1.

abstract 2
2. introduction 3
3. definition of adr 4
4. adr a tool to lower the burden of Nepal’s courts 4
5. salient features of the adr 6
6. limitations of the adr 7
7. what cases are suitable for adr in Nepal? 8
8. overview of the adr tax framework in pakistan 9
I. introduction 9
II. dispute settlement process 10
III. what is adr mechanism in pakistan? 12
9. overview of the adr tax framework in Bangladesh 14
I. introduction 14
II. dispute settlement process 15
III. what is adr mechanism in Bangladesh? 16
10. overview of the adr tax framework in India 18
I. introduction 18
II. dispute settlement process 19
III. what is adr mechanism in India? 20
11. selection of the model country 22

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 12. study of the model country 24
I. legal basis of the adr institution 24
II. organizational structure and appointment system of key persons 26
III. mandate 29
IV. operational methodology 30
a) How to apply for ADR? 30
b) Prescribed Fee 31

c) Time Limit 31
d) Notice of the Proceedings 31
e) Proceedings of the ADR 31
f) Conclusion/Recommendations of the ADR 33
V. past performance 33
VI. Abbreviations: 43

VII. Reference: 44

Table of Contents
1. ABBREVIATIONS......................................................................................................................................... 2
2. BACKGROUND............................................................................................................................................ 3
3. TAXPAYERS CONFIDENCE AND TAX OMBUDSMAN......................................................................................4
SALIENT FEATURES OF THE OMBUDSMAN STRUCTURE........................................................................................................... 6
RISKS ASSOCIATED WITH TAX OMBUDSMAN.................................................................................................................... 6
4. JURISDICTION OF TAX OMBUDSMAN.......................................................................................................... 7
5. OVERVIEW OF THE TAX OMBUDSMAN FRAMEWORK IN PAKISTAN....................................................8
INTRODUCTION............................................................................................................................................................ 8
LEGAL BASIS OF THE FEDERAL TAX OMBUDSMAN............................................................................................................. 10

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 ORGANIZATIONAL STRUCTURE AND APPOINTMENT SYSTEM OF KEY PERSONS.......................................................................... 11
MANDATE................................................................................................................................................................. 11
OPERATIONAL METHODOLOGY..................................................................................................................................... 12
PAST PERFORMANCE................................................................................................................................................... 13
OVERVIEW OF THE ADR TAX FRAMEWORK IN BANGLADESH..............................................................................15
INTRODUCTION.......................................................................................................................................................... 15
DISPUTE SETTLEMENT PROCESS...................................................................................................................................... 15
ADR MECHANISM IN BANGLADESH................................................................................................................................. 16
TAX OMBUDSMAN IN BANGLADESH............................................................................................................................... 18
APPOINTMENT OF TAX OMBUDSMAN............................................................................................................................ 19
ORGANIZATIONAL STRUCTURE AND APPOINTMENT SYSTEM OF KEY PERSONS.......................................................................... 20
RESPONSIBILITIES AND FUNCTIONS OF TAX OMBUDSMAN IN BANGLADESH............................................................................ 20
7. OVERVIEW OF THE ADR FOR RESOLUTION OF TAX DISPUTES IN INDIA.......................................................23
INTRODUCTION.......................................................................................................................................................... 23
DISPUTE SETTLEMENT PROCESS...................................................................................................................................... 24
DISPUTE SETTLEMENT THROUGH INCOME TAX SETTLEMENT COMMISSION.............................................................................. 25
8. SELECTION OF THE MODEL COUNTRY........................................................................................................ 26
9. REFERENCE:.............................................................................................................................................. 27
1. ABBREVIATIONS......................................................................................................................................... 2
2. BACKGROUND....................................................................................................................................... 3
3. TAXPAYERS CONFIDENCE AND TAX OMBUDSMAN......................................................................4
SALIENT FEATURES OF THE OMBUDSMAN STRUCTURE........................................................................................................... 6
RISKS ASSOCIATED WITH TAX OMBUDSMAN.................................................................................................................... 6
4. JURISDICTION OF TAX OMBUDSMAN............................................................................................... 7
5. OVERVIEW OF THE TAX OMBUDSMAN FRAMEWORK IN PAKISTAN........................................8
INTRODUCTION............................................................................................................................................................ 8
LEGAL BASIS OF THE FEDERAL TAX OMBUDSMAN............................................................................................................. 10
ORGANIZATIONAL STRUCTURE AND APPOINTMENT SYSTEM OF KEY PERSONS.......................................................................... 11
MANDATE................................................................................................................................................................. 11
OPERATIONAL METHODOLOGY..................................................................................................................................... 12
PAST PERFORMANCE................................................................................................................................................... 13
.......................................................... OVERVIEW OF THE ADR TAX FRAMEWORK IN BANGLADESH
......................................................................................................................................................................... 15
6....................................................................................................................................................................... 15
INTRODUCTION.......................................................................................................................................................... 15
DISPUTE SETTLEMENT PROCESS...................................................................................................................................... 15
ADR MECHANISM IN BANGLADESH................................................................................................................................. 16
TAX OMBUDSMAN IN BANGLADESH............................................................................................................................... 18
APPOINTMENT OF TAX OMBUDSMAN............................................................................................................................ 19
ORGANIZATIONAL STRUCTURE AND APPOINTMENT SYSTEM OF KEY PERSONS.......................................................................... 20
RESPONSIBILITIES AND FUNCTIONS OF TAX OMBUDSMAN IN BANGLADESH............................................................................ 20
7. OVERVIEW OF THE ADR FOR RESOLUTION OF TAX DISPUTES IN INDIA...............................23

