FBR restores two appeals regime
Through the Finance Bill 2025-26, it is proposed that the two appeals regime would be restored and first appeal would lie before the Commissioner (Appeals) regardless of the amount of tax involved and the second appeal would be filed before the ATIR.
In May 2024, through Amendment Act, a single appeal was provided against the assessment order before filing of reference in the High Court.
It was explained by the policymakers that trillions of rupees are stuck in tax litigation and the measure would facilitate early settlement. However, the amendment failed to bring the desired result and was criticised by the taxpayers, tax practitioners and the trade bodies.
It was observed that assessing officer of Grades BS 16 to 18 can raise tax liability of billions, whereas, Commissioner (Appeals) of BS 20 can hear appeals up to Rs10 million in sales tax and Rs20 million in income tax.
Copyright Business Recorder, 2025
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