Tax Law - FBR Dispute
WON
Overturning Incorrect Tax Assessment Through Tribunal Appeal
Handled By
Muhammad Ahmed Qureshi
Location
Islamabad
Case Background
Client, a manufacturing business, received a tax assessment order from FBR alleging under-declaration of income and disallowing legitimate business expenses. The assessed additional tax liability exceeded Rs. 1.2 crore plus penalties.
Legal Challenge
Challenges: (1) complex factual matrix involving multiple tax years and transactions, (2) FBR's reliance on presumptive assessment methodology, (3) need to reconstruct business records from partial documentation, and (4) tight statutory timelines for appeal.
Legal Strategy
Our approach: (1) conducted detailed forensic review of client's financial records to identify allowable deductions, (2) engaged chartered accountant expert to prepare alternative computation, (3) compiled comparative industry data to support profit margins, and (4) filed comprehensive appeal with legal arguments challenging FBR's methodology under applicable provisions of Income Tax Ordinance 2001.
Final Outcome
Tribunal allowed the appeal in part: (1) reduced additional tax liability by 78%, (2) waived all penalties finding no willful default, (3) directed FBR to issue revised assessment within 30 days. Client saved approximately Rs. 95 lakh in tax and penalties. Matter concluded with no further appeals by FBR.