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 INTRODUCTION.......................................................................................................................................................... 23
DISPUTE SETTLEMENT PROCESS...................................................................................................................................... 24
DISPUTE SETTLEMENT THROUGH INCOME TAX SETTLEMENT COMMISSION.............................................................................. 25
8. SELECTION OF THE MODEL COUNTRY.......................................................................................... 26
9. REFERENCE:......................................................................................................................................... 27

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1. ABBREVIATIONS
ADR: Alternate Dispute Resolution

IRD: Inland Revenue Department Nepal

CVT: Capital Value Tax

FBR: Federal Board of Revenue Pakistan

NBR: National Board of Revenue Bangladesh

HCD: High Court Division

AO: Assessing Officer

FED: Federal Excise Duty

DCT: Deputy Commissioner of Taxes

FTOAAR: Authority of Advance Ruling IndiaFederal Tax Ombudsman

ITSC: Income Tax Settlement Commission India

DRP: Dispute Resolution Panel India

ITA: Income Tax Act

ITO: Income Tax Ordinance

ITAT: Income Tax Appellate Tribunal

ADRC: Alternate Dispute Resolution Committee

CITFTO: Federal Tax OmbudsmanCommissioner of Income Tax

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 2. BACKGROUND

Alternative Dispute Resolution has been developed as a mechanism for speedy disposal of
disputes bypassing normal appellate mechanism. In recent past this mechanism has become a
popular device across the world, particularly in the developing countries that are facing challenge
of bringing untaxed money into the tax .net. Nepal is the one of those countries who has endured
a serious revenue implications fallout where traditional appellate mechanism adds to
encumbrances in taxpayer facilitation. Pending appeals with the Revenue Tribunal dealing with
appeals under The Income Tax Act 2001, Value Added Tax Act 1995, Custom Act 2007, and
Excise Act 2001 witnessed a tremendous increasing trend1. The government is now committed to
reform the tax grievance for redressal of their complaints. Nepal needs more effective
instruments efficient devices to alter change the current structure of the tax justice system.

The objective of this study is isstudy aims to highlight the importance and effectiveness of
administrative authoritiesy dealing with ‘The Ttax Ppayerss Ggrievance Rredressal Ssystems.’

To prescribe the framework into the taxation system of Nepal by providing the mechanism in
form of Alternate Dispute Resolution (ADR) for Inland Revenue Department (IRD) to resolve
taxation dispute on speedy and timely manner.s Itit is important to understand that “law” is
nothing more thanbut a social mechanism which is created by the society itself to uphold
maintain social order. Defining “law” as a social mechanism means the law is a changing process
and it often changes when the society so demands. Therefore, to achieve the expected outcome
of ADR, Inland Revenue Authority (IRD) needs to make this mechanism flexible by balancing
the inflows of the revenues against the ease of doing business as the ADR would fail to achieve
its intended objective where the process is being considered as an impermeable barrier.

