AYESHA A. MALIK, J.---This common judgment decides upon the issues raised in the petitions detailed in Schedule "A" appended with the judgment as all petitio ns raise common questions of law and facts. The Petitioners have challenged notices issued under Section 3B of the Punjab Agricultural. Incom e Tax Act, 1997 ("Act") by the Respondents for recovery of agricultural income tax.
2. The basic case of the Petitioners is the same. They have received notices of recovery of agricultural income tax for the assessment years 2012, 2013, 2014, 2015, 2016, 2017 and 2018. The Petitioners' contention is that these notices are barred by time as the Respo ndents cannot recover agricultural income tax beyond the two year limit prescribed, meaning thereby that if notices are issued in the year 2019, the Respondents can only recover agricultural income tax for the assessment years 2016-17 and 2017-18. It is also their contention that the Respondents have issued recovery notices on the basis of which they seek immediate recovery which denies the Petitioners the right to appeal as prescribed under the law. It is also their case that the amount sought to be recovered is not in accordance with law and the Respondents have failed to take into consideration factors such as that the Petitioners have not declared agriculture income tax in the returns filed by them or that they have not filed any income tax return; exemptions granted to the Petitioners by the Government of Punjab on account of flood and drought have not been considered; the fact that the Petitioners to whom the notices have been issued are not the owners of the property , hence not liable to pay the agricultural income tax; that the tax has already been paid or simply that the amounts sought to be collected have been miscalculated and are excessive amounts than the actual liability , if any, of the Petitioners. Some of the petitions have also alleged lack of jurisdiction of the Respondents as the subject land is not located in the Province of Punjab or the district. It is their contention that under the Act, the Petitioners are entitled to the right of appeal in terms of Section 7 of the Act which right cannot be exercised if the Respondents issue recovery notices without passing an assessment order . It is also their case that in the very least, the Respondents must hear the objections of the Petitioners with respect to the amounts sought to be recovered so as to ensur e that if at all there is any liability for any assessment year, then the Petitioners are made liable to pay amounts that are due from them and not otherwise.
3. Report and parawise comments have been filed on behalf of the Respondents. Learned Law Officer stated that report and parawise comments filed in some of the petitions may be read into all the petitions as the grounds stated in the petitions are essentially the same. He stated that the Deputy Secretary (Recovery), Board of Revenue, Punjab vide letter dated 19.2.2019 and the Secretary (Taxes), Board of Revenue, Punjab vide letter dated 20.3.2019 brought to the notice of all Assistant Commissioners in Punjab that the august Supreme Court of Pakistan vide judgment dated 8.1.2019 titled Member (Taxes), Board of Revenue, Punjab, Lahore and others v.
Qaisar Abbas and others (2019 SCMR 446) has allowed Assistant Commissioners to collect agricultural income tax from the persons who have declared agricultural income in their returns filed under the Income Tax Ordinance, 2001 ("Ordinance ") in terms of Section 3B of the Act. As per their understanding, Section 3B read with Section 4(4) of the Act allows the Respondents to recover agricultural income tax for the assessment year 2012 onwards.
Learned Law Officer argued that in terms of the dicta laid down by the august Supreme Court of Pakistan in 2019 SCMR 446 (supra) the Respondents are not required to levy or assess agricultural income tax rather they can issue notices for direct recovery against income declared. Hence notices were issued for payment within 15 days.
He further argued that after the expiry of 15 days amounts can be recovered as arrears of land revenue as provided under the Punjab Agricultural Income Rules, 2001 ("Rules "). In order to facilitate the objective to recover all amounts due as agricultural income tax, the Board of Revenue obtained a list of persons who have declared agricultural income in their returns for the tax years 2012-13 and 2013-14 onwards. The lists were consulted and on the basis of the data provided, distric t-wise lists were issued to the field formations for issuance of recovery notices. Hence he stated that the data provided in the notices is correct and as per the declarations made by the Petitioners in their income tax returns with respect to agricultural income tax. Therefore, the notices are not barred by time as the matter has just been decided by the august Supreme Court of Pakis tan in 2019 SCMR 446 (supra).
The learned Law Officer argued that in terms thereof, the Respondents are entitled to recover agricultural income tax for the year 2012 onwards.
4. In terms of the arguments made from both sides, there are two issues which need adjudication. The first issue is whether the recovery notices issued are barred by time and secondly whether as a consequence of the recovery notices issued under Section 3B of the Act, the Petitioners are entitled to file an appeal/objections against the amounts sought to be recovered. With respect to the first issue, the august Supreme Court of Pakistan in 2019 SCMR 446 (supra) considered whether notices issued for the assessment year 2014 for recovery of agricultural income tax under Section 3B of the Act could have been issued at that time, given that Section 3B was inserted through the Finance Act on 29.6.2013 and came into force on 1.7.2013. As per the judgment the relevant assessment year began on 1.7.2014, in terms of the definition of the assessment year given in Section 2(ac) of the Act. The august Supreme Court of Pakistan concluded that the Respondents could recover agricultural income tax for the past two years, being the assessment years 2012 and 2013. Hence in terms of the decision of the august Supreme Court of Pakistan, the Respond ents are entitled to recover , as arrears of agricultural income tax for the assessment years 2012 and 2013. In this regard, it is noted that earlier notices were issued to the Petitioners including the Petitioner Qaisar Abbas in the instant petition, which were challenged before this Court in W.P.
No.15628/ 2015 and ultimately the order of this Court dated 26.10.2015 was modified by the august Supreme Court of Pakistan to the extent that recovery for the years 2012 and 2013 was allowed. Hence it is clear that in terms of the decision of the august Supreme Court of Pakistan, the Respondents are entitled to recover agricultural income tax for the assessment years 2012 and 2013.
5. The dispute before the Court is due to the fact that the Respondents initiated a fresh process to recover agricultural income tax on the basis of which fresh notices were issued in 2019 for recovery of agricultural income tax for the years 2012 and 2013. Hence the Petitioners before the Court have raised the objection of limitation.
Essentially the Respondents were required to issue recovery notices for the years 2012 and 2013 based on the original notices issued in the year 2014 for the assessment years 2012 and 2013 which were challenged in W.P.
