How to Appeal an Income Tax Assessment in Pakistan: Step-by-Step Guide

If you have received an income tax assessment from the Federal Board of Revenue (FBR) that you believe is incorrect, you have the legal right to challenge it. This guide outlines the tax appeal process in Pakistan, including how to file a notice of appeal with the Commissioner of Income Tax (CIT) and escalate your case to the Appellate Tribunal, if necessary.

---

Who Can File a Tax Appeal?

Any taxpayer in Pakistan who disagrees with an income tax assessment, including on matters such as advance tax, rental income, or withholding tax, can initiate an appeal with the CIT.

---

Step 1: File a Notice of Appeal with the Commissioner of Income Tax (CIT)

You must submit a written notice of appeal within 30 days from the date of the assessment. The appeal must:

Be in writing and signed by:

• The taxpayer, or
• Their authorized representative

Include the following details:

• Taxpayer’s full name and address
• The tax year being appealed
• The amount of tax in dispute
• Clear and concise grounds for the appeal

Where to file:

Commissioner of Income Tax  Federal Board of Revenue (FBR)

Step 2: Review by the Commissioner of Income Tax (CIT)

Once your appeal is filed, the CIT will review your case and issue a decision. This process may involve examining the assessment, your submitted documents, and any additional records. If the CIT upholds the original assessment, and you still disagree with the outcome, you can further escalate the case to the Appellate Tribunal Inland Revenue (ATIR).

---

Step 3: Appeal to the Appellate Tribunal Inland Revenue (ATIR)

The Appellate Tribunal is an independent judicial authority that handles tax disputes between taxpayers and FBR. To initiate this appeal, you must file a memorandum of appeal within 30 days of receiving the CIT’s decision.

The memorandum of appeal must:

• Be in writing and signed by you or your representative
• Include:
  • Your name and address
  • The relevant tax year
  • The amount disputed
  • Detailed grounds for appeal

Where to file:

Appellate Tribunal Inland Revenue  

Step 4: Decision of the Appellate Tribunal

• The Appellate Tribunal will evaluate your appeal and issue a final decision.
• The Tribunal may:
• • Uphold the CIT’s decision, or
  • Overturn it and grant relief (e.g., reduce your tax or order a refund)

Note: The Appellate Tribunal’s decision is final and binding. There is no further right to appeal within the tax system.

---

Conclusion

If you believe your income tax assessment is unfair or incorrect, you have the right to file a tax appeal.

Summary of the Appeal Process:

1. File a written notice of appeal with the CIT within 30 days of the assessment
2. Include all required information and grounds for appeal
3. If unsatisfied with the CIT’s decision, file a memorandum of appeal with the Appellate Tribunal within 30 days
4. The Appellate Tribunal’s decision is final

Taking prompt and accurate steps ensures your rights are protected, and you receive fair tax treatment under Pakistani tax law.