A.   Background (BG)

1.   This refers to the related Important TLQCs in trail, blue, italic and double Line (a) 3201 of 14.7.25 about E-Invoicing & Integration adverse action restrained  - ---- interim order (b) 3187 of 5.7 25 about FST Invoice Electronic Integration - Get Free from PRAL & KCV (c) 3186 of 4.7.25 about Request for Extension is ST E-Invoicing & Integration deadline ----

2.   We also refer to several Other TLQC including (a) 3175 of 24.6.25 about FST Invoices Electronic Integration - Further Extension as we predicted & KCV (b) 3096 of 28.4.25 about FST Invoice Integration by all & Major Issues (c) 2976 of 19.12.24 about FBR Integration with Digital Invoicing System

B.   Executive Summary

===================== has filed a writ petition challenging the legality of the FBR’s directive dated ------, which enforces mandatory electronic integration of the taxpayer with PRAL (Pakistan Revenue Automation Ltd.).

• Interim stay has been allowed viz the dispensation sought for, from production of certified copies of documents, is allowed subject to all just and legal exceptions.
• ---- has fixed ------, as the next date of hearing for further proceedings.

C.   Case Reference 

Further to KQU 3479 of ---------, being an important matter, we would inform you about ----------------------- (Attachment 3218.1) in the ensuing paragraph, with emphasis in bold & Underline for quick reading.

D.   Learned Counsel for Petitioner Submissions

1.    All the SROs, which have been made basis for issuance of the Impugned Order dated ----------, requiring compulsory electronic integration of the petitioner with PRAL, have been issued without any jurisdiction and authority as the mandate to issue such notifications/SROs vests with the Member (Policy) and other alike authorities in terms of section 8 of the FBR Act, 2007.

2.   Without prejudice to the foregoing submissions, these SROs have been issued beyond the sphere of authority and power conferred upon the FBR under the statutory provisions of Sales Tax Act, 1990.

3.   The only power and authority, which vest with FBR was to issue a Sales Tax General Order (STGO).

E.   LHC Deliberation

1.   Points raised need consideration.

2.   Learned counsel for the respondent-FBR action & Interim relief as well as Learned Assistant Attorney General accepts notice and seeks some time to obtain instructions in the matter and to file report and parawise comments, if need be. Allowed. They may do so before -----------.

3. The dispensation sought for, from production of certified copies of documents, is allowed subject to all just and legal exceptions.

F.   Further Details & Services 

Should you require any clarification or explanations in respect of the above or otherwise, or require Income Tax, Federal & Provincial Sales Tax or Withholding Tax Advisory, Statement or Return Filing or Review services, or related accounting matters like the above, please feel free to email Mr Amsal at amsal@kasbati.co with CC to info.kasbati@professional-excellence.com. Your Good self may continue to get other services from your current Tax & Legal Advisors.

Best regards for Here & Hereafter

Asif S Kasbati (FCA, FCMA & LLB)

Managing Partner 

Kasbati & Co (1400+ Tax, Levies, Companies, Economy, Inflation, HR, Banking, Finance, etc

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