Alternative Dispute Resolution (ADR) is any mechanism for settlement of a dispute outside the
court.  ADR could be through a body, a person, or a method created by law to resolve civil
disputes, which is an alternative process to litigation. In tax related disputes, office of the Tax
Ombudsman plays a role as an independent authority to resolve tax related disputes being in an
1
PEFA assessment of Government of Nepal, PI-13, has assessed that number of appeals pending before the
revenue tribunal has doubled within two years.

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ADR mode. Ombudsman is recognized as an alternative process to court action where the
taxpayer or the Revenue can resolve the tax disputes without recourse to normal legal channel.
It is not a panacea for all evils, but an alternative route to a speedier and less expensive mode of
settlement of disputes. It is a voluntary and co-operative way out of the impasses. Thus, ADR is
nothing but an alternative method and platform of resolving disputes other than by litigation. As
“law” it is a social institution and a social need, ADR is also a socio-legal system which can be a
basic need for the societies, especially those that are under developed and their taxation system is
on an embryonic stage like Nepal in the near future. Courts in Nepal which are burdened with
litigants may encourage the ADR system, so that the disputes may be easily be settled and can be
less inexpensive to discourage the tax evasion, black money and compromised unauthorized
practices.

3. TAXPAYERS CONFIDENCE AND TAX OMBUDSMAN

To ensure justice, it is imperative that courts provide provisions for appeals and rectification of
errors and wrongdoings. is a must. The concept of Oombudsman was thought as a measure to
raise citizen’s grievance against public authority’s mistakes and misdeeds.

Sweden is the first country which made a constitutional provision in 1809 to introduce the office
of the Ombudsman of Justice (Justitie Ombudsman).

Finland is the second country to introduce the office of Ombudsman in 1919. After the Second
World War, the idea of the Ombudsman institution began to spread rapidly throughout Europe.

Tax collection without harassing the taxpayers and without excessive use of the powers by the
tax collecting apparatusmachinery is a serious issue. In a number of cases theat taxpayers are not
inclined to normal appellate mechanism because of different interpretation of laws, tedious and
prolonged process of litigation, costand cost of litigation beside many others.
ThereforeTherefore, to address this situation a serious platform or mechanism needs to be put in
place which balances the situation and serves both parties to meet their expectations and
interests.

Tax appellate authorities in Nepal takes considerable time and in many cases the taxpayers have
to face the disruption in operation of business, mental stress, fines, penalties and unnecessary

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legal costs as the time consumed in tax disputes before a judgment attains finality. The question
may arise as tothat why the Government of Nepal and Inland Revenue Department need the
mechanism like Tax Ombudsman in the taxation framework. In Nepal, courts are overburdened
with civil, criminal as well asincluding disputed tax matters, the trial life span is inordinately
long and the expenditure is very high. The abnormal delays in disposal of tax disputes and
appeals have become a majorgreat concern from the view point of taxpayer’s
perspectivetaxpayer’s perspective as well as for Inland Revenue Department (IRD) as it is failing
in achieving the optimization of the resources in order to increase the inflows from the taxation.

Tax Ombudsman as alternative dispute resolution system by the IRD may help to change the
practical picture of prolonged tax disputes involving complex interpretation of facts and law. It
may also give more time to courts to decide criminal and civil matters.

Thus, the ADR system provides advantages for both the accused taxpayers and the IRD by
eliminating or reducing indefinite period in Nepal. The rate of recovery in disputed tax matters is
very low in Nepal due to faulty, weak investigation system, lack of proper audit and
investigation system, non-availability of technical investigation officer and lack of modern
investigation tools and equipment’s. As the traditional legal system cannot ensureprovide easy
and timelyspeedy substantive justice on these grounds groundsdue to these reasons, introducing
ADR system in taxation framework and policies of Nepal is the only way that can provide a
strong foothold forground to ensure justice. There is another way to get a swiftspeedy disposal of
disputed tax matters. The way includes increasing resources, both in the form of finance and
manpower, which is very difficult for a country like Nepal which is already on the edge of
economic crisis, low GDP and low Per Capita income. Considerable resources of the state can be
saved by introducing and implementing effective alternative dispute resolution by IRD. It also
provides an alternative way for the court to avoid dealing with cases that can be compounded or
mediated outside courtroom, and enables the court to try only those matters where there is a real
basis for dispute. The alternative dispute resolution offersprovides benefitsadvantages for the
accused taxpayers and IRD. Plea bargaining is one of the most effectiveimportant type of ADR
mechanism which is proposedsuggested for the criminal justice system. The principal benefit of
plea bargaining for the accused is that they can receive a lighter sentence because of admitting
their guilt. Again, the IRD can also save a large sum huge amount of money through alternative
dispute resolution, which otherwise they might spend on advocates.

