Tax Appeal & Litigation Assistance

First, identify what you have actually received

Not every letter from FBR is an assessment, and the right response depends entirely on which stage you are at. Read the heading, the section quoted and the date, because the section number tells you what is being asked and the date starts a clock.

• A notice to file a return: you have not filed, and FBR is requiring you to. Filing usually closes it.
• A notice calling for information or documents: a request at the enquiry stage. Answer it fully and on time; this is the cheapest point to resolve a case.
• A show-cause or amendment notice: FBR is proposing to change your assessment and must give you an opportunity to be heard. Your written reply here shapes everything that follows.
• An assessment or amended assessment order: a decision has been made and a demand created. This is what you appeal.
• A recovery notice, attachment of a bank account or a notice to a third party: enforcement of an existing demand. This is urgent and needs immediate action.

Responding to a notice properly

The single most damaging thing a taxpayer does is ignore a notice. An unanswered notice typically results in a best-judgement assessment based on FBR's own estimates, and you then spend far more effort dismantling a number than you would have spent explaining your position in the first place.

A good reply is specific and documented. Address each point raised, in order. Attach the evidence — bank statements, invoices, contracts, withholding certificates, import documents — and reference each attachment in the text. Keep the tone factual. If you genuinely need more time, request an extension in writing before the deadline rather than after it, and say why.

The appeal ladder

Pakistan's tax appeal structure is sequential: you cannot skip a tier, and each tier has its own time limit and its own character.

Time limits and the deposit question

An appeal to the Commissioner (Appeals) must generally be filed within thirty days of service of the order, and a further appeal to the Tribunal within sixty days of the appellate order. These periods are strict. Condonation of delay is possible but discretionary and requires a genuine, evidenced reason — a missed deadline is the most common way a good case is lost.

Filing an appeal does not automatically stop recovery of the demand. Where you need to prevent enforcement while the appeal is pending, a separate application for stay is required, and the appellate authority may require part of the demand to be deposited or secured. Alternative dispute resolution is also available in appropriate cases and can be faster than litigation, particularly where the dispute is about quantum rather than principle.

Preparing a case that can win

• Assemble the complete file: the notices, your replies, the order under appeal, and every document you rely on, paginated.
• Identify the grounds precisely — a factual error, a misapplication of a section, a denial of the opportunity to be heard, or a legal position supported by reported decisions.
• Draft grounds of appeal that are specific. "The order is bad in law" argues nothing; "the addition under section X ignored the withholding certificates at pages 14–19" argues something.
• Reconcile your figures with FBR's and explain each difference; unexplained gaps are read against you.
• Attend hearings or ensure your authorised representative does, with the file. Repeated non-appearance can result in the appeal being decided against you on that basis alone.
• Keep proof of filing and of every submission made.

How to avoid ending up here

Most of the assessments we see could have been prevented by ordinary record discipline: filing on time, staying on the Active Taxpayer List, collecting withholding tax certificates for every deduction, keeping bank accounts for business and personal use separate, retaining invoices and contracts for at least six years, and ensuring the wealth statement is consistent with declared income. Where a transaction is unusual — a gift, an inheritance, a foreign remittance, a property sale — keep the documentation at the time, not when it is asked for three years later.

Getting help with your case

Describe your situation in the form below — the section quoted, the date of the notice or order, the amount in dispute and what has happened so far. We will tell you what stage you are at, what the applicable deadline is, and what the realistic options are. If the matter requires representation before the Tribunal or a High Court reference, we will say so plainly rather than take on work that needs a tax lawyer.

Frequently asked questions