ࡱ> wzv_ Zbjbj,E,E ;N/N/kR&8T ,+LL"nnnIII*******$-/@*IIIII*nn*Inn*I*:m,n@j **0+R/5// IIIIIII**GIII+IIII/IIIIIIIII : IN THE HIGH COURT OF SINDH AT KARACHI C.P. NO. D-3204 / 2013 Present: Mr. Justice Syed Hassan Azhar Rizvi. Mr. Justice Muhammad Junaid Ghaffar. Allied Rental Modaraba Petitioner VERSUS The Assistant Commissioner, Sindh Revenue Board & Others Respondents Date of hearing: 11.12.2013. Date of Judgment 27.01.2014 Petitioner: Through Mr. Emadul-Hassan Advocate. Respondent No. 1 & 2: Through Mr. Zamir Ali Khalid Advocate. Mr. Mustafa Mahesar Assistant Advocate General for the Province of Sindh. J U D G M E N T Muhammad Junaid Ghaffar, J:- Through the instant petition the petitioner has challenged the Order in Original No. 160/2013 dated 12.7.2013 passed by the Respondent No. 1 and has sought the following relief(s):- Declare that the services including Operations & Maintenance services performed in other provinces i.e. outside the jurisdiction of the Sindh Province are not covered by the Sindh Sales Tax on Services Act, 2011. Declare that the letter No.SEB.COM-I/AC-2/Modaraba/7143/2013 dated 18.07.2013 issued by Mardan, Khyber Pukunkhaw Province is illegal and without any jurisdiction, Declare that Operation & Maintenance Income from Operations & Maintenance services come under the ambit of the Tariff Code 9822.2000 Maintenance & Cleaning Services as mentioned in the First Schedule to the Sindh Sales Tax on Services Act, 2011 and are not under Contractual Execution of Work and Furnishing Supplies as mentioned under the Tariff Heading 9809.0000 in the Second Schedule. Declare that the exemption threshold of Rs.50 Million for composite contract including supplies and Rs.10 Million for services is for individual contract and not the aggregate of all contracts executed for that enterprise. Restrain the Respondents from issuing notices to the Petitioners customers outside the jurisdiction of Province of Sindh. Restrain the Respondents their servants, agents, attorneys, assignees or any other person acting under their behalf from levying Sales Tax under the Sindh Sales Tax on Services Act, 2011 on income from Operations & Maintenance activities mistreating it under Contractual Execution of Work and Furnishing Supplies under the Tariff Heading 9809.0000 in the Second Schedule to the Sindh Sales Tax on Services Act, 2011 till the disposal of the instant petition as the Petitioner is being prejudiced illegally by burdening the Petitioner with an illegal levy. Suspended the operation of the impugned Order-in-Original No.160 of 2013 on 12.07.2013 demanding payment of the alleged short/non-payment till disposal of the instant petition. Cost of the petition may be awarded. Any other relief, which this Honble Court may deem fit and proper under the circumstances, may be awarded. 2. Briefly, the facts as per the memo of petition are, that the petitioner which is a Modaraba Company is duly registered with the Securities and Exchange Commission of Pakistan (SECP) and is being run and managed by its Management Company i.e. Allied Engineering Management Company (Pvt.) Limited. It is stated that the petitioner and its management company are dealers and the representatives of world renowned company M/s Caterpillar Inc.-USA, for the last 20 years. It is further stated that the petitioner is engaged in the business of rental of Heavy Industrial Equipments including Power Generation Equipments, Earth Moving and material handling equipments and in addition to this, the petitioner is also involved in providing Operation and Maintenance services for the equipments owned by its customers on a fixed monthly services fee basis. It is further stated that the Operation and Maintenance is a special kind of business for maintaining heavy machinery and includes maintenance and cleaning of the equipments owned by the petitioners customers to keep the equipments in good running condition which includes on/off-services, oiling etc. and is not by any stretch of imagination execution of work. It is further stated that the petitioner earns its income from its Operation and Maintenance activities which includes providing of services within the jurisdiction of the Province of Sindh as well as outside the Province. It is further stated that after the promulgation of the Sindh Sales Tax on Services Act, 2011 (Act, 2011), the petitioner got itself registered with the Sindh Revenue Board (SRB) as a Modaraba Company and is regularly filing monthly Sales Tax Return under the Act, 2011. However, such returns are filed as Nil returns as the petitioner believes that since the services provided for the Operation and Maintenance are defined in the First Schedule to the Act, 2011, under heading 9822.2000 i.e. Maintenance or Cleaning Services, therefore the same are not taxable. It is stated that somewhere in April 2012 the petitioner was asked verbally to submit its Rental Agreement, Operation and Maintenance Agreements and Management Accounts for the period of 9 months ending 31.3.2012 which was duly submitted vide letter dated 25.4.2012. Thereafter, Show Cause Notice bearing No. SRB-COM-I/AC-V/MOD/Allied Rental/ 5359/2011 dated 15.3.2013 was issued to the petitioner, after a lapse of a period of almost one year, wherein it was alleged that the services being provided by the petitioner are taxable under heading 9813.3900 i.e. Services