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 Pakistan Bar Council & FBR Registered

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

  • Copy of impugned assessment order / show-cause notice with demand notice (Section 137).
  • Tax return and wealth reconciliation statements for relevant tax years.
  • Prior correspondence, replies submitted to FBR, and documentary evidence.
  • Power of Attorney / Wakalatnama signed by authorized taxpayer/director.

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

Need Expert
Legal Counsel?

Free Session
Initial Consultation
100% Secure
Private & Confidential

Request a Callback

Enter your WhatsApp number and our legal team will connect with you shortly.

Typical response time: Under 5 minutes