Filing a return
Appealing an FBR Order
An appeal to the Commissioner (Appeals) must be lodged within thirty days, and for an assessment or penalty that runs from the date the notice of demand was served rather than from the date on the order. The fee is Rs 5,000 for a company and Rs 2,500 otherwise. A late appeal can be admitted where you were prevented by sufficient cause.
We do this for clients:Tax Advisory and FBR Representation in Pakistan
Where these figures come from
- Statutory basis
- Income Tax Ordinance, 2001, as amended by the Finance Act 2026, for tax year 2027 (1 July 2026 to 30 June 2027).
- Last checked against the statute
- by BarrioVibe, which files income tax returns through FBR IRIS.
These figures are an estimate computed from the rates above, not tax advice for your situation. Your return depends on facts a form cannot see, so treat the number as a starting point and speak to us before you file on it.
What an appeal costs
Section 127(4). Small enough that cost is rarely the obstacle, which is worth saying to anyone who has been quoted a large figure to file one.
| Appeal | Company | Anyone else |
|---|---|---|
| Against an assessment | Rs 5,000 | Rs 2,500 |
| Any other case | Rs 5,000 | Rs 5,000 |
What the appeal itself has to contain
Section 127(3). A defective appeal is a live risk, because the deadline does not pause while you correct it.
- It must be in the prescribed form
- It must be verified in the prescribed manner
- It must state precisely the grounds upon which the appeal is made
- It must be accompanied by the prescribed fee
- It must be lodged with the Commissioner (Appeals) within the thirty days
Which orders can be appealed
Section 127(1) lists them rather than granting a general right, and the list is worth checking before assuming. It covers orders under section 120(2A), sections 121, 122, 143, 144, 162, 170, 182 and 205, an order under section 161(1) holding a person personally liable for tax, and an order under section 172(3)(f) declaring a person to be the representative of a non-resident.
Two of those are worth noticing. Section 170 is a refund order, so a refusal to refund is appealable in the ordinary way. And section 182 is the penalty table, so a penalty is appealable separately from whatever assessment produced it.
What happens after you file
Section 128 requires the Commissioner (Appeals) to give notice of the day fixed for hearing to both the appellant and the Commissioner whose order is under appeal. So it is an adversarial hearing rather than a review on the papers, and the officer who made the decision is a party to it.
The practical consequence is that the grounds you stated in the appeal are the ones being argued. Section 127(3)(c) requires them to be stated precisely, and a set of grounds drafted as a general complaint gives you less to work with at the hearing than one that identifies the specific finding and the specific provision.
Questions
The questionspeople ask
How long do I have to appeal an FBR order?
Thirty days under section 127(5). For an assessment or penalty appeal that runs from the date the notice of demand was served, and in any other case from the date the order was served. Neither is the date printed on the order.
What does it cost to file an appeal to the Commissioner (Appeals)?
Under section 127(4), Rs 5,000 for a company appealing an assessment and Rs 2,500 for anyone else, with Rs 5,000 in any other case for a company.
Can I appeal after thirty days?
Possibly. The proviso to section 127(5) lets the Commissioner (Appeals) admit a late appeal where satisfied the appellant was prevented by sufficient cause. It is a discretion to be persuaded, not a right, and the application has to explain the cause.
Which FBR orders can be appealed?
Section 127(1) lists them, including orders under sections 120(2A), 121, 122, 143, 144, 162, 170, 182 and 205, an order under section 161(1) making a person personally liable, and one under section 172(3)(f) declaring a representative of a non-resident.
Can I appeal a refusal to give me a refund?
Yes. Section 170 orders are in the appealable list, and section 170(5) separately allows an appeal against the Commissioner failing to pass a refund order within the sixty days that section allows.
Does the value of my dispute decide which forum hears it?
Not any more. Section 126A split jurisdiction at twenty million rupees, but it was inserted in 2024 and omitted by the Finance Act 2025. Commentary written in that window still describes the threshold as current.
Is a penalty appealed separately from the assessment?
Yes. Section 182, the penalty provision, is listed in section 127(1) in its own right, so a penalty order is appealable whether or not the underlying assessment is also under appeal.
What is the strongest ground against an amended assessment?
Often a procedural one. Section 122(9) requires that no assessment be amended without giving the taxpayer an opportunity of being heard, and section 122(5A) is expressly subject to it, so an amendment made without a hearing is vulnerable on the face of the statute.
Also here
Relatedguides
Amended assessments
How long FBR has to reopen a return, the hearing it cannot skip, and why filing is itself an assessment order.
Filing your return
The IRIS screens in order with the amount codes you will actually see, the wealth statement nobody expects, and what it costs if you are late.
Recovery
The notice that starts everything, the provision behind a frozen account, and why the recovery powers do not reach a live dispute.
Thirty days, from the right date
An appeal filed late needs the Commissioner to accept a reason, and a strong case is no help if the clock ran out. If you are holding a demand notice, the date on it is the thing to check first.