Notices, audits, assessments and appeals
Replies to FBR notices, audit and assessment proceedings, and appeals before the Commissioner (Appeals), the Appellate Tribunal Inland Revenue and the Lahore High Court under the income tax and sales tax laws.
Overview
An FBR notice has a deadline, a section number and consequences for silence. Most of the damage in tax cases is done before a lawyer is consulted: a notice under section 114 or 122 ignored, an ex parte assessment passed, recovery started from the bank account. Fortis Legal Partners responds to notices, represents taxpayers in audit and assessment proceedings, and carries appeals through the Commissioner (Appeals), the Appellate Tribunal Inland Revenue and, on questions of law, the Lahore High Court.
We act for individuals, professionals, traders and companies on income tax, sales tax and federal excise matters: filing and revision of returns, withholding disputes, exemption certificates, and the stay of recovery while an appeal is pending. The advice is practical: what the notice actually requires, what to concede, and where the department is outside its powers.
We identify the section, the deadline and what the officer can and cannot do under it, and seek an extension where needed.
A written reply with bank statements, ledgers and supporting evidence, drafted to close the issue rather than invite more questions.
If an adverse order is passed, an appeal is filed within the statutory period with an application to stay recovery.
Second appeal before the Appellate Tribunal, and a reference on questions of law to the Lahore High Court.
Governing law: Income Tax Ordinance, 2001 and Sales Tax Act, 1990
Replies to FBR notices, audit and assessment proceedings, appeals before the Commissioner (Appeals) and the Appellate Tribunal Inland Revenue, and tax references before the Lahore High Court.
Governing law: Article 199 of the Constitution of Pakistan, 1973
Constitutional (writ) petitions under Article 199, civil and criminal appeals and revisions, bail before the High Court, and references from tax and customs tribunals. Both founding partners have been Advocates of the High Court since 2023.
Section 122 allows the Commissioner to amend your assessment if he believes income has escaped tax or the return is wrong. You must be given an opportunity to explain before the amendment. A reasoned reply with documents at this stage often ends the matter; ignoring it leads to an ex parte order.
Ask this on WhatsAppYes, recovery under section 140 can be made from banks once tax is due and not stayed. Filing an appeal does not automatically stop recovery; a stay must be sought from the Commissioner (Appeals), the Tribunal or the High Court.
Ask this on WhatsAppGenerally thirty days from service of the order for an appeal to the Commissioner (Appeals), and sixty days for the Appellate Tribunal, with limited scope for condonation of delay. Check the date of service on your copy immediately.
Ask this on WhatsApp
Matters in this area often touch these as well.
Nothing on this page is legal advice and no representation is made as to the outcome of any matter.
Describe it in a short WhatsApp message. Someone from the firm reads it, tells you whether it is something we handle, and fixes a time.
+92 3110220257·Please do not send case documents in a first message. We will tell you what to bring.
