On the same day it buried LIOYD's reference, the same division bench of the Sindh High Court — Justice Agha Faisal (author) and Justice Shah Nawaz Memon — dismissed another fossil from the files: the income tax reference filed by Tarom S.A. Romania, the Romanian airline, against the Commissioner of Income Tax, Companies-I (case 181 of 2005).
The story is identical, and that is precisely the point. The reference had lain dormant for years with no effort by the applicant to have it listed, and when the matter was finally called, the applicant went unrepresented. The bench dismissed it for non-prosecution, again following the Supreme Court's ruling in Commissioner Inland Revenue v. Rafeh Limited (PLD 2020 SC 518).
There is a special lesson here for foreign litigants. Tarom is a Romanian company — and distance, time zones, and changed management are the usual explanations when a foreign party's Pakistani litigation goes quiet. The court's answer is unsentimental: being abroad is no excuse. If you litigate in Pakistan, you must keep local counsel engaged, keep your file moving, and appear when called. An applicant who vanishes for years will find the reference dismissed, not adjourned.
As with all non-prosecution dismissals, the court decided nothing on the merits of the tax dispute itself. The underlying tax position of the department remains undisturbed. For tax advisers, the practical takeaway is administrative, not legal: diarise every reference, file listing applications, and never assume an old file is safely parked. Purani file par dhool jamne dena — in the High Court's eyes — is the same as abandoning it.