Commissioner General of Inland Revenue vs Cargills Quality Dairies (Pvt) Ltd. – SC/SPL LA/NO 82/2022-2025

In the case between the Commissioner General of Inland Revenue (Respondent-Petitioner) and Cargills Quality Dairies (Pvt) Ltd. (Appellant-Respondent), the Court addressed whether the Court of Appeal erred in interpreting Section 7(1) of the Tax Appeals Commission Act as directory, rather than mandatory, when no specific question of law had been raised. The findings established that the Court of Appeal’s interpretation of Section 7(1) as directory was incorrect in law. Relying on the statutory provisions of the Tax Appeals Commission Act and judicial standards governing appellate procedure, it was emphasized that the correct interpretation of statutory provisions directly affects the lawfulness of appellate court determinations and proceedings before the Tax Appeals Commission. Directions w