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Properties' Fair Market Value Compulsory Disclosure in IT TY 2025 Return

17 July 2025

Author: Asif S Kasbati (FCA, FCMA & LLB)

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From: Asif Siddiq Kasbati <asif.s.kasbati@professional-excellence.com>
Date: Tue, Jul 15, 2025 at 6:54 PM
Subject: TLQC3203= Properties' Fair Market Value Compulsory Disclosure in IT TY 2025 Return
 
530+ Taxes & Levies Quick Commentary - TLQC 3203

 

A.   Background (BG)

 

1.   This refers to the related Important TLQCs in trail, blue, italic and double Line (a) 3202 of 15.7.25 about Updated Tax Rates for Property Buyers & Sellers (b) 3197 of 12.7.25 about SRO 1213 Draft Simplified Electronic ITR Salaried Individual, etc (not having business income) Form for TY 2025

 

2.   We also refer to several Other TLQC including (a) 3196 of 12.7.25 about Budget 2025-26: Yousuf Adil Comments on Finance Act (b) 3194 of 10.7.25 about Budget 2025-26: KPMG Comments on Finance Act (c) 3182 of 28.6.25 about Budget 2025-26: AFF Comments on Finance Act

 

B.   Updated Commentary

 

Further to KQU 3463 of 15.7.25, being an important matter, we would inform you about ------------------- (Attachment 3203.1) ------------------------- (Attachment 3203.2) in the ensuing paragraph, with emphasis in bold & Underline for quick reading.

 

2.   The FBR has made it mandatory for income tax return filers for the tax year 2025 to declare the fair market value of immovable properties during purchase, sale, or if already owned, starting July 1.7 25. As per a draft return form issued through SRO 1213(I)/2025 dated July 7.7.25 (TLQC3197 of 12.7.25 refers), a new section has been added requiring taxpayers to manually re-enter the fair market valuation and other details of each property, even if the system has already auto-filled the information based on past declarations.

 

3.   Taxpayers must ensure all their immovable properties are declared with their fair market value. They must also make sure that the previously declared property details are re-entered manually. The new requirement applies to all individuals who file tax returns and own immovable assets, including plots, houses, apartments, and commercial units. FBR has also warned that incomplete property information may lead to an invalid return.

 

4.   Mr Muhammad Ahsan Malik, a real estate expert, expressed concerns about the new provision, describing it as unnecessary. He noted that taxpayers are already required to declare the purchase value of properties in their income tax returns, and adding a new declaration for the fair market value could lead to confusion. He questioned the FBR’s lack of trust in taxpayers, pointing out that the declaration process already includes the property’s value.

 

5.   Mr Malik also criticized the treatment of fresh filers, particularly in relation to the taxation on property transactions. He stated that fresh filers should not be treated as late filers and face higher tax rates on the sale and purchase of immovable properties.

 

6.   Additionally, Mr Malik raised concerns about overseas Pakistanis, who have not received any tax relief in the 2025-26 budget. He pointed out that overseas Pakistanis still need to obtain approval from the concerned Commissioner Inland Revenue to verify their non-resident status for tax purposes. Instead of providing relief, the government has added another layer of bureaucracy, requiring a certificate from the Commissioner.

 

7.   Mr Malik further alleged that obtaining the necessary certificate from the Commissioner Inland Revenue would be difficult for overseas Pakistanis without paying a bribe.

 

C.   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.comYour Goodself 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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