High Court Division · Special Original Jurisdiction
Grameen Kalyan v National Board of Revenue and others
Writ Petition 17727/2017 · Decided 10 September 2026
Grameen Kalyan challenged an order dated 27.11.2017 of the Commissioner of Taxes, Taxes Zone-14, Dhaka. After the Additional Commissioner had cancelled its assessments for the assessment years 2012-2013 to 2016-2017 under section 120 of the Income Tax Ordinance, 1984, the petitioner filed revisions under section 121A, which the Commissioner rejected by order dated 14.11.2017. That order mistakenly recorded the tax payable on the returns as paid. After notice to the petitioner, the Commissioner corrected the order under section 173, recording that the tax was unpaid and rejecting the revisions for non-compliance with section 121A(4)(b). The High Court Division found the impugned order merely corrected one word, that section 173 empowered the Commissioner to correct the error on his own motion, and that the petitioner had not paid the tax due under section 74, being unable to treat tax deducted at source from Grameen Telecom as its own payment. The Rule was discharged, the stay vacated, and the respondents were directed to issue a demand notice for the unpaid tax.
- Q1
Whether the Commissioner of Taxes could, under section 173 of the Income Tax Ordinance, 1984, correct his earlier revision order which had wrongly recorded the undisputed tax as paid.
- Q2
Whether the petitioner had paid the tax payable on its returns, as required by section 121A(4)(b) as a pre-condition to a revision, when it relied on tax deducted at source in the name of Grameen Telecom.
- Payment of the tax payable on the returns is a pre-condition to entertaining a revision under section 121A(4)(b) of the Income Tax Ordinance, 1984, and the petitioner had not paid it.
- An assessee filing returns under section 75(2)(d)(iii) is bound to pay tax under section 74 and cannot treat tax paid at source by Grameen Telecom as its own payment.
- Section 173 of the Ordinance empowers the Commissioner to correct an error in his order on his own motion, and a correction made within thirteen days after prior notice to the assessee was lawful.
- The impugned order merely corrected the word recording the tax as paid to unpaid in the earlier revision order and disclosed no illegality warranting interference.
- As the impugned order was a continuation of the action challenged in Writ Petition No. 14364 of 2017, a fresh writ petition could have been avoided by seeking a supplementary rule in that petition.
it was legally bound to pay tax as per section 74 of the Ordinance having no scope to walk away treating payment of tax by Grameen Telecom at source as its own payment.
In the court’s own words.
Writ Petition 17727/2017, as published by the Supreme Court of Bangladesh. 15 pages, with paragraph numbers for citing.
1IN THE SUPREME COURT OF BANGLADESH
2HIGH COURT DIVISION
3(Special Original Jurisdiction)
4WRIT PETITION NO. 17727 OF 2017
5In the matter of:
6An Application under Article 102 of the
7Constitution of the People’s Republic of
8Bangladesh.
And
9In the matter of:
10Grameen Kalyan, Grameen Bank Bhaban (8th
11Floor), Section-2, Mirpur, Dhaka represented by
12its Managing Director.
… Petitioner
-Versus-
13The National Board of Revenue, Rajashya Bhaban,
14Segunbagicha, Dhaka represented by its Chairman
15and others.
… Respondents
16Mr. Fida M. Kamal, Senior Advocate with
17Mr. Abdullah-Al-Mamun, Senior Advocate,
18Mr. Sarder Jinnat Ali,
19Mr. Md. Umber Ali,
20Mr. Md. Delower Hossin,
21Mr. Khaja Tanvir Ahmed and
22Mr. Syed Muntazim Ali, Advocates
…For the petitioner
23Mr. A. M. Jamiul Hoque (Faisal), D.A.G with
24Mr. Md. Abdus Samad Azad, D.A.G,
25Mr. Mohammad Delawar Hosain, A.A.G,
26Mr. Ariful Alam, A.A.G,
27Ms. Sabikun Nahar, A.A.G,
28Mr. Md. Arifur Rahman, A.A.G and
29Mr. Mohammad Abdul Mannan, A.A.G
…For the respondent no. 2
30Heard on 13.08.2026, 20.08.2026,
3107.09.2026 and 10.09.2026.
32Judgment on 10.09.2026.
33Present: Mr. Justice Md. Mozibur Rahman Miah
And
34Mr. Justice Rezaul Karim Md. Mozibur Rahman Miah, J.
