I.    BACKGROUND

1.   This refers to the related Important CDQCs in trail, blue, italic and double Line (a)  TLQC 3256 dated 2.9.25 about ATIR can grant Stay over specified limited days, as Tribunal decision delayed – ATIR Third Member (b) TLQC 3123 dated 14.5.25 about Mandatory Compliance for Tax Audit Procedures u/s 177 - FBR Letter

2.   We also refer to several Other TLQC including TLQC1909 dated 30.6.25 about Time Limit under ST Section 45B is Mandatory - SCP

II. EXECUTIVE SUMMARY

1.  SCP held that the order was passed beyond the stipulated time limits and the extension request was also made too late. Time-bound proceedings u/s 179(3) and 179(4) of per Customs Act are Mandatory.

2.  Reliance was placed on  a larger bench in the case of -------------------\

III. DETAILS

A.   Reference and Question of Law

1 to 2 

B.  SCP Deliberations

1.   Legal Requirement and Applicable Law

1.1  to  1.3 .

2.   Facts as to Computation of Limitation

3.   Extraction Beyond Prescribe Period  

3.1 to 3.3

4.   Judicial Precedents on Time-Bond Proceeding

4.1 to 4.2 

C.   Court Decision

Since, in terms of the above calculation the order was passed much beyond the time limits and even the alleged extension was much beyond the limit prescribed, (as it ought to have been extended, if at all, within the time frame), leaving the decision that is order-in-original as time barred and consequently the proceedings under the aforesaid show cause notice could not continue any more.

With this understanding this petition is converted into appeal and is allowed and the impugned order of the High Court is set-aside in the above terms. CMA No 5968/2025, which is a stay application, is disposed of.

IV.   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 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 

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