No. 15628/2015 and connected petitions and by referring to the decision of the august Supreme Court of Pakistan, notifying the Petitioners that they are now liable to pay the said amounts as the august Supreme Court of Pakistan has decided in favour of the Revenue Department. The fact that the Respondents did not mention the decision of the august Supreme Court of Pakistan in the notices issued in 2019 nor have they mentioned that the demand raised is as per the original demand raised in 2014, has led to confusion consequent to which so many petitions have been filed before the Court.
6. On this issue, the learned Law Officer was confronted with the notices issued in 2019 and was asked to explain whether the data contained in these notices are identical to the data contained in the original notices issued in 2014 for the assessment years 2012 and 2013. In terms of the detailed reply and list provided, he states that the data is the same and it is based on the information provided by the Petitioners in their income tax returns as obtained from the Federal Board of Revenue. Therefore it is his contention that for the purposes of the petitions before the Court, the Respondents are entitled to recover agricultural income tax for the assessment years 2012 and 2013 on the strength of the decision of the august Supreme Court of Pakistan. To this extent, the contention of the learned Law Officer is correct and the Respondents are entitled to recover agricultural income tax based on the original notices issued in 2014. However any recovery will be subject to the right of appeal under Section 7 of the Act. So far as to the recovery notices issued for the assessment years 2014, 2015 and 2016 the question of limitation has to be looked into in the first instance before any recovery can be made. It is also noted that since right of appeal is available under the Act, propriety demands that the objection of limitation be decided by the competent authority under the Act in order to streamline the process of recovering agricultural tax. Hence the second issue becomes relevant on whether the Petitioners can file objections/appeal against the recovery notices.
7. The Petitioners have a right of appeal against the amounts sought to be recovered under Section 7 of the Act which provides that for the purposes of appeal, review or revision, an order passed under this Act shall be deemed to be an order of a Revenue Officer within the meanings of Sections 161, 162, 163 and 164 of the Punjab Land Revenue Act, 1967, provided that proceedings of suo motu, review or revision of an order in respect of any income year shall not be initiated after the expiration of two years from the end of the assessment year in which the total agricultural income of the said income year was first assessable. In any taxing scheme the right of appeal is provided under the law to resolve disputes of liability to pay tax. The right of appeal is a statutory right under the Act which means that any recovery is subject to the right of appeal.
8. In the cases before the Court several objections have been raised with respect to jurisdiction being that the notices issued have not been issued from the Assistant Commissioner of the relevant district where the agricultural property is located. By way of example in W.P. No.34758/19, the Petitioner is resident of District Sheikhupura whereas the notice has been issued, by Assistant Commissioner , Lahore. In W.P. No.39480/19, the Petitioner is resident of District Narowal whereas the agriculture land is situated in North Wazirastan. In other cases objections have been raised that the Petitioners do not own any agricultural land nor have the Petitioners declared any agricultural income or that the Petitione r has never filed any income tax return. By way of example in W.P.
No.40004/19, the Petitioner claims that she is a housewife with no source of income except for foreign remittance from a family member; that she has neve r filed any income tax return nor declared any agricultural income yet she has been served with a recovery notice. In another set of cases, the Petitioners claim exemption on the basis of notification issued by the Disaster Management Department declaring their area exempt from agricultural income tax for the relevant years 2012, 2013, 2014, 2015 and 2016. Hence on the streng th of the notifications they claim that they are not liable to pay agricultural income tax. By way of example, the Petitioner in W.P. No.39556/19 states that he is entitled to exemption from agric ultural income tax on the basis of notificat ion dated 23.5.2012, 28.7.2016, 2.6.2017 and 21.1.2019. In another set of petitions, the Petitioners claim that they are not the owners of any agricultural land nor have they declared any agricultural income in their income tax returns yet they have been served with recovery notices. In W.P. No.36974/2019, the Petitioner claims that he has never filed any income tax returns, hence the question of applying Section 3B of the Act is totally without jurisdiction. In other cases, the Petitioners claim that they have already paid the total agricultural income tax yet notices have been issued. By way of example in W.P. No.36709/2019, the Petitioner claims that he has paid the total agricultural income tax for the years 2015, 2016, 2017 and 2018, hence he is not required to pay any amount. In another set of petitions, the Petitioners' claim that they took the benefit of amnesty scheme, 2018, hence they are not liable to pay agricultural income tax. These are all substantive issues which need resolution under the Act before any recovery can be initiated.
9. On the basis of the aforesaid, it is evident that notwithstanding the statement made by the learned Law Officer, that all amounts were correctly taken from the data provided by the Federal Board of Revenue is correct, there are discrepancies in the recovery notices that have been issued. The question is what is the effect of Section 7 of the Act when recovery notices are issued under Section 3B of the Act. In this regard , the august Supreme Court of Pakistan in its decision 2019 SCMR 446 (supra) held that for the purposes of Section 3B of the Act, where an assessee has declared agricultural income in its income tax returns, the Respondents can issue recovery notices directly and are not required to levy and assess agricultural income tax in terms of Section 3 of the Act. Essentially the august Supreme Court of Pakistan has held that the Respondents are entitled to recover agricultural income tax on the basis of the declaration given in the income tax returns, as per Section 3B of the Act. In a taxing statute an assessment order is necessary in order to support the demand raised and to ensure that the taxing officer has taxed a person as per the confines of the law. It ensures uniformity and equality in the demand raised in the absence of which doubt is raised and arbitrary exercise of jurisdiction is possible as there is no check on the taxing officer, and a citizen is substantially without protection from unequal and unjust demands. Under the Act Section 3 is the charging section which calls for the levy, assessment and collection of tax. Three important steps on the basis of which agricultural income tax can be recovered. In this regard Section 3B of the Act merely provides that a person is liable to pay agricultural income tax on the basis of agricultural income declared in the income tax return.
