of additional 2 dd ON 24.04.2021 dl. Attorney General for A oF filing ont filed “RP 1 thts 2020 I , , Const. PNo. 17/2019, ‘ &) oy Justice Qazi Faez Isa. ‘ exes on = A XAG § LS & » > Petitioner Ow LS 2S sscoomet Onl The President of Pakis/.A for filing of additional documents filed a 04,2021 by Additional Attorney General a C.M. A No. /2021 In C.R.P. No. 296/2020 In Const. P. No. 17/201: x2) e % Justice Qazi Faez Isa a x ee g, & XS ; ~ Petitioner * (SOHAIL MEHMOOD) Additional Attorney General for Pakistan ty 5 &IN THE SUPREME COURT OF PAKISTAN (REVIEW JURISDICTION) C.M. A No. /2021 In C.R.P. No. 296/2020 In Const. P. No. 17/2019 Justice Qazi Faez Isa Petitioner Versus The President of Pakistan & others Respondents APPLICATION UNDER ORDER XXXIIT RULES 6 OF THE SUPREME COURT RULES, 1980 FOR FILING OF ADDITIONAL DOCUMENTS Respectfully Sheweth: - 1. That ‘on»21.04.2021 the Hon’ble Bench directed to place on record the complete oder dated 14.09.2020 passed by the Zulfiqgar Ahmed, Commissioner Inland Revenue under section 122(1)/122(5)i PRAYER In pursuance of above order the same may kindly be allowed to be placed on record. (SOHAIL MEHMOOD) Additional Attorney General for Pakistan ISLAMABAD. — » Se: Wh WR. inland 2 f Revenue; tH ee SS Me 'Y Serviog Name: SARINAM ISA . Reglstration 4230197221542 Address: 22/2, 7th Central Street, Phase-II, DHA Karach! South Tax Year: 2018 a Period : 01-Jul-2017 - 30-Jun-2018 | Contact No: 0923452003432 deceee ones Oe peas _100000077117734 EDesctiption ee ute cen ee eee D Code Amount 9" Demanded income Tax ae : 9204 35,857,507.00 Tax Chargeable 9200 36,434,047.00 Taxable Income 9100 104,680,020.00 3, LTotal Income 9000 104,680,020.00 This Is not a valid evidence of being a"filer" for the Purposes of-clauses (23A) and (35C) of sections 2 and 181A. “Page 1 of 164 , Printed’on Mon, 4 Sep 2020 16:60: Evacuees Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad“t thland ‘ents, Revenu i Service Name: SARINA MISA < * Registration 4280197221542 Address: 22), 7th Central Street, Phase-II, OHA) Karachi South Tax Year? 2018 Period : 01-Jul-2017 - 30-Jun-2018 Contact No: 0092345200342 Bus ote ee F 1 14-Sep-2020 AMO Document 14-Sep-2020 RY) 7 READ H SE 2(5)(i) OF INCO! The taxpayer Is an Individuat deriving Income from property and profit'on debt. The taxpayer along-with her children has owned (03) s Off shore properties as detalled-below:- f Pecan of Title/ownership 90 Adefaide | Sehr Isa Khoso & Road, London, _| Zarina Montserrat E10 SNW . | Khoso Carrera oa 40 Oakdale Zarina Montserrat 27-03-2013 | GBP 245,000 Road, London, | Khoso Carrera & E-31 4DL Arslan Isa Khoso % 50 Coniston Zarina Montserrat 16-03-2004 GBP 236,000 Court, K. Street, | Khoso Carrera & Sehr London. W2 Tsa Khioso 2AN 28-06-2013 | GBP 270,000 02, Inttlally, these properties were not declared elther by the taxpayer or by her husband (Honorable Mr. Justice Qazi Faiz Isa} in their tax returnis/wealth statements e-filed with the department. The aforesaid act of non-declaration of offshore properties resulted in filing of Presidential Reference No, 01 of 2019 before the Honorable Supreme Judicla} Council of Pakistan against the Hon?ble Justice Mr, Qazi Faiz Isa, Page 2 of 164 Printed on. Mon, 14 Sep 2020 15:58; Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad‘Name: SARINA MISA Registration 4230197221542 _ Address: 22/€,7th Central Street, Phase-Il, DHaviKarachi South Tax Yeart2018 : Period : 01-Jul-2017 - 30-Jun-2018 Medium : Online Due Date : 14-Sep-2020. HOC Document 14-Sep-2020 *., Contact No: 00923452003432 OS 8 oa8 Mt aforesaid Presidential Reference No.01 of 2019 was challenged by the Hon?bte Justice Mr. Qazi Faiz Isa, amongst others, in Constitiitional Petitions ‘No.17 and 19 of 2019.and.CMA No.?7417"0f 2019 and Constitutionaf Petitions Nos.20-32 and 34 of 2049, In the Supreme cous of Pakistan, Inland Revenue ' Service 04, During the pendency of Presidential Refetence No.01 of 2019 the taxpayer e-filed her income tax return for Tax Year 2018 on 31-01- _/ 2020.decfaring total Income of Rs,4,071/864/- which-Includas income" * from property at Rs.3, 593,540/- and profit on debt at Rs.478 | 324/-, Wealth Statement as on 30.06.2018 was also e-flled alongwith the return by declaring lacal and Foreign Assets thefein at Rs,119, 915,126/- and also reflecting her share In the above sald (03) Offshore Properties. Foreign Incame and Assets Statement u/s 116(A)(1) wag also e-filed declaring foreign income from property at Rs.3,593,540/& profit on debt at Rs:28,324/-. Forelgn moveable & Immovable assets were also declared to the tune of Rs.78,125,080/-. The return so filed was deemed to be assessed u/s 120(1) of the Income Tax Ordinance, 2001. 05, After hearing the above sald constitutional petitions at length the larger Bench of the Hon?ble Supreme Court of Pakistan vide its order Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadinland Revenue Service Name: SARINA MISA Registration 4230197221542 Address: 22/,7th Central Street, Phase-ll, DHA/ Karachi South ” Tax Year!2018 : Contact No: 00923452003432 Due Date : 14.Sep-2020 HAIN Document 14-Sep-2020 : Page 4 of 164 datec 19-06-2020 quashed Reference No.0% of 2019 declaring {t to be of no legal affectand abating the Proceedings, pending in the Supreme Judicial Council (including the Show Cause Notice dated 17-07-2019 issued by the Supreme Judicial Council) against the taxpayer?s.pusband, The FBR)» however, was directed by the Hon?ble Supreme Court to scrutinize the explanations of the taxpayer and her two childrch and pass appropriate orders. The precise directions of the Hon?ble Supreme Court of Pakistan vide paras 4.to 8 of its order dated 19-06-2020, are as under: - Wethin 7 daps af: chts. Onider, the boncerned » Commissioner of Inland Revense shall, ddmself (and noksome other officer exercising delegated powers) issue appropriate notlees uniter the Income tax Ordinances, 200L (P200L Ordinancel) to the spouse and children of the Petitioner to oer on cxplanation regarding the nature wnt source Of the Junds (separately for cack Property) whereby the three Properties in the United Kingdom (via, No. 40, Oakdale Road, Loniton LIL 4DL; No. 9b, Adelaide Road London ETO SNAG ant No, 56, Coniston Court, Kendal Strees London 2 24) that are tn the aames of the spouse and the children were acquired. Vor purposes of this Order the Commissioner Suland Revenue having farisdiction over the Spouse of the Printed on Mon, 14 Sep 2020 15:58: €vacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabada=) Vea) Name: SARINAM ISA Reglstration 4230197221542 Address: 22/& 7th Central Street, Phase-Il, DHA, Karachi South Tax Year: 2018 Contact No: 0923452003432 Period : 01-Jul-2017 - 30-Jun-2018 Medium : Online Due Date : 14-Sep-2020 AU Document 14-Sep-2020 Petitioner (who must te a Commisstoner exercising Jurisdiction and performing functlons etistamabad) shalt ba aesnted also ta be the Comusisstoner ha Wiig jurisdiction over the children (The spouse aid chifdren are 4Aerein after referred to as Pthe respondents?) Any notices issucd or Proceedings taker (or proposed to be issued or taken) under the 2001 Ordinance in relation to any of the respondents int FeSpech OF OR accouny af the properties aforestld prior fo the mate af this Order stand terminated, E forthwith, The nortees shall be served of the officiah residence af the Pewtioner. atistanabadthrough caurler service and sich other nieats a3 may be considered onpropriate and. ‘shall be deemed served on the respoudauts. whew received. aN aly ¢ address, : dhe respondents shall Jurnish their replics to the notices along with such material and record tix igtaemed appropriate In case any of them ts outside the country, if shall be the responsibility of suck person to timely file a . respanse, and the proceedings before the Commissioner shall Page 5 of 164 nO be adjourned or dalapeit, far the reason of non-availability in Paklstan of such persan, Upon receipt of the replies (and of such additional material/record as way be filed int response to such ? Printed on Mon, 14 Sep 2020 15:58: _ Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName: SARINA MISA Reglstratlon 4280197221542 Address: 22/E,.7th Central Street, Phase-Il, OHA Karachi South Tax Years2018 i Period 01-Jul-2017 - 30-Jun-2018 . . a Medium : Online Contact No: 00923452003432 Due Date : 14-Sep-2020 AT Document 14-Sep-2020 clarification or planation, if any, as the Commussioner may, in writing, have sought), the Commissioner shall give an opportunity of hearing te the respondents tn LOrson or through an authorised repraseniative/counsel anid shail thereupon make ax order in accordance with the 2001 Ordinance. Me proceedings shalt be concluded before the | Commissioner within 60 days Of the date Of receipt of the viotiees as SSoresatd, and the order shall be tssued by him. - withle 75 days af the sald date of recelos, and.ne adjournment ‘ i or extension int me whatsoever shall be siven aS affeces or : extends the ee Ze : : 06. In_ compliance. to the Supreme Court of Pakistan?s above - 5 referred order, tax proceedings were initiated, Accordingly, a notice under section 176(1) of the Incomie Tax Ordinance, 2001 was isstied on 25-06- 2020 allowing the taxpayer an opportunity Eo file certain documents/evidences towards explaining the sources of Investment made into the purchase of the (03) Offshore Properties, The relevant portion of this notice is reproduced as under: - fizcompliance to the Honorable Supreme Court of Pakistan?s Order in CP No. {7 & 19 oS 2019 dated 19-06- Page 6 of 164 Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadBee i uli Revenue} ices Se ya : ate Servica J 122(1)(Orderto amend Self or Best Jud¢ment or provisional assessmeht) Name: SARINA MISA “Registration 4230197221542 Address; 22/8, 7thCentral Street, Phase-ll, DHA) Karachi South Tax Year t2018 Perlod : 01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432 DueOster eee 202 + 14-Sep-2020 AO Document 14-Sep-2020 2020, ta: proceedings under the Liceme Tax Ordinance, 2001 are in hand to help you explain the sources Of investnent made into the purchase of 03 offshore. Properties as directed by the Apek Court, Abcordingly, you are requestedlo Poder an explanation regarding the nature and saitrce of firtuls (separately for each Property whereby the thice properties in the Untied. Kingdom (lz, No. 40, Oakdale Road London GI 4#DL,; No. 90, t . Adelaide Road, London B10 SNF and No. 50, Coniston Court, i Kendal Street; Loudon W'? 248y that are in the names of the i Spoise and the children were acquired? The. Partleulars.of the Properties and the stpporting docunjents re "eg Uae red are Asted-as. undsr: a) Property at 40, Oakdale Road, Londen, ELT 4DLe & Detail of sources of invesbnent along with woney tral! reflecting in the bank statements showing the rangle of money to the account of the solieitor/seller. wh Agreement to sel! and sale deed duly reflecting the guantwent of investinent and the licidental charges, &) Property at 90, Adelaide Road, London E10 SNIF: » & Detail of sources of investment along with money trait reflecting in the bank statements showing the transfer of money to the account.of the solicilor/seller. Page 7 of 164 Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha. Khan Avenue, F-5/1 IslamabadRS! Inland = Revenue Name: SARINA MISA “Registration 4230197221542 Address: 22/6, 7thyCentral Street, Phase-li, OHA, Karachi South Tax Yeary2018 Period : 01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432 Due Date ; ue 2020 £14-Sep- AC Document 14-Sep-2020 th Agreement to sall and sale deed duly reflecting the quantum Of investment and the incidental charges. ¢Y Property a 50, Coniston Court, Kendal Street, London W2 edhe 4 Detail of sources-of investnieut along with money tra{l (oflecting tn the bank statenjéms showing the transfer of moray 40 the decount of the solicitarheller, 4, Agreement ta wel! anit sale deed duly ri eflecting the quantum oS investment dhd the incidental charges. . YOu map file any ather detail/ documents and evidence in t Tee support of pour defense, ifso desired t Yiu are requested to make compliance to the notice oy te c \ 92-07-2020, positively. Please note that alf written replies along with attachments may be uploaded through FRIS login so: as to make tt part of permanent electronic record? 07. Following attempts were made to ensure proper service of the sald notice. I. Tax officials were deputed to serve the notice at the designated residential address i.e. House No. 7, Judges Enclave, Opposite Punjab House, Islamabad on June 25, 2020. The security officials at the main gate of the Judges Enclave, after a contact on the intercom, Informed the tax officials ‘to serve the notice In Prifted of Mon, 14 Sep 2020 15:5 "Page 8 of 164 Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadtee @ : : RSE= i ! Revenue TMA # Service Name: SARINA MISA : +" Registration 4230197221542 Address: 22/&) 7th Central Street, Phase-lI, DHAYiKérachi South Tax Year 2018 Contact No: 00923452003432 Period : 01-Jul-2017 - 30-Jun-2018 Medium : Online Due Date : 14-Sep-2020 IONE Document 14-Sep-2020 Page 9 of 164 the Supreme Court on taxpayer?s husband Hon??ble Mr. Justice Qazt Faez Isa, The officials returned out of deference. TL Tax ‘officials visited the Supreme. Court of Pakistan to serve the notice on Hon?able Mr. Justice Qaz! Faez Isa on June 272020, The R&I branch of the Supreme Court of Pakistan; after due consultations, informed thé tax officials to serve the notice at -Mr, Saleem ? Caretaker of the Judges Colony: When the tax officials again went to Judges Colony to serve the notice, the security at/the malin gate of the Judges Colony Infarmed that ?Mr,. Saleem was not available to receive the notice? Renole of. +. “the officials are available Omrecord).