Sales Tax Appeals in Pakistan challenging section 11 orders, refunds and penalties

Sales tax appeals are won on invoices, payments and the law

Most sales tax appeals turn on a few questions: was the input tax genuine and properly supported, was the supply correctly classified and rated, was the order made within time and on proper notice, and were surcharge and penalty correctly applied. Each needs evidence on the record and a clear legal argument.

Under section 45B of the Sales Tax Act, 1990, a person aggrieved by an assessment, penalty, refund or other appealable order can appeal to the Commissioner Inland Revenue (Appeals), normally within 30 days of receiving it. Orders of the Commissioner (Appeals) can be appealed to the Appellate Tribunal Inland Revenue under section 46, also within 30 days following the 2024 amendments, and a reference on a question of law can then be made to the High Court under section 47. Recent amendments have also opened routes to appeal directly to the Tribunal in some cases, so the forum should be chosen with care.

An appeal does not by itself stop recovery. Where FBR can attach bank accounts or recover from buyers, a stay application is as urgent as the appeal. Disputes can sometimes also be resolved through alternative dispute resolution, which our tax dispute resolution team can assess.

Before filing, we review the order issue by issue and tell you honestly which points are strong, which are weak and what each is worth. Some issues are best settled by paying or by correcting a return; others deserve to be argued fully. Focusing the appeal on the issues that matter keeps costs down and makes the arguments that remain more persuasive.

This page covers sales tax appeals. For income tax orders, see income tax appeals, and for cases across several taxes or forums, our tax litigation service. Where the appeal needs rebuilt records, our bookkeeping team can help prepare them.