Hence it imposes a liability to pay tax on the basis of an admission of earning agricultural income. Sections 3 and 3B of the Act are the charging sections of the taxing statute which have to be enforced through the procedure prescribed under the Act. The procedural machinery is provided for under Sections 4, 4A. 4B, 4C and 4D read with the Rules. These sections set out the process on the basis of which the taxing officer will compute and collect agricultural income tax and the recovery notice is the final step that has to be taken once tax has been charged. A recovery notice means that the liability to pay tax has been determined, in this case based on the declaration given under Section 3B of the Act. However it does not mean that the taxing officer cannot assess and levy agricultural income tax on the basis of the revenue record before it. Hence a recovery notice is premised on an assessment order which sets out the details of the tax liability . In the cases of agricultural income tax the august Supreme Court of Pakistan has held that an assessment order is not required under Section 3B of the Act and that the Respondents can initiate recovery on the basis of the declaration made in the income tax return. However it has not curtailed the right of appeal under Section 7 of the Act nor has it allowed the Respondents to ignore the procedure prescribed under the Act and the Rules especially with reference to computation of tax. In terms of the decision of the august Supreme Court of Pakistan, the judgment of this Court in W.P. No. 15628/2015 was modified to the extent that an assessment order is not mandatory under Section 3B of the Act, however at the same time the august Supreme Court of Pakistan upheld the findings that the assessment order can be challenged under Section 7 of the Act which gives the right of appeal to the taxpayer and it has also upheld the findings that calculations must be provided of the tax levied. Therefore the Respondents are required to disclose the information taken from the Federal Board of Revenue, the rate applied and the tax sought to be recovered in the recovery notices so that the taxpayer is clear on what amount is due against agricultural income tax.
10. It is further noted that the Respondents must follow the procedure under the Act and the Rules to ensure that the rights of the land owners are protec ted and that the obligation to pay tax follows due process. There is a complete procedure provided under the Act and the Rules to collect agricultural income tax which requires the Respondents to issue notice to the taxpayer calling for payment and requires, as of right that the taxpayer be given time to file an appeal, review or revision against the order of Revenue Officer. It appears that the Respondents failed to bring these facts into the notice of the august Supreme Court of Pakistan while arguing in the case 2019 SCMR 446 (supra) and are now misinterpreting the judgment of the august Supreme Court of Pakistan by ignoring the statutory right of appeal, review or revision available under Section 7 of the Act.
11. The thrust of the Respondents' case before the Court is that they can make direct recovery on the strength of the agricultural income declared under Section 3B of the Act. There is no cavil to the statement because the law itself provides that the Respondents can recover . agricultural income tax on the basis of declared agricultural income in the income tax returns for any assessment year filed under the Act in terms of the rates specified in the second schedule. However the taxpayer has a right to appeal against the amount sought to be recovered even if it is based on a declaration in the income tax return and direct recovery inflicted by the Respondents adversely affects the Petitioners' right of appeal under Section 7 of the Act. Furthermore the objections raised before this Court are substantive issues and necess itate a decision by the competent authority before agricultural income tax is recovered. In the cases before the Court objections with regard to limitation; objections with regard to jurisdiction; with regard to amount sought to be recov ered; with regard to ownership and with regard to exemptions offered by the Government itself require due deliberation and entitle the Petitioners due process under the Act.
12. Under the circumstances, the recovery notices issued under Section 3B of the Act shall be deemed as assessment orders which are liable to appeal under Section 7 of the Act. The Respondents are obligated to hear the objections and decide the same in accordance with law. For the purposes of the cases pending before this Court and the recovery undertaken by the Respondents for agricultural income tax, the Petitioners should be granted thirty days' time to file their appeals/objections, if at all under Section 7 of the Act after which the cases shall be decided in accordance with law and subsequently if any amount is due the Respondents may recover the same under the Act and the Rules.
13. In view of the aforesaid, while partly allowing the Petitions, this Court finds as follows:
(i) The Petitioners' contention that demand for agricultural income tax for the years 2012 and 2013 is barred by time is without any merit given that the august Supreme Court of Pakistan has allowed recovery of agricultural income tax for that period. However , the amount sought to be recovered as agricultural income tax for the period 2012 and 2013 is subject to right of appeal/objections which may be availed by the Petitione rs within 30 days' time from the date of release of this judgment.
(ii) It is also held that against the recovery notices issued under Section 3B of the Act, remedy of appeal is available to the Petitioners under Section 7 of the Act. In this regard, the recovery notices can be challenged within 30 days' time from the date of release of this judgment under Section 7 of the Act before the competent authority , who is directed to decide the appeals filed by the Petitioners within 30 days' time after which the Respondents can recover agricultural income tax from the Petitioners as per law .
SCHEDULE-A Details of W rit Petitions mentioned in judgment Dated 27.6.2019 passed in W .P. No. 25557/2019 Sr.
No.WP No.Parties Name
1. 25557/19 Qaisar Abbas v . Member (T axes) Board of Revenue, Punjab Lahore etc.
2. 36000/19 Shahid Mahmood v . Government of Punjab through Secretary Finance etc.
3. 36125/19 Sheikh Muhammad Nassar Javaid v . Federation of Pakistan etc.
4. 36132/19 Malik Mureed Hussain v. Federation of Pakistan etc.
5. 36138/19 Shaikh Marije Javaid v. Federation of Pakistan etc.
6. 36158/19 Nadeem Mumtaz v . Government of Punjab through its Chief Secretary etc.
7. 36140/19 Muhammad Saqib Javaid v. Federation of Pakistan etc.
8. 36159/19 Zia ur Rehman Shakir v . The Member (T axes) Board of Revenue, Punjab Lahore etc.
9. 36175/19 Abid Hussain Bhatti v . Government of Punjab through Chief Secretary etc.
10. 36177/19 Javaid Iqbal v. Federation of Pakistan etc.
11. 36269/19 Syed Muhammad Raza v . Government of Punjab through Chief Secretary etc.
12. 36270/19 Rehan Nawaz etc. v. Member (Taxes) Board of Revenue, Punjab Lahore etc.
13. 36284/19 Ijaz Ahmad Hashmi v . Member (T axes) Board of Revenue, Punjab Lahore etc.
14. 36441/19 Altaf Ezid Khan v. Federation of Pakistan etc.
15. 36344/19 Akhlaq Ahmad Hashmi v . Member (T axes) Board of Revenue, Punjab Lahore etc.
