Islamabad, January 30, 2026: The Federal Board of Revenue (FBR) has initiated recovery of Super Tax from taxpayers following the landmark judgment of the Federal Constitutional Court. Field formations of the FBR began issuing notices on Thursday for outstanding Super Tax payments exceeding Rs200 billion.
Large Taxpayers’ Offices (LTOs), Medium Taxpayers’ Offices, and Corporate Tax Offices are currently computing the amounts due for taxpayers within their jurisdictions. Thousands of taxpayers are expected to be impacted by the court ruling.
Some taxpayers have already received notices, while others are awaiting final computations. Notices have been issued under Section 138(1) of the Income Tax Ordinance 2001 for the tax year 2023, with strict warnings for non-compliance. According to one notice, failure to pay may result in attachment or sale of movable and immovable assets, appointment of a receiver, and even arrest for up to six months.
The notices also clarify that non-payment may be due to tax deletion in appeal, pending rectification applications, or prior adjustments. Taxpayers not falling under these conditions are required to pay the liability by the stipulated deadline, or face coercive recovery measures under Section 140 of the Ordinance.
The Federal Constitutional Court upheld the constitutionality of Section 4B, declaring the levy a valid tax. Similarly, appeals regarding Section 4C were dismissed for taxpayers but allowed for the tax department, confirming its constitutional validity. Section 4C Super Tax applies at a 10% rate for tax year 2022 to 15 identified sectors where income exceeded Rs300 million.
For oil exploration and petroleum companies operating under Petroleum Policies and Concession Agreements governed by the Fifth Schedule, the Court directed Commissioners to issue fresh notices in strict compliance with the law, while ensuring that any agreed caps in these agreements are not exceeded.
The FBR has urged all affected taxpayers to comply promptly to avoid legal and financial consequences.