35This matter has been referred by the Hon’ble Chief Justice of Bangladesh vide his order dated 13.05.2026.
36On an application by the petitioner, namely, “Grameen Kalyan” under Article 102 of the Constitution of the People’s Republic of Bangladesh, a Rule Nisi was issued in the following terms on 14.01.2018:
“Let a Rule Nisi be issued calling upon the
respondents to show cause as to why the impugned
order contained in Nathi No. 6(20)/p¡x-287(®L¡w)/
LxAx-14/¢ l¢iE/173/2017-2018 dated 27.11.2017
issued by the respondent no. 2, as evidenced by
Annexure-‘A’ to the writ petition reviewing his
own order contained in Nathi No. 6(20)/p¡x-
287(®L¡w)/ LxAx-14/ ¢l¢iE/2017-2018/38 dated
14.11.2017, as evidenced by Annexure-‘B’ to the
writ petition should not be declared to have been
issued without lawful authority and is of no legal
effect and/or pass such other or further order or
orders as to this court may seem fit and proper.
At the time of issuance of the rule, this court
also passed an interim order staying operation of
the Nathi No. 6(20)/ p¡x-287(®L¡w)/ LxAx-
14/¢l¢iE/173/2017-2018 dated 27.11.2017 issued by
respondent no. 2, as evidenced by Annexure- ‘A’ to
the writ petition for a period of 6 (six) months
which was subsequently extended from time to
time.”
37The salient facts leading to issuance of the rule are:
38The petitioner is an assessee in Circle-287 (Companies), Taxes Zone- 14, Dhaka bearing e-TIN-642965369474. As per object clause 1 of its Memorandum of Association, it provides financial support in the form of loans and grants to the bank's staff and the members of the Grameen Bank and their families. The petitioner, with a view to fulfil its objectives as set down in its Memorandum of Association, received an endowment fund of Tk. 320,18,54,404/- out of donations/grants and loans received from different donors/organization being channelized through Grameen Bank. The petitioner once decided to invest out of its endowment fund through an affiliated organization, as set down in clause 8, and, selected Grameen Telecom on condition that, Grameen Telecom shall share the income to meet the expenses, and, it entered into following agreements with Grameen Telecom:-
39(i) Memorandum of Understanding dated 11.4.1999 regarding loan;
40(ii) Agreement dated 15.1.2003 regarding investment in the equity of
41Grameenphone Ltd;
42(iii) Deed of Assignment of Shares dated 18.3.2003;
43(iv) Deed of Assignment of Shares dated 21.3.2004;
44(v) Deed of Further Assignment of Shares dated 15.5.2004;
45(vi) Agreement dated 23.9.2004 regarding 3% shares of
46Grameenphone Ltd. off-loaded by Marubeni Corporation; and
47(vii) Deed of Assignment of Shares dated 15.5.2005.
48Afterwards, the petitioner entered into a fresh Equity Participation Agreement dated 13.04.2011, a registered instrument, with Grameen Telecom in pursuant to section 2(2)(bb) of the Income Tax Ordinance, 1984 (shortly, “the Ordinance”) with a stipulation that the income from such joint investment would be made at 57.5% by Grameen Telecom, and, 42.5% by Grameen Kalyan in the purchase of shares in Grameen Phone Limited, and, eventually transferred Tk.53,25,62,941/- to Grameen Telecom with stipulation that the income forthcoming from such investment would also be divided at 57.35% that would go to Grameen Telecom, and 42.65% to the petitioner. Thereafter, the petitioner filed returns of income under section 75(2)(d)(iii) of the Ordinance disclosed income, being its share of dividend, and then taxes deducted at source, and, paid tax at the rate applicable for dividend enacted every year in the Finance Act, along with income from its business from the Assessment Years 2004-2005 to 2016-2017, which has been accepted by the taxes department in regular assessments in all the years, and, no objection was raised whatsoever. The petitioner filed its income tax returns for the Assessment Years 2012-2013, 2013-2014, 2014-2015, 2015- 2016 and 2016-2017 showing income as per audited accounts, and, paid tax under section 74 of the Ordinance which has been duly credited in the Tax