16. 36416/19 Muhammad Yousaf v. Member (Taxes) Board of Revenue, Punjab Lahore etc.
17. 36466/19 Mian Muhammad Farooq etc. v. Federation of Pakistan etc.
18. 36526/19 Safdar Saleem v . Member (T axes) Board of Revenue, Punjab Lahore etc.
19. 36604/19 Sana Ullah Qamar Bajwa v. Federation of Pakistan etc.
20. 36613/19 Ansar Abbas Khan v. Federation of Pakistan etc.
21. 36698/19 Ch. Pervaiz Akhtar v . Chairman Federal Board of Revenue, Islamabad etc.
22. 36709/19 Asif Mahmood v. Federation of Pakistan etc.
23. 36760/19 Muhammad Bilal V irk v. Member (T axes) Board of Revenue, Punjab Lahore etc.
24. 36794/19 Mian M. Ashraf v. Federation of Pakistan etc.
25. 36798/19 Zafar Alam Chaudhry v . Government of Punjab through Chief Secretary etc.
26. 36824/19 Syed Muhammad Raza v . Government of Punjab through Chief Secretary etc.
27. 36934/19 Muhammad Ayub Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
28. 36966/19 Dost Muhammad v . Member (T axes) Board of Revenue, Punjab Lahore etc.
29. 36969/19 Junaid Fareed Dah v . The Assistant Commissioner / Collector City Lahore etc.
30. 36972/19 Mehr Muhammad Ashraf v. Federation of Pakistan etc.
31. 36974/19 Naeem Akhtar v. Federation of Pakistan etc.
32. 36981/19 Javed Hussain v . Member (T axes) Board of Revenue, Punjab Lahore etc.
33. 37020/19 Muhammad Iqbal v . Member (T axes) Board of Revenue, Punjab Lahore etc.
34. 37021/19 Manzoor Ahmad v . Member (T axes) Board of Revenue, Punjab Lahore etc.
35. 37048/19 Mian Shahzad Ahmad v . Member (T axes) Board of Revenue, Punjab Lahore etc.
36. 37062/19 Sadia W aqar v . Member (T axes) Board of Revenue, Punjab Lahore etc.
37. 37064/19 Syed Ali Kazim v . Member (T axes) Board of Revenue, Punjab Lahore etc.
38. 37065/19 Syed Afzal Hussain Shah v . Member (T axes) Board of Revenue, Punjab Lahore etc.
39. 37091/19 Mian Muhammad W aqar Ahmad v . Member (T axes) Board of Revenue, Punjab Lahore etc.
40. 37108/19 Ghazanfar Abbas v . Member (T axes) Board of Revenue, Punjab Lahore etc.
41. 37111/19 Sikandar Khan v . The Assistant Commissioner/Collector , Lahore etc.
42. 37150/19 Faisal Mehmood Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
43. 37222/19 Areeb Burhan v . Member (T axes) Board of Revenue Punjab Lahore etc.
44. 37226/19 Muhammad Omer Khan v. Federation of Pakistan etc.
45. 37227/19 Muhammad Farooq Khan v. Federation of Pakistan etc.
46. 37228/19 Dr. Nasir Mumtaz Gorya v. Federation of Pakistan etc.
47. 37229/19 Mehar Ghulam Farid v . Member (T axes) Board of Revenue, Punjab Lahore etc.
48. 37239/19 Arfan Saddique v . Member (T axes) Board of Revenue, Punjab Lahore etc.
49. 37240/19 Malik Iftikhar Sarwar v. Federation of Pakistan etc.
50. 37259/19 Rana Habib v . Member (T axes) Board of Revenue, Punjab Lahore etc.
51. 37260/19 Rana Awais Tauseef v . Secretary/Member (T axes) (Agriculture Income Tax)
Board of Revenue, Punjab Lahore etc.
52. 37591/19 Muhammad Sabir Ali v. Government of Punjab through its Secretary Ministry of Finance etc.
53. 37598/19 Irfan Mumtaz v . Government of Punjab through its Chief Secretary etc.
54. 37625/19 Manzoor Hussain v . Member (T axes) Board of Revenue, Punjab Lahore etc.
55. 37628/19 Qamar Zaman v. Federation of Pakistan etc.
56. 37629/19 Ahmed Sultan Cheema v. Federation of Pakistan etc.
57. 37644/19 Zia ud Din v . Member (T axes) Board of Revenue, Punjab Lahore etc.
58. 37645/19 Syed Safdar Huissain Gillani v. Federation of Pakistan etc.
59. 37756/19 Syed Tayyab Hussain Rizvi v . Government of Punjab through its Chief Secretary etc.
60. 37668/19 Haji Muhammad Younis v . Member (T axes) Board of Revenue, Punjab Lahore etc.
61. 37778/19 Syed Yousaf Jamil Hussain Rizvi v . Government of Punjab through its Chief Secretary etc.
62. 37805/19 Nazir Ahmed Qamar v. Federation of Pakistan etc.
63. 37864/19 Omer Pasha Chaudhry v . Member (T axes) Board of Revenue, Punjab Lahore etc.
64. 37874/19 Haji Fayyaz Ahmed etc v . Member (T axes) Board of Revenue, Punjab Lahore etc.
65. 37879/19 Muhammad Arif Liaqat v . Member (T axes) Board of Revenue, Punjab Lahore etc.
66. 37894/19.Abid Rasheed v . Member (T axes) Board of Revenue, Punjab Lahore etc.
67. 37920/19 Rab Nawaz v. Federation of Pakistan etc.
68. 37966/19 Sardar Bahadar Khan Maken v . Member (T axes) Board of Revenue, Punjab Lahore etc.
69. 37967/19 Ijaz Ahmed v. Federation of Pakistan etc.
70. 37210/19 Akhtar Umar Hayat Lalika v. Federation of Pakistan etc.
71. 38264/19 Mehar Muhammad Iqbal v. Federation of Pakistan etc.
72. 31207/19Muhammad Saeed Akhtar v . Government of Punjab through its Chief Secretary etc.
73. 31973/19 Amjad Tofique v . Government of Punjab through its Chief Secretary etc.
