dated 27.07.2026 to publish Rule 231CB proposed to be inserted in the Income Tax Rules, 2002 regarding Independent Case Scrutiny Committees.

Government ofPakistan Revenue Division Federal Board of Revenue Islamabad, the 27b Ju1y,2026. NOTIFICATION S.R.O. I 165(Iy2026.- In exercise ofthe powers conferred by sub-section (4) of section 133A read with sub-section (1) of section 237 of the Income Tax Ordinance,2001 (XLX of2001), the Federal Board of Revenue is pleased to direct that the following further amendments shall be made in the Income Tax Rules, 2002, the same having been previously published vide Notification No. S.R.O. 1138(l)12026, dated the 21't July,2026, as required under sub-section (3) of the said section 237 , namely'. In the afbresaid rules, after rule 23 I CA, the following new rule shall be inserted, namely: - "23lCB. Independent case scrutiny committees. - (l) This rule shall provide for constitution ol independent case scrutiny committees. (2) Inthis rule, unless there is anlthing repugnant in the subject or context, - (a) "Chairman" means the chairman of the independent case scrutiny Committee; (b) "Commissioner" means as defined in clause (13) of section 2 of the Income Tax Ordinance 2001 (XLIX of 2001); (c) "Committee" means any of the Independent Case Scrutiny Committees constituted under these rules for specified territorial jurisdiction; (d) "petition" means a petition to the Supreme Court under Articlel S5(3) of the Constitution of the Islamic Republic of Pakistan or Federal Constitutional Court arising from any of the tax laws; (e) "reference" means a reference to the High Court under Section 133 ofthe Income Tax Ordinance, 2001 (XLIX of200l); (0 "Secretary" means an officer of Inland Revenue nominated by the Board for the purposes of the Committee; (g) "Serving member of the Committee" means an in service officer of BS 20 or above of Inland Revenue service; and (h) "tax laws" means the Income Tax Ordinance, 2001 (XLIX of 2001), the Customs Act, 1969 (lV of 1969), the Sales Tax Act, 1990, and the Federal Excise Act, 2005 and includes any rules, regulations, or notifications issued thereunder. (3) The Board by an order shall constitute the following committees with powers, functions and jurisdiction, namely: - I

ommittee No. I S. Member trtus ctions and Jurisdiction o. (i) to timely examine each case to file retired Judge of the recommendation I se a reference before the Hi upreme Court. Federal ourt. a petition before the Su onstitutional Court or any f the High Courts of ourt or Federal Constitutional Court; references akistan ii) to review pending to Advocate having not tions periodically of litigation ss than fifteen years hether continuation of revenue: ence ln tax and in the interest mmercial litigation iii) to maintain a database of settl2 ber questions and relevant preced re the High Coutts egal or the Supreme Court of guide future litigation decisions akistan ure consistency, and TSSUE iv) to identifl, systemic uiring legislative or administrati A senior serving or retired ention and recommend appropriale officer of the IRS of BS 2C easures to theBoard.3 or above ember urisdiction: References to be fil Islamabad High Court and CP fore the Supreme Court and Fe nstitutional Cou( by IllO Islama CTO Islamabad. RTO Islamabad. RTO eshawar. RTO Abbottabad DG I lslamabad and its Directorates

Committee No.2 S. Member Status Functions & Jurisdiction No. ( i) to timely examine each case an{ make recommendalion 1rr file of other',{ise a relerence belore the Higli Coun. a petition belore the Supremf A retired Judge of the Court or Federal Constitutional Court: I Chairman (ii) to review pending relerences an{ Supreme Court, Federal petitions periodically to determin! Constitutional Court or any o1 whether continuation of litisation id of the High Courts warranted in the interest of ,aua"nua: Pakistan (iii) to maintain a database oi settled] legal questions and relevant precedents to guide future litigation decisions and ensure consislency: and An Advoc ate having not less than fifteen years' (iv) to identify systemic issues experience in tax and requiringlegislativeor administrative litigation intervention and recommend appropriate1 commercial Member before the High Courts measures to the Board. and/or the Supreme Court of Pakistan Jurisdiction: References to be filed before Lahore High Court and CPLAs before the Supreme Court and Federal A senior serving or retired Constitutional Court by LTO Lahore. officer of the IRS of BS 20 LTO Multan, CTO Lahore, RTOJ or above Member Lahore, RTO Rawalpindi, RTO Gujranwala- RTO Faisalabad, RTO Multan, RTO Bahawalpur. RTO Sialkot. RTO Sargodhaand RTO Sahiwal.

Committee No. 3 S. Member tatus lFrr,"tions & .Iurisdiction No. retired Judge of th hairman 1 Supreme Court, Fe Constitutional Court or any o e High Courts of Pakistan Advocate having not le fifteen years' experi tax and commerci itigation before the Hi2 ember urts and/or the Suprem Court of Pakistan senlor servlng or re officer ofthe IRS ofBS 20 ) ember above

