1. Restoration of Two-Tier Appeals: A Major 2025 Shift

Starting July 1, 2025, Pakistan reinstated the two-tier appellate framework under the Finance Act 2025. Taxpayers must now first appeal to the Commissioner (Appeals), and then to the Appellate Tribunal Inland Revenue (ATIR), before proceeding to a High Court via a tax reference.
This overturns the prior system (2024 Amendment Act), which had bypassed these forums and sent cases straight to high courts—overloading them and delaying justice.

Key Changes in 2025 Tax Appeal Framework

2. FBR’s Expanded Recovery Power: Appeals Are No Longer a Shield

Under the Tax Laws (Amendment) Ordinance, 2025 (enacted May 2), FBR gained unprecedented powers to:

• Immediately recover tax—even pending appeals—if a relevant issue was ruled by a High Court or Supreme Court.
• Attach bank accounts, seal premises, and monitor business activities without notice.

This development significantly erodes taxpayer protections, making timely appeal submissions and legal strategy more critical than ever.

3. Why Appeals Before the Commissioner Are More Critical Now

• Filing with Commissioner (Appeals) is required before escalation to ATIR or higher bodies—miss this and you lose appellate rights.
• Appeals offer more control over framing your tax dispute, allowing for procedural and factual defense before moving to tribunal.

4. Broader Implications: Litigation Surge & Systemic Lag

• Pakistan sees over 70,000 annual tax-related appeals—despite having fewer than 10 million income‑tax filers. This is unlike other countries where appeals rarely reach final courts.
• High courts remain bogged down amid weak tribunal capacity, inadequate reasoning in orders, and inefficient case resolution.

5. Why Legal Representation for FBR Appeals Is Essential in 2025

Processing time is tight:

• Appeals to ATIR must typically be decided within 90 days, with extensions allowed up to 180 days.
• FBR’s new powers to enforce recovery legally bind you even while appeal proceedings are live.

Legal strategy matters: Effective legal briefs help ensure that appeals are fully actionable, fully reasoned, and timely filed.

Your Step‑by‑Step Appeal Checklist – Commissioner (Appeals)

1. Assessment order/notice (sales/income/federal excise tax).
2. Power of Attorney appointing your legal representative.
3. Any supporting documents (e.g. financials, audit records, correspondence).
4. Legal opinion & appeal draft explaining disputed points and relief sought.
5. Adherence to strict timelines—file quickly to protect rights under new rules.

Documents Required for Filing an Appeal

Bottom Line: Act Strategically, Act Quickly

In 2025, federal reforms have given FBR the teeth to recover tax instantly—even before appeals conclude. Meanwhile, the legal taxpayers’ route has improved with the restoration of the two‑tier system—but only if you follow the process correctly.

Early, precise, and professionally documented appeal submissions before the Commissioner (Appeals) are now more urgent than ever.

Let us help you draft and file a strong appeal within 6–9 working days—aligning with the Commissioner (Appeals) framework to shield your rights and business.

Appeal Checklist

Ready to start or just want expert advice? Contact us today.