° Mil. ‘The notice was also sent through Iris system, 23 well as courler service at the residential address |.e. House. No. I “Judges Enclave, Opposite Punjab House, Islamabad, vide TCS #- 2364676366, dated 25.06.2020, The courler service returned the notice unsetved,6n 29,06.2020 with the remarks ?RD 7 Refused Delivery.? 08, However, no compliance to the above notice u/s 176 was made on the due date, Therefore, a reminder was issued on 03-07-2020 for compliance on 09-07-2020. It was also accompanied by a copy of notice under sectlan 176(1) dated 25-06-2020, The reminder sent through manual service as well as through Courier service again remained Printed oh Mon, 14 Sep 2020 18:58: » Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadIntend Service Name: SARINA MISA Registration 4230197221542 Address: 22/6, 71h Central Street, Phase-Il, DHAWKarachi South » Tax Year?2018 Contact No: 00923452003432 Period : 01-Jul-2017 - 30-Jun-2018 Medium : Online Due Date : 14-Sep-2020 AE Document 14-Sep-2020 “Page 10 of 164 unserved. Therefore, these notices had to be served through affixture at the designated address le. House No.07,Judges Enclave, Opposite Punjab House, Islamabad. This time the taxpayer attended the office.on the due date |,¢., 09-07-2020 and filed ber reply contending thatshe was not awere.about these notices until the same were affixed at the outer gate Of her residence, The reply 1s reproduced as under; - , Tite open envelopes with their contents on Sill display: were pasted on te gate of mp husband's Oitlal residence. [ have attached @ picture of the en velopes attisched 10 the gale to _ this letter, One envelope is addressed 42 me, one Lo my daughter, and one to upson. My datighter fs marticd, has three children and tives separately; my-son lives te London: T am’ returning the envelopes which were addressed to them. You | want 10 write to them please wrtte to them directly. Since the day the notice was pasted onthe house gael have been given oily F days to respoid. - Yue write that notice was sent to me on 25th June 2020 but 1 did not receive it On 25th June my father died. Ady father wos living with me and my husband since the beginning of last Yea; he was suffering from grade 4 cancer, had one infected Kidney and a large henor surgically removed. fdo not claim any special privilege or favor on account of) my being married: to a Supreme Court Suge, but l did expect to be treated like a Printed on Mon, 14 Sep 2020 15:58: Evacuse Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad Revenue tiName: SARINA MISA Address: 22/6, 7tiyCentral Street, PhaseclI, OHA, Karachi South Tax Yoara2018 Perlod : 01-Jule: 2017 - 30-Jun-: 2018 Contact No: 00923452003432 - Medium : Online Due Date :44.Sep-2020 AA Document 14-Sep-2020 Page 11 of 164 Auman being, and not targeted the very day my father died. The deed body af my father was pluced with ice blocks and Lay in the house tilt he was transported 10 Karachi for burial, [am in mourning and have not ventured Gut of my home nor ant it @ Psion to contact ct lamper: Qhenly displaying your noti¢esyor ‘public viewing made me Jeel like a crook: Sveryone has seen these notices, am ashwned to step out, Linow Mat you, as asentor officer, would nat have stooped to such tactics, bub, asl was tolewhen L. had visited the FBR Wice carkier in the year, Pluck uparsay hen” ireciions have come from above). Mr. Lavan Khan's. One ” has targeted me and my childven to settle scores wth mB. husband since May 2019, Shas seeing @ programn'on television in which an lacome . , tax expert was saying that FBR cannot ask any Question afer a * certain period. M was very technical but l rentember him mentioning diffrent perlods and that afler §. dears PLR cannot ask any question, In my. present coudition [an not able to get tax advice, AS a Sentor officer it is also your duty to help taxpayers. Please tell me tf what L£. demas on the television is CONrect, The tate Mr. Rehan Flasan Nagui was a very reputable and senior tax cousulrant, I sure Jou have heard of him, Registration 4230197221542 inland Revenue Soetvice Printed on Mon, 14 Sep 2020 48:68: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadPage 12 of 164 Name: SARINA MISA * Address: 22/6, 7th Central Street, Phase-ll, DHApKarachi South Tax Yeart2018 * Contact No: 00923452003432 HOE Medium ; Online used to file np reruns through him My. Naqvi advised me that ‘should epen a foreign currency decowit and put my earnings and savings tn tt 10 safeguard against frequent devaluation of the rupee and to enable me to Masser money abroad. £ remember hin mentioning that there ts some law (/ dont remember Ls name, bur [i sure vou know) whtth encouroges Jorelgn currency account holders (0 save mon. ley and ral to use illegal means 10 twansfer money.ubroad. acted onde advice Gnd opened a pound and dollar forelgn curréley account with "the Standard Charrered Bank at Karachi. Mtr: Naqvi also told me thet no-one‘ can ask questions about Soraign currency accounts. Please provide me with the name A the law and was not Mr. Nagvi's advice correct, i Tédo not understand why pot have sent a notice In relation ta “tax year 20L8” when one of the Properties mentioned by you was bought in 2004 and two in 2013, Please help ne understand, Trcould watt for vou to provide me answers to the questious which [ve asked in paragraphs 4, 5 and 6. However, Lhnaw that br. Znran Khan's coterie will come an TV. and say L ain not providing answers and restart therr, false propaganda, Therefore, Lam going to provide you all the ‘nformation which Lremember and have here with me. Please keep tn mind that Registration 4230197221542 Due Date : 14-Sep-2020 Document 14-Sep-2020 Inland Revenue Service fa 1-Jul-2047 - 30-Jun-2018 Printed on Mon, 14 Sep 2020 15:58; Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName: SARINAM ISA Registration 4280197221542 ; . Address: 22/8y7th Central Street, Phase-II, OHAM"Karachi South Tax Year? 2018 eS ‘ : Perlod : 01-Jul-2017 - 30-Jun-2018 Contact No: 0923452003432 eon nee ne ; -Sep- OC Document 14-Sep-2020 ‘ just because Lam, providing information it does not mean thatl & 5 . accept FERS authority lo ask ne yuesiions, which the law does not allow. The documents pasted ow the.gate start by saying L ant “well aware", Well aware of what? Please do not write an viddles. f ar vot afar: wer buthave taught English for decades, Please tell me in plain English. You refer tovan order of the Supreme Court of Pakisten bue you donor eaclose.it, Please provide it to ine, And, what does "Request Regarding" mean? This ts afr ragment Of a sentence, and is meaningless, : We, Lenran Khants coterie h has spretd fies about me.since Map of last pear and said that ny husband was the owner of the three, Properties in London, They pretended that they received a his information ji from ote Abd@l Waheed Dogar, who they sap. a wrote to Mirza Shahzad Akbar. But. hey did not ask me a single : question about these properties. Why? Therefore, L re@uested the respected Judges of the Supreme Court who were hearing wy husband's case to hear me. On 18 June 20202 was hearg, and the respected Judges were satisfied that L and my children f were the owners of these properties, had paid fer them and i legally transferred money through my foreign currency bank . : account at Karacki maintained with Standard Chartered Bank through proper banking channels. showed in Court Page 13 of 164 Printed on. Mon, 14 Sep 2020 15:58: * Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadBe Name: SARINA MISA Registration 4280197221542 : str + Address: 22/)7th Central Street, Phase-II, DHA, Karachi South Tax Year : 2018 ss Period : 01-Jul-2017 - 30-Jun-2018 2 Cantact No: 00923452003432 Medium : Online oS NOUVEL = nl peeatee ee "i i i supporting documents. Then / learnt that some order had been passed, which was not sent to me, ordering FBR to do te something. On 22nd June 2020 Lwrote to the ten respected Sudges, £ dave iol vet heard from the respected Sudges, probably because the Supreme Court is on summer vacation, Tihsure that, as @ senior Olfiter, you will not becone.a Pury! 10 the malicious lvciics of the coterie. FBR’ records will also inform yout that Islamabad is not my home. Before coming +o Islamabad, £ lived in Quetta for $ years, [have now been away fram my hae in Sarachi for 11 pears, Letme now tall vou about the properties het vow have asked about. i : i SbiConiston Court, Kendal Street, Loudan, W22AN: 16 ‘6 ae . ears ago, in the year 2004 / bought this very small one- 8 ¢ 3 ‘i _ bedroom cpartment (of an area of under 500 square feet) on the ee sixth floor for ?230,000. Later f udded my daughter's nadie to 2 oe : &. The Property kegister maintained by the Land Registry Meh shows the date and. price of purchase. rn . Ween T was In Quetta with my husband terrorists + Mhteatened to atlack, and dld attack. At the time both mp son . and daughter were married, working and living with their : spouses in London. Atp son worked in an estate agency and also ‘i did some private contractual work: My son-in-law was working Jar the UK Ministry of Justice and my daughter-in-law worked ‘Page 14.0f 164 : Printed on Mon, 14 Sep 2020 15:58: €vacuee Trust Complex Fourth Fioor, Agha Khan Avenue, F-5/1 IslamabadContact No; 0923452003432 ATONE “Page 15 of 164 Name; SARINAM ISA Address: 22/E, 7th Central Street, Phase-II, DHA, Karachi South Tax Year : 2018 i Perlod : 01-Jul-2017 - 30-Jun-2018 Medium : Online asa financial analyst in the City of London. Both ay daughter and son drehighly educated: my daughter did her graduation, LLM and Barat Law, and my somtiiy eraduation and Masters ta Pisfosophyp, Both of them gotuiveled and started: worklng at. relatively young ages. [feared that the next terrorist attacknjay be snecessfil and I wanted to secure my children's Sitture, Therefore, [ helped tien buy two Properties ln arctatively cheap area orga outskirts of Landau, hv Tsband was not in Savour of this because he did not want his elildren to live abroid, Dut! told hin that why. expose them to danger; and ther iy we were (o be killed at least Ml be hdppy. to kriow my children were safe in homes thay awned. Middclaide Road, London, BLO Nila LUFT) MivedN > buy this property for my daughter ar a'price of ?270,000; this Lroperty was bought in both our names and still stands in both our names. My daughter lived in this property with he tnsbard and alsa had her first child while she was living there. The Property Register maintained by the Land Registry shows Ue date and price of purchase. : dédOakdale Road, London, BI ADL: tr 2013 f helped buy my son a property for 7245, 000; this property was bought tn both our names and still stands in both our names. Adv son ty living ia this property. The Property Register maintained by the y Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad Reglstrationd230197221542 Due Date : 14-Sep-2020 Document 14-Sep-2020" i 4 zg i %Name: SARINAM ISA Registration 4230197221542 Address: 22/8)7th Central Street, Phase-ll, DHA, Karachi South Tax Year :2018 Perlod 01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432' « ene 2 | i eee Land Regisiry shows the date and, {price of purchase. IDK will eksono doubt appreciate thatk ond my children | are probably one of @ few who boughs. Properties in Li ondon in ourhanes. If we wanted to-eoncedl our ounership. of the Croperties we could have. easily purchased shen USING 2 Shin Ushore company ta hide the properties’ real owners. you x don't belteve me, please ask Mr. Imran Khan and his well expertenced porerte.as to how thay coucewled thelr oun ; ownership of properties ubroad. YaG have asked Jor the “money frail" for the properties, £ dont know whatyou mean by “money wall” Please explain ond + Wdentifp the provision in te Income Tex Ordinance, 2001 where “money trail” is mentioned so L can understand vou and be able fo auswer your question properly, |. = FERS old record will show thatl used to work in the he URS 3 : prestigious Karaché American School in Karachi, Jstarted = D “work in thts School before L macried any Iuisband, Lrcome ta : was deducted. by the School jrom my paycheck, Later f started Jiling income tax returas with the RIO at Karachi. Mr. Naqvi : would prepare my income tax returns. After working for @ecades at the School L resigned. 7 alvo was part owner with a Sitend of properties in Kavacht from which I derived rent. 7 diselosed these properties and. reatal income and puid taces on ‘Page 16 of 164 Printed on Mon, 14 Sep 2020 15:58: Evacuse Trust Some Fourth Floor, Koha Khan Avenue, F-5/1 IslamabadAddress: 22/6, 7th Central Street, Phase-ll, OHA, Karachi South Tax Year : 2018 Period : 04-Jul-2017 - 30-Jun-2018 Contact No: 0923452003432 Medium : Online Page 17 of 164 NAAN (eee eee them too. In addition, / had, and still 0 WR agricultural lands in the arewaf Dek Korar, Tapa Zangipur, Thul, Disiriee Sacobabud, Sindh and in Tehstt Deva Murad Jamali, Disieter Nascerabad, Balochistan, de Nagui advised me that income tax & not payable on agrictiliural income, detutls of whiefrare mentioned tn my returns. } T2& have also asked nero. Provide & copy of agreemchi v0 sell" for the thrée London properties, Mere were no suck “GSTECIETES. Lhe stles were dane through solicitors, Li London the buper daes not enter-inte the transaction with the seller nor ‘does the Super hand over the money to the seller. Bveryihing is done through solicitors. J caunot Say what documents the soticttors obtained from the sellers and what documents they prepared, “SLO x Yih have also asked for the "sale deed" Jor euch of the Properties. As regards $0 Coniston Court Kendal, Street, 2 2AN, London there is no sale deed A long lease was executed &p the Chatrch Couimissioners, who own the Property, in my Savor and then my daughter's name was added. 