KARACHI: The Karachi Tax Bar Association (KTBA) has formally expressed strong objections to the sudden abolition of manual filing of income tax returns for the Tax Year 2025. In a letter addressed to Rashid Saheb, the KTBA highlights concerns regarding the belated decision made through SRO 2070(I)/2025 dated November 3, 2025, followed by Circular No. 02 of 2025-26 dated November 5, 2025. These directives mandate compulsory electronic filing for all individuals starting Tax Year 2025.
According to the KTBA, this move contradicts the official position previously acknowledged by the Department before the Federal Tax Ombudsman in complaints 22729/KHI/IT/2025 and 25084/GWL/IT/2025. The association argues that Rule 73(2DD) of the Income Tax Rules, 2002, explicitly permits manual filing for individuals in Tax Year 2025, subject to certain exceptions. Abolishing this option retrospectively undermines legal consistency and taxpayer rights.
Key Objections Raised by KTBA:
1. Contradiction to Official Position: The SRO and subsequent circular conflict with the Department's stance before the Federal Tax Ombudsman.
2. Prospective Application of Law: The SRO lacks clarity on its effective date. Based on Section 23 of the General Clauses Act, 1897, such amendments should apply prospectively from Tax Year 2026 onwards.
3. Violation of Vested Rights: Rule 73(2DD) grants taxpayers the right to file manually for Tax Year 2025. Retrospective removal of this right is untenable without clear legislative intent.
The KTBA warns that enforcing compulsory electronic filing for Tax Year 2025 could cause confusion, hardship, and uncertainty among taxpayers entitled to manual filing. The association is confident that the Federal Board of Revenue (FBR) will consider their objections and defer the abolition of manual filing for Tax Year 2025.
This development underscores ongoing debates between tax authorities and professional bodies in Pakistan over procedural adjustments in tax filing mechanisms. The outcome of KTBA's objections may impact tax compliance strategies for individuals in Pakistan.
