Appeals
Appeals before the Commissioner (Appeals) and Appellate Tribunal against orders and assessments.
Overview
Appeals against tax orders before the Commissioner (Appeals) and the Appellate Tribunal Inland Revenue, including stay of demand while the appeal is pending.
Why it matters
If an order is wrong, the law gives you the right to appeal, first to the Commissioner (Appeals) and then to the Appellate Tribunal. Appeals must be filed within strict time limits, so acting quickly matters.
Who needs this
- Taxpayers who disagree with an assessment, penalty or refund order
How it works
Who does each step, and how long it usually takes once documents are complete.
- 1Order reviewTAXWORK
Grounds and chances assessed.
1–2 days - 2Appeal to CIR(A)TAXWORK
Memo of appeal and grounds filed.
Within 30 days of the demand notice - 3Stay applicationTAXWORK
Request to stop recovery while the appeal is heard.
If needed - 4HearingsTAXWORK
Arguments presented.
Weeks to months - 5TribunalTAXWORK
Further appeal to ATIR if needed (fee Rs 2,000, or Rs 5,000 for a company).
Within 60 days of the CIR(A) order
Documents we need
Tick what you already have, then send the list to us.
What you receive
- Filed appeal
- Stay application
- Representation at hearings
Deadlines, risks and penalties
- Missing the time limit can end your right of appeal unless the delay is condoned
- Tax remains payable unless recovery is stayed
Mistakes we fix, and what our fee covers
Common mistakes we fix
- Missing the reply date on a notice, so an ex-parte order is passed
- Replies without documents or legal grounds
- Paying a demand that could have been reduced or stayed
- Missing the appeal limitation period
Included in our fee
- Reading of the notice and your records
- Written reply with the legal grounds and documents
- Representation before the officer or appellate forum
- Updates after every hearing and a copy of each order
Law and references
The sections and rules this service is based on.
- Section 127 – appeal to Commissioner (Appeals), within 30 days
- Section 131 – appeal to Appellate Tribunal, within 60 days
- Section 133 – reference to High Court
Questions
How long does it take?
Filing within 30 days; decisions usually take months. Step by step: Order review (1–2 days), Appeal to CIR(A) (Within 30 days of the demand notice), Stay application (If needed), Hearings (Weeks to months), Tribunal (Within 60 days of the CIR(A) order).
What does it cost?
We give a fixed quote after reviewing your case. Government fees are extra where they apply.
What happens if I miss a deadline?
Missing the time limit can end your right of appeal unless the delay is condoned. Tax remains payable unless recovery is stayed.
Do I have to pay the demand before appealing?
Not necessarily, but recovery can continue unless a stay is granted.
Is there a step-by-step procedure?
Appeal to the Commissioner (Appeals): Challenge an assessment, penalty, refund or other order of an Inland Revenue officer. Open the procedure →
Is there a step-by-step procedure?
Appeal to the Appellate Tribunal Inland Revenue: Second appeal against the Commissioner (Appeals) order, by you or the department. Open the procedure →
Is there a step-by-step procedure?
Reference to the High Court: Taking a question of law from the Appellate Tribunal's order to the High Court. Open the procedure →
Is there a step-by-step procedure?
Alternative Dispute Resolution (ADR): Settling a large tax dispute through an FBR committee instead of litigation. Open the procedure →
Is there a step-by-step procedure?
Show-cause notice to amend an assessment: Replying when FBR proposes to change your filed return. Open the procedure →
Is there a step-by-step procedure?
Bank account attached or recovery started: Immediate steps when FBR moves to recover a demand. Open the procedure →
Is there a step-by-step procedure?
Revision by the Commissioner: Asking the Commissioner to revise an order in your favour. Open the procedure →
How long do I have to file an appeal?
Appeal periods are short, usually counted from the date the order is served. We check the exact limitation date for your case.
Does an appeal stop recovery?
Not automatically. A separate stay application may be needed, which we file alongside the appeal.
Why clients choose TAXWORK
Individuals, businesses and companies across Pakistan and overseas.
Rawalpindi/Islamabad, Sialkot and Karachi (with Raza Siddiqui & Co., Chartered Accountants).
You get the scope and a fixed fee in writing before any work starts.
Progress updates, and a copy of everything we file or submit for you.
Keep reading
Related guides
Got an FBR notice? What to do in the first 48 hours
Most notices have short deadlines. Don't ignore one, and don't reply without checking your records.
Read guide →Filer or non-filer: what it costs you in 2026-27
Non-filers pay double or more on bank profit, dividends, property and cars. Getting on the ATL usually pays for itself.
Read guide →Buying or selling property this year
Advance tax for filers was halved in the budget. Here's what buyers and sellers pay and what to keep on file.
Read guide →Related services
See all 63 services →Our representative attends hearings before the tax officer with your documents and arguments in order.
View service →Notices & appealsFBR notice repliesWritten replies to information, audit, amendment and show-cause notices, prepared from law and your records.
View service →Notices & appealsRecovery & bank attachment reliefUrgent help when FBR has attached a bank account or started recovery, including stay applications.
View service →Audit & assuranceSpecial reviews & due diligenceStock counts, agreed-upon procedures for banks and partners, due diligence and tender certificates.
View service →Ready to get appeals done?
Send your documents on WhatsApp or book a meeting. A consultant confirms the scope and a fixed fee before any work starts.