ISLAMABAD: The Federal Board of Revenue’s (FBR) field formations began issuing recovery notices to taxpayers on Thursday for the payment of outstanding tax demands for Super Tax, amounting to over Rs200 billion.
It is reliably learnt that the Large Taxpayers’ Offices (LTOs), Medium Taxpayers’ Offices, and Corporate Tax Offices are computing the amount of super tax to be paid by the potential taxpayers falling within the jurisdiction of respective tax offices.
According to an estimate, thousands of taxpayers are required to pay Super Tax following the judgment of the Federal Constitutional Court.
In some cases, notices were served on Thursday, while computations of tax continued in the field formations throughout the day on Thursday. In other cases, notices were served under section 138(1) of the Income Tax Ordinance 2001 to the taxpayers for tax year 2023.
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The FBR’s field offices have warned the taxpayers that non-compliance would result in attachment and sale of movable and immovable properties, appointment of a receiver for the management of movable or immovable property, and arrest and detention in person for a period not exceeding six months, one of the recovery notices of Super Tax issued by the field formation said.
Another notice said that the non-payment of Super Tax may be due to one of the following reasons: (i) the demanded tax amount deleted in appeal; (ii) any pending application for rectification, and (iii); the demand has already been paid or adjusted from a refund. If neither of the said conditions applies to the taxpayer’s case, the taxpayer is hereby requested to discharge the said liability on or before the due date.
Failure to comply may result in the recovery of the said demand through coercive measures, including under section 140 of the Income Tax Ordinance 2001.
In respect of section 4B, the Court dismissed the taxpayers’ appeals, and declared the provision to be constitutionally valid, holding that the levy imposed thereunder constitutes a valid tax under the Constitution.
In case of section 4C, the Court dismissed the appeals filed by the taxpayers and allowed the appeals filed by the tax department and the Federation, holding that section 4C is constitutionally valid as enacted and that its application to the relevant tax year is not barred on account of retrospectivity.
The Court held that section 4C super tax is applicable at the rate of 10 percent for the tax year 2022 on the 15 sectors identified in the First Proviso to Division IIB of the Ordinance, where the income of such persons exceeded Rs300 million during the relevant tax year.
In relation to oil exploration and petroleum companies operating under Petroleum Policies and Concession Agreements governed by the Fifth Schedule to the Ordinance, the Court directed the concerned Commissioners to issue fresh notices and to apply section 4C strictly in accordance with law and the specific terms and conditions of each agreement, while ensuring that any agreed caps contained therein are not exceeded.
Copyright Business Recorder, 2026
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