74. 32072/19 Muhammad Afzaal Shah v. Federation of Pakistan etc.
75. 32073/19 Muhammad Amin Shah v. Federation of Pakistan etc.
76. 32075/19 Muhammad Akram Shah Hashmi v . Federation of Pakistan etc.
77. 32423/19 Muhammad Naseem Tahir v. Federation of Pakistan etc.
78. 32450/19 Tasneem Akhtar v. Federation of Pakistan etc.
79. 32452/19 Ghulam Dastgir Lak v. Federation of Pakistan etc.
80. 32919/19 Malik Saeed Ahmad v. Federation of Pakistan etc.
81. 33009/19 Aftab lqbal Dillon v. Federation of Pakistan etc.
82. 33245/19 Zafar Iqbal v . Member (T axes) Board of Revenue, Punjab Lahore etc.
83. 33279/19 Usman Khalid v. Federation of Pakistan etc.
84. 33778/19 Wali Muhammad Chaudhry v . Member (T axes) Board of Revenue, Punjab Lahore etc.
85. 33780/19 Tariq Javid v . Member (T axes) Board of Revenue, Punjab Lahore, etc.
86. 33940/19 Faiza Ahmad Malik v. Federation of Pakistan etc.
87. 34014/19 Asif Manzoor Ahmad etc. v . Member (T axes) Board of Revenue, Punjab Lahore etc.
88. 34084/19 Muhammad Nazir v . Member (T axes) Board of Revenue, Punjab Lahore etc.
89. 34088/19 Noor Muhammad v. Federation of Pakistan etc.
90. 34120/19 Rana Tahseen Ikhlaq v . Federal Board of Revenue through its Chairman etc.
91. 34140/19 Salim Shahid Sattar v. Federation of Pakistan etc.
92. 34146/19 Mian Zahid Hussain Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
93. 34148/19 Abu Bakar Sarfraz v . Member (T exes) Board of Revenue, Punjab Lahore etc.
94. 34174/19 Babar Sibtain v . Federal Board of Revenue through its Chairman etc.
95. 34378/19 Sheharyar Ali v. Federation of Pakistan etc.
96. 34464/19 Wasif All Khan v. Federation of Pakistan etc.
97. 34614/19 Ghulam Sarwar v. Federation of Pakistan etc.
98. 34691/19 Azhar Abbas v. Federation of Pakistan etc.
99. 34697/19 Muhammad Ramzan v. Federation of Pakistan etc.
100. 34736/19 Faiz Rasool v . Government of Punjab through its Chief Secretary etc.
101. 34742/19 Shahid Rasool v . Goverment of Punjab through its Chief Secretary etc.
102. 34744/19 Muhammad Naeem v . Government of Punjab through its Chief Secretary etc.
103. 34754/19 Malik Muhammad Akhtar Awan v . Member (T axes) Board of Revenue, Punjab Lahore etc. 104 34758/19 Zubair Rasool v . Government of Punjab through its Chief Secretary etc.
105. 34831/19 Ch. Muhammad Saleem v. Federation of Pakistan etc.
106. 35073/19 Allah Nawaz Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
107. 35074/19 Allah Nawaz Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
108. 35082/19 Ahmad Ijaz Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
109. 35085/19 Muhammad Faheem Khalid v . Member (T axes) Board of Revenue, Punjab Lahore etc.
110. 35095/19 Muhammad Khalid v. Federation of Pakistan etc.
111. 35096/19 Chaudhry Muhammad Ashraf v . Member (T axes) Board of Revenue, Punjab Lahore etc.
112. 35265/19 Ijaz Hussain v. Federation of Pakistan etc.
113. 35270/19 Ch. Qamar uz Zaman v. Federation of Pakistan etc.
114. 35274/19 Shah Nawaz Zulfiqar v. Federation of Pakistan etc.
115. 35309/19 Khuram Munawar Manj v . Member (T axes) Board of Revenue, Punjab Lahore etc.
116. 3531 1/19 M. Bilal V irk v. Member (T axes) Board of Revenue, Punjab Lahore etc.
117. 35330/19 Tahseen Rana v . Government of Punjab through its Chief Secretary etc.
118. 35350/19 Ali Raza v. Federation of Pakistan etc.
119. 35357/19 Zulfiqar Ali v. Federation of Pakistan etc.
120. 35359/19 Muhammad Iqbal v . Member (T axes) Board of Revenue, Punjab Lahore etc.
121. 35384/19 Salman Nasir Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
122. 35658/19 Mehar Liaqat Ali Chaudhry v. Federation of Pakistan etc
123. 35686/19 Rana Naveed Afzal Khan v . Federal Board of Revenue through its Chairman etc.
124. 35799/19 Muhammad Imran v . Member (T axes) Board of Revenue, Punjab Lahore etc.
125. 35836/19 Muhammad Zul Sabtain Amir v . Federal Board of Revenue through its Chairman etc.
126. 35862/19 Muhammad Ajmal Aziz v . Government of Punjab through its Chief Secretary etc.
127. 35965/19 Faisal Rasheed Chaudhry v. Federation of Pakistan etc.
128. 35974/19 Abdul Rauf v. Federation of Pakistan etc
129. 35976/19 Farooq Rasheed v. Federation of Pakistan etc.
130. 35987/19 Maqbool Qadir v . Federal Board of Revenue through its Chairman etc,
131. 35354/19 Muhammad Omar Hayat v, Federation of Pakistan etc.
132. 35072/19 Allah Nawaz Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc
133. 33310/19 Munawar Hussain Manj v . Member (T axes) Board of Revenue, Punjab Lahore etc.
134. 35468/19 Rana Noralz Bashir Ahmad Khan v . Federal Board of Revenue through its Chairman etc. 135, 35594/19 Muhammad lshfaq v. Federation of Pakistan etc.
136. 35596/19 Rukhsana Naseem v . Member (T axes) Board of Revenue, Punjab Lahore etc.
137. 35650/19 Muhammad Aslam Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc
138. 35688/19 Rana Mujeeb Afzal Khan v . Federal Board of Revenue through its Chairman etc
139. 37523/19 Tahir Mehmood v . Member (T axes) Board of Revenue, Punjab Lahore etc.