Calculation/Refund Form (I.T.30). The petitioner however challenged the assessments made by the DCT for the Assessment Years 2012-2013, 2013- 2014, 2014-2015 and 2015-2016 before the Commissioner of Taxes (Appeals), and, then second appeals before the Taxes Appellate Tribunal, and, being aggrieved by the order passed by the Tribunal also filed reference applications vide Income Tax Reference (ITR) No. 107/2015, 621/2015, 622/2015 & 573/2016 before this Hon’ble Court. But as regards to the assessment year 2016-2017, it is lying with the Commissioner of Taxes (Appeals) in connection with an appeal filed by the petitioner. At that juncture, the Additional Commissioner of Taxes, Inspecting Range-1, Taxes Zone-14, Dhaka (hereinafter referred to as the Respondent No. 3) passed orders upon initating a proceeding under section 120 of the Ordinance in a hastily manner cancelling the assessments, whereof the Deputy Commissioner of Taxes revised the assessments, and issued assessment orders, Tax Calculation Sheet and demand notice. The petitioner then challenged the said order in Writ Petition No. 14364 of 2017, whereupon this Hon'ble Court directed to take legal steps before the authorities below, and, accordingly, the petitioner filed revision petitions under section 121A of the Ordinance before the Commissioner of Taxes (Respondent No. 2) who entertained the applications, but upon hearing the petitions, rejected the same, without touching the grounds furnished in the revision petitions of all the assessment years separately, in a single order, and, maintained the orders passed by the Additional Commissioner of Taxes. The petitioner then informed the said order of the Hon'ble Court by filing a supplementaryaffidavit annexing the order passed by the Commissioner of Taxes
49(Respondent No. 2) whereupon, the Hon'ble Court heard the Writ Petition No.14364 of 2017, on 24.11.2017, and instant rule and order of stay. Thereafter, the Commissioner of Taxes issued a notice vide e¢b ew 6(20)/p¡- 287(®L¡w)/LxAx-14/¢l¢iE/2017-2018/39 dated 16.11.2017 stating therein that, in the earlier order dated 14.11.2017 passed by him, he by mistake recorded, payment of 'undisputed portion of tax' “i¥mhnax fË−cu BuLl Af¢l−n¡¢da Hl f¢lh−aÑ f¢l−n¡¢da E−õMLl¡ q−u−R”, being a pre-condition to filing the revision, as set down in sub-section 4 of section 121A of the Ordinance as paid, but ultimately the same had not been paid. In issuing the notice, the Commissioner of Taxes, ignored the entire assessment records of the petitioner for all the assessment years in which it is clearly recorded that the undisputed portion of tax was paid in all the years for which clearance was also issued by the DCT upon which the appellate authorities admitted the appeals. However, the petitioner filed an application through an authorized lawyer stating therein that, taxes were paid under section 74 of the Ordinance at the time of filing of the returns of income in all the years, hence, there arises no necessity of reviewing the earlier order, but the Commissioner rectified his earlier order under section 173 of the Ordinance rejecting the revisions on 27.11.2017 on the ground of non-payment of undisputed portion of tax as laid down in sub-section 4(b) of section 121A of the Ordinance which has been impugned in the instant writ petition.
50Mr. Fida M. Kamal, learned senior counsel along with Mr. Sarder Jinnat Ali, learned counsel appearing for the petitioner at the very outset submits that, when the DCT has confirmed payment of undisputed tax in his certificate contained in I.T.59, before the Taxes Appellate Tribunal long
before, in respect of Assessment Years 2012-2013, 2013-2014, 2014-2015 and 2015-2016, hence, the opinion of non-payment of undisputed portion of tax, is mere conjecture, and, the order passed under section 173 of the Ordinance by the Respondent No. 2 is not maintainable in law.
51The learned counsel next submits that an order of rectification under section173 of the Ordinance cancelling earlier order, on the plea that undisputed portion of tax was not paid under sub-section 4(b) of section 121A of the Ordinance when, after scrutiny by the Taxes Appellate Tribunal the assessments attained finality under sub-section (5) of section 159 of the Ordinance and the appeal for the assessment year 2016-2017 has been admitted by the Commissioner of Taxes (Appeals), is a clear violation of law and hence, not maintainable.
52The learned counsel further contends that the petitioner has filed reference applications in respect of Assessment Years 2012-2013, 2013- 2014, 2014-2015 and 2015-2016 framing questions of law for answer of the Hon'ble Court, as such, cancellation of the assessments at this stage under section 120 of the Ordinance and maintaining the same by Respondent No. 2 through his rectification order is not maintainable in law.
