A. BACKGROUND: (1) TLQC 3758 of 28.9.26 about Parliamentarian Tax & Wealth Directories for TYs 2020 to 2025 release demanded by PAFO & Media coverage - in trail, blue, italic and double Line (2) Other relevant TLQCs are in para VII.

B. EXECUTIVE SUMMARY

1. Owing to matters in Background read with para VII (as we are constantly covering important matters in our Commentaries) and over 10 reasons (as partly covered Business Recorder of 28.9.26 as well Attachment 3760.1) in ensuring paragraphs, based on our over 34 years’ core tax experience, we are of the considered view that extension atleast till 31.10.26 is inevitable (or in worst scenario upto 15.10.26) via Circular, ISA.

2. We appreciate PTBA, KTBA, LTBA & Other bars in highlighting Glitches in Return Forms & IRIS issues, FBR & PRAL cooperation was then led to the resolution of several matters, however, certain matters are still outstanding to be reported.

3. Hence, Professionals may work hard (like our 786 Tax team too), however, no need to feel pressure but take care of yours & team Health.  

(I)   RETURN FILING DEADLINE

As per section 118, (a) Individuals & Associations of Persons having year from 1.7.25 to 30.6.26 and (b) Companies having year-end between 1.1.25 to 31.12.25 are required to file TY 2026 Return on or before 30.9.26.

(II)   EXPECTED EXTENSION REASONS

Based on over 34 years’ core tax experience, we understand that General Extension is likely to be allowed at least till 31 October 2025 (or 15 days Specific Extension in worst scenario) owing to the following 10+ reasons; however, refer to Timely Filing and Extensions Paras as well: 

1. FBR missed Draft return SRO deadline (other than Traders)

FBR missed deadlines for issuing more detailed draft 4 returns forms vide SRO 835 of May 7, 2026 for Individuals, SME, AOPs and Companies for Tax Year 2026 (TLQC 3511 of 9.5.26 refers) consist 147 pages and sought feedback from taxpayers. Considering Rule 34A(2), the draft was late by over 7 months. TY 2025 return was simpler and its draft was issued vide  SRO 1212 (TLQC3195 of 10.7.25 refers) of 89 pages only.

2. FBR missed Final Return SRO deadline (other than Traders)

The 4 final returns Final forms were issued vide SRO 1495 dated September 2, 2026 (TLQC3714 of 7.9.26 refers) consisting of 111 pages. As per Rule 34A, it was required to be issued by 31.1.26. Hence, hence delayed by over 7 months.

3. Delayed Small Shopkeepers / Traders return draft form

Regarding Small Shopkeeper and Returns, the Karachi based Senior Tax Expert Kasbati stated SRO 1109 dated 14.7.26 was issued as Draft SRO Special Procedure for Small Shopkeepers / Small Retailers (TLQC 3620 of 16.7.26 refers) (covering Special procedure Applicability, Exclusions, Registration, Voluntary Nature, Tax Rate, Minimum Tax under this Special Procedure, Audit, Return Filing, Withholding & Other Provisions and Draft form was also delayed.

4. Small Traders Final Form are awaited

The final return of small traders is still awaited. We understand that the return is incomplete and PTBA is in touch with FBR and PRAL to complete the same.

5. FBR Policy & IRIS Issues

5.1 Delayed SRO head to delayed return on IRIS

5.2 IRIS was either not working at all OR very slow for certain days in September 2026.

5.3 IRIS is likely to be working very slowly from 29.9.26 & 30.9.26 as the Taxpayers face this issue almost every year; as we understand that IT speed system issues are still not fully resolved.

6. Rain, Electricity and Internet issues

6.1 The Torrential rains in certain areas disrupted office work, electricity failure, no or slowed internet speed and caused severe cash flow issues, despite government claims of economic improvement.

6.2 Internet in Islamabad, Pindi & same parts internet was suspended on 26 & 27.9.26 

7. Other Deadlines

Similar deadlines add pressure on the system, such as the annual sales tax return deadline on 30.9.26, and the e-invoicing in increasing.

8. Parliamentarian Directories

PAFO has Written letter to Finance Minister to direct FBR to publish Parliamentarian Directory for TYs 2020 to 2025 (TLQC 3785 of 28.9.26 in trail refers) and even now can be used from TY 2026 to show that Govt not only ask Public to file returns but also ensure that the Parliamentarians become example.

9. Tax Years 2023 VS TY 2024 & TY 2025 and Issue as to TY 2025 cum TY 2026

ATL at about 4 Million, which we trust seems to be system error, as it would has TY 2025 (as well as TY 2026 as our 786Tax Team checked) return filers, hence, it should be more than 9 million.

10. Return expected Quantity

10.1 Broadening of Tax Base as per Advisor to FM: Advisor to Finance Minister Mr Khurram Shahzad speech at ICAP Post Budget Conference 2026 wherein he stated there will be 3.5 million into tax net, however, the Scheme has not been successful so far with only about 1,000 new filers therefrom so far. It was reported few days ago only 2 new person have filed returns from the said category. 

