What is the Appellate Tribunal Inland Revenue?

The ATIR is the second and final fact-finding forum in the tax appeal hierarchy. Appeals against orders of the Commissioner (Appeals) lie to the Tribunal under Section 131 of the Income Tax Ordinance 2001 (Section 46, Sales Tax Act 1990). Because the Tribunal is the last forum for facts, the evidentiary record must be complete here — after ATIR, only questions of law go to the High Court.

What is the time limit for an ATIR appeal?

Generally 60 days from communication of the Commissioner (Appeals) order, with the prescribed fee. Limitation should be verified from the order and current law immediately on receipt, and appeals filed well within time.

Can the Tribunal grant stay against recovery?

Yes. The Tribunal can grant stay of recovery of the disputed demand during the appeal, for periods and on conditions provided by law. A stay application is filed with or immediately after the appeal where recovery pressure exists.

What happens after the Tribunal's decision?

On questions of law arising from the Tribunal's order, a reference lies to the High Court under Section 133 of the Income Tax Ordinance 2001 within the prescribed time. Factual findings of the Tribunal are generally final.

Why do taxpayers lose at the Tribunal?

Most commonly: incomplete evidentiary records carried up from earlier stages, grounds not taken below, and reliance on argument without documents. We build the paginated record from the notice stage precisely so the Tribunal file is complete.

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Appellate Tribunal Inland Revenue — Second Tax Appeal

The Appellate Tribunal Inland Revenue (ATIR) is the second appeal — and the last forum for facts — in Pakistan's tax dispute hierarchy. Appeals against Commissioner (Appeals) orders lie under Section 131 of the Income Tax Ordinance 2001 (s.46, Sales Tax Act 1990), generally within 60 days, with the Tribunal empowered to grant stay against recovery. After ATIR, only questions of law reach the High Court — so the record must be complete here. IMAAR's tax lawyers and ICMAP accountants prepare Tribunal appeals as the decisive round they are.

Send CIR(A) Order for Review Call +92 300 0839839

Lahore Tax Bar M-1842
ICMAP CoP F-2092
Attorney of the High Court
16+ Years

Why the Tribunal Round Decides Everything

The Tribunal is the final arbiter of facts — bank reconciliations, source of credits, genuineness of expenses, quantum of estimated sales. The High Court thereafter examines only questions of law under s.133. Practical consequence: a document missing from the Tribunal record is usually gone forever. Our appeals are therefore built as complete, paginated evidence books, with every ground preserved — including grounds the CIR(A) ignored, which we specifically press.

Governing Law

Income Tax Ordinance 2001, s.131 — appeal to the Tribunal; s.132 — disposal; s.133 — reference to High Court on questions of law; Sales Tax Act 1990, s.46; Tribunal's stay powers over recovery during appeal.

How We Run Your ATIR Appeal — 5 Steps

Limitation check, same day. Send the CIR(A) order; we confirm the deadline (generally 60 days) and the appealable findings immediately.
Grounds engineering. Grounds drafted to attack each addition on facts and law — and framed so that, if needed, clean questions of law arise for the High Court.
The record. ICMAP-prepared reconciliations, bank trails and working papers compiled into a paginated book — the difference between assertion and proof.
Stay against recovery. Filed with the appeal where demand pressure exists, so FBR cannot attach accounts mid-appeal.
Hearing & onward strategy. Argued before the Bench; on an adverse point of law, the s.133 reference to the Lahore High Court is prepared within limitation.

Coming from an earlier stage? Start here: FBR Notice Reply · Commissioner (Appeals).

Frequently Asked Questions

What is the ATIR?

The second and final fact-finding forum in the tax appeal hierarchy — appeals from Commissioner (Appeals) orders under s.131 ITO / s.46 STA. After it, only questions of law go to the High Court.

What is the appeal deadline?

Generally 60 days from communication of the CIR(A) order, with the prescribed fee — verify from your order immediately and file well within time.

Can the Tribunal stop FBR recovery?

Yes — stay of the disputed demand during appeal, on statutory periods and conditions. We file the stay application with the appeal where pressure exists.

What comes after the Tribunal?

A reference to the High Court on questions of law under s.133, within the prescribed time. Facts found by the Tribunal are generally final.

Why do taxpayers lose at ATIR?

Incomplete records, grounds not taken below, argument without documents. We build the record from the notice stage so the Tribunal file is complete.

Your Last Chance on the Facts — Prepare It Like One

Send the Commissioner (Appeals) order today for a free review of grounds, limitation and stay options.

WhatsApp the Order Call +92 300 0839839

Speak Directly to Our Advocate

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Abdur Rehman Sandhu, Advocate

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Content reviewed by IMAAR's licensed tax practitioners (Lahore Tax Bar M-1842) and Abdur Rehman Sandhu, Attorney of the High Court. Last reviewed: July 2026. General information, not advice on your specific matter.