Commissioner General of Inland Revenue vs Cargills Quality Dairies (Pvt) Ltd. – SC SPL LA 82/2022-2025

In the case between the Commissioner General of Inland Revenue Department of Inland Revenue and Cargills Quality Dairies (Pvt) Ltd. , the court addressed the issue of whether Section 7(1) of the Tax Appeals Commission Act is to be interpreted as mandatory or directory in situations where no specific question of law was raised. It was held that the erroneous conclusion of the Court of Appeal—which interpreted Section 7(1) as directory—was legally incorrect due to the absence of a properly raised question of law. The relevant portion of the Court of Appeal’s judgment was set aside, and the remainder was allowed to stand. The Tax Appeals Commission was directed to hear objections concerning Section 7(1) and related matters in accordance with proper legal procedure. This decision reaffirmed th