Tax Law, Professional Practice & FBR PolicyAugust 14, 2026

Filing a Return and Practicing Law Are Not the Same

M

Muhammad Rehan Sarwar Advocate High Court

Author

Chairman FBR recently remarked that the specialized knowledge tax consultants have long held about how the Board operates could become redundant this year, given artificial intelligence, third party data, and the new faceless assessment system. As a practicing Advocate handling income tax and sales tax matters daily, I want to respond to that directly and without hedging.

If tax consultants are truly as redundant as suggested, the test is simple. Let AI prepare every tax return in the country. Problem solved.

If Chairman FBR has that much confidence in his institution, his systems, and their performance, then rather than singling out consultants for criticism, sideline the profession entirely and hand the whole tax system over to AI. Only then will it become genuinely clear that filing a tax return is not simply a matter of filling in a few fields. Behind every return sits an understanding of the law, a careful examination of facts, correct legal interpretation, tax planning, and above all, the acceptance of professional responsibility.

The professionals being quietly diminished today by being labelled redundant are, in reality, the ones whose shoulders carry a substantial share of this country's tax compliance. AI can be an excellent tool. But the complexity of the law, the nuance embedded in facts, and the legal responsibility attached to a filed return cannot simply be handed to an algorithm.

And if we truly are as unnecessary as suggested, then rather than criticizing and discrediting the profession, eliminate it altogether, and let AI take over the entirety of FBR's own system as well, its flaws, its notices, its audits, its appeals, and the interpretation of tax law itself. Only then will everyone understand that filing a return and practicing tax law are two entirely different things.

There is one further point worth stating plainly. Officers up to Commissioner level within the Income Tax department are themselves running private offices as tax consultants on the side. If redundancy is truly the concern, that is where it actually exists.

The legal point beneath all of this is simple. Preparing a form is clerical work. Practicing tax law is professional judgment exercised under the Income Tax Ordinance and the Sales Tax Act, carrying real liability whenever that judgment is wrong. No algorithm signs an appeal, argues a question of law before the Tribunal, or bears responsibility when an interpretation is challenged years later. Reforming the system, investing in AI, and holding consultants accountable where they genuinely fall short, all of that is fair and necessary. But dismissing an entire profession as redundant, while some of the department's own senior officers quietly maintain private consultancy practices, is not reform. It is misdirection.

Muhammad Rehan Sarwar

Advocate High Court

The Nomologists Law Firm

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