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 ctions and Jurisdictiontrtus o. retired Judge of the upreme Court. Federal onstitutional Court or any f the High Courts of akistan I ber Advocate having not ss than fifteen years re the High Coutts or the Supreme Court of akistan mmercial tax and litigation ence ln (i) to timely examine each case recommendation to file se a reference before the Hi ourt. a petition before the Su ourt or Federal Constitutional Court; ii) to review pending references tions periodically to hether continuation of litigation in the interest of revenue: iii) to maintain a database of settl egal questions and relevant preced guide future litigation decisions ure consistency, and iv) to identifl, systemic uiring legislative or administrati ention and recommend appropriale easures to theBoard. 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 TSSUE ember 2 S. Member 2 3 A senior serving or retired officer of the IRS of BS 2C or above

Committee No.2 S. No. Member Status Functions & Jurisdiction I A retired Judge of the Supreme Court, Federal Constitutional Court or any of the High Courts o1 Pakistan Chairman ( 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 Court or Federal Constitutional Court: (ii) to review pending relerences an{ petitions periodically to determin! whether continuation of litisation id warranted in the interest of ,aua"nua: (iii) to maintain a database oi settled] legal questions and relevant precedents to guide future litigation decisions and ensure consislency: and (iv) to identify systemic issues requiringlegislativeor administrative intervention and recommend appropriate measures to the Board. Jurisdiction: References to be filed before Lahore High Court and CPLAs before the Supreme Court and Federal Constitutional Court by LTO Lahore. LTO Multan, CTO Lahore, RTO Lahore, RTO Rawalpindi, RTO Gujranwala- RTO Faisalabad, RTO Multan, RTO Bahawalpur. RTO Sialkot. RTO Sargodhaand RTO Sahiwal. 1 An Advoc ate having not less than fifteen years' experience in tax and commercial litigation before the High Courts and/or the Supreme Court of Pakistan Member J A senior serving or retired officer of the IRS of BS 20 or above Member 3

Committee No. 3 S. No. Member tatus 1 retired Judge of thhairman Supreme Court, Fe Constitutional Court or any o e High Courts of Pakistan 2 Advocate having not le fifteen years' experi tax and commerci itigation before the Hi ember urts and/or the Suprem Court of Pakistan ) senlor servlng or re ember lFrr,"tions & .Iurisdiction officer ofthe IRS ofBS 20 above 4

(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) Chairman. The quorum for a meeting of the Committees shall be two Members, including the (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. (18) Ilthe Committee may not render a decision within the prescribed timeline (including 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. (19) Where the period of limitation for filing a reference or petition is expiring within fifteen 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. (20) The Chairman may, after prima facie satisfaction ofurgency, approve hling ofreference or petition. (21) Any emergency approval granted under sub-rule (19) shall be subject to post-facto 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. (24) Chairman and Members shall hold office for a term of one year which may be extendable for a further term on continued fitness and satisfactory performance, as may be decided by the Board. (25) Chairman or any Member may resign from his office at any time by writing under his 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. 6 (22) The Committee shall cause to be published, on a yearly basis, anonymized summaries 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. (23) The Secretary shall maintain a searchable database ofpublished decisions for reference by field formations and to ensure consistency in future decisions.

' (27) The Chairman and Members of each Committee shall be paid lees as follows:- (a) the Chairman shall be entitled to a monthly fee oftwelve hundred thousand rupees, and in addition thereto, a per case fee of twenty-five thousand rupees in respect of which a recommendation is made, whether in favour of filing or otherwise, subject to a maximum of twenty cases Per month; (b) the Advocate Member shall be entitled to a monthly fee of eight hundred thousand 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; (c) where a retired officer of Inland Revenue is nominated as a Committee member, he shall be entitled to a monthly fee ofeight hundred thousand 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 cases Per month; (d) the remuneration ofthe support staffshatl be determined by the Board; and (e) The serving Board Member and the Secretary shall not be entitled to additional remuneration; except as provided in rules related to reward and honorarium. (28) All Members shall be entitled to TA"/DA for official travel as admissible to a grade 21 officer of the Federal Govemment. (2g) The Committee shatl submit an annual report to the Board by the 3l st of March each year, covering the preceding financial year and shall consist of' - (a) the number of cases reviewed, and recommendations made (to file, not to file, or to withdraw); (b) the outcome of filed references and petitions (decided in favour, against' pending, or settled); (c) analysis of success rate and factors contributing to favorable or unfavorable outcomes; revenue implications of decisions made pursuant to Committee recommendations; identification of recurring legal issues and systemic problems requiring legislative or administrative intervention: and recommendations for improving litigation management and enhancing the effectiveness of the Committee. The annual report shall be placed before the Board for consideration and appropriate (d) (e) (f) (30) action.". (Muhammad Amin Qureshi) Sccretary (Rules & SROs) 7 I F.No. I tl tR&S/10261