ISLAMABAD: The decision of the Alternative Dispute Resolution (ADR) committees would be binding on wholly state-owned enterprises (SOEs) by the federal government under “The Income Tax Ordinance (Third Amendment) Bill, 2026”.
The National Assembly Thursday passed “The Income Tax Ordinance (Third Amendment) Bill, 2026” to strengthen the Alternative Dispute Resolution (ADR) mechanism for resolving tax disputes.
Provided that in case of SOE which is, directly or indirectly, wholly owned by the federal government, the decision of the committee shall be final and binding on the Commissioner and the SOE, the new law said.
READ MORE: NA passes Income Tax Ord (Third Amend) Bill: ADR mechanism gets a boost
Provided that in case of SOE, except an SoE, which is directly or indirectly, wholly owned by’ the Federal Government, either party may prefer an appeal to the Federal constitutional court or the Supreme Court as the case may be, within a period of 60 days against a decision of the committee or where on decision is made, upon receiving order of the dissolution of the committee.
Major changes to ADRC regime included that the ADRC decision is binding for wholly owned SOEs and for other SOEs, right of appeal against ADRC decision to the federal constitutional court or the Supreme Court.
ADRC Members’ remuneration – 50percent of the Chairperson and 100percent taxpayer nominee to be borne by the taxpayer, and FBR nominee (Chief Commissioner) shall be from a ‘different’ field formation (LTO/RTO).
According to the “The Income Tax Ordinance (Third Amendment) Bill, 2026”, where the aggrieved person is a state-owned enterprise, ‘SOE’, the limit of tax liability mentioned shall not apply, and it shall be mandatory for such aggrieved SoE to apply to the Board for the appointment of a committee for the resolution of any dispute under this section.
Provided further that no suit, prosecution, or other legal proceedings shall lie against the SOD or the Committee in relation to the dispute resolved under this section.
Copyright Business Recorder, 2026