Income Tax | Sales Tax | Federal Excise | Provincial Sales Taxes

Tax Litigation & FBR Appeals Lawyers

Tax Litigation: Procedural Defense and Appeals

Robust legal representation to defend your rights in high-stakes tax disputes before the Commissioner, ATIR, and High Courts.

Your Advocate in High-Stakes Tax Disputes

When a disagreement with the FBR cannot be resolved through an audit, the dispute escalates to Litigation. This formal appellate process requires deep legal expertise, focusing heavily on procedural adherence and evidentiary sufficiency—precisely where most cases are won or lost.

LTA Pakistan’s litigation team provides comprehensive representation at all appellate stages. We manage your case from the ground up—building a strong legal argument, preparing Grounds of Appeal based on Constitutional and Statutory Law, and passionately advocating on your behalf before the Commissioner (Appeals), ATIR, and higher courts.

Our Defense Strategy Across Appellate Forums

Commissioner (Appeals)

The crucial first step. We meticulously prepare and file your appeal, ensuring facts and legal grounds (including procedural challenges) are precisely presented to challenge the initial tax order.

Appellate Tribunal (ATIR)

The final fact-finding forum. Our professionals argue your case based on precedents and points of law, proving facts through documentary evidence to secure a definitive ruling.

High Court & Beyond (Writ/Reference)

For substantial questions of law, FBR actions that are ultra vires, or violations of Constitutional Rights (Article 10A), we file reference applications and Writ Petitions.

Common Questions on Tax Appeals

No, filing an appeal generally does not automatically stop tax recovery. We must file a separate Stay Application with the Appellate Tribunal (ATIR) or High Court, providing a strong legal basis and often depositing a mandated percentage of the disputed amount to obtain temporary relief from recovery.

Writ Petitions before the High Court are used to challenge jurisdictional flaws (e.g., FBR acting ultra vires), violation of due process (e.g., lack of mandatory notice), or when the tax law itself breaches a Fundamental Right (e.g., Article 10A).

The FBR can only amend a finalized assessment based on 'definite information' showing escaped income. We frequently challenge amended assessments where the FBR attempts to reopen the case based merely on a change of opinion or vague material, arguing that such attempts are unlawful.

The ATIR is the final fact-finding body. We leverage the Qanun-e-Shahadat to insist that primary documentary evidence (e.g., bank records, filed contracts) must be accepted as conclusive proof, often overriding the Assessing Officer’s oral assumptions or interpretations.

Tax recovery must follow strict procedural steps (e.g., mandatory Section 138 notice). We challenge any recovery action taken without observing these legal formalities, often obtaining court directions against arbitrary attachment of assets.

Protect Your Assets: Consult Our Litigation Team

Don’t let an unjust tax demand go unchallenged. Secure formidable legal representation to advocate for your rights at every appellate stage.

Secure Your Defense Now