2 have also enquired about the “quantum of davestnent” in respect of each broperty. Please explain what Jou mean by this, Unlike Pakistan, where mast people show te Putchuse price to be Sess than what the property is actually Registration’4230197221542 Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName: SARINAM ISA Registration 4230197221542 . i . . Address: 22/6 ,7th Central Street, Phase-ll, DHA, Karachi South . Tax Year :2018 7 : ‘ F Perlod : 01-Jul-2017 - 30-Jun-2018 a Medium : Online Contact No: 00923452003432 2 Due Date : 14-Sep-2020 . HOA a Document 14-Sep-2020 ae bought for, because they May vot have sufficient white money zi ° on may Want to reduce payment af taxes, this does not Aappen i Mi London. The prices mentioned by me above is what was paid 10 buy these properties. Yl remember correctly the pricets Less that ?250,000 there is ne Stop duty ar very little samp at aly, and tt goes typ Lrogeessively. But as £ don't remenber £ don't want to make a specific statement-as irs Deen many pears. Ln any case t did nok directly pay anything as everything was paid through the solicitors, f F . Koh also enguired about "incidental charges” an the — Properties, Again, { do not.understand what vou mean, However, difecent taxes urd charges are imposed by different vanthovities, £ am filing income la returns wlth: HM Revenue, 4 aad Customs of UK and pay theome téx on my net earnings, - whlch means after deduction of all expenses incurred on the propertigs, 4 Hiker f stanped working at the Karachi American School p and sold the rented properties which LZ owned tn Pakistan [+ ae Stopped filing income tax returns in Pakistan because Lwas = wavised that I did uot have any "taxable" income in Pakistan, Te records of FBR will confirm thet? have paid income tax on alt my fexable income. J was then Informed that the law was recently changed in Pakistar, L think in the yaa 2OL8, surely Printed on, Mon, 14 Sep 2020 15:58: “S Page 18 of 164 eee Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-6/1 Islamabadintand Revenue Servica ‘27h lla Nor tanh ale. provisional assegsment), ij : >Name: SARINA M ISA ot Registration 4230197221542 Address: 29/2; 7th Central Street, Phase-ll, DHA, Karachi South Tax Year ; 2018 : Period : 01-Jul-2017 - 30-Jun-2018 _ *Gontact No: 0923452003432 Dus Dae hee ein ? 14-Sep- AAA ", Beeument 14-Sep-2020 vou must kiyow this,.The new low vequired that foreign Propetes and mantes not earned tn Pakistan also now have to be declared, TBhout waiting Jor the FBR myself took the initiative , +0 comply with the new lin / contacted a focal iucotire tax. rz \_) praciilionar to help meprepure tnd file ny returas, He lold me that my RTO had heex changed from Karacht to Islamabad acid asked may Thad requested PER 0 do so, tsaidz hid not done So, He told me thai FER cannat do this itselfand RTO can only” . be.changed pon My request. Why did FBR break the a : wrote. 1o' Dr, datuhatmed. Ashfag Alone on Bist Vanvary 2020 - : but he did not reply, probably because he had no answer to j ? , Whar L wrote. Is this how FBRIs run? he r Shehow the respected Judges af the’ Supreme Court - : : Jearat of Dr. MubhanmadAshfag Alimed's mischief and upon } the intervention of the Skpreme Court yp REO was changed fissees back to Karachi. Therefore, f was able to file mp income tax oe, . tetarn for 2018 and 2019, F ‘ 425: the year 2018, my taxable income was Rupees 4,971, 864 and {paid income tax equat to Rigees 576,540, FBR happily accepted my tax return and the tec paid by me, £26; the year 2079, f had taxable income of Rupees ‘ S531, 076- and t paid income tax equal lo Rupees 809,970, i Page 19 of 164 a : Printed on Mon, 14 Sep 2020 16:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadcents BR Lei idan Tinlarid | : p ; i aes eT | e Revenue) Service | Name: SARINA M ISA ” Address: 22/8; 7th Central Street, Phase- Registration 42301 97221542 Il, OHA, Karachi South Tax Year: 2018 Period: 01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432 eos 4a HHA ae Document 14-Sep-2020 > Fidase tell me if my RIO has ouce again been chunged (a Iskeshabad, behind my back anit withols me requesting this. Y 208, how have you issued me the notice? f L2ifjeve lhe Chairperson of FLR Ms, Neusheen Javaid : r Anjad, ofter serving Jor less than three months, has been removed. Liseems she wes. “et prepared ta da the bidding of the coterte. Has the entire FBR been Put to serve the object of removing a Supreme Court Judge? LER has got 4 new Chairman for only three months and, tfor @ specifictask and Dr, : ¢ » Mthammed-Ashfag Ahmed no doubt continues to take €? : ‘ é * "instructions Sion ‘upar say, GS . Aihher than appreciating Leople voluntarily coming Sorward to declare their income end paying taxes the cowerié 5 4 vatineks them. Op is it because an @ woman and. the misogynist corerte does nol respect wamen'’s independent financial shrtus? . Please tell me pow Wauy wor-salaried women in Pakistan ae ‘ : acces? x ShOuld the FER not ask Mr. Imran Khun why he pays " * . bess tax than £ de and yet somehow managed to buy very 2 : expensive properties and lives in a 300 kanals massive mansion? Should FER not ask Mp. Imran Khan, Mirze Shahzad Akbar, Mr Anwar Mansoor Khan and Mr, Farogh Naseem how they Hegally obtained my past income tax records and "Page 20 of 164 Printed on Mon, 14 Sep 2020 15:58: a Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName:.SARINA M ISA Registration 4230197221542 Address: 22/8, 7th Central Street, Phase-lI, DHA, Karachi South Tax Year : 2018 Period : 01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432 Medium : Online . Due Date : 14-Sep-2020 CAO ma Document 14-Sep-2020 _ Page 21 of 164 disclosed them? S3dbid Hot want to drag anyone iio thls but Ive Aad enough of being spied on, abused and harassed for the last year aud nade to feel like a commoner tninal Please do not blame ame Fadl that l ask FBR (odo is to Movide ime coptes-of the dacome lax records of: (by MeAtmran Kuan, (2) Abdul Waheed Dogar, (3) Mirza Shahzad Akbar, (4) ddr. Furogh Naseem, (5) Ar, Anwar MMansdor Khan and (6) Dir Muhammad Ashfaq Alimed whether they shaw the Properties of thelr wives ard children in heir jreome tax : Papersy please provide capies of + thelr returns, from ‘when thep started raping. income tex till now, as they had obtained and disclosed may records, They should have ng objection if FER treaty theng shntlarly, Every day we are told that we are strividg fon the Madinah ke Rivasat, therefore, Lam sure these gentlemen will be only too hgppy to infarm an ordinary, taspaylig woman about how much tar May pay and, the status of their wives and children's propertles, ifr not then L may heve to ask thent Guestions. L52.sure as a dedicated professional vou will apply the faw with an ever hand and not allow wourself to be used or bullied Shave provided you the information you asked me for, Can vou now please tell me why exactly you wanted this Jnfermation? Your notice concludes by saying that L "may file Me, Rovenu Service Printed on Mon, 14 Sep 2020 15:58; Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName: SARINAM ISA Reglstratlon 4230197221542 Address: 22/6y7th Central Street, Phase-II, DHA@Karachi South Tax Year:2018 Contact No: 00923452003432 Perlod : 01-Jul-2017 - 30-Jun-2018 Medium : Online Due Date : 14-Sep-2020 ANITA - Document 14-Sep-2020 4 Page 22 of 164 any: other detail/documents ard evidence jn support af your defense but since you have not taldute-sohat lam defending [ cannot take the benefit of your offer Please let me know what I an Cejending? [#Aclasé the following: 4 Return of fncome, Wealth Statement and £ oreign dncome and Assets Statement for the Tax Year 2018, 4 Return of Licume, Wealth Statementand foreign Income and. Fei CLS Statement, for the cu Year core, a? Cortifiedte ‘eur by U: bere Stamsh Karachi. dated 5.42.2019,° 4 Standard Chartered Bank's Certificate tn respect of Sereign currency (2) abcoua dated 6.132019, showing deposits for the pears 2003 to 20/3 amaunating to ? 672,490 and remittances abroad during the wets 2003- 2013 amaunting to ? 698,002, 5. Gavernment of Pakistan, National Savings Centre, Jnvestment Position Certificate dated 6.2.2019 in respect Y SSC. Reg. No. 40300. SSC Reg. No. 4/912, SSC Reg. No. 4212, SSC hog, No. 42495, total amounting ro Rs, Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName SARINA M ISA * 22/E, 7th Central Street, Phase:ll, OHA, Karachi South ‘Tax Year : 2018 Addre: Contact No: 00923452003432 * Registration 4230197221542 '1-Jul-2017 - 30-Jun-2018 inline Due Date : 14-Sep-2020 HNO ~ . §, Document 14-Sep-2020 “Page 23 of 164 21,050, 000, 6 Tax Deduction Certificate issued 4y National Saving Centra tx respect of SSC. keg. No. 8573, amounting ta . Rs, 5.000, 0000, 7 Tax Deduction Certiftecte issued bp Nattoireat Saving Centre in respect of panment of) (profit and@ deduction af Fax inrespect S SSC Keg, Nos. 40300, 41212, 42120 and 42495, amounting to Rs. 21,650,000, &. Ta Deduction Cortifiiate issued bp Nationa? Saving . Centre int respect of payment profit and deduction f tax in vespect of SSC Rey. Nos: 38983 and 3905 in respect Of profit on investment of Rs: £0,000, 000, 2% The Property Register maintained by the Loud Registry showing the date and price of pwchase Of thé property at 50 Contston Court, Kentlal Street, London, W2 24N, JQ The Property Kegister maintained by the Land Registry showing the date and price of purchase of the property at 90 Adelwide Road, London, E10 SNH, Sh The Property Register maintained. ‘by the Land Regksiry > Printed on Mon, 14 Sep 2020 15:58:. Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadniang oo i 3 even ¢s » Service Name: SARINA MISA : Reglstratlon 4230197221542 Address: 22/6, 7th Central Street, Phase-Il, DHA, Karachi South Tax Year : 2018 Perlod : 01-Jul-2017 - 30-Jun-2018 * Contact No: 00923452003432 oisoae: cane -2020 -Sep-; UO _ Document 14-Sep-2020 Showing the date and price of purchase of the, PVOPETLY af 7 40 Oakdale Road, London, Li 402, 42. Recerpied letter dated 3.) 2020 submitted personalhe 10 Dr. Muhammad Ash fig Aimed, B. Plennwe Of the envelopes attached ta the gate cit. t4. Retutning the open original envelopes with notices fo ny déteghter and som? ? 09...» Having considered the taxpayer?s reply dated 09-07-2020, a r rejoinder was Issued on 14-07-2020 for compllarice by 21-07-2020, the E relevant portion whereof is feproduced hereunder: : f es se PThis ts int continuation WY your’ eS dated 09.07, 2020» a r delivered ia this office onthe same date in person tn response i 40 Reminder Notide why I76 of the lucome Pax Ordinance, 200 ee Chereinafier Phe Ordinance?). Yau are well aware that the current proceedings under the Ordinanee have been initiated in compliance to the Hon?ble Supreme of Pakistan 2s Order dated 12.06.2020 delivered in CP No. 17, 19-30 32, 34 of 2019 and CA # 7417/2079, 4. The Order of the Supreme Court Of Pakisian and the ? , : ‘Page 24 of 164 Printed on Mon, 14 Sep 2020 15:58: mi wh) r Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadt Name: SARINAMISA . Registration 4230197221542 Address: 22/E/7th Central Street, Phasé-l!, DHA, Karachi South Tax Year : 2018 Perlod : 04-Jul-2017 - 30-Jun-2018 = Contact No: 00923452003432 Due Date : mids 2020 a ACMA] | Document 14-Sep-2020 : Provisions of the lacome Tax Ordinance, 2001 enjoin upow me 4a hetp you explain the dree (3) shore properties owned by dou jointht with pour children Ms, Seharlsa, and My Arsalan ‘ £60, within the stiputated timeyxtame. £ also Qppreciate yous 4 Participation in the on-going Proceedings and hope that with dour similar cooperation this office shotld be able ro couplete the process strictly in uccortlance with the. law aad Wie Supreme . 5 Court of. Pakistants directions. Four reply déted 09.07.2020 : ar Partly riisas a few legal questions and, bartly addresses le _: Core issue pertaining to the explanation of the sources of mS Javestnent made inta three Qishore properties. However: some the querlesfobservations raised are beyond the mantdate af i proceedings it hand referred above. This obice would briefy cvell upon pour legal questions dna then move on to evalijate > the. documents that vour “goodself have filed by way of defense/explanalion tose sources of tavestment made into the subject properties, g 3. Your assertion (para ¢ of your letter) that ?after $ years FBR Sah cannot ask anp question? vis-?-vis undisclosed opshore properties ts lacorrect in view of Section LLL (2) (ii) Of the Ordinance. Likewise, your observidion (para $ of your letter} that Pne one can ask guestions about JSoreign currency " Page 25 of 164 _ Printed on Mon, 14 Sep 2020 15:58: ‘ me = ‘ Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadta t) oS Name: SARINAMISA Registration 4230197221542 . % : Addressi22/F, 7th Central Street, Phase-II DHA; Karachi South Tax Yéar :2018 oe 11-Jul-2017 - 30-Jun-2018 Contact No: 0923452003432 eum Online HAAR Saiiect eee % ee ‘accounts,? is quite misplaced in view oS the Protection of e Zcanomie Reforms fm endment) Ordinance, 1999 fas amended), where-under the exemptions and tnrumurtities. krovided under the Protection kconomle Reforms Act, L293, were ho wore avatleble to private, foreign currency accounts opened afisr 16,12,1999, or incremental depastis made iio the . Pre-existing forelga currency accounts, Morvover, your era objection (Para 6 6f your letter) vis-Pevis GE 2018:is misplaced : tn view of the express provisions of Section LLL QHUD of the i : = x Ordinance, ‘ 3 : ~ . of i x ; : : 3 4. Now, this office turns to pour quite a valid question and * : * fegiimate right of) inowing asto Pwhatl am defending?? Let = spt : Sitst frame the questions that You have to defend and explain; co i sal and then would indicate ds to dow you could do thet lasatiyy he provisions of the Opdmance hore. J. de és ane admitted fact that you own three offshore. properties located in London Jattitly with your children ? dds, Sehar Lsa, ond Mr: Arsalan Iva: Ln spite Of the fact that (i) Property at 50 Coniston Court, Kendal Street, London, was purchased in 2004, (it) Property at 90 Adelaide foad, London was Page 26 of 164 ~~ Printed on. Mor, 14 Sep 2020 16:68: | Lames Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadot ae Name: SARINA M ISA Registration 4230197221542 Address: 29/E, 7th Central Street, Phase-II, DHA, Karachi South Tax Year :2018 ‘ : : Perlod : 01-Jul-2017 - 30-Jun-2018 oe: “Contact No: 00923452003432 : weodlum Online HEME G cos Ca eae ee Purchased in 2013, and OY Property at do Oakdale Road, Londons purchased li 2013, Bios? ware concealed. and not disclosed tn your wealth Statement as 04 30.06.2013. These Mloperties continued to stay concealed unitt, (you disclosed Heys 1 your Wealth statement 23-0n 30-06. 