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The alternative dispute resolution also provides benefits for the prosecutors. The ADR
mechanism relieves the prosecutor from the lengthy long process of legal technicalities, long
arguments and proof. By using alternative dispute resolution in disputed tax matters, both the
prosecution and judges can save time and avoid the uncertainty of the outcomeresult of a
contested trial in the disposition disposing of cases. It is also a distressing experience for the
taxpayer depending on the nature of the case, to spare time in producing evidence in the court to
get the sense of justice. Therefore, the ADR mechanism also provides benefit for the taxpayers in
the sense that an accused is coming out with a guilty verdict at the end of the day, although with
a less severe penalty er punishment but in a short spanperiod of time.

SALIENT FEATURES OF THE OMBUDSMAN STRUCTURE

 Expeditious resolution of the tax disputes.

 Taxpayer’s facilitation by providing a forum where the taxpayer can redress fearlessly of
legal consequences.
 Decreased cost of the tax dispute resolution associated with litigation.
 Enhances and manages cordial relationships between IRD and taxpayers.
 Improve the service delivery to the IRD, Tax consultants and Legal advisors.
 Addresses customer concerns and improves tax compliance.
 Lowering the burden of the judicial system.
 Optimization of the resources.
 Discouraging the tax evasion and unauthorized practices.


RISKS ASSOCIATED WITH TAX OMBUDSMAN

Nepal IRD can immensely benefit from through the introduction of the Tax Ombudsman in the
taxation framework, however, we cannot deny certain associated risks of alternative dispute
resolution which the Government and IRD of the Nepal should take oncater for. ADR has certain
limitations, including the arguments such as, ADR is not a system of precedent, it has lack of
legal expertise, sometimes ADR settlements may not be ultimately determent for ensuring justice

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and finally court action may still be required, a type of ADR, plea bargaining has also some
disadvantages towards the legal procedure and disputed tax matters which can be raised as a
great phenomenon in Nepal. Generally, when accused taxpayer agrees to plea bargain, he also at
the same time waives his some of constitutional rights. These rights include the right not to
incriminate oneself, the right to a court trial, and the right to confront one's accuser.

However, despite the irrefutable facts aboutof the limitation, the benefits provided by the ADR
platform areis usually like to outweigh the cost of limitations. Therefore, to address the economic
situation and adverse performance of the IRDDR, it is recommended to adopt the practices of the
ADR.

4. JURISDICTION OF TAX OMBUDSMAN

There’s no hard and fast rule as to at what stage in a tax dispute ADR should be attempted,
although it’s unlikely to be before all facts have been explored and technical positions
exchanged. However with some cases, fully establishing the facts or technical positions are part
of the complaint which may be determined by the Tax ombudsman as fit to be decided within the
legal frameowork available for ADR. It may also be suitable for cases which have entered a
formal appeal process.

ADR scope may cover a wide range of disputes across different taxes, particularly those which
relate to, assessment of taxes, mal administration, violation of due process of law, non-action of
tax authorities, transfer pricing, inappropriate exercise of jurisdiction by the tax officers. It may
also be functionaluseful in long outstanding disputes where positions on both sides have become
entrenched, with prolonged litigations.

MoreoverOn the other hand, it is also important to understand that ADR is not a substitute of the
existing conventional appellate system available under Inland Revenue Department (IRD) and
taxation policies of the Government of the Nepal. In fact, it works side by side with the existing
appellate system. However, at any stage of the existing appellate system the facility of ADR can
be availed by the aggrieved taxpayer without them having to relinquish foregoing the rights and
incentives available under the current appellate framework and judicial system.