53The learned counsel lastly submits that it is a settled issue that, the Commissioner cannot review and rectify his own order, hence, the order passed by Respondent No. 2 reviewing his own order is beyond jurisdiction and clearly a malice in law, and, therefore, it constitutes coram non judice, hence, not maintainable in law and finally prays for making the rule absolute.
54On the contrary, Mr. Md. Abdus Samad Azad, learned Deputy Attorney-General appearing for the respondent no. 2 by filing an affidavit-
in-opposition by controverting all the assertion made by the learned senior counsel for the petitioner at the very outset submits that the assesseepetitioner failed to fulfil the pre-requisite conditions as required under the provision of section 74 (1) of the Ordinance and failed to submit the necessary challans or pay orders in support of payment of tax as against the Dividend Income and Income from other sources under section 33 of the Ordinance the assessee concealed the income by declaring false, fabricated, manipulated and created income as a 'Dividend Income for the purpose of avoiding payment of real and correct tax and the assessee-petitioner misguided the court in this respect.
55The learned Deputy Attorney-General further submits that under section 120 of the Ordinance for the Assessment Years: 2012-2013 to 2016- 2017 as the assessment orders passed therein earlier by the DCT is erroneous insofar as it prejudicial to the interests of the revenue initiation of the proceeding under section 120 of the Ordinance was well within the lawful authority and very much sustainable in law.
56The learned Deputy Attorney-General next contends that the Commissioner of Taxes, Taxes Zone-14, Dhaka issued impugned order under sections 121A/173 dated 27.11.2017 asserting therein that, in the earlier order passed by him, he committed a mistake, saying that “c¡¢MmL«a ¢lV¡−eÑl ¢i¢š−a fÊ−cu BuLl f¢l−n¡¢daz gmax 2012-2013, 2013-2014, 2014-2015, 2015-2016 J 2016-2017 Llh−oÑl SeÉ c¡¢MmL«a ¢l¢ine j¡j¡m¡pj§q BuLl AdÉ¡−cn, 1984 Hl 121H(2) J 121H (4)(H)(¢h) d¡l¡l naÑ f¢lf¡me Ll¡u öe¡e£l SeÉ Nªq£a q−m¡” which is being a pre-condition for filing revision, as set down in subsection (4) of section 121A of the Ordinance, but fact remains actually the
same has not been paid by the petitioner, Grameen Kalyan and eventually he (respondent no. 2) rectified the same order under section 173 of the Ordinance for correction of such inadvertent errors still the assesseepetitioner did not pay the admitted liability under section 74 (1) of the Ordinance as it was clearly detected and also established in the revise assessment orders of the Additional Commissioner of Taxes under section 120 of the Ordinance.
57The learned Deputy Attorney-General further submits that the assessee declared income as 'Dividend Income' escaping the actual and correct income of the assessee-petitioner under the head 'Income from other sources' under section 33 of the Income Tax Ordinance, 1984 by paying lower rate of tax applicable for Dividend Income @ 20% though the higher rate is applicable for the Income from other sources @ 37.50% in accordance with the provision of the Income Tax Ordinance, 1984.
58The learned Deputy Attorney-General also submits that the Commissioner of Taxes passed the impugned order as per law who issued the impugned order under sections 121A/173 of the Ordinance for correction of the errors having given reasonable opportunity of being heard to the assessee-petitioner within the lawful authority and there is no violation of Article 27 & 41 of the Constitution of the People's Republic of Bangladesh but the assessee-petitioner misguided the court and misinterpreted the provision of law in the case.
59He next submits that the impugned revision order under section 121A of the Ordinance dated 14.11.2017 and the impugned notice under sections 121A/173 of the Ordinance for correction of errors and order passed thereof
are all within the lawful authority and based on legal aspect which has not caused any irreparable loss and injury in any way to the petitioner and also did not violate the fundamental rights of the petitioners as enshrined in Article 27 & 31 of the Constitution of the People's Republic of Bangladesh and therefore, the Rule and order of stay issued by the Hon'ble High Court is liable to be vacated and discharged.
60The learned Deputy Attorney-General goes on to submit that the order dated 14.11.2017 has simply been corrected on 27.11.2017 by replacing the word "Af¢l−n¡¢da" in place of incorrect word "f¢l−n¡¢da" which was inadvertently written earlier, since the challan submitted for showing tax deducted at source by the Grameen Kalyan was not correct at all since the said challans are related with Grameen Telecom not Grameen Kalyan and hence Grameen Kalyan cannot claim tax deposited through the said challans, and hence it goes counter in making payment of admitted tax under section 74 of the Ordinance which was actually required correction of earlier order and as such the order passed under sections 121A/173 of the Ordinance is lawful and hence the rule may kindly be discharged.