2018 filed on 31.09.2020, This was only efter the Department hod Came nto the 2 : Possession of definite information vis-?-vis Pou Owing these Properties, > > | 2. °, 6 Although you own $0% share.in alt three properties, Veto * wher tt comes (a :thetr purchasediny stienk made Ynto, therm Fou claim to have thought? the ferst one, and Phielped buy? yéur Of _ daughter aud son the 2ndand. rd properties, respectively, Jom 5 ea which Wt would be fair to-constrie that the entire invest@ant it i a, would be explained Ay you. However, vour wealth statement as : ‘ on 50.06,2018 reflects, Only 50% of the investment made into ano he properties implying that the. remaining investment (equal te . 3 S026 Of the total tavestneng was made by your children. Tus, the total quantum of investment made into he three properties, . on the basis of the information avatlable ott record by the : : i Samily, is worked out as ander: S| Prapery Parttentans | Purchas | Total tavasinent | SOS Share ] ' Pagé 27 of 164 . . Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad.122(1\ (order to amend Self or Bestiudament or provisional assessment) Name: SARINA MISA Registration 4230197221542 Address: 22/E/7th Central Street, Phase-Ii, OHA, Karachi South Tax Year : 2018 : ._ Perlod : 01-Jul-2017 - 30-Jun-2018 ~ Contact No: 00923452003432 Medium : Online TANOIOR Doacneniea # e Fear 4 | £0 Coniston Courg | 2004 | Re, P04) FIDE SX. Strack, London 2 | £0 Adelaide Road.| 2013 |Reazgoe [Rs i London 24,138, 3007. I 40 Oakdale Roud,| 2013. | Fn 35,302,100 | R s g& s 4 £2,020, 66.0/- ‘ London 19,181 0307. s, Tol Rs. 104,680, 02U/- | R . : NN : S2,340)010/- © 7. You are regiested to take a clear-eus.siance whether you are assunting the responsthility of. explaining only 50% of the Javesinient as in column S inplying thal your children mustered their oun sources corresponding to Midir shares ‘OR the ?Toral tavestnent? as in column ¢ implying that the resources were ' managed by the parents and thes gifted to children? This ix a/ : Ae Fey germane yuestion to future ouleome of these fax ei : Proceedings. &. Notwithstanding, iy other investments Vhat you have made sme WH 2012, @ snapshot of your total laxedHegitimate sources x available with you til! 30.06.2012 as Ber Your awn tax declarations available with he tax department is as under: Other Total Incoma Total Fax Z Leenpie Romarks Declared Fat ae Sbanine A , : -» + Page 28 of 464 : Printed on. Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName: SARINAM ISA Registration 4230197221542 Address: 22/6/7tn Central Street, Phase-ll, OHA, Karachi South “Tax Year : 2018 : " Perlod : 01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432 : Medium : Online ! Due Date : 14. sep-200 ‘ MOET Document 14-Sep-2020 @ | 2007) ks. 990.2602 | Bs. 26177 [Ni * | neoma tneldes Rs. 15,920 worked back ou the baris of wet parent Of Ry. 1, 5.92/- z (1) | 2008 | Res, 2. Lb 183/- 4S, 949257. | Nik Jncome ineluaes Rs. LOS2ALIW- worked Lack on the basis of tax te + ‘mre Of Rs. 65; 77d/- ‘ 1D \2008| Rs L392 350% | Rs. 97.255% VNU Iucome worked back an the ” % basis tax payments Of Rs. 3 I7.BS5/-~ OD | 2010 | Rs. 760,051. | bs 135, 5054 | NT Income tactitles Rs. 1,517.30. : : ‘ hed back on the basis of tas Z :. Mel Of RS LOY DAT fm Rs, 47,835 | Mik Income includes Rs, 1,691,040/- CY | 204 | Rs. LIV SIOU- - é worked back onthe Lasls af fax ; a. a oe iment of Rs. 126, 604/- a ; es fs: L171. Oe | Rs. 78605 | Wit Hil : § : £8, 9.575 98th | Rs. $51,087/.| Nit Mit ‘ ae : | Thus, on the eve of TIF 2023 during which the offihbre : : Proberties were purchased and other investments werednade % Jon had total whiteheed sources to the tune PRS GBI, 3 1/- 3 : 4 even Uf it is assumed that ou incurred absolutely no personal 4 . expenses, Against scl a backdrop pou made ad investment of 83. 80,638, 700/- (100%) or Rs, 40,319, 350 0%) into the burchase of two additional offshore properties, Additionally, "for T/¥ 2012, and 2013 Jou have declared toral assets at Rs. 2 £6,517, 505/- and Rs. 18,095,363/~ respectively. Thus, the ” “ Page 29 of 164 : Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadinland Revenue fi Service ae J ‘ eve Pa i J - es 1224) (Order to amend seit or Best Judgment or provi is onal assessment) Name: SARINAM ISA j Reglstration’4230197221542 - Address: 22/6/7th Central Street, Phase-lI, DHA, Karachi South » Tax Year :2018 Period : 01-Jul-2017 - 30-Jun-2018 Contact No: 0923452003432 auspee ue 2020 14-Sep- NLA ee Pdefense? that you have to PrOvIgE I$ vis-?P-vis these tnvestotentts which “pparenily ave et Commensurate with dee available sources as per tax declarations, Ka Statement as on 30, 06.2 While, you have nor Fulfilled your statutory responsibility Siting the incume ree retiras and wealth statements for the T/Us 201S.20L6, and * 4017, your wealth siatement as on 3 Q6.2018, indicates thet vour assets have gone to Rs, 119,915,126. (0%, of offthore Properties) from Rs. 15,095,3637. tn 2U3~ showing an therease of Rs. 104,855,763 although no income was offered Sor taxation. Sa : ©) Lucon, i a 06.208 ee x Likewise, your Foveign icone & Assets Statement (FLAS) for Me period enditig of 30.06,20L8, in addition lo the si ‘ qorementlaned three Properties, alsa reflects @ lump-sum ee ' Kguid/bank asset to the wune of RS. 25,785,070. Jn this connection, you are requested to furnish complete bank a : statemant ef the bank account{s) in which this amount is lying : from the date af opening of the aceounts rill 30. 26.2018, duly « 4 reflecting complete debits and credits, +++ Page 30 of 164 : ; ‘Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad+:Page 31 of 164 Name: SARINAM ISA Address: 22/8) 7th Centr: “Contact No: 00923452003432 Registratlon 4230197221542 al Street, Phase-ll, DHA, Karachi South Tax Year : 2018 Period : 01-Jul-2017 - 30-Jun-2018 Medium : Online Due Date : 14-Sep-2020 ANT Document 14-Sep-2020 Qi Documents Furnished You have also submitted Staudard Chartered Bank?s certificate dated WE7T22029 tn respect of Jorelen currency (2) account, showing total credits therein to Hetine of ? 071,490 and debits 10 the tune Y? 698,002 (meade. (0 Took as Premittances abyoied?) ciring the period 2003-2003. This is definttely a good. starting point towards explaining the dnvestnent made into ike bank acvountlofshore, Properties, But Jol would appreciate that for an tn vestitent to gel explained vou need fo produce the evidence ofa tacedlegitinate Sources and then doowmentarily connect its passage tothe seller of the Properties, Kindly provide complete bank Statement ofthe account duly reflecting the.a vailabilige Sf requiste cash ‘deposits coinciding wih she tine of depasttfourchase of the Properties, and then their renfiance through normal banking chaunels into your accoult in the UK or directly fo your solicttar?s accounh Apparently since the depostissinlo the » Joreign curreney accounts did not enjoy any tax exemption, the 10. onus squarely rests on you to prove that elther this amount was already taxed or did nat.attract taxation. Your explanation to the above questions duly supported by required documents must reach this office by Huly 21, 2020? In response to above notice/rejoinder the taxpayer attended the Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad. » i: 4, ?foland Revenue, Services i Name: SARINA M ISA Reglstration4230197221542 Address: 29/6, 7th Central Street, Phase-II, DHA, Karachi South ‘Tax Year : 2018 Period : 04-Jul-2017 - 30-Jun-2018 ; Contact No: 0923452003432 Nene Due Date : 14.Sep.2020 OC a Decumant 14-Sep-2020 office on 21-07-2020 and filed her reply. Her reply Is reproduced-as under: ~ i ‘ PLT am te receipt of a’ ‘Refoinder” signed by yon which has 6 different datesmentioned on tts first page; Fl) "Dite Ditte: 02-Jul-2020" (2) "Documeitl: 25-Jun-2020” cp) “Assignment Date: 24-Jul-20°, (9. "Due Dates 2f-Sl20", 2 "Compliance Dute L#-Jukeao" and, (©) "Printed omTue, L4 Jul 2020 14:10:39" Therefore, 1 do not krow few (0 refer to the date of the Rejoinder. Is this helpful to taxpayers? And is it helpfitl to give taxpayers only 5 days to réply? 1 had informed Jou in my earlier letter of Hh. July, 2020 that my father had . bassed qway on 25th fine, 2020, but it seems notto have i i g = inattered at afl, There ts also no reason lo rush because the eee ' AG ‘Sisreme Cours hias still not ghven tts reasons for the 19th Joe i 2 2020 order, j : : 4 Because of the indecent haste shown by pou Cid - to file a review petttion tn the Supreme Court on 20th July, : 2020, in which pou and your colleagues conduct is mentioned ta the following puragraphs: The AbSets Recovery Unit (2ARO?) is said to Aave been set up vide Cabinet?s unpublished and purported Puatification? dated bth November, 20/8, - Page 32 of 164 Printed on. Mon, 14 Sep 2020 15:58: 4 Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad sheruca,‘ Name: SARINAM ISA “Contact No: 00923452003432 ; ’ Reglstration 4230197221542 Address: 22/6 07h Central'Street, Phase-ll, HAY Karachi South Tax Year: 2018 Period : 01-Jul-2017 - 30-Jun-2018 Medium : Online Due Date : 14.Sep.2020 THMNOARLNA) eee eet atiached herewith as Annexure PC?. This Purported Pnalification? stipulates that a PSentor Wicer fiom the Lederal Board of Revenue? ta be a Member of ARU, Mr. Mihannnad Ashfaq Abutad (2th Aéimed?) was the chosen Senior Officer. However the notification appointing Mr. Ainied cs ARU 2s Member lies not bech Lrodiced, On EF Aprit\2019 br. Ahared was inviled by Atiza Shahzad Akbar at his Wesidenee? vier office “hours, Par (£900 bis?, that. as a7 pit This’ clandestine | ia at meeting took place to discsss the purported: Peomplaint oY Me: Abdul Wahved Dogar? (2Mr. Dagar?) as per " the Pidinutes of the Meeting? @roduced with CHA 4 I3E3/2020, attached asAnnexure PD?), ‘The 2 purported Minutes were typed out on a Plain piece @f paper, which is undated wrnunbered and unsigned. The folldssing day, on Té April 2019. tp: Abimed | Page 33 of 164 again meat with Mirza Shahzad Akbar. In this arecking \ the Law Minister, Mr. Farogh Naseent, was also present, The ?Record Note? (oroduced with Cald JI8S/2020, attached as Annexure ?E2) of this meeting , : Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad wiName: SARINAM ISA : Registratlon4230197221542 dress: 22/6/7th Central Street, Phase-ll, DHA, Karachi South Tax Year : 2018 : Period : 01-Jul-2017 - 30-Jun-2018 ontact No: 00923452003432 ieDuee: TAO oun ts also Qeped out on a Plain piece of paper, ty undated, “anunbered and unsigned. The Retord Note wales, that, hdr. Muhammad Ashfag ahmad, Member ARU Sion FBR Snggested that th order to obtein t farisdletion, @ farntal letter may be written Oy ARO 10 the Chairntiu LDR. The same was agreed bp the Chairman ARV to Sorward the complaint to Chairman FBR for assessmenl and? analysis into the declapation Sf assets of those Sree tioned i tn the compliant?. The Income Tax 2+ * Ordinanee does. Rot confer anp authoripvan outsiders, pee a , including the venliavefiel ARU: Be tliat as, it may, the Chairman FBR presumably did not agree to this yy reguest as the Chairman? approval das Mot been referred to. nar filed. PRLS es seas i Therdfire, since the Chairman FER had ts = . declined the aforesaid request, Mr, Manzoor Ahmad Peseta , Kayant, the Secretary of the ialanfiel ARU, oy + bypassing the Chairman FBR wrote letter dated. So May, 42019 to the chosen and multifaceted Ale. Ahmed (Produced with CHA 3383/2020, attached. aS AUNCXUPE ?F2) as under: Se i i ? 2 . 7 * Page 34 of 164 Printed on Mon, 14 Sep 2020 15:58: - Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadi i Name: SARINA MISA - Address: 22/E)7th Central Street, Phase-ll, OHA) Karachi South | Contact No: 00923452003432 HOTU tt Pes We 2 ers Of Superior: Registration 4230197221542 Tax Year?2018 Period : 01-Jul-2017 - 30-Jun-2018 Medium : Online * Due Date : 14-Sep-2020 Document 14-Sep-2020 ‘Ss ie ln coutiauation of this affiec letter of even number dated 22nd April, 2019 oi the subject cited above addressed tothe Chuttinan LER, f am directed-t0 request thak analysis and assessment ofiassels of the ddividuals and faintly Of lhe persans ce omeerHeel way be expedite hand tre) eport thereon may es submitted to this . ice atthe earliest confin ming: wherher the offshore disses have been declared by he persons imentioned is ie the complaint, Further property detatls, of the persons ~ mentioned (n the complaint are enclosed for taformation. ” The following was not disclosed in the above letters ., ? Who were the certain Members of Superior .. Judiciary? ? Lhe referred letter dated 22nd April 2019 is not produced, Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, Printedon.