provided or rendered in respect of Modaraba and Mushariqa Financing as listed in the Second Schedule to the Act, 2011. Such notice was replied by the petitioner through its consultant vide letter dated 18.4.2013 and 24.4.2013. It is further stated that thereafter the respondent No. 2 issued another Show Cause Notice bearing No. SRB-COM-I/AC-V/MOD/Allied Rental/6224/2011 dated 20.5.2013 whereby it was alleged that the petitioner has not paid Sales Tax on its Operational and Maintenance Services which is also taxable under heading 9809.0000 i.e. Services provided or rendered by persons engaged in any contractual execution of work or furnishing supplies as specified in the Second Schedule of the Act, 2011. The said show cause notice was also replied by the petitioner through its consultant vide letter dated 20.6.2013 whereafter respondent No. 2 has passed an Order in Original bearing No. 160/2013 dated 12.7.2013 whereby the contention of the petitioner has been rejected and the recovery of the alleged short payment of Sales Tax has been enforced. The petitioner through the instant petition has challenged the said Order in Original and has sought the above relief(s). 3. Mr. Emadul-Hassan, learned counsel for the petitioner contended that in fact the petitioner had got itself registered in good faith with the belief that in view of the provisions of the Act, 2011 they were not liable to pay any Sales Tax and hence were justified in filing Nil returns. Learned Counsel contended that the services provided by the petitioner are defined in the First Schedule of the Act, 2011 under heading 9822.2000 which are exempt services. It was further contended that once the petitioner had furnished the rental, operational and maintenance agreements on or about 25.4.2012, the matter stood settled as no further proceedings were initiated until 15.3.2013 when the first Show Cause Notice was issued to the petitioner. Learned Counsel contended that even after reply to the Show Cause Notice dated 15.3.2013 no order was passed and subsequently on 20.5.2013 another Show Cause Notice was issued to the petitioner in which the contention of the respondent No. 2 had altogether changed and a new allegation was alleged against the petitioner. Learned counsel submitted that the heading 9809.0000 listed in the Second Schedule of Act, 2011, relates to the services provided to the Construction Industries and was not applicable to the Operation and Maintenance Services being provided by the petitioner. Learned Counsel further submitted that the Operation and Maintenance Services being rendered by the petitioner are distinguishable and do not fall under the Contractual execution of work as specified under heading 9809.0000. On a query by this Court that as to how the instant petition is maintainable directly against an Order in Original for which an alternate remedy has been provided under the Act, 2011, the Learned Counsel contended that the impugned Order in Original was without any lawful authority and jurisdiction, as such a writ petition was maintainable before this Court against the said Order in Original. However the learned counsel further informed that in fact an appeal dated 13.8.2013 has also been filed against the said Order in Original after filing of the instant petition but that was just as an abundant precaution to avoid the period of limitation. The Learned Counsel relied upon the case reported in 2011 SCMR 265 (Miss Zubaida Khatoon Vs. Mrs. Tehmina Sajid Sheikh), PLD 1970 SC 180 (Mian Muhammad Latif Vs. Province of West Pakistan Through Deputy Commissioner, Khairpur), PLD 2011 KARACHI 293 (Syed Jehangir Ali Vs. District Co-ordination Officer, Hyderabad), 2011 PTD 1558 (Shahnawaz (Private) Limited Vs. Pakistan through the Secretary Ministry of Finance, Government of Pakistan, Islamabad), 2009 PTD 201 (Safe Way Through Proprietor Vs. Deputy Collector Customs, (Appraisement Group-I) Lahore). 4. Conversely, Mr. Zamir Khalid Advocate appearing on behalf of the respondent No. 2 contended that since the petitioner has already filed an appeal against the same Order in Original impugned in the instant petition, hence cannot avail both the remedies simultaneously on its own sweat will and therefore, the instant petition was liable to be dismissed. On merits the learned counsel contended that the word Contractual execution of work covers all sorts of works being executed through contracts and agreements, irrespective of its nature and is not confined to any category of services. Per learned counsel the agreements provided by the petitioner fall under heading 9809.0000 as the services provided by the petitioner are in the nature of contractual execution of work. Learned counsel further referred to the provision of Section 2(79) of the Act, 2011, which defines service or services and Section 2(96) which defines taxable services. Learned Counsel further contended that in view of provision of Section 3 subsection (2) of the Act, 2011 if a person is not registered in a certain category and services provided are taxable, then such person is liable to pay Sales Tax on providing such services. It was further contended that the respondent No. 2 has only demanded tax on services which were, and are being provided within the Province of Sindh and have no concern with the services being provided by the petitioner to its customers