Ending Discretion at the Source
FBR's Compliance Risk Management System now controls income tax case selection, creating an auditable trail that may also help test AMLA referrals arising from ordinary tax matters.
Read full briefing →Publications
News & Insights
Advocacy and Professional Ethics: The Advocate's Duty Beyond Winning a Case
An examination of the advocate's duties to the court, clients, and the public under Pakistan's professional canons, and why ethical advocacy extends beyond winning a case.
Read full briefing →When One Arm of the State Sues Another
A Lahore High Court ruling examines the FIA–FBR dispute over confidential tax records, executive consultation, and Section 216 protections when AMLA powers are invoked.
Read full briefing →Before the Charge of Money Laundering, the Law Demands a Number
The Supreme Court holds that AMLA money laundering charges cannot proceed until the underlying tax liability has actually been assessed and adjudicated, reaffirming the Taj International precedent.
Read full briefing →A Return Form Is a Legal Instrument, Not a Software Screen
FBR's redesigned Tax Year 2026 return form under Section 237 marks a structural shift toward algorithmic, data-driven filing, raising real questions about statutory limits and fair transition for taxpayers.
Read full briefing →When Is a Notice Final Enough
FBR's appeal against a Peshawar High Court ruling on a cigarette-factory sealing puts two questions before the Federal Constitutional Court: when a show cause notice becomes final enough to challenge, and what "reason to believe" requires under Rule 28A(6) of the Federal Excise Rules.
Read full briefing →A Right That Survives Its Neighbour: Tax Credits and the Super Tax
The Federal Constitutional Court holds that a Section 168 tax credit is a distinct legal right that can be adjusted directly against Super Tax liability, rather than confined to the slower refund route under Section 170.
Read full briefing →A New Architecture for Alternative Dispute Resolution
The Third Amendment Act 2026 replaces Section 134A of the Income Tax Ordinance, redesigning the ADR Committee's composition and tightening the finality and transition rules for tax disputes of Rs. 50 million or above.
Read full briefing →When the Machine Assesses the Penalty: Customs Enters the Automated Age
FBR has notified penalties under Section 82(1) of the Customs Act and introduced the Overstayed Cargo Management Rules, 2026, letting the Customs Computerised System assess overstayed-cargo penalties automatically.
Read full briefing →Filing a Return and Practicing Law Are Not the Same
A response to Chairman FBR's remarks that AI, third-party data, and faceless assessments could make tax consultants redundant, arguing that filing a return and practicing tax law are fundamentally different things.
Read full briefing →Consistency Is Not Optional: A Lesson From One Rejected Refund
The Federal Tax Ombudsman rules that a rejected income tax refund claim amounted to maladministration, reaffirming that administrative consistency and the right to a hearing are legal obligations, not courtesies.
Read full briefing →A Short Order Is Not a Green Light
A Federal Tax Ombudsman ruling holds that coercive recovery under Section 4C, based on a short order before the detailed judgment's reasoning is released, amounts to maladministration, and directs FBR to issue clear policy across all affected categories.
Read full briefing →When a Ruling Isn't Enough: The Difference Rectification Makes
How a Federal Tax Ombudsman rectification order completed relief under Section 216, adding enforceable directions to a finding that lacked them.
Read full briefing →A Tax Struck Down, and a Refund Undefined
The Federal Constitutional Court struck down Section 7E of the Income Tax Ordinance as void ab initio while upholding Super Tax under Section 4C, leaving taxpayers with a settled right to refunds but no notified mechanism to claim them.
Read full briefing →Who Polices the Tax Department: A Jurisdictional Fight Worth Watching
An Islamabad High Court case over the Federal Tax Ombudsman's suo motu jurisdiction under Section 9 could reshape who reviews how FBR treats taxpayers.
Read full briefing →Two Supreme Court Rulings, One Lesson About Discipline
Two Supreme Court sales tax rulings, one on conceded legal points, one on limitation, converge on a single lesson: legal discipline is not optional at any stage of a case.
Read full briefing →When Enforcement Itself Becomes the Injury
A Federal Tax Ombudsman order creates a new 'Business Continuity Cases' category, recognizing that suspension and sealing can inflict harm no legal victory fully undoes.
Read full briefing →FBR's IRIS 2.0: A New Filing Season, and a New Set of Problems
A practitioner's ground-level account of the defects in FBR's redesigned IRIS 2.0 portal for Tax Year 2026, and why the system must be fixed before further changes.
Read full briefing →When Courts and Bureaucracy Move at Once
An Islamabad High Court ruling on Super Tax and a major FBR field-formation restructuring show why practitioners must track both the judicial and administrative sides of tax.
Read full briefing →Pakistan's Tax Landscape in 2026
A review of FY26 collections, the Finance Act 2026 reforms, key Federal Tax Ombudsman rulings, and the structural challenges that keep Pakistan's tax base narrow.
Read full briefing →FBR This Week: Three Stories, One Question
Three FBR developments in one news cycle, a refund ruling, new case scrutiny committees, and a 52-hour system shutdown, reveal the divided direction of tax administration.
Read full briefing →FBR's IRIS Portal: When the System Fails the Taxpayer
An analysis of the persistent problems plaguing FBR's IRIS portal and the concrete steps needed to build a digital tax system that truly serves taxpayers.
Read full briefing →The New Anatomy of a Tax Dispute: Finance Act 2026 and the Income Tax Ordinance, 2001
How the Finance Act 2026 and the faceless, algorithm-driven framework have reshaped tax disputes, and what taxpayers must prove before a notice ever arrives.
Read full briefing →Analysis of the Finance Act 2026 Adjustments to Corporate Taxes
An institutional breakdown of the recent FBR adjustments impacting corporate tax slabs and sales tax registrations for services in Punjab.
Read full briefing →SECP Directives on Foreign Direct Investment Disclosures
Reviewing the compliance mandates for domestic partnerships receiving capital injections from overseas investors, focusing on disclosure protocols.
Read full briefing →High Court Ruling on Virtual Power of Attorney Formats
A briefing on Lahore High Court guidelines validation for remote legal representation of overseas citizens using biometric consulate verifications.
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