Tax Services
Income Tax Appeals & FBR Appeals in Karachichallenging an assessment order the right way, at the right forum
When an assessment order is passed against you that you believe is factually or legally wrong, filing an appeal within time is the only way to preserve your right to challenge it. Once the appeal window closes, the order generally stands regardless of how strong the underlying argument might have been, which makes the decision to appeal, and how it's drafted, a genuinely consequential one.
Sahar Law Associates represents individuals and businesses in Karachi before the Commissioner (Appeals), the Appellate Tribunal Inland Revenue, and, where a question of law arises, in reference proceedings before the High Court of Sindh. Our appeals practice covers disputes on income tax assessments, sales tax demands, and penalty orders issued by Inland Revenue authorities.
An appeal is not simply a repeat of what was said at the assessment stage — it requires identifying precisely where the assessing officer erred, whether on facts, on the application of law, or on procedure, and framing grounds that a higher forum will actually engage with. We build appeals around that discipline rather than filing a generic objection.
Who this is for
Who needs this service
Individuals or businesses whose declared income or tax liability was amended by the Commissioner following an audit or notice.
Entities penalized for alleged non-compliance who believe the penalty was wrongly imposed or excessive.
Businesses contesting an input tax disallowance or sales tax assessment raised by FBR or the Sindh Revenue Board.
Taxpayers needing to escalate to the Appellate Tribunal Inland Revenue after an unfavourable first appeal.
Companies facing similar issues raised year after year that need a consistent, well-reasoned litigation strategy.
Problems we solve
What we take off your desk
- Assessment order received with additions to income that don't reflect the taxpayer's actual position.
- Appeal deadline approaching with no grounds yet drafted.
- Previous appeal dismissed due to weak or incomplete grounds and evidence.
- Stay of recovery not sought, exposing the taxpayer to coercive recovery action while the appeal is pending.
- Penalty imposed disproportionate to the alleged default, with no legal basis properly examined.
- Business unsure whether to accept an order or pursue further appeal to the Tribunal.
How it works
Our process, start to finish
Order review and merits assessment
We review the assessment order in detail and give you an honest view on the strength of an appeal before you commit to filing one.
Drafting grounds of appeal
We draft precise grounds addressing factual and legal errors in the order, supported by evidence and relevant case law.
Filing and stay applications
The appeal is filed within the statutory limitation period, along with a stay application against recovery where appropriate.
Hearing and follow-through
We represent you at hearings before the Commissioner (Appeals) or Tribunal and pursue the matter until a decision is issued.
What we need from you
Documents typically required
- Copy of the assessment or penalty order under challenge
- Original notice and all responses filed at the assessment stage
- Tax returns and wealth statements for the relevant tax year
- Books of accounts and supporting financial records
- Any correspondence exchanged with the assessing officer
- Proof of tax paid, if any, on the disputed demand
- Power of attorney or authorization for representation
If a document is missing, tell us — in most matters we can work from what you have and obtain the rest on your behalf.
How appeals actually proceed in Karachi
The Commissioner (Appeals) offices and the Appellate Tribunal Inland Revenue bench dealing with Karachi matters handle a substantial caseload, and hearings can be adjourned multiple times before a case is finally argued. We prepare clients for this reality upfront — an appeal is rarely resolved in a single hearing, and steady, well-documented follow-up matters as much as the initial drafting.
We also see businesses in Karachi treat the first appeal (before the Commissioner Appeals) as a formality on the assumption that the real fight happens at the Tribunal. This is a mistake — a well-argued first appeal can resolve the matter faster and more cheaply, and even where it doesn't succeed, it builds the factual record that the Tribunal will rely on later.
Limitation periods and recovery risk
An appeal to the Commissioner (Appeals) must generally be filed within 30 days of receiving the order, and further appeal to the Tribunal has its own limitation period running from the Commissioner (Appeals)'s decision. Missing these windows without a strong justification for delay can mean losing the right to appeal altogether, so we treat the date of receipt of any order as the first thing to establish and calendar.
Filing an appeal does not automatically stop FBR from pursuing recovery of the disputed amount. A separate stay application, supported by reasons, needs to be filed and argued to prevent coercive recovery measures while the appeal is pending, and we file this alongside the appeal itself rather than as an afterthought.
Deciding whether to appeal at all
Not every unfavourable order is worth appealing — sometimes the amount involved is small relative to the cost and time of litigation, and sometimes the order, while unwelcome, is legally sound. We give clients a candid assessment of the merits and the likely cost-benefit before recommending an appeal, rather than filing simply because the order was disappointing.
Where we do recommend proceeding, our fee is quoted based on the forum involved and the complexity of the factual record, agreed with you before the engagement begins, and we keep you updated at each hearing rather than only at the final outcome.
Questions clients ask
Frequently asked questions
- How long do I have to file an appeal against an assessment order?
- Generally 30 days from the date the order is served, though this can vary by forum and circumstance, which is why the exact date of receipt of the order needs to be confirmed immediately.
- Does filing an appeal stop FBR from recovering the disputed tax?
- Not automatically — a separate stay application needs to be filed and, in many cases, argued before the Commissioner or Tribunal to suspend recovery while the appeal is pending.
- What's the difference between the Commissioner (Appeals) and the Appellate Tribunal?
- The Commissioner (Appeals) is the first appellate forum within the tax department, while the Appellate Tribunal Inland Revenue is an independent forum you can approach if you're dissatisfied with the Commissioner (Appeals)'s decision.
- Can I go straight to the Tribunal without appealing to the Commissioner first?
- No, the law generally requires exhausting the first appellate remedy before the Commissioner (Appeals) before approaching the Tribunal, except in limited circumstances.
- What happens if I lose at the Tribunal?
- Where a genuine question of law arises, a reference can be filed before the High Court of Sindh, though this is limited to legal questions rather than a re-examination of the facts.
- Is it worth appealing a small penalty amount?
- It depends on the principle at stake and whether the same issue is likely to recur in future years — we give an honest cost-benefit view before recommending you proceed.
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