61The learned Deputy Attorney-General also submits that the assesseepetitioner failed to fulfil the pre-requisite conditions as required under section 74(1) of the Ordinance and also failed to submit the necessary challans or pay orders in support of payment of tax as against the alleged claimed Dividend Income and/or Income from other sources under section 33 of the Ordinance in its name not in the name of Grameen Telecom and therefore, the assessee misreported and misinterpreted the income by declaring false, fabricated, manipulated and created income as 'Dividend
Income' for the purpose of avoiding payment of real and correct tax and as such the rule may kindly be discharged being not fulfilled the condition provided in section 121A(4)(b) of the Ordinance.
62The learned Deputy Attorney-General next submits that the only point of law raised by the assessee-petitioner was whether or not the Joint Commissioner of Taxes rightly treated the income of the assessee, Grameen Kalyan received from Grameen Telecom as per agreement sharing the profit earned as "income from other sources" or of "dividend income", and the same being voluntarily settled by the petitioner by withdrawing ITR No. 363 of 2019 that upheld the Tribunal’s order and thus the said revision filed under section 121A of the Ordinance has been rightly rejected on 14.11.2017 and thereafter, made correction thereof under section 173 of the Ordinance on 27.11.2017 due to non-depositing tax liability under section 74, which is a pre-condition to entertain the revision under section 121A of the Ordinance and hence the rule issued in the instant Writ Petition is liable to be discharged since there has been no illegality in passing the order impugned in the Writ Petition No. 14364 of 2017 dated 14.11.2017 as well as order dated 27.11.2017 passed in the instant writ petition under sections 121A/173 of the Ordinance and finally prays for discharging the rule.
63Be that as it may, we took notice of the submission so placed by the learned senior counsel for the petitioner and that of the learned Deputy Attorney-General, perused the writ petition, supplementary-affidavit filed by the petitioner including the Annexure appended thereto vis-à-vis the affidavit-in-opposition so filed by the learned Deputy Attorney-General for respondent no. 2 and the document annexed as of Annexure.
64Since in the Writ Petition No. 14364 of 2017, we have exhaustively discussed and addressed all the relevant issues raised by the petitioner and countered by the respondent no. 2, we thus don’t feel it expedient to repeat the same in adjudicating the instant writ petition since the order impugned in the instant writ petition is nothing but the continuation of the action taken by the respondents against which filing of a fresh writ petition could have easily been avoided rather could seek a supplementary rule in conjunction of earlier writ petition.
65Having said that, in the impugned order dated 27.11.2017 simply a correction has been made by replacing a word “Af¢l−n¡¢da” in place of “f¢l−n¡¢da” incorrectly made in earlier order dated 14.11.2017 which has been passed while dismissing the revision and impugned in the Writ Petition No. 14364 of 2017.