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 5. OVERVIEW OF THE TAX OMBUDSMAN FRAMEWORK IN PAKISTAN
INTRODUCTION
Redressal of public grievances is the linchpincorner stone of judicial systems throughout the
civilized societies. The more speedy the redressal, the more efficient a judicial system is known
to be. For seeking the redressal, the right of appeal has been bestowed upon every individual by
almost all the countries. The respect and regard accorded by the courts to this right toof appeal is
the principalmain element that has inculcated in public, faith and hope keeps public faith and
hope alive in a judicial system.

Alternative Dispute Resolution (ADR) in Pakistan, is not a new concept. The fact of the matter
isIn fact, dispute resolution in Pakistan is, in one form or another, as old as the country itself.
Parties have presented disputes to Panchayat’s or Jirga’s – committee of honorable elders of the
community – to resolve them for years. However, this type of particular dispute resolution has
been most often been associated with marital and other family matters. The focus of this case
study is on ADR related to commercial activities in Pakistan, the major fraction of which relates
to the taxation and disputed tax matters.

Right of appeal is one of the most important rights of taxpayer whereby the taxpayer can prefer
an appeal before Commissioner (Appeals) in case of Income Tax, Sales Tax and CVT or
Collector (Appeals) in case of Customs Act, against any order that the Taxpayer believes to be
contrary to the facts or unjust in one way or the other.

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 Figure 1 Tax Dispute Settlement Process

Commissioner
Tax Dispute (Appeals)
Settlement Appellate Tribunal
Process High Court
Supreme Court

After the decision by the first appellate authority, both the taxpayer and tax collector have a right
of filling a second appeal before the Appellate Tribunal Inland Revenue or Customs Tribunal. A
reference on any law points before a High Court can be agitated by parties, where after, a
petition can also be moved in the Supreme Court against any decision of the high court in the
reference petition.

The existing conventional appellate system works within the framework of respective fiscal laws
and facts of the case and it takes its own course and time. The result is that a considerable
number of appeals continue pouring in for adjudication which entails extended time periods.

12 | P a g e
Taking cognizance of this situation and realizing taxpayer’s genuine problems the state of the
Pakistan extended the ADR facility, which was available only in Sales Tax Law, to Federal
Excise, Customs & Income Tax Laws as well.

The key objective of introducing the ADR is the expeditious resolution of contentious issues
between the taxpayer and tax collector with no hardship to the taxpayers by independent experts
free of cost.

LEGAL BASIS OF THE FEDERAL TAX OMBUDSMAN

Ombudsman is originated from Swedish language; Swedish word “ombuds” means

“officer” or “spokesman” or “representative”. The office of Ombudsman was first
conceived in Sweden by the Swedish Constitution Act 1809, over about two centuries ago,
as an earlier prototype, the King’s Chancellor of Justice (Rowat, 1986: 135; Wade, 1967:
12). According to dictionary meaning, ombudsman is “a government official whose job is to
examine and report on complaints made by ordinary people about the government or
public authorities” (Oxford Advanced Learner’s Dictionary, 2000). Professor Rowat (1986)
has defined ombudsman as “an independent and politically neutral officer of the legislature
who receives and investigates complaints from the public against administrative action and
who has the power to criticize and publicize but not the reverse such action.” As per the
definition of Loewenstein (1965: 403), “Ombudsman is an independent official chosen by
Parliament to watch over the administrative services in whose practices the general public
is interested.” Thus, ombudsman is an independent and nonpartisan officer of the
legislature, authorized by law to inquire into pronounced grievances of citizens against
public authorities and suggest to the concerned authority to take remedial measures.

In Pakistan ADR system rests on Federal Tax Ombudsman which was established through
primary legislation, known as Federal Tax Ombudsman Ordinance, 2000. Prior to Federal Tax
OmbudmanOmbudsman, Wafaqi MoOhtasib was created in 1983. The FTO’s office main
objective is to provide taxpayers’ grievance promptly and without any hassle, an effective
redressal system is vital. The Federal Tax Ombudsman is appointed by the President of
Pakistan for a period of four years. Once appointed his services are protected in the same
manner as the services of Judges of High Court and Supreme Court of Pakistan. He can

13 | P a g e
issue any order against any officer of the Federal Board of Revenue. He also enjoys powers
to punish for non-compliance (contempt) of his orders in the same manner as provided
under the Contempt of Court Act, 2004.

