Taxpayers can challenge specified income tax orders within 30 days, with assessment appeals subject to payment of tax due and prescribed filing fees.
The Federal Board of Revenue (FBR) has outlined the procedure for filing appeals against specified income tax orders under Section 127 of the Income Tax Ordinance, 2001, updated up to June 30, 2026, for Tax Year 2027.
Under the provision, a person dissatisfied with an eligible order issued by a Commissioner or an Inland Revenue officer may appeal to the Commissioner (Appeals), subject to the conditions specified in the law. State-owned enterprises (SOEs) are excluded from the appeal route provided under subsection (1).
The provision covers specified orders relating to assessments, amendments to assessments, penalties, refunds, tax recovery and other matters. It also applies to certain orders concerning personal liability for tax, the appointment of a representative for a non-resident person, implementation of appellate directions and refusal to rectify an alleged mistake under Section 221.
Taxpayers may approach the appellate tribunal directly
Section 127 allows an aggrieved person to choose between filing an appeal before the Commissioner (Appeals) and surrendering that right to approach the next statutory appellate forum directly by filing an appeal before the Appellate Tribunal Inland Revenue.
However, a taxpayer cannot appeal against an assessment order under Section 127 unless the tax due under Section 137(1) has been paid.
The appeal must be submitted in the prescribed form, verified in the prescribed manner and supported by clearly stated grounds. It must also include the applicable filing fee and be lodged within the statutory time limit.
The FBR may prescribe a mechanism for electronic filing of appeals under subsection (3A).
Appeal fees under Section 127
The prescribed appeal fees depend on whether the appellant is a company and whether the appeal concerns an assessment.
| Type of appeal | Company | Other taxpayer |
| Appeal against an assessment | Rs5,000 | Rs2,500 |
| Any other eligible appeal | Rs5,000 | Rs1,000 |
Thirty-day deadline for filing appeals
Under Section 127(5), an appeal relating to an assessment or penalty must be filed within 30 days from the date the relevant notice of demand is served.
For other appealable orders, the 30-day period begins on the date the order is served on the aggrieved person.
The law also provides relief where an appellant misses the deadline for a sufficient reason. Under subsection (6), the Commissioner (Appeals) may admit a late appeal if the appellant submits a written application and the Commissioner is satisfied that a sufficient cause prevented the appeal from being filed within the prescribed period.
The provision therefore establishes the filing requirements, fee structure and time limits applicable to taxpayers seeking to challenge specified income tax orders during Tax Year 2027.