140. 37623/19 Javed Qayyum v . Member (T axes) Board of Revenue, Punjab, Lahore etc.
141. 37635/19 Farrukh Hayat Pannoun v . Government of Punjab through its Chief Secretary etc.
142. 37709/19 Syed Zia Haider Rizvi v . Government of Punjab through its Chief Secretary etc. 143 37717/19 Muhammad Zahid v . Member (T axes) Board of Revenue, Punjab Lahore etc.
144. 37735/19 Sarfraz Hussain Abadi v. Federation of Pakistan etc.
145. 37737/19 Khaqan Khawar v . Member (T axes) Board of Revenue, Punjab Lahore etc.
146. 37740/19 Rai Muhammad Yasin Khawar v . Member (T axes) Board of Revenue, Punjab Lahore etc.
147. 37781/19 Syed Sajjad Haider Rizvi v . Government of Punjab through its Chief Secretary etc.
148. 3781 1/19 Belum Husnain v . Member (T axes) Board of Revenue, Punjab Lahore etc.
149. 37863/19 Hamid Mehmood Cheema v. Federation of Pakistan etc.
150. 37867/19 Sikandar Hayat v . Member (T axes) Board of Revenue, Punjab Lahore etc.
151. 37869/19 Iftikhar Ahmad v . Member (T axes) Board of Revenue, Punjab Lahore etc.
152. 37880/19 Rana W aseem Liaqat v . Member (T axes) Board of Revenue, Punjab Lahore etc.
153. 37881/19 Salah ud Din Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
154. 37893/19 Majid Rasheed v . Member (T axes) Board of Revenue, Punjab Lahore etc
155. 37922/19 Khuda Dad v. Federation of Pakistan etc.
156. 37935/19 Tasneem Akhtar v . Federation of Pakistan etc,
157. 37955/19 Khan Muhammad through M. W aqas v . Member (T axes) Board of Revenue, Punjab Lahore etc.
158. 37956/19 Zaigham Abbas Asghar v. Federation of Pakistan etc.
159. 37965/19 Rehan Ajmal v. Federation of Pakistan etc.
160. 38034/19 Dr. Noreen Akmal v . Federation of Pakistan etc. 161 38064/19 Manzoor Qadir v . Member (T axes) Board of Revenue, Punjab Lahore etc.
162. 38066/19 Muhammad Riaz v . Member (T axes) Board of Revenue, Punjab Lahore etc.
163. 38085/19 Khalid Rehan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
164. 38113/19 Muhammad Ayub v . Member (T axes) Board of Revenue, Punjab, Lahore etc.
165. 38115/19 Sikandar Khan v. The Assistant Commissioner, etc.
166. 38137/19 Fahmida Akbar v . Member (T axes) Board of Revenue, Punjab, Lahore etc.
167. 38136/19 Malik Anis Akbar v . Member (T axes) Board of Revenue, Punjab Lahore etc.
168. 38138/19 Asim Akbar v . Member (T axes) Board of Revenue, Punjab Lahore etc.
169. 38141/19 Nisar Ahmad Hayat Malik v . Member (T axes) Board of Revenue, Punjab Lahore etc.
170. 38143/19 Sardar Khalid Nawaz Maken v . Member (T axes) Board of Revenue, Punjab Lahore etc.
171. 38163/19 Imran Khan v. Federation of Pakistan etc.
172. 38164/19 Noman Ali v. Federation of Pakistan etc.
173. 38165/19 Muhammad Nazir v. Federation of Pakistan etc.
174. 38171/19 Zulfiqar Ali v. Government of Punjab through its Chief Secretary etc.
175. 38172/19 ljaz Hussain Minhas v . Member (T axes) Board of Revenue, Punjab Lahore etc.
176. 38251/19 Ghulam Serwar v. Federation of Pakistan etc.
177. 38306/19 Muhammad Boota v . Member (T axes) Board of Revenue, Punjab Lahore etc.
178. 38350/19 Mazhar Fareed Wattoo v. Federation of Pakistan etc.
179. 38353/19 Muhammad Akhtar Waseem v. Federation of Pakistan etc.
180. 38355/19 Mushtaq Ahmad Shah v. Federation of Pakistan etc.
181. 38356/19 Sikandar Hayat v. Federation of Pakistan etc.
182. 38406/19 Muhammad Sarwar v. Federation of Pakistan etc.
183. 38407/19 Mumtaz Ali v. Federation of Pakistan etc.
184. 38408/19 Ch. Muhammad Ashraf v. Federation of Pakistan etc.
185. 38409/19 Ahmad Mansoor Kamal v. Federation of Pakistan etc.
186. 3841 1/19 Zarina Kamal v. Federation of Pakistan etc.
187. 38412/19 Kamal Ahmad v. Federation of Pakistan etc.
188. 38413/19 Saeed Ahmir Awan v. Federation of Pakistan etc.
189. 38420/19 Muhammad Shauja Sadozai v. Federation of Pakistan etc.
190. 38544/19 Ahmad Unsar Zaman Khan Butt v. Federation of Pakistan etc.
191. 38549/19 Muhammad Shabbir v. Federation of Pakistan etc.
192. 38611/19 Muhammad Mushtaq Butt v. Federation of Pakistan etc.
193. 26170/19 Ali Gohar Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
194. 26933/19 Syeda Maimanat Mohsin v . Government of Punjab through its Chief Secretary etc.
195. 28046/19 Mazhar Hussain Shah v . Member (T axes) Board of Revenue, Punjab Lahore etc.
196. 28051/19 Sardar Hassan Mehmood v . Member (T axes) Board of Revenue, Punjab Lahore etc.
197. 28054/19 Sardar Hassan Mehmood v . Member (T axes) Board of Revenue, Punjab Lahore etc.
198. 28619/19 Muhammad Ashraf Gondal v . Member (T axes) Board of Revenue, Punjab Lahore etc.
199. 28838/19 Abdul Razzaq v. Federation of Pakistan etc.1 200 29652/19 Ch. Mehmood Akhtar v. Federation of Pakistan etc.
