The Litigation Hierarchy

When a dispute arises with the National Board of Revenue (NBR), businesses must follow a specific legal path:

1. Commissioner (Appeals)

• Time Limit: File within 90 days of the order.
• Pre-deposit: Requires a 10% deposit of the disputed tax.
• Focus: This is the primary stage for factual representation and document submission.

2. The Appellate Tribunal

• Status: A high-level judicial body for deeper legal interpretation.
• Pre-deposit: An additional 10% (20% total) is usually required.

3. Alternative Dispute Resolution (ADR)

A “fast-track” option involving a Facilitator to reach a mutual settlement. Once agreed, the decision is binding and cannot be appealed further.

4. High Court & Supreme Court

Reserved for “points of law” or cases where fundamental rights are violated through Writ Petitions or Reference Applications.

Proactive Compliance Tips

• VDS Compliance: Properly handle VAT Deduction at Source to avoid triggers.
• Mushak 6.3: Always issue tax invoices; missing paperwork is the leading cause of lost cases.
• iVAS Records: Maintain clean digital records in the Integrated VAT Management System.