Commissioner General of Inland Revenue vs. First Media Solution (Pvt) Ltd – sllr 2019 volume 3 page 107

In the case between Commissioner General of Inland Revenue and FIRST MEDIA SOLUTION (PVT) LTD, the issue concerned whether a Notice of Assessment issued without the name or signature of the officer constituted a valid assessment under the Value Added Tax Act, No.14 of 2002, with particular reference to sections 60(1) and 61(1). The findings established that the omission of the officer’s name or signature is a curable defect and does not render the assessment invalid, provided no prejudice results to the taxpayer. The court reaffirmed the interpretative principle that statutory requirements expressed in mandatory terms (“shall”) may, in light of context and inclusionary provisions, be directory rather than strictly mandatory. The analysis relied on statutory construction of the Value Added