201. 29653/19 Ch. Muhammad Asghar v. Federation of Pakistan etc.
202. 29654/19 Tanveer Ahmad Qureshi v. Federation of Pakistan etc.
203. 29656/19 Shah Nawaz v. Federation of Pakistan etc.
204. 29987/19 Abid Ansar v. Federation of Pakistan etc.
205. 30455/19 Sohail Sarwar v. Federation of Pakistan etc.
206. 30119/19 Syed Muhammad Zahid Gillani v . Member (T axes) Board of Revenue, Punjab Lahore etc.
207. 30302/19 Muhammad Hayat v. Federation of Pakistan etc.
208. 30845/19 Syed Ijaz Ali Shah Gillani v. Federation of Pakistan etc.
209. 31077/19 Muhammad Saeed Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
210. 31080/19 Fahad Ahmed v. Federation of Pakistan etc.
211. 31426/19 Badar uz Zaman v . Member (T axes) Board of Revenue,Punjab Lahore etc.
212. 31427/19 Badar uz Zaman v . Member (T axes) Board of Revenue, Punjab Lahore etc.
213. 31667/19 Abdul Jabbar v. Federation of Pakistan etc.
214. 31701/19 Muhammad Aslam v. Federation of Pakistan etc.
215. 31705/19 Abdul Rehman v. Federation of Pakistan etc.
216. 31707/19 Azmat Hayat Malik v. Federation of Pakistan etc.
217. 31708/19 Adnan Rehmat v. Federation of Pakistan etc.
218. 31710/19 Ch. Mubarak Ali v. Federation of Pakistan etc.
219. 31839/19 Mirza Muhammad Mubeen Baig v. Federation of Pakistan etc.
220. 31969/19 Syed Shahid Raza Bokhari v . Government of Punjab through its Chief Secretary etc.
221. 32481/19 Ghulam Sarwar v. Federation of Pakistan etc.
222. 32632/19 Waseem Zafar Bajwa v . Government of Punjab through its Chief Secretary etc.
223. 32653/19 Tanveer Ahmad v. Federation of Pakistan etc.
224. 32669/19 Manzoor Hussain v . Member (T axes) Board of Revenue, Punjab Lahore etc.
225. 33617/19 Rana Ishfaq Ahmad v. Federation of Pakistan etc.
226. 33682/19 Shoukat Ali v. Member (T axes) Board of Revenue, Punjab Lahore etc.
227. 33683/19 Shoukat Ali v. Member (T axes) Board of Revenue, Punjab Lahore etc.
228. 33687/19 Syed Safdar Hassan Gillani v. Federation of Pakistan etc.
229. 33771/19 Muhammad Ghareeb Alam v . Government of Punjab through its Chief Secretary etc.
230. 33776/19 Ibnan Javid v . Member (T axes) Board of Revenue, Punjab Lahore etc.
231. 33779/19 Muhammad Tariq W ali v. Member (T axes) Board of Revenue, Punjab Lahore etc.
232. 33943/19 Zahid Hafeez v. Federation of Pakistan etc.
233. 33945/19 Samreen Yahya v. Federation of Pakistan etc.
234. 33947/19 Nazir Ahmad v. Federation of Pakistan etc.
235. 33961/19 Muhammad Awais v . Member (T axes) Board of Revenue, Punjab Lahore etc.
236. 34051/19 Nuzhat Jabeen v . Member (T axes) Board of Revenue, Punjab Lahore etc.
237. 34053/19 Muhammad Ahmad etc. v. Federation of Pakistan etc.
238. 34119/19 Rana Shaheen Ikhlaq v . Federal Board of Revenue through its Chairman etc.
239. 34121/19 Babar Sattar v. Federation of Pakistan etc.
240. 34123/19 Muhammad Iftikhar Rana v . Member (T axes) Board of Revenue, Punjab Lahore etc.
241. 34127/19 Ch. Mudassar lqbal v . Member (T axes) Board of Revenue, Punjab Lahore etc.
242. 34142/19 Muhammad Fayyaz v . Member (T axes) Board of Revenue, Punjab Lahore etc.
243. 34143/19 Mian Shahid Hussain Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
244. 34145/19 Nadeem Safdar Bhatti v . Member (T axes) Board of Revenue, Punjab Lahore etc.
245. 34147/19 Malik Zaheer Abbas v . Member (T axes) Board of Revenue, Punjab Lahore etc.
246. 34151/19 Muhammad Akhtar Chaudhry v . Member (T axes) Board of Revenue, Punjab Lahore etc. 247 34152/19 Zubair ul Hassan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
248. 34154/19 Javid Sattar v. Federation of Pakistan etc.
249. 34162/19 Ahsan Raza Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
250. 34165/19 Ambreen Haider v. Federation of Pakistan etc.
251. 34175/19 Mehar Ahmad Ali Gull v. The Assistant Commissioner etc.
252. 34177/19 Barak Nauman Tarar v. Federation of Pakistan etc.
253. 34178/19 Muhammad Ziyad v . Government of Punjab through its Chief Secretary etc.
254. 34235/19 Muhammad Younas v. Federation of Pakistan etc.
255. 34315/19 Altaf Hussain Awan v. Federation of Pakistan etc.
256. 34318/19 Sajjad Hussain Awan v. Federation of Pakistan etc.
257. 34383/19 Umar Hayat y. Federation of Pakistan etc.
258. 34443/19 Khalid Manzur v. Federation of Pakistan etc.
259. 34535/19 Muhammad Zubair Alamgir v. Federation of Pakistan etc.
260. 34715/19 Muhammad Salman Babar etc. v . Member (T axes) Board of Revenue, Punjab Lahore etc.
261. 34738/19 Muhammad Nadeem v . Government of Punjab through its Chief Secretary etc.
262. 34748/19 Muhammad Saleem v . Government of Punjab through its Chief Secretary etc.
263. 34759/19 Ijaz Sehole v . Government of Punjab through its Chief Secretary etc.
264. 34761/19 Muhammad Akhtar v . Government of Punjab through its Chief Secretary etc.
265. 34926/19 Shujah Haider etc. v. Assistant Commissioner etc.
