A. Background: DNVC of 9.3.26 about FTO orders (as reported Profit Pakistan today’ of 9.3.26) captained on FBR to provide taxpayers access to assessment records (Attachment 3600.1)

B. Updated Commentary

Further to KQU 3971 of 30.6.26, being an important matter, we would inform you about FTO defies own order? (Attachment 3600.2 - FTO order is not on website till about an hour before release of this TLQC) in ensuing paragraph, with emphasis ours in bold & Underline, Italic for quick reading.

2. Till FBR representation is decided by the President, the FTO is not following its own order, which had affirmed the fundamental right of taxpayers to obtain copies of their tax documents and order sheets.

3. The FBR has challenged the said order of the FTO, before the President.

4. FTO order stated, “the AR’s emphasis, during hearing, was on decision of this Forum in C. No. C. No. 29003/ISB/ST/2025 but according to the record, the same has been challenged before the Hon’ble President of Pakistan. Therefore, the same has not attained finality so far. The above referred complaint as relied upon by the AR, was decided by FTO on 2.3.26 as under:

5. “Conclusively, the Complainant has fundamental right duly supported by STA, 1990 and Constitutional provisions of Pakistan to obtain copies of sales tax documents inclusive of order sheets pertaining to details of proceedings of the case with which the Complainant remained engaged with the Deptt”, FTO order added.

6. In a recently issued order the taxpayer placed heavy reliance on earlier Order passed by FTO, in which the FTO had previously ruled in unambiguous terms that taxpayers possess a constitutionally and legally grounded right to access records pertaining to their proceedings before the FBR. The Forum had held in that order that a complainant holds a fundamental right, supported by law and the Constitutional provisions of Pakistan, to obtain copies of tax documents including order sheets detailing the proceedings of cases in which the complainant had been engaged with the Department.

6. The FTO declined to treat the earlier ruling as a binding or persuasive precedent, noting on the record that earlier order had been challenged before the President of Pakistan and had therefore not attained legal finality.

7. The development raises pointed questions about the practical enforceability of taxpayer rights within Pakistan’s administrative justice framework.

8. If an ombudsman’s own prior findings on fundamental rights can be neutralized by a challenge that has not yet been decided, taxpayers are left in legal limbo precisely when procedural clarity matters most, experts claimed.

9. The original order had been considered a significant affirmation of citizens’ rights under Pakistan’s constitutional framework, recognizing the right to information regarding one’s own tax proceedings as not merely administrative courtesy, but a matter of legal entitlement. The order had been invoked in subsequent cases as an authoritative statement of taxpayer rights in dealings with the revenue department.

10. The matter now draws attention to the broader question of how pending challenges to FTO orders interact with their operational precedential value and whether taxpayers who rely on such orders in good faith are left exposed when those orders are contested upward through the administrative hierarchy.

C. Further relevant TLQCs

(a) 3352 of 18.11.25 about IHC directive violated as Tax Dept denied access to ‘order sheet entries’

(b) 3021 of 20.1.25 about Taxpayer has Right to get his Minute / Order Sheet – IHC

D. Kasbati & Co Views & Recommendations

Keeping in the view undesigned over 33 years' Core Tax experience and IHC two orders covered in para C, we are of considered view that Order sheet is the Right of the relevant Taxpayer and tax Bars should strongly oppose to the latest FTO order.

All the Associations are recommended to take up this matter with their Tax Committees and Tax Consultants to oppose the latest FTO order.

Hence, we are sharing this to TLQC to PTBA, LTBA & KTBA relevant officials too, in order to take urgent action and take the matter to respective High Courts.

E. Multiplication: Although all the Commentaries are to the extent of the Subscribed IDs only, however, your Goodself is allowed to share this QC is for the Noble Cause to Impart Knowledge and to protect Taxpayer Rights.

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 Statement, Advisory, Return Filing or Review services, please feel free to email Mr Amsal at amsal@kasbati.co with CC to info.kasbati@professional-excellence.com, asif.s.kasbati@professional-excellence.com.

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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