The Lahore High Court (LHC) has declared all tax reference applications filed after the prescribed time limit inadmissible, ruling that the Federal Board of Revenue (FBR) and other government departments cannot rely on office objections to justify delays in sales tax and income tax cases.
A division bench comprising Justice Abid Aziz Sheikh and Justice Munawar Iqbal Duggal issued the judgment. The court dismissed all miscellaneous applications seeking condonation of delay filed by the FBR and other government institutions.
The court held that removing office objections after the limitation period has expired does not make an application legally valid. Citing earlier Supreme Court precedents, it ruled that incomplete applications cannot be treated as lawfully filed.
The bench stated that the time granted to remove office objections cannot be regarded as an extension of the statutory filing period. It added that government departments and ordinary citizens stand equal under the law of limitation, and the FBR cannot be given any special or preferential relief on grounds of delay.
The court described as unreasonable the applications for condonation of delay submitted three years after references were filed in 2023. It rejected the petitioners’ reliance on office procedure or practice as grounds for the delay.
According to the ruling, litigants cannot shift the consequences of their own negligence and incomplete filings onto the office of the court. The High Court also directed that a certified copy of the judgment be sent to the Appellate Tribunal Inland Revenue.
