Order review
The order, its findings and the strength of each issue assessed.
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If an income tax order is wrong, an appeal is how you challenge it, but the time limits are short. We prepare grounds of appeal, file within time, apply for stays against recovery and argue your case before the Commissioner (Appeals) and the Appellate Tribunal Inland Revenue.
An appeal is a fresh chance to show that an assessment, penalty or refund order is wrong in fact or in law. It must be filed on time, with clear grounds, and supported by evidence. Recovery can continue while it is pending unless you obtain a stay.
Under section 127 of the Income Tax Ordinance, 2001, a taxpayer can appeal to the Commissioner Inland Revenue (Appeals) against orders such as amended assessments, best judgment assessments, penalty orders and refund decisions, normally within 30 days of receiving the order. Following the Finance Act, 2025, a taxpayer may instead elect in writing to appeal directly to the Appellate Tribunal Inland Revenue, giving up the appeal before the Commissioner (Appeals) for that order. Orders of the Commissioner (Appeals) can then be appealed to the Tribunal under section 131, within 30 days, and a reference on a question of law can be made to the High Court under section 133.
Filing an appeal does not by itself stop FBR from recovering a demand. A stay application, to the Commissioner, the Commissioner (Appeals) or the Tribunal as the case requires, is often as urgent as the appeal itself. The law also provides for alternative dispute resolution under section 134A for certain cases, which we consider where it suits the dispute.
This page covers income tax appeals. For sales tax orders, see our sales tax appeals service, and for disputes across several taxes or forums, our tax litigation team. Where an appeal depends on reconstructed records, our accounts reconciliation team can help prepare the evidence.
A fixed fee per appeal, agreed after we review the order.
The order, its findings and the strength of each issue assessed.
Filing deadline confirmed from the date of service.
Clear grounds on facts and law, drafted and filed.
Applications to stop recovery while the appeal is heard.
Evidence and documents compiled for the forum.
Submissions supported by statute and case law.
Representation before the Commissioner (Appeals) and ATIR.
Follow-up so relief granted is reflected in your records.
Many appeals fail for procedural reasons before the merits are heard.
Appeals filed after 30 days need a condonation request and may be refused.
We file within time.Without a stay, FBR can attach bank accounts while the appeal is pending.
We apply for stays.Grounds that do not identify the error narrow what can be argued.
We draft specific grounds.Documents not produced earlier may be harder to rely on later.
We build the record.Electing to go directly to the Tribunal gives up the first appeal for that order.
We advise on the route.Limitation and jurisdiction points can decide an appeal on their own.
We raise legal issues.Send us the order the day you receive it.
We review the order and tell you the options and the deadline.
Agreed for the appeal stage.
Grounds and, where needed, a stay application filed.
Paper book and written arguments submitted.
We represent you and follow up the decision.
Additions to income, wealth or foreign assets.
Disallowed expenses and unexplained deposits.
Firm assessments and partner issues.
Minimum tax, withholding and related-party issues.
Refunds refused or reduced.
Penalties and default surcharge orders.
Our appeals combine legal argument with accounting evidence, prepared by the team that understands your records.
LLB-qualified advocate to draft and argue appeals.
ACCA and ICAP Chartered Accountant qualifications and an FBR-registered income tax practitioner.
Limitation tracked from the day of service.
Reconciliations and documents prepared for the record.
A clear view of each issue's strength before you file.
Agreed per appeal stage.
Have a question that is not here? Send it to us on WhatsApp and we will reply the same day.
Send it to us now. We will confirm your deadline, tell you the options and quote a fixed fee for the appeal.
Book your free consultationThis page is general information about our services, not tax, legal or financial advice for your specific situation. Laws, rates and deadlines change with each Finance Act and official notification.