant TLQCs List is given Para IV for ready reference 

II. EXECUTIVE SUMMARY 

Commissioner Appeals had directed for Rectification of Order passed u/s section 4B/4C. In the light of FCC decision the concerned Tax Officer (without passing Rectified order) issued Recovery notice on the basis of Original order 4B/4C within one day time. SHC DB stayed the Recovery proceedings till reassessment and actual calculation of due amount u/s 4B/4C

III. DETAILS

A. Reference & Issues

1. Further to KQU 3769 of ----- being an Important matter, we would inform you about -------------------------------------- (Attachment 3434.1) in the ensuing paragraph, with emphasis in bold & Underline for quick reading.

2. The Petition pertains to a demand raised against the Petitioner for payment of Super Tax u/s 4B/4C.

B. Learned Counsel for Petitioner Submissions

1. Learned Counsel for the Petitioner submitted that neither the vires of the levy nor the applicability of the Tax is being disputed, however, the Petitioner had earlier filed an appeal against the assessment made on the subject, which was disposed of by the Commissioner Appeals through an Order dated ----- directing Rectification.

2. He submitted that although such Rectification exercise has not been completed, a demand has nonetheless been raised reiterating the quantum and providing only one day for payment.

3. He submitted that the Petitioner is willing to deposit the undisputed amount of tax with the Department, pending the Rectification.

C. SHC order

1. Let notice be issued to the Respondents as well as D.A.G. for ------------.

2. In the meanwhile, no coercive action to be taken against the Petitioner in pursuance of the demand notice dated ------.

IV. List of further TLQCs about section 4B/4C 

(a) 3432 of 2.2.26 about Section 4C: FCCP Order's Mr Shabbar Zaidi Comments

(b) 3429 of 29.1.26 about PSX Fallen as KC predicted & may fall more, as 4B & 4C FCCP order 

(c) 3428 of 28.1.26 about IT S. 4B & 4C upheld by Federal Constitutional Court against Taxpayers Press Release DNVC based Comments (without Short Order) & KC Views as to Major Implications

(d) 3433 of 2.2.26 about 4B & 4C Recovery measures, its Economic impact and PTBA recommendations

(e) 3315 of 24.10.25 about Super Tax u/s 4C: Senate proposed 4% while NA levied 10% 

(f) 3312 of 21.10.25 about of 4B & 4C Super Tax is on Windfall & not Feasible to be taxed 

(g) 3309 of Sunday 19.10.25 about 4B & 4C Super Tax Imposed without Policy Statement & not an FTR 

(h) 3308 of 15.10.25 about 4B & 4C Super Taxes are not Retrospective and could be Discriminatory 

(i) 3305 of 13.10.25 about 4B & 4C Super Tax cannot be Retrospective, as not Beneficial 

(j) 3304 of 11.10.25 about 4B & 4C Super Tax is not Retrospective - Bangladesh Tax @21% while Pakistan Tax @93% 

(k) 3301 of 10.10.25 about 4B & 4C Super Tax: Think Tank absence; Additional tax or not; & Industrialists leaving Pakistan as Higher Taxes 

(l) 3364 of 28.11.25 about 4B & 4C Super Taxes pending cases to FCCP. Hearing on 1.12.25 cum Major effects 

(m) 3363 of 28.11.25 about Constitution of the Islamic Republic of Pakistan 

(n) 3312 of 21.10.25 about of 4B & 4C Super Tax is on Windfall & not Feasible to be taxed 

(o) 3308 of 15.10.25 about 4B & 4C Super Taxes are not Retrospective and could be Discriminatory 

(p) 3305 of 13.10.25 about 4B & 4C Super Tax cannot be Retrospective, as not Beneficial 

(q) 3304 of 11.10.25 about 4B & 4C Super Tax is not Retrospective - Bangladesh Tax @21% while Pakistan Tax @93% 

(r) 10+ Other TLQC about SCP Stay order Hearings stay order

(s) 30+ TLQC about SHC, LHC & IHC and related matters

(t) 2673 of 19.3.24 about 4C TY 2023 IHC order in Sindh, Punjab, etc Taxpayers' favour in case of Pakistan Oil Field, etc 

(u) 2422 of 21.7.23 about IHC Super Tax 4C order in Taxpayers Favour in case of Fauji Fertilizer, etc 

V. Further Details & Services

Should you require any clarification or explanations in respect of the above or otherwise, or require Advance on 4B or 4C, Income Tax, Federal & Provincial Sales Tax or Withholding Tax Statement, Advisory, Return Filing or Review services, please feel free to email Mr Amsal at amsal@kasbati.co with CC to info.kasbati@professional-excellence.com, asif.s.kasbati@professional-excellence.com.

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 Quick Commentary Service Provider and High Level 440+ Tax & Levies Laws Consultants)