outside the Province but in that case the petitioner is liable to explain and justify that such services have been provided outside the Province of Sindh. Learned Counsel further contended that the petitioner was previously registered with FBR as a service provider under the Sales Tax Act, 1990 and after promulgation of the Act, 2011 got itself voluntarily registered with the respondent No. 2 as a Modaraba Financing concern, but till date is filing Nil returns, which amounts to a willful default without any justifiable explanation and therefore the respondent No. 2 has initiated the proceedings against the petitioner. It was further contended that there are material factual controversies involved in the instant matter therefore; this Court cannot entertain the instant petition which requires determination of facts. In support the learned counsel relied upon the case reported in 2012 SCMR 416 (Collector of Customs Vs. Fatima Enterprises Ltd.,). 5. We have heard both the learned counsel and have perused the record and the case law relied upon by the parties. Learned AAG has adopted the arguments of the learned counsel for the respondent No 1 & 2. By consent the matter is being decided at Katcha peshi stage for final disposal. 6. Since a preliminary objection regarding maintainability of the instant petition has been raised on behalf of the respondents, therefore we would like to address this issue before coming to the merits of the case. It appears that the petitioner has come to this Court after contesting the matter initially before respondent No. 2; has also participated in the adjudication proceedings by replying to the Show Cause Notice; and thereafter an Order in Original has also been passed in the matter. It is also an admitted fact that the petitioner after filing of instant petition, in which the said Order in Original has been impugned, has also filed an appeal on 13.8.2013 and has chosen to avail the departmental remedy as well. It is noted with concern that such appeal was filed by the petitioner after filing of the instant petition before this Court on 2.8.2013 wherein notices were also ordered to be issued to the respondents on 7.8.2013. Learned counsel appearing for the petitioner has failed to satisfy this Court as to how the conduct of the petitioner, in the manner as stated above, can be appreciated by this Court merely on the ground that the appeal was filed by the petitioner under a mistake and to avoid any lapse of limitation period for filing of an appeal therefore the instant petition was maintainable. We are afraid that this is hardly a justifiable ground for deciding the issue of maintainability of the instant petition in favour of the petitioner. It is a settled law that the person who wishes to challenge any act of a Government functionary on the premise, that such an act is without jurisdiction or a lawful authority, has to challenge such an act under the Constitutional Jurisdiction of this Court at the very first instance, and not after submitting itself to the jurisdiction of the concerned officer or authority who has initiated such an action. We have gone through the replies filed by the petitioner against the Show Cause Notices issued by the respondent No. 2 and are of the view that no such objection, as to the jurisdiction or authority of the respondents was challenged and rather the petitioner had chosen to contest the case on merits as well as on facts, with regard to the quantum and nature of services provided within and outside the Province of Sindh as well as the amount of materials and consumables involved in such services rendered thereon. There is a plethora of case law of this Court as well as the Honble Supreme Court of Pakistan, that if any person resorts to a statutory remedy against an order, then the same could not be abandoned or by passed without any valid and reasonable cause and such person cannot file a Constitutional Petition challenging the same action. We are afraid that the petitioner has not been able to put forward any valid or reasonable cause to justify the filing of the instant petition. In this context it would be advantageous to refer to the judgment of the Honble Supreme Court in the case of Commissioner of Income Tax Vs. Hamdard Dawakhana (Waqf) Karachi reported in PLD 1992 SC 847, wherein the Honble Supreme Court held that such practice, in cases when statute provides alternate and efficacious remedy up to the High Court, invoking Constitutional Jurisdiction of the Courts cannot be approved or encouraged. In the above judgment the Honble Supreme Court had relied upon the following observation of the Court in C.A. NO. 79-K/1991 which was as follows:- We may now revert to the question, whether the appellant was justified to file above Constitution petition against the order of the Tribunal instead of invoking section 136 of the Ordinance for making a reference to the High Court. According to Mr. Rehan Naqvi, a reference under the above provision would not have been adequate and efficacious remedy as it would have taken years before it could have been heard. The same could be true for a Constitution Petition. The tendency to bypass the remedy provided under the relevant statute and to press into service Constitutional jurisdiction of the High Court has developed lately, which is to be discouraged. However, in certain cases