LHC Rules IRIS Uploads Do Not Constitute Legal Service Under Tax Law

LAHORE: The Lahore High Court (LHC) has ruled that simply uploading an appellate order to the Federal Board of Revenue’s (FBR) Inland Revenue Information System (IRIS) does not fulfill the requirements for valid service under the Income Tax Ordinance, 2001. This decision came from a division bench comprising Justice Mirza Viqas Rauf and Justice Anwaar Hussain, who evaluated three related reference applications led by taxpayer Tahir Mehmood.

The applications contested three orders from the Appellate Tribunal Inland Revenue, which had dismissed the taxpayers’ appeals as time-barred, arguing that the mere act of uploading the orders to IRIS constituted sufficient service. In one instance, a taxpayer cited Covid-19 and quarantine restrictions following international travel as barriers to accessing the portal. In the other two cases, taxpayers reported learning of the Commissioner (Appeals)’ orders only after receiving recovery notices in April 2026, well after the orders were issued.

Justice Anwaar Hussain, who authored the judgment, emphasized that Section 218(1)(d) of the ordinance stipulates that electronic service must be conducted in a prescribed manner. This ruling clarifies the legal standing of electronic notifications and underscores the necessity for compliance with established procedures.

This landmark decision has significant implications for taxpayers, as it reinforces the requirement for proper notification processes, potentially affecting numerous pending cases. Taxpayers may now seek to challenge decisions made under similar circumstances. Legal experts anticipate that this ruling will prompt the FBR to review its notification practices to ensure compliance with the law.