__- Mon, 14 Sep 2020 15:58: -5/1 IslamabadName: SARINA MISA Registtation 4230197221542 Address: 22/E, 7th Central Streel, Phase-ll, DHA, Karachi South Tax Year :2018 : : % Period : 01-Jul-2017 - 30-Jun-2018 -Contact No: 00923452003432 Medium’: Online EEN sieeeasectigs ? Who Pdweeted? the Secretary ARU to write the letter; and i 2 The stated PFurther hoperty details? are not mentioned. The Secrenarp?s lelier fers to offshore assets? which was Incorrect Usage because in income tex. arlance tt means t@ take wdvaniage of no tax or tower tar reghine, The Properties were wot boughtlin the names of em Qishore conpanies so it was wrong 10 refer to then as cies : 5 ohare assets. However, Me. Luran Khar adnittedlp 7 t bought a property in London in the name Sa Jersey opshore company (PLD 2018 Stpreme Court LL4, at 4 ‘ ; . S (BB Neither the unlaryfiul ARU nor its Secretary had P : the authority to seek and ablain confidential, | protegted Mifermation,and it doing so also violated sections 198 and 216 of the’ Income Tex Ordinance and have made . henselves liable for prosecution hereunder; tn respect whereof the Petitioner reserves her rights. . 4 char&de was played out, The Secretary ARG wrote letter dated & May 2019 to a Member Of the ARG, namely Me. Alimed, to do the needful. bs: Ahmed * Page 36 of 164, : f 1 Printed on Mon, 14 Sep 2020 15:58; Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad pe. ee ‘ ri Name: SARINA M ISA Reglstratlon4230197221542 z Address: 22/6, 7th Central Street, Phase-Il, DHA. Karachi South Tax Year :2018 i! : Perlod : 01-Jul-2017 - 30-, Jun-2018 S a i 7 Medium : Online Contact No: 00923452003432 . Due Date : 44.5, 2020 = oe ae TOGO A Document 14-Sep-2020 # Jumped to play his part, He wrote to Mirza Shahzad , Akbar letter dated 10 May 2012 (attachment PL to the Reference, attached ay Annextre ?G?). This lester is written on the false assumption that the requistte approval had been grafted by the Chairman LER, Ahmed alsa took it upon himself ta assign, Flo the relevant field formation &.e. Commissioner LRS, 3 faternational Caxres/ALOL Zone, Ustamabad, for cognizance, analysis and report under Taw? © Wie val Com paisslonen' Wits ds Za ~ubfidar Ahmad, the sume person who has sent notices to the Petitioner ead to her adiils, non-dependent children (iat the Petitioner ?s hushandis address), Ha has beew chosen By the avacutive and. assigned the matter. dlr. : Zidfigar Ahinad, Commissioner, on the sanre dey that : is x és 10 May 2019, (attachment VILE fo the Reference, es allached as Annexure ?H?), wrote: : . Lhe contents of the complaint fled have been checked with the available Income Tax records of the taxpayers, verification of the Off-Shore assets provided by the contplainant with the declaration of the Laxpayer’s, 7, ? . , * "Page 37 of 164 - Printed on "Mon, 14 Sep 2020 15:58: -5/1 Islamabad Evacuee Trust Complex Fourth Floor, Agha Khan Avenue,_ Name: SARINA MISA . ' Reglstratlon4230197221542 Address; 22/2) 7th Central Street, Phase-Il, OHA, Karach: South Tax Year: 2018 01-Jul-2017 - 30-Jun-2018 soe Contact No: 0923452003432 . " pus bate : ee 2020 ¢ *14-Sep-1 a AOE Document 14-Sep-2020 reveal that these have not been disclosed in the renans We : gid-wealth statements filed, thd hence remain concealed om the date of ie aequisttion, He Aiea The absence of following deiails in the aforesatd letter Den “Is most significant: ? The referred to Haxpa vers? are hot iden ified, it s nol mentioned whether the Paxpajers? are’ the Petitioner, her children and or Inishand or _ ehh of them or someone else; "? Rbnot mentioned Whicl Plucome Dace aw of the taxpayers? and for which period was purportedly 2chethed?s 2 ; 0 Phe cross-verifleation of | the Off-Shore asselgP - ts. mentioned but without stating what is meant F ‘ by cross.vérification, and with what svusitt cross Be verified and what is meant by Off-Shore assets. 5 What these Passels? are is also not mentioned: 4 is mentioned that, Pthese fassets) have wot been disclosed in the tax returns and wealth ‘ : ~N stalaments filed? but the assels are not snentioned nor whose returns ts referenced; and, + 2 ? E , : Page 38 of 164 Printed on. - Mon, 14 Sep 2020 15:58: é : t Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad‘Name: SARINA M ISA Address: 227, 7th Central Street, Phase-Il, DHA, Karachi South ii i [ “7200 (Order to amend Selt or Best Judament or provisional assadement Reglstration 4230197221542 Tax Year : 2018 Period : 01-Jul-2017 - 30-Jun-2018 ‘ontact No: 00923452003432 Medium : Online Due Date : 14-Sep-2020 SAA Document 14-Sep-2020 y The word ?couceated? has been used knowingly, though the requirement for disclosure of foreign Properties came for the Sirst time in thelave-in the ear 2018, ” Mr, Lilfigan Ahmad has already expressed an adverse opinion and shouldnot have been chosen Tor the ask, However he has been assigned the saine task again, probably Sor thls very reason. Th re ish?t even a bretence left uf dealing just: with the Petitioner and her children Dit the sane Way, thatis L0 May 2029... Mr Zla Akined But, Assistant Commisstonér (IR) working direct) undek dd. Zulfigar Ahined wrote bo hit, that the Petitioner ?who also file (Slefther return Sor Tax year abd? (attachment Li to the Reference, attiched as Antexure 22), Ia 2044 the Petitioner was not working, had no taxable income and was not living tn Karachi. Copp of the said return S 2014 has not been filed nor has the Petitioner been Provided tt hy Me Zulfigar Ahmad. The nNOn-exrsting return has been tatentionally referred (0 for the sole purpose of z Nip , Printed on Mon, 14 Sep 2020 16:58; Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F+5/1 Islamabad&s inland Revenue Service Name: SARINA MISA Registration 4230197221542 Address: 22/€, 7th Central Street, Phase-ll, DHA, Karachi South Tax Year : 2018 : * Period : 01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432 i er FOAUMEGUAMOGNO Deere overcoming the limitation period, The Petitioner came taIslamabad in September 2074 with her husband when her husband was appointed as a Judge of the Supreme Court, after Meg gsvtth hime ter Quetta since | ee September 2009, therefore, she couldn? possibly have * » filed the said reiurn Tt ts also inexplicable why she would de so for just this one year and not. (file any for the preceding pear and. subsequent, The Petitioner also did not receive any pucporied notlees Dead Tax . Fear 7 2016, 2017. end oe ay Als loyalty to do Shehzud Akbar, whom he considers L i . _. ff his boss, Mr. Alined vide letter dated 10 May 207% Ree i. reported to Mirza Shak. tad Akbar that the, Pain oe : Sindings o the enguiry by.the satd freld dijicers are dee "gleaned as under? (Annexure ?G?), He concluded by 3 : stating that, ?The proceedings under the tax Jaws tn these cuse have been inttiated?. However, Mr. Ahmed did nor attach copies of the so-called initiation of (procecdings under the tax laws? ov any PPOOS with” - regard thereto Jor the simple reason that no Proceedings were initiated against the Petitioner, as went Dahan -. , { ig? Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad ‘sd nace Name: SARINA/M ISA . Reglstration 4230197221542 Kiress: 22/6) 7ih Central Street, Phase-ll, OHA, Karachi South Tax Year : 2018 Period 01-Jul-2017 - 30-Jun-2018 ‘ontact No: 00923452003432 ; i pueDae : es 2020 } *14-Sep- UIE , Document 14-Sep-2020 there was ne cause or reason to do so. ir. Ahmed, has demonstrated that ke does tiot hestlate to le to please, On Mirsa Shahzad Akbar?s insu’ ‘uetions, he tasked the so-called field officers?,o Conduct an Inquiry. And, he id all this behind the buck af the Petitioner and hem children. Ia one dap everything was done. Mr. Ahined y Presented a report vide his letter dated 10 May 2019 ° hy contain taxdetails of the Petitioner, and Shared ? ; these with sfirza Shahzad Akbar, who was not 4 Ge employed in FBR. These were also sheared with the then 5 Be baw Minister-and.the them Attorney-General, wiho : : c would have shared them with the Prime Minister: in i blatant disregard of the provistons-of the Income Tax “s au § : * Ordinance, The Peritloner, as stared above, reserves aes Aer right to seek theit PUOSCCHUON. j * Bees Mr, Ahmed Is an officer of FBR and a Pasa government servant and cannot take on any other asstenment which the law does not permit, least ofall &n aur unlansfidl organtzation like the ARU, Mowever, he has placed himself at the beck and call of Mirza Shahzad Akbar, a man who proceeds with Taemunity against anyone tn the name ofaccountabsity but about oh ‘ , > f * !Page 41 of 164 3 z Printed on Mon, 14 Sep 2020 15:58: :: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad@ i + tnland "he eats, Revenued SF Service " Names saRINA MISA - Reglstratlon 4230197221542 Address: 29/E, 7th Central Street, Phase-ll, DEA, Karachi South Tax Year : 2018 Period : 01-Jul-2017 - 30-Jun-2018 “Medium : Online Due Dato : 14-Sep-2020 ASU . Document 14-Sep-2020 te Contact No: 00923452003432 whom nothing is known and who. does not disclose even Mis source of livelihood, At, Aluted surrendered his independence as an oifieer of FER and as a a goverment servant and tack, and continues to take: tustructious froma private Lersol, uamely, Mirza Shahzad Akbar. For the rendering of servites, Mr. ahmed strtdtaneously halds pve inportantt positions, (@) Mepber (@h-Operations) and, ODiveciwor Ceneral Caternationil Taxes), Llamubad Revenue Diviston?s notification dated ‘3th May, 2020 is attachad us ‘ Annexure 27?), Sach ofthe. Jobs that Kr. Ahined hus been glen are fillltine, bit his sadispensability by such : that he simulianeously holds two Jill-tine positions, ‘ ae - ‘Onder the commuia of Btr. Aluned and a newly. ener appointed temporary Chairman the desired resilt is sought to be athieved. Cony of Extablistinent?s Division?s notification dated the Seth, 2020 ks attached as Annexure PEP, : bdr, Zulfigar Ahinad states that he sent a notice to the Petitioner on 25th June, 2020 which, according to him, the Petitioner did not receive, The . pe * Pelitioner?s father, who was living with the Petitioner Printed on Mon, 14 Sep 2020 15:58: ! Page 42 of 164 : Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadale Saree Name? SARINA M ISA Registration 4230197221542 Address: 22/8, 7th Central Street, Phase-Il, OHA, Karachi South Tax Year : 2018 Period : 01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432 ous Danie 2020 '14-Sep- ARIANA Document 14-Sop-2020 : tn tslamaboa, died on 256 June, 2020, The Petitjoner has thever refused to receive & nétive. The Petitioner was also not sent any notice In thé normal wap, The Petitioner found pasted ott the Gale of the house, the Offictal residence of Justice ya, Hee open envelopes with their contents on full display. Photograph attached as Annexure 2ZE?, Two notlces tn one envelope nee adldressed to the Peritaner were dared 3th July, 2020 aud 25th June, 2020 and kept by the Petitioner, attached as te PHE? annie i ae Ti he Jonbe dated Fi July, 2020, whidlp i i was pasted on the gatejend retrieved gave ite Petitioner just 3 days rofeespond. The Petitioner wash * ed nol given time to grieve losing her only surviving : Fae ; parent Uf the Petitioner sought time Mi. ImPan Khan2s ; Be ‘ Goverument would have once again unleash a vicious ae) Propiganda against her, which would have been ee , unbearable, The Petitioner, therefore, without the benefit of professional advice, drafted the reply herself. The Petitioner personally went to deliver her reply to ne Me. Zulfigar Alynad on 9th July, 2020 and returned lo hia the open envelopes and notices to ker children, L Page 43 of 164 ‘ _ Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadwee \ 4 f Revenue sas : ie i Be 8 service Name: SARINA M ISA Registration 4230197221542 ‘Address: 22/6) 7th Central Street, Phase-ll, OHA, Karachi South Tax Year: 2018 Period 01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432 Dusan : oree -2020 : op-: HOU - eee esopaen slating that Pity daughter is married, has three children and lives separately: wy son Itves in London. Lf vou want 10 write 10 them Please write to them directl?. Copy of the Peitioner?s reply cated th July; 2020 13 attached as Annexure POP, ~ dhe Petitioner ?s son engaged the services itr, Rashid forahion, one of Paki ISCUR?S shdge seblar ‘ H chertened necountants and aFellow er the Listitale of % Chartered Accountants of Pakistan. He Nas, over 30 * yoats Of experiance u¢ tational and international level.” He ts a former partner at'A, zB Ferguson 86 Co, and Sormer Connect dlember of the lnstliute of Chartered Accountants Of Pukistas. What Mr Rashid Lbrahimy said about the working of FBR and the violation of the law by FBR nakes « shocking read. Ade. Rashid eek : Lbreakimis letter dated 15th July 2020 was written to toa FBR and he provided me with ifs copy as well as his fetter dated 9th July, 2020 are attached as Annecures PP? and 7?, The conduet of Mr. Zulfigar Ahmad and ADR noted iu ir. Rashid lbrahin?s letter dated L51h July, 2020 ks self-evident and shows that FBR and Mr. Ludfigar Ahmad have already decided everpthing> Printed on Mon, 14 Sep 2020 15:58; Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad_ Name: SARINA MISA * “Registration 4230197221542 Address: 29/6, 7th Central Street, Phase-ll; DHA, Karachi South Tax Year : 2018 Period : 01-Jul-2017 - 30-Jun-2018 » Contact No: 0923452003432 pieotae ae 2020 -Sep- TATA became esep ae volices to the Petitioner and her children are wnerelp to dentonstrate a pretense at providing aa opportunity to reply and ofa hearing: 28, pear later, deja vu The Petitioner?s Sather after unsucce, ‘Silly battling cancer, passed quip nly on 25th June, 2020, the very day Mr. Zillfigar dhonad dishonesty says the Petiitoner refused fo recelve his: . hotiee Asif this was not enough teath threats are continuously being eclended to the. Petitioners ‘The’ Pesitioties: did. wot want fo ose her Therefore, she. went to the fearest. Potice i station & on Ath June, 2026 beck ‘ase shey feared for her husbiind?s life, but.she’ was not ‘helped. Instead, the si ‘ Government machinaty was deployed to he helter(fpratect ae @selfproclaiged ierrorist, The Petitioner submitted an . 