66Simply put, we have to examine if the petitioner had at all paid admissible tax while filed the said revision under section 121A of the Ordinance taking into account of its income other than income it alleged to gains as dividend income in compliance with section 121A(4)(b) of the Ordinance. The emphatic answer is “No” basing on the materials available on record and clear negation expressed repeatedly in the affidavit-inopposition filed by the respondent no. 2. Now it would also be profitable if we revisit the relevant portion of the impugned order (as has been corrected) dated 27.11.2017 which are as follows:
“অিতির কর কিমশনার, পিরদশ র -১, কর অ ল-১৪, ঢাকা
কতৃক ২০১২-১৩, ২০১৩-১৪, ২০১৪-১৫, ২০১৫-১৬ ও ২০১৬-১৭
করবষসমূেহর জন% আয়কর অধ%ােদশ, ১৯৮৪ এর ১২০ ধারায়
67,ণীত আেদেশর িব/ে0 করদাতা ,িত1ান িবগত ২৯/১০/২০১৭ইং তািরেখ িরিভশন মামলা দােয়র কেরন। আয়কর নিথর রকড পরী:াে; দখা যাে= য, অিতির কর কিমশনার, পিরদশ র -১, কর অ ল-১৪, ঢাকা িবগত ২৬/০৯/২০১৭ইং তািরেখ আেলাচ% করবষসমূেহর :ে? আয়কর অধ%ােদশ, ১৯৮৪ এর ১২০ ধারার আেদশ ,দান কেরন, যার িব/ে0 িরিভশন মামলাসমূহ িনধািরত সময়সীমার মেধ% দােয়রকৃত। এছাড়াও িরিভশন িফস বাবদ ,িতCট করবেষর জন% পিরেশািধত টাঃ ২০০/= (টাকা দুই শত) মা? এর চালােনর কিপ (চালান নং-৩২০৯, ৩২৪৪, ৩২৪৬, ৩২৪৯ ও ৩২৫০, তািরখ ১৯/১০/২০১৭ইং, বাংলােদশ ব%াংক, ঢাকা) দািখল করা হেয়েছ। িকG দািখলকৃত িরটােণর িভিHেত ,েদয় কর পিরেশািধত নয়। ফলতঃ করদাতা ,িত1ােনর ২০১২-১৩, ২০১৩- ১৪, ২০১৪-১৫, ২০১৫-১৬ ও ২০১৬-১৭ করবষসমূেহ জন% দািখলকৃত িরিভশন মামলা আয়কর অধ%ােদশ, ১৯৮৪ এর ১২১এ (২) ও ১২১এ (৪এ ) ধারার শত পিরপালন করেলও ১২১এ (৪িব) ধারা পিরপালন না করায় বিণত করবষসমূেহর জন% দািখলকৃত িরিভশন মামলা আমেল নয়া গল না এবং িরিভশন মামলাসমূহ ,ত%াখ%ান (Reject) করা হেলা। অন% কান আপিH Jনানীকােল উLাপন করা হয়িন। আয়কর অধ%ােদশ, ১৯৮৪ এর ১২১এ /১৭৩ ধারায় উিMিখত ভােব ২০১২-১৩, ২০১৩-১৪, ২০১৪-১৫, ২০১৫-১৬ ও ২০১৬-১৭ করবষসমূেহর িরিভউ আেদশ সংেশাধন করা হেলা। সংেশািধত আেদেশর অনুিলিপ করদাতা ,িত1ান ও উপকর কিমশনার, সােকল-২৮৭ ( কাNানীজ), কর অ ল-১৪, ঢাকা এর িনকট ,রণ করা হাক।”
As per the above provision of section 121A(4)(b), the petitioner has admittedly not paid tax when it filed returns of the assessment years impugned in the writ petitions under section 75(2)(d)(iii) so it was legally bound to pay tax as per section 74 of the Ordinance having no scope to walk away treating payment of tax by Grameen Telecom at source as its own payment.
68On top of that, section 173 of the Ordinance has clearly mandated the respondent no. 2 to correct error on its own motion which it done within 13(thirteen) days of passing earlier order in the revision even by giving prior notice to the petitioner as it has also been reflected in the impugned order where it has been asserted that “িকG িরিভউ আেদশCটেত ভOলবশতঃ ,েদয় আয়কর অপিরেশািধত এর পিরবেত পিরেশািধত উেMখ করা হেয়েছ, যা আয়কর অধ%ােদশ, ১৯৮৪ এর ১৭৩ ধারায় সংেশাধেনর িনিমেH করদাতা ,িত1ােনর কান ব ব%/আপিH আেছ িক না জানােনার জন% অনুেরাধ কের প? ,রণ করা হয়। উ পে?র পিরে,ি:েত করদাতা ,িত1ােনর :মতা,াP ,িতিনিধ সরদার QজRাত আলী, এডেভােকট হাQজর হেয় িলিখত ব%াখ%া দািখল কেরন। তাঁর সােথ িবষয়Cট িনেয় আেলাচনা হয়। িকG িতিন করদাতা ,িত1ান-Tামীণ কল%াণ এর নােম আেলাচ% কর বৎসরসমূেহর জন% দািখলকৃত িরটােণর িভিHেত ,েদয় কেরর িবপরীেত পিরেশািধত কেরর কান ,মাণ দািখল করেত পােরনিন”.
69All in all, we simply don’t find any iota of illegality in the impugned order which warrants any interference by us at all.
70In the result, the rule is discharged however without any order as to costs.
71The order of stay passed at the time of issuance of the rule and extended from time to time stands vacated.
72The respondents are directed to do the needful relating to the unpaid tax from the petitioner by issuing necessary demand notice immediately.
73Let a copy of this judgment and order be communicated to the respondents forthwith. Rezaul Karim, J.
I agree.
74Abdul Kuddus, BO
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