10.2 Earlier Govt: Former FM Mr Shaukat Tarin had stated there were 15 million non-filers, while former special assistant to the PM Dr Waqar Masood had mentioned 7.4 million.

10.3 Expected Extension Taxpayer & ATL as per KC: A minimum of 11.5 million returns should be filed for TYs 2026, compared with 8.5 million taxpayers on the ATL as of 1.8.26 plus 3.5 New Shopkeepers as per Govt.

11. Return filed Quantity

11.1 As the total number of returns filed till stood at around 3 million (other than Traders) out of expected 8 million, while traders at about 1,000 out of expected 3.5 million. BR has in stated 8 million as expected set non filers instead of 11.5 Million.

11.2 The current filing number of around 3 million is far less than the expected non-traders returns of 8 million or Traders would have likely filed 1,000 as few days ago only about 350 had filed) though Govt is expecting 3.5 million. KC suggest and evident from BR (with underfund same) that NTN holder should be given an opportunity to file their returns during an extended period of atleast one month, which the FBR may announce on 30 September morning to avoid millions of extension applications.

12. Non-Compliance issues

12.1 Based on our over 34 years’ pure tax experience, we anticipate less than 30% would have been filed, even if keep the bench mark of 8.1 million of TY 2024 plus 3.5M Trader means 11.5 M in all. In line of its proper disclosure and declaration, the remaining time is not sufficient for the tax filers to arrange their payment of tax and file their proper and correct declarations even though 90% of the demand has already been paid by the tax filers by way of withholding taxes and advance taxes.

12.2 Considering the aforesaid circumstances, we strongly acknowledge the contributions of the tax filers whose names are appearing in the latest ATL or earlier ATL by giving them relief if by any chance they are unable to file their tax returns before the extended deadline of filing i.e. 30.9.26.

12.4 We are of the view the aforesaid granting one month extension will enhance the tax filers confidence on the Government, reduce the trust deficit and they will reiterate their commitment to Pakistan by paying their due shares of taxes, even at the cost of their depleting financial health.

13 Extension requests from various quarters

13.1 Owing to several reasons, PTBA, KTBA, LTBA & other Bar have applied for extension of one month.

13.2 Moreover, certain Trade bodies have also already applied for similar extension.

13.3 We expect more applications from several Bars, Trade & Industry Bodies too shortly.

14. Ease of Doing Busing

Extending the deadline to 31.10.26, for those unable to file by 30.9.26. This, he said, would enhance taxpayers’ confidence in the government and reduce the trust deficit.

III. TIMELY FILING

Having stated above, in order to avoid any Default Surcharge, Penalty & Notices, we recommend you submit your Income Tax Return as soon as possible by 30.9.25, however, without taking stress.

IV. EXTENSION APPLICATION

If your Goodself could not file a return by 30.9.25, we recommend submitting an online extension application with applicable reason from this TLQC and keeping in view Section 119 which is reproduced below for ready reference:

119. Extension of time for furnishing returns and other documents.— (1)  A person required to furnish —

(a) a return of income under section 114 or 117;

(b) & (c) Omitted

(d) a wealth statement under section 116, may apply, in writing, to the Commissioner for an extension of time to furnish the return, or statement, as the case may be.

(2) An application under sub-section (1) shall be made by the due date for furnishing the return of income, statement to which the application relates.

(3) Where an application has been made under sub-section (1) and the Commissioner is satisfied that the applicant is unable to furnish the return of income, statement to which the application relates by the due date because of —

(a) absence from Pakistan; 

(b) sickness or other misadventure; or

(c) any other reasonable cause, the Commissioner may, by order, in writing, grant the applicant an extension of time for furnishing the return, or statement, as the case may be.

(4) An extension of time under sub-section (3) should not exceed fifteen days from the due date for furnishing the return of income, employer’s certificate, or statement, as the case may be, unless there are exceptional circumstances justifying a longer extension of time:

Provided that where the Commissioner has not granted extension for furnishing return under sub-section (3) or sub-section (4), the Chief Commissioner may on an application made by the taxpayer for extension or further extension, as the case may be, grant extension or further extension for a period not exceeding fifteen days unless there are exceptional circumstances justifying a longer extension of time.

(5) Omitted

(6) An extension of time granted under sub-section (3) shall not, for the purpose of charge of default surcharge under sub-section (1) of section 205, change the due date for payment of income tax under section 137.

V. SHARING THIS EMAIL TO FBR & MEDIA

We are concurrently sharing this email with FBR officials to consider the same and grant general extension in order to avoid non-compliance at large by over 7M extension letters and approval thereof. 

For the public benefits at large, we are sharing this comprehensive email to Print & Electronic Media Representative.

VI. CONCLUDING REMARKS

Knowing that Great Tax Consultants are working hard (including our team is working till late night for several days, even working on Sunday 27.9.26 too (when IRIS was down  / Slow) and has plans in the next few days) include our another office 786 Tax, however, we recommend that no need to feel pressure but take care of yours, thei