Cargills Quality Dairies (Pvt) Ltd. V. The Commissioner General of Inland Revenue – CA TAX 29/2014-2022

In the case between Cargills Quality Dairies (Pvt) Ltd. (appellant) and the Commissioner General of Inland Revenue (respondent), the court addressed whether the Secretary to the Tax Appeals Commission (TAC) was vested with the authority to reject an appeal for non-compliance with security deposit requirements under Section 7 of the TAC Act, and whether such rejection, executed without a hearing, violated principles of natural justice. The Court of Appeal determined that only the Commission itself, not the Secretary, was authorized to make such decisions and that statutory requirements regarding security for appeals are directory rather than mandatory in the absence of penal consequences. The judgment emphasized the necessity of procedural fairness, particularly the right to be heard before