4 application Gt 6:15 pm-on 24th Sune, 2020 ro the sree 8 i * Bearest police station, that ts, Secretartat Police Station : Sor registration of FIR against Agha Yiikher-ud-Din Mirza (copp aitached as Annexure PR?) Unforntnately, FUR was not registered. Stebsequently, the Honourable Chief Justice took: notice in Crimtual Original Petition No, 39/2020 and issued notices whereupon an FIR was ; Page 45 of 184 . 7 Printed on» Mon, 14 Sep 2020 18:58: + Evacuee Trust von ar Floor, ape Khan Avenue, F-5/1 Islamabad.Name:SARINA M ISA Contact No: 00923452003432 PA MOrder to amend Sait or Bast wudamant ar provisional assesment) Reglstration 4230197221542 iddress: 22/, 7th Central Street, Phase-ll, DHA, Karachi South » Tax Year : 2018 Period : 01-Jul-2017 - 30-Jun-2018 Medium : Online Due Date : 14-Sep-2020 TT 5 eee registered by the Fld but this was done 6 days later, dhaths, on 28th June; 2020. The Petitioner fled her Wiidavit on 74th Sul), 2020 in the sata case (eopy of Petitioner? s affidavit ( attached as ?S?). Previously the entire Governme. vrachinery was brought into Play lo protect Mr. Dogar, who neither Me public hor this Honourable Court knows anything abouh The President oY Pakistat, the Prime Minister, the Law Minister, the Attorney-General, Mirza Siahzad Akbar and, sadly even the Council accapted Mr, Dagar to be an upright laiv-ablding: cttigen, but except the Government?s side-no one énoris who he és, Amat whe does nol pay-a rupee in Weome tint, A man who does, not disclose who he works for, Angin wile does 4or disclose tis properités, those This wie ond children » butt dwells ula ake Petitioner?s Baits with tipunity. The then Chief Justice Astf Saeed Khan Khosa wrote an order on 19th August, 2019 saying, that, Pthe \ eredentials or antecedents Of the informant? are taconsequential, It had been repeatedly stated that the Petitioner?s husband hus Padmitted? the Properties, The Petitioner?s husband did no suck thing. The very tearued Mr. Justice Khosa undoubtedly knew the , . . fila P Printed on Mon, 14 Sep 2020 15:58: Evacuée Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadflped Reglstration 4230197221542 22/E, 7th Central Street, Phase-lI, OHA, Karachi South Tax Year :2018 Period : 04-Jul-2017 - 30-Jun-2018 “Contact No: 0092452003492 . pus oe ee 2020 TOA) .* Document 14-Sep-2020 Address; A difference between acknowledging and admitting : Sontething. ft would be like a. Judge acknowledging that iz His wife ran a boutique and hbe misconswued that he had admitted to be its owner aud the owner of the. building in which it.jnas situated. The Petitioner ty ot a lanyer, but this/sn0te meter of law but of the isuge of the English language, which the Petitioner has taught for decades, and of which e Lelitioner has some knowledge. Per Wie base vai henge io jow reghtire % that all assets, in Pakistan and abjoad, had fo be & declare ed dad. income tax ptiid on. foreign earnings. foo, / the Petitioner engaged the s services Of an income tax s practifiener to, file ier returns, However, the gentlenian = = engaged by the Petitioner informed her tigt her RTO ey i wW Aad been transferred from Karachi to tslamabad, The : Petilioner alwaps filed her returns from Karachi, Therefore, the Petitioner was. 'pusled haw her RTO was’ ae i changed to istamabad, The consultant asked the Petitioner whether she had sought the trausfer of her 4&0 to Islamabad because RTO ks changed only on the request of the taxpayer. The Petitioner had never " Page 47 of 164 : Printedon. Mon, 14 Sep 2020 15:58: -Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad.‘ 5 Name: SARINA M ISA a 7 : Registration 4230197221542 ‘Address: 22/6; 7th Central Street, Phase-ll, DNA. Karach| South Tax Year : 2018 Perlod : 01-Jul-2017 - 30-Jun-2018 “Contact No: 00923452003432 pueDie ee 2020 £44-Sep- CONN Decunient 14-Sep-2020 requested for such change. However, it transpired that this was done on the behest Of chosu targeting the Letittoner?s husband to better manoge things and to da So quickly from islanabadkjrom where Mr. Lay Shans Government could more easily lean on, biti or bribe the officers of FBR with choice Postings. The Petitionér personally weat to the FER and met, amongstothers. Mr, dlimed, and requested for her &TO 10 be changed back to Karachi and subsmittedt deters | dated 27th January, 2020; attached ds Aanecures EP? y and 70%, Hawever, nothing was done, This Honourable Court somehow lewnt of the Petitioner?s. ‘predicament and then the RTO was immediately changed back to see Karacht vide Notification dated 30th January, 2020 copy attached as Antexure PF. Dthe LER had done right in changing the Petitloner?s RIO to Islamabad it would not have reverted the Petitioner?s RIO back to Karacht, but Anowlig it acted foul, It corrected the Wrong done to the Petitioner withoul a murmur. The Petitioner wanted (0 get te the boliom of what was done and wrote letter dated 31st January, 2020 to Mr. Ahmed, capy is ‘ ; ? “Page 48 of 164 : ‘ 3 Printed on. Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName; SARINA M ISA = Reglstratlon4230197221 542 dress: 22/6, 7th Central Street, Phase-ll, DHA, Karachi South Tax Year ; 2018 Perlod ; 01-Jul-2017 - 30-Jun-2018 : “Contact No: 00923452003432 Barba d oe 2020 ?14-Sep- HAA a een : attached as Annexure ?W?. The Petitioner has not see ae recelved a reply fiom Mr. Aliméed, which means Ar: dimed adnstis the allegation contained. Mherein, thet he Was Rot working Independently, but receiving tastructions from Pupir say? Crom above) is correc? Duce the Pesivfoner?s RTO had b Cee chauged back to Karachi ddr. Zitlfigar Aland had no Surisdittion and is legalle not empowered fo have ksued Notices to the Petitioner, Unless af course aad once agaln, behind the Petitioners back, ker oY das _ Seen changed back ta erode: Sasmers MPbcoor Wad ya Ahmed. } : : “ulfigar Alunad, Zia Allnud Butt used the sane terms ae: Ofshore-assed or offshore Croperties th their ledhers dated Sth May 2079 and three letlers dated 10th May, Ns ; 2019 (Annextires 2F? to PL? respectively) when these : terms did not exist in the Incone Tax Ordinance. It was wholly inappropriate for « professional und. employaes of the FBR ta resort to sensationalism and travel * beyond the lam, The usage of the terms Olfshore-asset and offshore properties by sentor officer OS FER shows Printed on Mon, 14 Sep 2020 Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad“Page 50 of 164 Name: SARINA M ISA dress: 22/E, 7th Central Street, Phase-ll, CHA, Karechi South Tax Year : 2018 41-Jul-2017 - 30-Jun-2018 ~ Contact No: 00923452003432 HOA Registration 4230197221542 Perlo Medium : Online Due Date : 14-Sep-2020 Document 14-Sep-2020 that they wanted to curry favour with Mirsa Shahzad kbar. The Petitioner has no-eibectation to be dealt with Justly by suck career opportunists, who have already demonstrated hetr teint, moral bankruptey and disdain the tan. Mi Zulfigar Alunad ls a small cog in 4 wheel whith ie moving with haste to ride roughshod over the Petitiarer and her family. We bectics emploped by ir. farrau Khan?s Goverment, FBR, and EBR?s by. Ahmed anc . Ate. Zudfigar Aimad conclusively establish that a charade is being énacied and there ts no chance of expecting aa erder passed in accordance with the provisions of the Income Tax Ordinance and one which macs the bese teneisey justioe, Lt is only in deference fo this Honourable Court?s fmpugned Order thar the Petitioner has submitted her reply to Mr. Lulfigar Ahmad?s notice and attended ta his Oice, which should in no manner be consiried as acknowledging Ais jurisdiction, either territorial or egal under the Lncome Tax Ordinance, Chole that the earlier notice (which replied through my Evacuee Trust Complex Fcurth Floor, Agha Khar Avenue, F-5/1 Islamabad Printed on Mon, 14 Sep 2020 18:5‘Addre sage 51 of 164 Name: SARINA‘M ISA Contact No: 00923452003432 TROT Document 14.5ep.2020 The tone in the No Period Inline 14-Sep-2020 Jeter of 9th Suby, 2020) and the Rejoinder Owhich f am now replying to) (the "Notice" and "Refoinder” respectively) are nvduen by two diferent persons. Sana Galified teacher wha vaught English Jor decades, Lain rained to Pick up wher shidents cheat, copy another?swork. plagharize or ash somtoojte else to do thelr work. comparison of she Notice Side ihe Rejoinder shows shat dhe wetting style, Syitan, grauimars word choice, Punctuation and sentence construction is by diferent authors, ice.is faanible and. pole i aa “not refer la anyspecifi He. brovision Slaw; Pefe , imconvineingly to @ "mottey trail". The parase "F ‘¢flecting in the bank) ‘statements. CaM, paragraphs oF 5 fal (and fey das two verbs, thet 4 Sit uneasily with each other, Pemonstrating discomfort with the use and yunderstandingsof the spatial aspect Of verbs. In paragraph 5, you use archaic phraseology = "you are requested to make compliance", instead of "to comply". This sentence ends with the word "positively". making Wt a fragile sentence, with an adverb attached to the end to weakly reaffirm the original idea, The penultinate seatence misses out the article ~ "to make it part of [the] permanent electronic record". The Siual sentence, "looking forward for pour coaperation” ts alsa ? , Printed on Mon, 14 Sep 2020 15:58: =o Trust Complex Fourth Floor, Agha han Avenue, F-5/1 Islamabad . Registration4230197221542 22/E, 7th Central Street, Phase-ll, DHA, Karachi South Tax Year : 2018 11-Jul-2017 - 30-Jun-2018Name: SARINA M ISA _ Address: 22/E/7th Central Street, Phase-ll, OHA, Karachi South Registratlon’4230197221542 018 1+Jul-2017 - 30-Jun-2018 - Contact No: 00923452003432 Due Date : pee 2020 2 ep- UMC Document 14-Sep-2020 ai : grammatically incorrect; one doesn't look Sorward, (Jor. one 2 . m looks forward to. The tone in the Rejotnder ix different, It is direct, winteal, asserting itself with speelfle reference to events and handpicked laws, It ts dismissive, entitled doesn? sedk fo explain itself or the contrudictions in the Reyjoinder, The plirase in paragraph 3 “is guite misplaced" é eondescending, comfortable and entitled - probably written with the help ofa . seasoned Jamper explaining Jaw, Hiei iosenpretation the law : ; és superior; correct, and should } be assunted: as holy. Further 4 : . Paragraphs are similar: aecusatiry, pulling the burden on the A : y taxpayer, and disregarding dueprocess and Legal, ‘protocols, it = a 5 jis about framing a’ certain wegative ideaonto the laxpaper a without supporting evidence, Ut is a work of blas, dnd ts oie calculated not tovestablish cransparency, but Yo eabrap the taxpayer tit requests ond responses to statements, Whe Rejoinder is stamped (with a red stamp) “Confidental", the Naticé is not so stamped. The Notice politely concludes, "You are requested to make compliance to Mie notice by 02-07-20, positively." in contrast, the Rejoinder versely concludes, "must reach this office by July 21, 2020" 4 ? ? : {Page 62 of 164 Printed on Man, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor Agha Khan Avenue, F-5/4 IslamabadContact No: 0092345200432 E HA Name: SARINA MISA ~ Address: 22/€, 7th Central Street, Phase-II, DHA, Kerachi South sent for stelomelrte analyyisy, 12a(4) (Order to amend Self or Best Judament or provisional asseésmen!) i Registration 4230197221542 Tax Year : 2018 Medium : Online Due Date : 14.Sep-2020 Document 14-Sep-2020 Another significant diference is the use completely diferent date Jovmids, The Novice concludes respectfully, “Looking Sorward 10 your Co-operation Wii tax admintsiration": thé Reyoinder does Hol, 27am sure you will agree hel an UYficer who hits the authority and jurisdiction (which I don't accept oF cortceds) to do something canok ash or task ahotherte da it for hiwe or surrender his independence. This further confirms what l have . deged in my review petition, Kindly let ne know whe wrote, .. the Notice aut the Refoinder beciuse it is alear hat you could ot ba the author af both. Ifyon do not accept my analysis / would reguest that both documents (Notice and Reoindar) be. L&ote that the following points/questions raised. by me in my letter of 9th Juls 2020 have not been responded to, which have emphasize: 4&0 not understand why you have sent g notice ys relation to “tax year 28 whan one of the properties mentioned by you way bought in 2004 and two in 2043. Pleuse help me undersrand. 4 oe Printed on Mon, 14 Sep 2020 15:58: Poriod : 01-Jul-2017 - 30-Jun-2018 Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad4 lg bear ane pzeay Hg Name: SARINAM ISA Registration 4230197221542 IRS Es qi Revenued Pah Service } © Address: 22//7th Central Street, Phase-lI, DHA, Karachi South Tax Year : 2018 6 ‘ Period : 01-Jul-2017 - 30-Jun-2018 ‘ontact No: 00923452003432 Medlum : Online ATA peur eee: B4AnG what does "Reanest Regarding" mean? This Me : ts a fragment ofa sentence, and i meaningless. Yai have asked for the "Money trath” Sor the Properties. | don't kyow what you mean by “money Wall" Please explatiand identify lhe provision th he Licome Tne Ordinaice, 2001 where “name tril” lg mentioned sol can understand you and be able la pepe answer yoru question properly. © Ah addition, L had, and stilf own agricultural larrds, : s : : in the avea of Deh Koran, Tape Zangipur, Tul, Distriet ay Yacobabad, Sindh and in Tehsil Deva Murad Jamali, : : 3 Disirtet Naseerabad, Balochistam. Mr. Naqvi advised x de 5 me that income tax ig not payable on agricultural e incone, details of which are mentioned in my retiltns, 2 * ‘ , Hiben | stopped working at the Kavachl Amerlean s School and sold the rented properties which [ awned in Pakistan d stopped filing income tax reluens ia Pakistan ee because L was advised that I did not Rave any “Gaxable” income in Pakistun. The recorads of FBR with Mi aoe 7 confirm that! have puld income tat on all mp taxable facomte. f was then informed that the law was recently Page 54 of 164 ‘ f Printedon -—- Mon, 14 Sep 2020 15:58; * 7 Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad? Revenue} ees , &Y Service Name: SARINAM ISA : Reglstratlon 4230197221542 Address: 22/E7th Central ‘Street, Phase-lI, DHA, Karach| South Tax Year ; 2018 Period : 01-Jul-2017 - 30-Jun-2018 _ Contact No: 00923452003432 Medium : Online NAL TUE sce eee eee Document 14-Sep-2020 changed in Pakistan, [ Chink in the Sear 2018, surely HOW must know this, Lhe new lew Teguired thet foreken Lropsries and monies nor eaned in Pakistan alsa yow have to be declared. WBhoul watting Jor the MBER LS anyself f00k the initiative to comply with the new law. / Contiated a focal income tax practitioner to help me Uepare and Jie my Feruras, te told me that msRTO hud been < changed from Karachi to ‘slamabad and asked me if) “had requésted FBR 10 to's, 1 said hail nor done so... ; in : He told me that FBR cannot do this tse ‘ated LILO ean eet 3 only be changeet upop mys request. Whip Zid FBR Break” : 5 OS thietanie L wrote to af Muhammad Ashfag Ainied on ingee r Bist Sanucary 2020 buf he did not reply, probably ’ j because he had no answer ta what wrote, Isthishow ee FER is run? L8ase tell me Y my RTO has once again been changed to Islamabad, behind m, ny back and without me requesting this. Uf not, how have You issned me the notice? LiBaliave the Chaisperson oS FRR ds. Nausheen , f , Printed on Mon, 14 Sep 2020 15:58; Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad _ Page 55 of 164.