invoking of Constitutional jurisdiction of the High Court instead of availing of remedy provided for under the relevant statute may be justified, for example when the impugned order/action is palpably without jurisdiction and/or mala fide. To force an aggrieved person in such a case to approach the forum provided under the relevant statute may not be just and proper. In the present case, the appellant had opted to avail of the hierarchy of forums provided for under the Ordinance upto the stage of filing of appeal before the Tribunal and, therefore, it would have been proper on the part of the appellant to have invoked section 136 of the Ordinance for making a reference to the High Court instead of filing a Constitutional petition. In our view, once a party opts to invoke the remedies provided for under the relevant statute, he cannot at his sweet will switch over to Constitutional jurisdiction of the High Court in the mid of the proceeding in the absence of any compelling and justifiable reason. 7. Similarly, the same view has been followed by the Honble Supreme Court in the case of The Commissioner of Income Tax Karachi and 2 others Vs. Messrs N.V. Philips Gloeilampenfabriaken reported in PLD 1993 SC 434. This Court in the case of Messrs Pak-Saudi Fertilizers Ltd. vs. Federation of Pakistan and others reported in 2002 PTD 679 after exhaustively examining the judgments of various Courts came to the conclusion, that a person cannot be permitted to pursue a petition before this Court and so also avail the alternate remedies at the same time. The relevant portion of the judgment is reproduced as under:- In the present case the petitioner has filed the petition after finalization of the assessment order. Even the first appeal was filed by it during the pendency of its petition. Pressing into service the principle of law enunciated in Banarsi Dass (cited supra) the petition is dismissed as not maintainable. As regards the challenge to framing of the main assessment order it is clarified that nothing in this judgment shall preclude the petitioner from pursuing his departmental remedies. The appellate authorities are directed to dispose of appeals strictly in accordance with law without any instructions or directions from any superior or other authority. 8. The same view has been followed by a Division Bench of this Court in the case of Arshad Hussain Vs. Collector of Customs and 2 Others reported in 2010 PTD 104. Similarly we have also followed the same view vide our judgment dated 19.12.2013 in the case of M/s Bilal International V/s Federation of Pakistan & others in CP No D-4268/2013. 9. Therefore, we are of the view that in the given facts and circumstances of the instant case, the petitioner has miserably failed to satisfy this Court, that as to what prevailed upon the petitioner, to abandon the proceedings before the departmental hierarchy to file the instant petition before this Court. Not only this, the petitioner even after filing of the instant petition, has also chosen to file an appeal within the departmental hierarchy without the leave of this Court and after issuance of notices to the respondents which cannot be approved by us. We are of the view, that the ratio of the judgments referred to above, passed by the Honble Supreme Court and this Court, is fully applicable to the case of the petitioner in hand. With utmost respect the judgments referred to by the learned counsel for petitioner, are not applicable as the facts of the instant petition are quite distinguishable and in none of these cases a petition was entertained by the Courts once a party had already submitted itself to the departmental jurisdiction by availing the alternate remedy under the law. In fact in the instant petition there is more to add, that even after filing of the instant petition the petitioner has chosen to avail the departmental remedy during the pendency of the instant petition. 10. Therefore in view of hereinabove, the instant petition is dismissed with all listed application(s). The Commissioner (Appeals) before whom the appeal filed by the petitioner is pending, is directed to decide the same within a period of 30 days from today after affording proper opportunity of hearing and in the meantime the respondent No. 2 shall not take any coercive action against the petitioner till the said appeal is decided. Since we have held that the instant petition is not maintainable, as such we have refrained ourselves from giving any findings on the merits of the case as it may prejudice the case of either of the parties which even otherwise is required to be decided by the appellate authority before whom the appeal is pending strictly in accordance with law and on merits and without being influenced by any of the observations hereinabove. 11. The petition stands dismissed. Dated: __01.2014 J U D G E J U D G E ARSHAD/     PAGE  PAGE 11 &'(38<>?@AϿymbWODODODODODWh=hpCJaJhpCJaJh=hMCJaJh=h?dACJaJh=h?dA5CJaJh=hx4CJaJh=hV$CJaJh=hd5CJ OJQJaJhph4;5CJOJQJaJhphp5CJOJQJaJhphd5CJOJQJaJh=hss5CJOJQJaJh=h {g5CJOJQJaJh=hd>*CJ OJQJaJ&'?@AKq! " # $ B D a b $a$gdMgddp^pgdp$a$gdssgddgdd   ! " # $ 6 8 A B V Y a b l m | ·····~rf]fQrhph -5CJaJhQ 5CJaJhphp5CJaJhphrl5CJaJhphx45CJaJhph?dA5CJaJh=hpCJaJh=h?dACJaJh=hMCJaJh=hpCJaJhpCJaJh=hdCJaJh=hMCJaJh=h=>*CJaJhd>*CJaJh=hdCJaJ| ~   ! 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