(4) The Secretary as defined in clause (f) of sub-rule (2) of these rules shall provide secretariat and administrative support to the Committee and shall- (a) convene meetings with the approval of the Chairman, circulate the agenda, maintain minutes and records ofproceedings; (b) coordinate with the concemed field formations and obtain records, comments, briefs or any other information required by the Committee; (c) communicate the decisions, recommendations and directions of the Committee to the concemed Commissioners and field formations. and ensure necessary follow-up; (d) maintain the records, database and correspondence ofthe Committee; (e) keep the concemed Commissioners informed regarding the proceedings of cases before the Committee; and (0 perform such other functions as may be assigned by the Committee, the Chairman or the Board. (5) The Committee may co-opt a Chartered Accountant as a non-voting member, where it is deemed necessary. The remuneration of such non-voting member shall be determined by the Board. (6) The Board may, for the purpose of identifuing suitable candidates, constitute a Search Committee, the composition, terms of reference and procedure whereof shall be determined by the Board. (7) Proceedings and records placed before the Committee shall be confidential. Any member having a conflict of interest in a matter shall recuse himself, and such recusal shall be recorded in the minutes. (8) The Secretary shall convene meetings, circulate agenda, maintain minutes and a case register or docket, and communicate recommendations of the Committee to the Commissioner concemed. (9) The Commissioner having jurisdictions for the purposes ol this rule shall, within ten days of receipt ofthe order ofthe ATIR or the High Court, refer a case for pre-filing scrutiny, and the Secretary shall place such cases before the Committee accordingly. (10) The referral shall contain all material particulars including the manner of reference, documents required, revenue implications involved, questions of law requiring interpretation, precedents and settled law, basis of the case. the original decision, the appellate decision, where applicable, and the recommendations of the Commissioner concemed, where applicable, and all relevant documents shall be attached thereto. (11) The Board may for reasons to be recorded in writing transfer the jurisdiction ofa case from one scrutiny committee to another Committee. (12) The Committee may call for any record, document, brief, or clarification from any office or field formation through the Secretary. (13) The Committee shall convene on a daily basis, whether in person or online, and shall prioritize its workload so as to ensure that every recommendation is finalized within a period offifteen days from the date of referral: Provided that where, for reasons to be recorded in writing, a recommendation cannot be finalized within the said period, the Committee may extend the said period to such further time bgt not

beyond limitation period provided in the law as may be necessat'y, subject to intimation to the Board. (14) Where the Committee recommends non-pursuance of any case, the Secretary shall intimate the Commissioner concemed for compliance of such directions. (ls) The quorum for a meeting of the Committees shall be two Members, including the Chairman. (16) The decision shall be taken by majority vote and shall be recorded in writing; any dissenting opinion, ifrecorded by a Member, shall form part of the official record. (17) While making decision of filing of reference or petition, the committee shall keep in view the binding precedents set up by the Supreme Court ofthe Pakistan or Federal Constitution Court, revenue involved in the particular case or other similar cases and interpretation of law and facts of the case. (including (18) Ilthe Committee may not render a decision within the prescribed timeline any extension granted), the case shall be deemed to have been cleared for filing, subject to compliance with all other applicable legal requirements and the Secretary shall record in wdting that the prescribed period has been lapsed and intimate Commissioner concemed accordingly. is expiring within fifteen (19) Where the period of limitation for filing a reference or petition days, or where there is imminent and substantial revenue loss requiring urgent intervention, the matter shall be placed belore the Chairman as an emergency case. approve hling ofreference (20) The Chairman may, after prima facie satisfaction ofurgency, or petition. (19) shall be subject to post-facto (21) Any emergency approval granted under sub-rule review by the full Committee within thirty days of the decision and the cornmittee may decide to withdraw the case if the law and facts so permits. summaries (22) The Committee shall cause to be published, on a yearly basis, anonymized of its recommendations, excluding confidential commercial information and taxpayer identifying details. The published summaries shall include the questions of law considered, the decision criteria applied. and the recommendations made. decisions for reference (23) The Secretary shall maintain a searchable database ofpublished by field formations and to ensure consistency in future decisions. year which may be (24) Chairman and Members shall hold office for a term of one extendable for a further term on continued fitness and satisfactory performance, as may be decided by the Board. his (25) Chairman or any Member may resign from his office at any time by writing under hand addressed to the Board with thirty days notice. (.26) Chairman or any Member may be removed by the Board on grounds of conflict of interest, misconduct, breach of confidentiality, or inability to perform functions, after providing an opportunity of being heard.

and Members of each Committee shall be paid lees as follows:-' (27) The Chairman a monthly fee oftwelve hundred thousand rupees, and (a) the Chairman shall be entitled to in addition thereto, a per case fee of twenty-five thousand rupees in respect of which a a recommendation is made, whether in favour of filing or otherwise, subject to maximum of twenty cases Per month; a monthly fee of eight hundred thousand (b) the Advocate Member shall be entitled to rupees, and in addition thereto, a per case fee of twelve thousand and five hundred rupees in respect of which a recommendation is made, whether in favour of filing or otherwise, subject to a maximum of twenty case! per month; Revenue is nominated as a Committee member, he shall (c) where a retired officer of Inland be entitled to a monthly fee ofeight hundred thousand rupees, and in addition thereto, a which a per case fee of twelve thousand and five hundred rupees in respect of a recommendation is made, whether in favour of filing or otherwise, subject to maximum of twentY cases Per month; be determined by the Board; and (d) the remuneration ofthe support staffshatl and the Secretary shall not be entitled to additional (e) The serving Board Member remuneration; except as provided in rules related to reward and honorarium. TA"/DA for official travel as admissible to a grade 21 (28) All Members shall be entitled to officer of the Federal Govemment. an annual report to the Board by the 3l st of March each (2g) The Committee shatl submit year, covering the preceding financial year and shall consist of' - and recommendations made (to file, not to file, or to (a) the number of cases reviewed, withdraw); and petitions (decided in favour, against' (b) the outcome of filed references pending, or settled); favorable or unfavorable (c) analysis of success rate and factors contributing to outcomes; (d) revenue implications of decisions made pursuant to Committee recommendations; (e) identification of recurring legal issues and systemic problems requiring legislative or administrative intervention: and enhancing the (f) recommendations for improving litigation management and effectiveness of the Committee. (30) The annual report shall be placed before the Board for consideration and appropriate action.". I F.No. I tl tR&S/10261 (Muhammad Amin Qureshi) Sccretary (Rules & SROs)