Not every FBR decision is final the moment it's issued. Assessments, penalties, and certain refund decisions can be formally appealed — but the process is deadline-driven, and missing the window closes the door on this level of appeal entirely.
The 30-Day Deadline
Under Section 127(2) of the Income Tax Ordinance, 2001 (with equivalent provisions in the Sales Tax Act and Federal Excise Act), an appeal must be filed within 30 days of the date you received the order. This is a hard deadline — count it from the day you were served, not the day the order was signed.
Where the Appeal Goes (2024 Threshold Changes)
Following the 2024 amendments, where your appeal goes now depends on the amount involved:
- Below the threshold — the appeal lies with the Commissioner Inland Revenue (Appeals), an independent authority separate from the officer who issued the original order
- Above the threshold (roughly Rs. 20 million for income tax, Rs. 10 million for sales tax, Rs. 5 million for federal excise) — the appeal goes directly to the Appellate Tribunal, skipping the Commissioner (Appeals) stage entirely
What the Commissioner (Appeals) Can Do
The Commissioner (Appeals) reviews the disputed assessment, refund, or penalty and has the authority to confirm, modify, or annul the original order. Appeals that get transferred onward are generally required to be decided within 180 days.
How to Prepare a Strong Appeal
- Clearly state which specific parts of the order you're disputing and why
- Attach all supporting documents — the original return, relevant bank statements, contracts, or prior correspondence with FBR
- Pay any admitted/undisputed portion of the tax demand where required, as this can be a precondition for the appeal to be entertained
- File within the 30-day window — a late appeal usually requires a separate, harder-to-win request for condonation of delay