© les jaland eS Sonics sie at shen ag Name: SARINA MISA Registration 4230197221542 Address: 22/8/7th Central Street, Phase-ll, DHA, Karachi South Tax Year : 2018 i Period : 01-Jul-2017 - 30-Jun-2018 Contact No: 00923482003422 oe ae Pe ! a HAA aoe: ‘rea ape Javaid dniyjad, after serving Jor less than three months, hasbeen removed. It seems she Wes Hat prepared to do the bidding of the coterte, Bas the entire FBR beers pret 40 Serve the object of removing « Supreme Court Sudge? FBR kas gota new Chetrmsan for only three . wnonths aud for a specifia task and Dr. Muhanad Ashfag Alimed no dowbt continues ta take tasinictions Trem taper soy? Rekher than appreciating people voluntarily coming Sorvard tb declare their ingame and, Paving taxes fhe. coterie attacks then, Or is: it becuu: set at a woian and the misogynist coterie does not respect women's al 7 5 daddepehdent finanaids, Stawis? Please tel, Ae ow many ee ; Aon-salacted women ta Pakistan pay taves? ; me) SKbuld the FBR nosask My, tmran Khan whphe tte Pays tess ta than L do and yet somehow managed to i ‘ : buy very expensive propertios and lives in @ 300 kanals massive mansion? Should FBR not ask Mr. Loran Khan, Mirra Shahead Akbar, Mr. Anwar Mansoor khan wad Mr. Laragh Naseem how they Mlegally obtalned nyt past lucome tax recardsy and disclosed «Page 56 of 164 » Printed on Mon, 14 Sep 2020 15:58: ie Eyvacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad“Page 57 of 164 Inline the? 1ilid rat waat to drag anyone inte this but [ve had Name: SARINAM ISA Reglstratlom4230197221542 Address:'22/E, 7th Central Street, Phasé-ll, DHA, Karachi South ° Tax Year: 2018 +04-Jul-2017 - 30-Jun-2018 Contact No: 0923452003432 Due Date : OMIM UA 14-Sep-2020 Document 14-Sep-2020 enough of being spled an, abused and harassed for the last year and made to feel like a common criminal, Please do not blame me if alt that 1 ask FER to dois Ta drovide me copies of the tacowte toa: records of> (L) My Imran Khan, (Z) Abdel Waheod Dozier, Bidirze Shixhsad Akbur, (4) Mr. Farogh Naseem, (5) Mv. Anwar Mansoor Khaz and oO Dn Muhammad ashy fag. Abimed whether they. show. the. properties oF. their wives and childven in their troome tax. Papers; y lease provide copies of thelr returns from when they Sarted paying Incomegax tif HOW, as they. fad f obtained aad disclosed my recavds, They should hay Ye 10 objection if FBRapeats them similarly. Evert. day we are told that we are striving for the Madinah ke Kiyasat, therefore, / un sure these gentlemen will be only too huppy lo inform an ordinary taxpaying woman about how much tax they pay and the status of their wives’ and children's properties. not hen I may have ‘lo ash them: questions. Printed on Mon, 14 Sep 2020 15:5 Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName: SARINAM ISA at Reglstration'4230197221542 dress: 22/8) 7th Central Street, Phaserll DHA, Karachi South Tax Year : 2018 : Perlod : 01-Jul-2017 - 30-Jun-2018 Contact No: 0923452003432 Medium : Online UR a 5S l38.sure as a dedicated ‘Professtonalyou wif amply thelaw with am ever Rand and nor allow yourself to be used or bullied. I have provided. JOU the information sou asked me Jor. Can por now Pleuse tell me why exaotly you wanted (his information? Your natlee caneludes by sq. ung: that L "nay Jile anyother detatlidocuments and evidence in Support of pour ¥ : y defense! bit Since you have nok told ne whit £ am 4 defending L cannot take the benefit of your offer, Please ; ' \.. detme know what I tn. defending? — a ¥ - Téparegraph 8 afyour Rejoinder you have referred ta - "as per. your on tax declarations available with phe res d . Aepartment’, but surprisingly, Jou de not provide me copies of Bete wy declaration. Dhave alreay srferued pou that the gentleman s wha used to deal with my tax matiers, Adv. Rehan Basan Nagve ae : Aas passed away. Since August/September 2009 £ have beer diving with my husband in Quetta, as he was oppotnted as the Chief Justice of the Balochistan tigh Court on Sth August. | 2009, Then in September 2014 L came to Aslantabad when my husband was appointed as a dudge of the Supreme Court, Therefare, / don'tunderstand which returns Pou are referring fo since 1 could not have filed the referred to returns. Kindly Be , , Rage 58 of 164 Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad_~ Name: SARINAM ISA Address: 22/E, 7th Central Street, Phase-ll, DHA, Karachi South Tax Year :2018 a; 1-Jul-2017 - 30-Jun-2018 _ Contact No: 00923452003432 inline Due Date : 44-Sep-2020 AIDA _ Document 14-Sep-2020 Provide me copies of all my tax rewurns, Hiker] came to deliver my letter ta powof Uh Luly 2020 Lhad also returned, "the open original envelopes with notices to my daughter and son" arti had said, "mp san lives in Lortdon: = you want to write (owen please write to them dtreeLy" I da not understand whether it is a lack of undetstantline on. pour Part or you ate ddantant to insult me and. ay family, because vou have once again pasted an open envelope and its “Confidential” cantents an fill display. on the gate of my husband's official residence, Lattach its philogriph This tinel am yiot removing the envelope and notice and returniug ft to. you, | leave tt pasted as you lefts; a symbol of ‘the derision that, an honest and independent Jidge and bis family és held bythe FBR and the Government, i - Uhlir tactios ave reminiscent af Mr. “Tunran Khan's government which did the sane with regard to a confidential reference filed against my husband. Fou have made a mockery ofthe word "Confidential". Confidentiality is for the protection of taxpayers, not for zealous, law breaking FBR officers. Therefore, J have no option but to release this Teter so the people judge for themselves because £have no confidence left ; ag Reglstration4230197221542 Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad» Name: SARINAM ISA : Registration 4230197221542 Address: 22/E, 7th Central Street, Phase-I!, OHA, Karachi South: Tax Year :2018 Period : 04-Jul-2017 - 30-Jun-2018 Medium : Online Contact No: 00923452003432 Due Date : 14-Sep-2020 14-Sep- A ~ Document 14-Sep-2020 In you to act independently from Mr, Juran Khan's govembent's agenda. Lbek forward to recelviie pour respouse to the woresald, And, Lf trust that.in deference te the Supreme, Caitrt Pott will now walt for the reasons to be given by the Supreme Court, and forthe outcome of the review petition? > ? if, Howeveriathe key questions put across vide notices dated 26-2020, 03-07-2020 and 44-07-2020 remained un-answered being | without proper documentary evidence to the effect of availability of funds/taxed sourtes and its Passage to the accounts of the solicitors/sellers.and the percentage of her investment in the (03) offshgré properties. In such ‘a citcumstances section 411(1) of the Income Tax Ordinance, 2001 comes Into Play which proVides that: - LLL, Cnexplelied income or assets 7 ©) Where P (@) any amaunt bs credited in a. (Person ?s books of account: @ «person kas made any investment or ts the ouner of any mionep or valuable articles [f (¢) a person has incurred any expenditure [orf 4) any person has concecled income ar furuished inaccurate particuliers of wneome tncludlig 2 ? . , 25: Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complax Fourth Floor, Agha Khan Avenue, F-6/1 Islamabad: Reven “A inland Lita irg alti hi) I Revenue eo Servi Neva SARINA M ISA Reglstration 42301 97221542 Addre’s: 22/6/7th Central Street, Phase-ll, DHA, Karachi South Tax Year : 2018 Perlod : 01-Jul-2017 - 30-Jun-2018 ‘ontact No: 00923452003432 ar aae aes HM + pees (0 the suppression of any production, sales or any amount chargeable, to tax; or : CY the suppresston fury tiem of reach Mable to tax in whole. oh jh part] ond the person offers no explanation about the nature and source Of the amount credited or the Tavestinent wtoney, * valuable article, OF fits fiom whith the expenditure was made : z LSUppression eK ny production, sales, any qmount chargeable : i 40 tax and Of any item of receipt liable fo fax] or the ” explanation Pered by Me person 45, A06, tn the Conmi{ssioner?s _ opinion, satisfactory, the ‘amount credited, value o the tavestinent, money, value of the article, or AMOUNT Of a expenditure Buppressed. amount oS production, sales or any se o::

investment made into the purchase of offshore Properties with proper documentary evidence therefore, provisions of section 111(1)(b) read with section £11(2)(il) of the Income Tax Ordinance, 2001 are attracted © In the ‘taxpayer?s case. This inference is also supported by a recent Printed on Mon, 14 Sep 2020 15:58: * Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/4 Islamabad.1 @ ne RSE even OP Servics | ~ Name: \SARINA MISA a Registration 4230197221542 ~ Address: 22/6, 7th Central Street, Phase-II, OHA, Karachi South Tax Year : 2018 ; Period ?01-Jul-2017 - 30-Jun-2018 Contact No: 00923452003432 ueDaeee, ANOULLALA Cees eo : judgement of the Honorable Supreme Court of Pakistan delivered-on oes 10,04,2018\in Civil Petition No. 945 of 2018 titled as Farukh Shahzad vs Commissioner Intand Revenue (legal) RFO Rawatpind! and others reported as 2018 PTD 2009, Relevant portion of this judgement is reproduced as under: PIF also notice that the addition SL ks.60 Million was made in Whe Laxible incor? of the petitioner under section L/W) af the Ordinalee on account of the peiitionerts failure to furnish , Material in support of his defense during reconciliation proceedings, The sii ‘provisions sipilate thee where @person Salis to offer a satisfictory eyplanation about the nature ad Source of investment, the value of the tivestment shall bé tncluded in the persons income chargeable to tect to the extent itls not adequately explained? ‘ 13. Due to faflure of the taxpayer to render an explanation, as a stated In para 11 above, a show cause natice under section £22(9) along- with statutory notice under section 122 coupled with separate show cause notice under section 111(1)(b) of Income Tax Ordinance, 2001 were, therefore, issued on 30-07-2020 requiring compliance by 10-08- 2020, Notices Issued under section 122(9) and 111(1)(b) of the Income Tax Ordinance, 2601 are reproduced here as under: - f Page 62 of 164 . Printed on Mon, 14 Sep 2020 15:58: - Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad,4 Rs: Revenue 3 Service pL nike W,..L., Name: SARINAM ISA Registration/4230197221542 dress: 22/6) 7th Central Street, Phase-li, DHA, Karachi South Tax Year :2018 Period : 01-Jul-2017 - 30. ‘Jun-2018 eS tact No: 00923452003432 ie ee ree as ep-2020 UGTA Document 14-Sep-2020 . ‘ : ; ee CA. 0: LEER DA: 38072020 a 219 response to the noticevuls 176. of the Income Tar Ordinance, 2001 thereinajier Pthe Ordinance 2) dated. 25.06.2020, reminder dated 02 87.2020, and the rejothder in sonuection therewith dated 14.07.2020. Jour detailed replies dated 09.0712020, and 2,07.2020 have been examined. Lou would appreciate that the OU-QOlME tax Proceedings in your case have been taken up.tn compliance lo oni ‘able Styar hie Pare : Court of Pakisten?s ‘Order dated 19.06.2020 in CP Na, yr 19- a q mh. 3062 3¢ 2012 and Chia #72019. 2. Four replies almost in fits initaad SY addressing the \ moot point tx the. Proceedings deal with far-fetched (even ur es understandable) ad-hotuinem attacks that too, indiPectly. Yoir 3 are once again solemnly assured that all’ the personsfauthorities mentioned in Jour correspondence have absolutely nothing to de with the eurrent tax Proceedings, and . that the same are not only being conducted, but. would, also be finalized ti in accordance with the law and the directions of the Hon?able Supreme Court of Pakistan. d ? , Page 63 of 164 Printed on.” Mon, 14 Sep 2020 15:58: 4 : . Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabadiplahs Revenue; saa RS Name: SARINA MISA ' Reglstratlon 4230197221542 Address: 22/E, 7th Central Street, Phase-II, DHA, Karachi South Tax Year ; 2018 Period : 01-Jul-2017 - 30-Jun-2018 «Contact No: 00923452003432 Tae mae ; ee 2020 £44-Sep- HORI Document 14-Sep-2020 3. Pwo key questions pul actass vide the aforementioned nolices precisely were: - ti) Whee i> the uetmal percemage of Your investment in respect Of ike three offshore POPEMES. purchased by you tn joint Ccgistered) ownershiz with yom bo children in 2004 and 2013 so that the sources oS investment related questions coiid be aligned between J0n and your children? Ci) What were the sources of titbesimen! utilized to burchase the three undectaredieoucealed: Oshore properties : and their, rpassage.to the account es the ie eee ele ©. | ; enersey enidence? ? f , * a £ ‘ % : . i i W lastead of filing the reqwisite Aahariaiae/ solurees of a & A ¢ ? ; aa divestoient anid reconciliation, vou have dismissty ely agitdted 5 5 a . . against these tax proceedings on the strength of grounds taken / fe in the review petition(s) filed before the Hon?ablé Suprenie Court, AM adverse allegations made agaist the undersigned, the FBR and tts officers tn any of'your letters or the Review Petitions before the Supreme Court aredenied. The said allegations can have no bearing whatsoever ar the tax Proceedings in hand tnittated in compliance to Honorable : sy Supreme Court?s awn explicit directions. Likewise, your request tohold the present proceedings in abeyance until the as ; P | _ "Page 64 of 164 Printed on’ Mon, 14 Sep 2020 16:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad* Page 65 of 164 ntact No: 00923452003432 TAIT Reglstration 4230197221542 ddress: 22/E, 7th Central Street, Phase-Il, DHA, Karachi South Tax Year : 2018 Period : 01-Jul-2017 - 30-Jun-2018 Medium ; Online Due Date : 14-Sep-2020 Document 14-Sep-2020 disposal of the review petitions is beyond the mandate of the undersigned who ts earnestly trying to abide by the time-frame given by the Honorable Supreme Cort of Pakisran, +. Snow, therefore, proceed to issue a show-cause notlee ty L229) Of the Ordinance with @ view to comply svith the or y 4 the pr Bes Court of Pakistan. g. y, tom OE « 6 ff is now an admitted fact that you owned 03 Lshore ¥ Properties located in Lenton 1 Jolnlly! with, porir children ? Ms. | Sehar tsa, and.Mr. Arsalan Isa. Jn spite of the fact that rhe Property at SO Coniston Court. Kendal Sweet, London; was: Purchased in 2004, and twosPr ‘operiies at 90.Adelaide Roud, - London, and at 40 Oakdale Road, London were purchased in 2013, those were conetaled und not disclosed tn Dour wealth stanement G8 on 30.06.2013. These properties continued to slay canc0ented unt you disclosed them in your wealth statement as on 30.06.2018 filed on 31.01.2020. This was only after the Department had come into the possession of defilte ‘nformation vis-?-vis you owning these Properties, it view of the Presidential Reference ugitnst your husband Honorable Justice Quit Faes ls. In the Rejoinder dated £4, 07.2020, pou ; , Printed on Mon, 14 Sep 2020 15:58; Evacuee Trust ‘Complex Fourth Floor, Agha Khan Avenus, F-5/1 Islamabad ; & & I. Reglstration4280197221542 Tax Year : 2018 t Period : 01-Jul-2017 - 30-Jun-2018 ‘ontact'No: 00923452003432 onic AOA cout eet Address 22/6, 7th Central Street, Phase-lI, DHA, Karachi South were requested 10 categorically state asto whether the entire investment ina the purchase of these properties was made hy Jou ar by your children te the extent of thelr registered shares, Since you have not addressed that critical question, therefore, an the basks of ownership docunrents in avatlable on record Wout total tavestment in-youe name works owe as wanders. > Shar otal SH) Property Particulars i ie en a 1 | 50 Coniston Cours, &| 2004 |* 100% | Rs. 24,041.32. | Street, Loudon tii) | 20Adelalde Road, London | 20137 S02 | Rs 21,138, 300/- Bee Cit 40 Oakdale Road, Landon | 20/3 “SOI \ Re, 19. 18 BOSOX . Lyi ee O(N. Totals | Rs. OF, 360, 6704. 7, This map not be out of place to mention that the. Property at 50 Coniston Court, K. Street, London, was re-leased in 2011, Fou are requested to indicate the actual payment/value of the release contract so that the seme could be included in the tolal quantum of investnent. In the absence of the re-lease value of 50. Coniston Court, K. Street, London, the total investment sPage 66 of 164 Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-6/1 Islamabadinland Revenue; Sei i “ Name: SARINAMISA 2 Registratlon'4230197221542 » Address: 22/E, 7th Central Street, Phase-II, DHA, Karachi South Tax Year ; 2018 : Period : 01-Jul-2017 - 30-Jun-2018 : dium : Online Contact No: 00923452003432 ti ‘ Due Date : 14-Sep-2020 AACA Document 14-Sep-2020 declared by. vou 4 your weatth statement as on 30.06.2018 is at &3. 64,360, 670/-, which begs a legal and valid explanation Stomyour end, witch till date has uot been given. L&} Total Sources in Tee Record &. Nobwithstanding, ap orhertnvestbenks that pou have nade. & ul 20/2, & snapshot of our total axedfegitimate sources tf avatlable with you till 30.06.2012 ineluiting the tai paid, as per Your own tax: declaratious ts as under: S| wx) Totatincame| TotaTax | Other | “Remarks | ; i _ * |S Declared “| Paid’ “| zecempte' : b is ss : = z ad Somrces. ‘ 2007) Ri. 999,266. | Rs. 26477 | , Mil | Tecome includes) Rs. . -| £3,.920/ worked back on NN Gh od the basis of tas payment of | : f id | Ret $924: : (4) |/2008| Rs. 2144183 | Rs. 04,9057 | RR | Income iacludes Rs. 1,082, 4707- worked back on the basis of tax payment Of R8.65,712/- (it | 2009) Re. 1,397,550 | Rs. 97,255/- Nil | Income worked back on pes | te basis tax payments of| RS, 97,257 (iy) | 2010 Rs, 1,760,05t/-| Rs. 135, 505/- Nit facome Includes Rs, Hie 1,517,310 worked back on the basis of tax payment Of Rs.S09, 231/- j w Printed on, Mon, 14 Sep 2020 15:58: Page 67 of 164 7 Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadName: SARINA'M ISA Registration4230197221542 Address: 22/E, 7th Central Street, Phase-lI, DHA, Karachi South Tax Year : 2018 Perlod : 01-Jul-2017 - 30-Jun-2018 ontact No: 00923452003432 Didone : ore 2020 3 14-Sep-: HH Document 14-Sep-2020 CY | 2011 | Rs. 2,903,8307-| Rs, MA EB 3 Ait facome includes Rg: 4,691,040/- worked back on the basis of tax Layment of Rs.126,604/- (i) | 2012 \ Rs. L177,05i/-| Ry. 7E,605te |. Nil NI Total © I 9.925, 9517. | rs. 551,087-| Nit | =a) 9 Dus, on the eve of P/E 2013 upte whith 03 offshore Properties were purchased and other investments Made, vou had total tated/lexitinate sources only fo te lune of Rs. . 2) SITE IRL/, even if it is assumed that you saeurred absohutely : N $ * no pérsonal expenses. However, the Sforesaid' ‘amount already : stands utilized towards the assets declared wy “PtO 30,06.2073. pee i Against such @ backdrop 3 Jou made an tn vestinent Of Rs, ie ul Gt, I60, 670/- into the purchase of the satd three offshore’ ae ae Properiies, Thus, the tavestment of Rs, 64,360, 670/- is overland el i above pour total taxediuilized sources of. RS. OI75,23B Till i date nothing has been brought on record by you or your si children i.e. M/s Sehar lva and Arslan-tva to establish that your : children possessed sources to Justify the availability of Rs. 64,360,670/- or any part thereof, O) Lotal Money Rawskited Qt ; ea 10. You vide your reply dated 09.07.2020 has provided a” Printed on Mon, 14 Sep 2020 15:58: Page 68 of 164 Evacues Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 IslamabadiS frlanel EVENU ss Name: SARINA'M ISA Reglstration 4230197221542 Address: 22/E, 7th Central Streel, Phase-Il, DHA, Karachi South Tax Year : 2018 Be ; Period : 01-Jul-2017 - 30-Jun-2018 jontact No: 0092345200432 eee "ARAL ; fecanerneree cortificate dated 06.12.2019, issued oy Standard Chartered Bauk, World Trade Centre Branch; Clifton, Kavacht Purporiedly by way of an explanation of the saurces’ Sf tavestment made tnto the purchase Of the 03 offshive Properties, Through the notice uls L76 Supra you were repeatedly requested to provide Supporting evidence ¢&, bank Statement showing the transfer Of money lnvested tn the Purchase of these properties 0 the account A solicirorsésellers, buk you have nor Provided any documentary iP evidence, Therefore, a notice ws 176 Of the Ordinance was issued Yo the — or ~ Wey *3 bark Ti response, the doctamentars evidence submitted by the ' Re Fcnwhas. revealed the Pilea S200 of affairs: y. age Debt yw hi J, - & SH Date Amsonnis/| Ml o Ap tirmiafcs : Chrrency 4 ae : 09-06-2003 | ?40,000 W\ cransferrat to hrs. ZMK Carrera (Barclay Bank Plo) 25-11-2003 | 73,000 \ Tr ransferrad to Alhted Irish Bank | : (Beneficiaries ?Burker Gitlerte) | tt | O8-12-2003_| 71,000 Transferred to Alen Edward and Co. 4] 19-02-2004 | 766,000 | Transferred 10 Ashbow Limited! Sivift : Message S J 3 ? v. " , Page 69 of 164 Printed on Mon,.14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, aul Khan Avenua, F-5/1 Islamabad~ Name: SARINAM ISA Contact No: 00923452003432 TOL Address: 29/e, 7th Central Street, Phase DHA, Karachi South Roglstration4230197221542 Tax Year : 2018 Period : 04-, Jul. 2017 - 30-Jun-2018 Medium Due Date : 14-Sep-2020 Document 14-Sep-2020 S_|_Ot-03-2004 | P3RAIS Transferred to Alen Edvard and Co. & | 26-05-2004 | 37,200 | Transferred to Ashbow Limtted/ Swiff -|~ Message, 2 | O¢- 08.2004 | 2£ £00 euitiied te Clutton! Swift Message - BIS 03162008 | PLLIO | Rustivtect to Cluttont Swift Message 99 | 28122004 | 71,180 emitted to Barclays Bank Plo, beneficiary 172,800 Beneficlary Ms. 8 Isa Ale # SOSA 5II3 SLISO buttons Ref Carrer himden s/o tt 40SU3489 Remilted ta Barclays Bank Ple London, rentitied to Bank of Bast. Asia Limtited Honk Kong, dencfishary Dive the: World Limited Ate # OLS -246» 50-MOIS-. SF fe.60.2006 PLO Remified to HSBC King's crass Branch Lottdon, Beneficiary Laura Sekultt &/C # FiCS9ASO F5.09.2006 710,450: emitted to Nat West Bank Ple London, beneficiary School of Oriental and African Studies (ds. Seher ksa Student LD 177502) it LS: 29.09.2007 Remitted to Barclays Bank Ple London, ensficiary My. S& Tea dle # SOSAS3IIZ L242.2007° Remitted to Barclays Bank Ple Loudon, Beneficiary Hs. 8. [su Ale # SOSASR3S (Education foe far danghter} + 2.” Page 70 of 164 Printed cn Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad Mon, 14 Sep 2020 15:58: -ef "Name: SARINA‘M ISA Address: Contact No: 00923452003432 DMO In 22/E, 7th Central Street, Phase-II, DHA, Karachi South Registratlon'4230197221542 Tax Year : 2018 Period : 01-Jul-2017 - 30-Jun-2018 Medium : Online Due Dato : 14-Sep-2020 Document 14-Sep-2020 a 16 44.01.2008 730.000 Remitted ta Barclays Bank London, bencficiary Mos, ZALK Carrera Ale # SO873489 (children education) = L4EOL2008 725,000 Kesittled to Hurclays Bank Ple London, Beneficiary Ms. Si tsi Ade # 50505333 Remijtted to the accounl of Mrs, ZMK) Carrera No, SOSTAEYchititren tuition ond siving expenses) cay Doughreris education and Lit wing expenses) 22.06, 2009 PLES,000 | Benefittiory ZMK Carrera Ades 4 50873489 For son and daughter graduate and post Seaduake university education) Remitted to Barclays Bank Landon,|. 23.06.2010. Rentitted to the wecount of Mrs, ZMK Ghrrera No. 50873489 sort Code (20-47-42, Barclays Bank, Knightbridlge faternational banking Centre Londen UB-(Sans university education and living daughter post graduate education and living expenses) re 12.02.2013 235,000 hemitted to Nat West Bank Ple London, beneficiary Ms, Seher Isa Khoso A/a # 79074367 (Eduoation ana staying expensas of daughter) - Page 71 of 164 Printed on Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad Mon, 14 Sep 2020 15:58;Name: SARINAM ISA Address: ‘ontact No: 0923452003432 OQ im 22/Ey7th Central Street, Phase-l!, OHA, Karachi South Registratlon 4230197221542 Tax Year 22018 Document 14-Sep-2020 2 R OB.O5.2013 STE PBSO Remitted ro Nat Test Bank Ple London, beneficiary #8) Scher Isa Khoso Ale # F907436R (Education and day ro day exnerses of daughter) 23) C805, 20/3 = Remitted to Nat West Bank Ple Loudon, beucfictary MMs. Seber Isa khoso Ale tt ZIY0T4SG2 (day to day expenses of daughter) Be ALOCLOIF #5600 Remitted to Nat West Bank Ple Londen, beneficiary is, Saher tsa Khoso Ale # 79074367 (Education anid dap to day eipenses of daughter). +4. Thus, on the basis of the date tabulated above foreign ¢ — “ exthange to the tate of ?. 737,503, and § 12,906 was.remitted - out bY you during IVY 2003 to 2013. However, as per the See i documentary evidence available on record, almost all swe transnotions durried aut by you under your own Signatures seer carted @ ?Purpase of Remittance,? other than purchase Sthe uader-investigation offihore properties such as children?y a i i education and their maintenance ete. Thus, it is clear thet neither you had resources nor their watt Uinking them with the purchuse of the properties, Printed on _ Page 72 of 164 Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad Mon, 14 Sep 2020 15:58:Weg iniand Sa, Revenu 2 Service ~ Name: SARINAMISA 4 "Registration 4230197221542 "Address: 22/8) 71h Central Street, Phase-ll, DHA, Karachi South Tax Year: 2018 Period : 01-Jul-2017 - 30-Jun-2018 zontact No; 00923452003432 . Dis vae : ae 2020 i *14-Sep-; * DAI + Document 14-Sep-2020 12. from 2003 till 20/3, as stated Yoresaid, the foreign exchange remitted bu vou ts 2737503 ants, 17,966. On the top of tits che tuvestnent in the three off-shore properties ts Rs, £4,360, 670/-, Nothing hasbeen brought on record to substantlate the sources through which any of the anoxunis \ mentioned in this para were carned by ot, your worthy husband, or your children, Please note Utat the anions remitted of tutte/Of ?737,503 ani SY. I66 constitute unexplained expenditure incurred abroad which warrants >. action under the Ordinance, separately) “13. The investment of RS. 64,360,670 in she three offshore . 4 properties were discovered in the period. relevant to tax. ear GN OY LirgGerdin, the addition oerdieeion MVM (i neve (has ta.be made th the immediately preceding texe year te, BOI8. : - hence, please. show caused as to why the deemed assessment for : Tax Year 2018 may not be amended why 122(1) read with AS : 2 eet + Section 122(5Y of the Ordinance, by treating an auourl of £8. 64,360, 670/- us income from unexpluined sources and added to your declared income under section LIT CL{ LILIA A) Gi) of the Ordinanée. 15. Your reply along with relevent documentary evidence, may reach this office by dugust /0, 2020. Statutory notices ule [22 ? 2 a Printed on Mon, 14 Sep 2020 15:58: Evacuee Trust Complex Fourth Floor, Agha Khan Avenue, F-5/1 Islamabad i