If you disagree with a tax order, you can appeal to the Commissioner Inland Revenue (Appeals), then to the Appellate Tribunal Inland Revenue (ATIR), and on questions of law to the High Court. Appeals have strict time limits, usually 30 days from the order, and you can seek a stay of recovery while the appeal is pending.
Who this is for
- Taxpayers with an amended assessment or demand they dispute
- Businesses facing penalty orders
- Taxpayers whose bank accounts have been attached for recovery
- Taxpayers wanting to take a question of law to the High Court
How the tax litigation & representation process works
- 1
Review the order
We review the order and the grounds for appeal.
- 2
File the appeal
We file the appeal within time before the right forum.
- 3
Stay of recovery
We apply for a stay of demand while the appeal is pending.
- 4
Hearing
We argue the appeal with written submissions.
- 5
Further appeal
We take the matter to ATIR or the High Court if needed.
Documents you need
- ◆The assessment or penalty order
- ◆The notices and your replies
- ◆Tax returns and supporting records
- ◆Proof of any tax paid
Timeline and fees
| Timeline | Appeals must usually be filed within 30 days of the order. Hearing times vary by forum. |
|---|---|
| Fees | Quoted in writing after we review your documents. Court matters are quoted stage by stage (filing, evidence, arguments) so you know the cost of each step before it starts. |
| Governing law | Income Tax Ordinance, 2001: sections 127, 131, 133 and 140 · Sales Tax Act, 1990 |
Forums
- Commissioner Inland Revenue (Appeals)
- Appellate Tribunal Inland Revenue (ATIR)
- Islamabad High Court, by tax reference and constitutional petition
- Alternative Dispute Resolution Committees under section 134A
Recovery and attachment
If FBR has attached your bank account, we move quickly for a stay so your business can keep operating while the appeal is decided.
Frequently asked questions
How long do I have to file a tax appeal?
Usually 30 days from the date of the order for an appeal to the Commissioner (Appeals). Other forums have their own time limits.
Can FBR recover tax while my appeal is pending?
Recovery can continue unless a stay is granted, so applying for a stay is often urgent.
Can tax cases go to the High Court?
Yes, by reference on questions of law against decisions of the Appellate Tribunal.