266. 35383/19 Mian Sarfraz Ahmad v . Member (T axes) Board of Revenue, Punjab Lahore etc.
267. 35463/19 Mian Muhammad Ashraf v. Federation of Pakistan etc.
268. 35539/19 Muhammad Nafees v. Federation of Pakistan etc.
269. 35597/19 Muhammad Naseem v . Member (T axes) Board of Revenue, Punjab Lahore etc.
270. 35645/19 Muhammad Razzaq v. Federation of Pakistan etc.
271. 35647/19 Fakhar ud Din v . Member (T axes) Board of Revenue, Punjab Lahore etc. 272 35655/19 Maqsood Alam v. Federation of Pakistan etc.
273. 35683/19 Rana Muhammad Afzal v . Federal Board of Revenue through its Chairman etc.
274. 35719/19 Arshad Malik v . Member (T axes) Board of Revenue, Punjab Lahore etc.
275. 38351/19 Muhammad Amin Shad v. Federation of Pakistan etc.
276. 38803/19 Muhammad Ameer v . Member (T axes) Board of Revenue, Punjab Lahore etc.
277. 38805/19 Abdul Majeed v. Member (Taxes) Board of Revenue, Punjab Lahore etc.
278. 38766/19 Muhammad Amin Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
279. 33265/19 Asif Ali v. Federation of Pakistan etc.
280. 38746/19 Madho Lal Hussain v. Federation of Pakistan etc.
281. 38924/19 Asad Javid Khan etc v . Member (T axes) Board of Revenue, Punjab Lahore etc.
282. 38860/19 Malik Fayyaz Ahmad v . Member (T axes) Board of Revenue, Punjab Lahore etc.
283. 39004/19 Hussain Siddique v . Government of Punjab through its Chief Secretary etc.
284. 39016/19 Javaid lqbal W arraich v . Member (T axes) Board of Revenue, Punjab Lahore etc.
285. 38993/19 Riffat Siddique v . Government of Punjab through its Chief Secretary etc.
286. 39005/19 Hassan Siddique v . Government of Punjab through its Chief Secretary etc.
287. 39323/19 Muhammad Saleem through Legal Heirs v . Federation of Pakistan etc.
288. 39293/19 Essa Bin Moeen v. Federation of Pakistan etc
289. 39292/19 Muhammad Ayub v. Federation of Pakistan etc
290. 39186/19 Waqar Ahmad Khan v. Federation of Pakistan etc.
291. 39167/19 Raja Javed Mujtaba v . Member (T axes) Board of Revenue, Punjab Lahore etc.
292. 39168/19 Raja Javed Mujtaba v . Member (T axes) Board of Revenue, Punjab Lahore etc.
293. 39099/19 Syed Shaheryar Raza v . Federal Board of Revenue through its Chairman etc.
294. 39182/19 Syed Gul Muhammad Shah v. Federation of Pakistan etc.
295. 39184/19 Essa Bin Moeen v. Federation of Pakistan etc.
296. 31645/19 Niaz Ahmad Phularwan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
297. 30647/19 Zulfiqar Ali v. Government of Punjab through its Chief Secretary etc.
298. 26167/19 Ayesha Rajab Ali v. Member (T axes) Board of Revenue, Punjab Lahore etc.
299. 31120/19 Zulfiqar Ali W attoo v . Member (T axes) Board of Revenue, Punjab Lahore etc.
300. 34442/19 Muhammad Amjad v . Member (T axes) Board of Revenue, Punjab Lahore etc.
301. 33743/19 Malik 'Allah Bakhsh v . Member (T axes) Board of Revenue, Punjab Lahore etc.
302. 39480/19 Wali Rehman v . Government of Punjab through its Chief Secretary etc.
303. 39556/19 Nazar Abbas Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
304. 39492/19 Rashid Tufail v . Member (T axes) Board of Revenue, Punjab Lahore etc.
305. 39519/19 Muhammad Mustafa v . Member (T axes) Board of Revenue, Punjab Lahore etc.
306. 39631/19 Mian Muhammad Ilyas v. Federation of Pakistan etc.
307. 39634/19 Huma Muhammad Din v . Member (T axes) Board of Revenue, Punjab Lahore etc.
308. 39635/19 Raja Javed Mujtaba v . Member (T axes) Board of Revenue, Punjab Lahore etc.
309. 39865/19 Hammad Zafar v. Federation of Pakistan etc:
310. 39867/19 Muhammad Habib Ullah Anjum v. Federation of Pakistan etc.
311. 39868/19 Sajid Ali v. Federation of Pakistan etc. 312 39822/19 Malik Naseer Ibne Rajjad v. Federation of Pakistan etc.
313. 40853/19 Mushtaq Ahmad Shad v. Federation of Pakistan etc. 314 40856/19 Muhammad Nazir Ahmad v. Federation of Pakistan etc.
315. 40920/19 Muhammad Samar Abbas v . Federation of Pakistan etc.
316. 40921/19 Muhammad Zahid Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
317. 40923/19 Muhammad Arif Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
318. 40927/19 Asif Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
319. 40929/19 Zafar Ullah Khan v . Member (T axes) Board of Revenue, Punjab Lahore etc.
320. 40931/19 Qasim Ali v. Member (T axes) Board of Revenue, Punjab Lahore etc.
321. 40932/19 Sakhawat Ali etc v . Member (T axes) Board of Revenue, Punjab Lahore etc.
322. 40933/19 Muhammad Shafqat Abbas v. Federation of Pakistan etc.
323. 40945/19 Raja Muhammad Afzaal v . Government of Punjab through its Chief Secretary etc.
324. 40946/19 Raja Muhammad Afzaal v . Government of Punjab through its Chief Secretary etc.
325. 40949/19 Raja Muhammad Afzaal v . Government of Punjab through its Chief Secretary etc.
326. 40950/19 Raja Muhammad Afzaal v . Government of Punjab through its Chief Secretary etc.
327. 40956/19 Mubashir Ahmed Korotana v. Federation of Pakistan etc.
328. 33655/19 Muhammad Ahmad Samar Saleem v . Federation of Pakistan etc.
329. 28356/19 Imran Ali Bhatti v. Federation of Pakistan etc.