If FBR issues an assessment you believe is incorrect — whether from an audit, a Section 111 notice, or an amended assessment — you have a structured right of appeal. Acting within the deadlines at each stage is critical, since missed windows generally can't be recovered.
Stage 1: Commissioner Appeals (CIR-A)
The first stage of appeal is to the Commissioner Inland Revenue (Appeals), filed within 30 days of receiving the assessment order. You'll need to lay out clearly why the assessment is wrong, supported by documentary evidence, and the CIR-A can uphold, reduce, or set aside the assessment.
Stage 2: Appellate Tribunal Inland Revenue (ATIR)
If the outcome at Commissioner Appeals is still unsatisfactory, the next stage is the Appellate Tribunal, filed within 60 days of the CIR-A decision. This is a more formal proceeding and professional representation is strongly advisable at this stage.
Stage 3: High Court
Appeals beyond the Tribunal go to the High Court, but only on a question of law — not simply disagreement with the facts found by the Tribunal.
Alternate Dispute Resolution
For larger disputes, FBR's Alternate Dispute Resolution mechanism offers a faster settlement route outside the formal appeal ladder, often worth considering for significant demand amounts.