High-Stakes Tax Defense

Tax Appellate Litigation & High Court Writs (ATIR, CIR Appeals, High Court)

We provide comprehensive legal representation and defense against arbitrary FBR assessments, audits, penalty orders, and unlawful recovery actions. Our advocates appear regularly before Commissioner (Appeals), Appellate Tribunal Inland Revenue (ATIR), and High Courts.

Timeline: Immediate Stay Defense & Statutory Appeal Timelines Advocates High Court & Tax Counsel

Who Needs This Service?

Corporations, partnerships, and high-net-worth individuals facing adverse assessment orders (u/s 121, 122), audit findings (u/s 177, 214C), unexplained income notices (u/s 111), bank account attachments (u/s 140), and penalty proceedings.

How It Works (Step-by-Step)

1

Order Review & Legal Precedent Research

Analyze the impugned assessment order, audit report, or show-cause notice against settled statutory provisions and superior court case laws.

2

Grounds of Appeal & Stay Petition Drafting

Formulate exhaustive Grounds of Appeal, stay applications against tax demand recovery, and comprehensive legal rebuttals.

3

Appellate Forum Representation & Arguments

Appear before the learned Commissioner (Appeals), Tribunal bench, or High Court judges to argue the merits, secure stay orders, and obtain relief.

Documents & Requirements

Statutory documentation split between client-provided records and consultant drafting

Client Records Prepared by Us
Provided By Client
  • Certified copy of impugned Assessment Order / Penalty Order with Demand Notice (Section 137).
  • Income Tax Returns, Wealth Statements, and audit correspondence for the disputed tax periods.
  • Records of previous written submissions and replies tendered before assessing officers.
  • Bank account freezing / attachment notices issued by FBR under Section 140 (if coercive action started).
  • Vakalatnama executed by the aggrieved taxpayer, partners, or authorized director.
Prepared By Consultant
  • Formulation and drafting of comprehensive Grounds of Appeal and legal arguments.
  • Filing of urgent Stay Applications against recovery of disputed tax demands before CIR(A) / ATIR / High Court.
  • Personal appearance, legal arguments, and precedent citation by High Court tax advocates.
  • Preparation of rejoinders, paper books, and case law digests for the appellate bench.
  • Procurement of appellate orders, stay extensions, and remand compliance before assessing officers.

Pricing & Engagement

Structured fee schedule per appellate forum (CIR Appeals, ATIR, High Court) including grounds drafting, rejoinders, stay petitions, and regular hearing representation.

Frequently Asked Questions

An appeal must be filed within 30 days of the receipt of the assessment order and demand notice. Condonation of delay requires strong, justifiable legal grounds.
Under Section 140, tax officers often attempt bank attachments. We immediately file urgent stay petitions before CIR(A), ATIR, or High Court to restrain bank attachments and recovery.
A Constitutional Writ Petition under Article 199 can be filed before the High Court when FBR acts without jurisdiction, in breach of natural justice, or where fundamental rights are infringed.
Legal Basis: Income Tax Ordinance 2001 (Sections 127–134, 137, 140); Sales Tax Act 1990 (Sections 45B–47); Constitution of Pakistan (Article 199). Content last reviewed: September 2026

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