Lahore High Court rejects delayed tax references by FBR

The Lahore High Court (LHC) has ruled that tax reference applications filed after the prescribed time limit are inadmissible. A division bench, including Justice Abid Aziz Sheikh and Justice Munawar Iqbal Duggal, determined that the Federal Board of Revenue (FBR) and other government departments cannot use office objections to justify delays in sales tax and income tax cases.

The court dismissed miscellaneous applications seeking condonation of delay, stating that correcting office objections after a limitation period has expired does not validate an application. Citing Supreme Court precedents, the bench ruled that incomplete applications cannot be treated as lawfully filed and that the time taken to resolve office objections does not extend statutory filing periods.

The judgment emphasized that government departments and ordinary citizens are equal under the law of limitation, and the FBR is not entitled to preferential relief for delays. The court characterized applications submitted three years after 2023 filings as unreasonable, noting that litigants cannot shift the consequences of negligence or incomplete filings onto the court. The LHC has directed that a certified copy of the judgment be sent to the Appellate Tribunal Inland Revenue.