Rule 231CB Framework Introduced

The Federal Board of Revenue has issued S.R.O. 1165(I)/2026 to insert Rule 231CB into the Income Tax Rules, 2002. Promulgated under Section 133A read with Section 237 of the Income Tax Ordinance, 2001, the provision establishes three Independent Case Scrutiny Committees to assess tax disputes independently.

Committee Membership and Mandate

Each panel consists of three members: a retired judge of the Supreme Court, Federal Constitutional Court, or High Court serving as Chairman; an advocate with at least 15 years of tax and commercial litigation experience; and a serving or retired Inland Revenue Service officer of Grade BS-20 or above.

These panels are charged with independently assessing dispute cases and orders issued by Appellate Tribunals before the tax authority initiates references or petitions in High Courts, the Supreme Court, or the Federal Constitutional Court.

Procedural Timelines and Scope

Inland Revenue Service Commissioners are required to forward eligible cases to the designated panel within 10 days of receiving an order from the Appellate Tribunal Inland Revenue or a High Court. Upon receipt, the committee must finalize its recommendations within a 15-day timeframe.

The regulation applies across Pakistan to income taxpayers embroiled in departmental litigation, Commissioners of Inland Revenue, and tax law practitioners handling federal tax matters.