As per the FTO Ordinance, The Federal Tax Ombudsman is required in all matters to perform
his functions and exercise his powers fairly, honestly, diligently and independently of the
executive and all executive authorities throughout Pakistan shall act in aid of the Federal Tax
Ombudsman.

The Federal Tax Ombudsman cannot hold any office in government offices nor can have any
other position carrying the right to remuneration for rendering of services. The Federal Tax
Ombudsman is entitled to salary, allowances and privileges which are decided by the President
of Pakistan and same do not vary are not varied are not varied during the term of Office of a
Federal Tax Ombudsman so as to ensure transparency and independence of the FTO once he is
appointed.

ORGANIZATIONAL STRUCTURE AND APPOINTMENT SYSTEM OF KEY PERSONS.

The Office of Federal Tax Ombudsman is headed by the FTO himself. The office is funded by
the Ffederal Ggovernment through revenue budget. The budget of FTO is available at the
disposal ofat the FTO himself. He can appoint as many advisors as he thinks appropriate. The
Advisors are usually former FBR high officials or lLegal practitioners.

The advisors to the FTO hold hearings in tax complaints received by the office of the FTO. A
formal response is required from the Federal Board of Revenue against each complaint. Once all
facts are placed on record, the advisor submits its report to FTO along with record. The FTO
analyze the case whether it requires his/her indulgence and whether the complaint is covered
under the scope of FTO as prescribed in the Federal Tax Ombudsman Ordinance, 2001. If he is
satisfied that the complaint is genuine and the taxpayer grievance needs redressal, he issues
recommendations or orders to the FBR to do the needful.

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MANDATE

The Federal Tax Ombudsman Ordinance, 2000 empowers the FTO to hold jurisdiction in the
following cases:

Where there is a decision, process recommendation, actand act of omission or commission of tax
officers which is:

a) (a) is contrary to law, rules or regulations or is a departure from established practice

or procedure, unless it is bona fide and for valid reasons;
b) (b) is perverse, arbitrary or unreasonable, unjust, biased, oppressive, or
discriminatory;
c) (c) is based on irrelevant grounds;
d) (d) involves the exercise of powers, or the failure or refusal to do so, for corrupt or
improper motives, such as bribery, jobbery, favouritismfavoritism, nepotism, and
administrative excesses;
e) (e) neglect, inattention, delay, incompetence, inefficiency and ineptitude, in the
administration or discharge of duties and responsibilities;
f) (f) repeated notices, unnecessary attendance or prolonged hearings while deciding
cases involving; assessment of income or wealth; determination of liability of tax or
duty; classification or valuation of goods; settlement of claims of refund, rebate or
duty drawback; or determination of fiscal and tax concessions or exemptions;
g) (g) willful errors in the determination of refunds, rebates or duty drawbacks;
h) (h) deliberate withholding or non-payment of refunds, rebates or duty drawbacks
already determined by the competent authority;
i) (i) coercive methods of tax recovery in cases where default in payment of tax or duty
is not apparent from record; and
j) (j) avoidanceAvoidance of disciplinary action against an officer or official whose order
of assessment or valuation is held by a competent appellate authority to be vindictive,
capricious, biased or patently illegal.

The above scope covers most of the issues faced by a common or small taxpayers who cannot
afford a long and tedious process of litigation.

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However, the Federal Tax Ombudsman in Pakistan, cannot assume jurisdiction on any case
which is subjudice before any court of law. The law further prescribes that Supreme Court,
Senate or National Assembly can refer any matter to be investigated by the Federal Tax
Ombudsman.

OPERATIONAL METHODOLOGY

The office of the FTO receives written complaints from taxpayers online. A complaint is made in
writing on solemn affirmation or oath and shall be addressed to the Federal Tax Ombudsman by
the person aggrieved and may be lodged in person at the Office or handed over to the Federal
Tax Ombudsman in person or sent by any other means of communication to the Office.

Online complaints are also entertained. Urgent matters can even be sent on WhatsApp number.
The taxpayers are required to submit record with informal application to FTO for redressal. The
office of FTO is equipped with complaint management system. Any complaint received is
directed to concerned registrar who verifiesy the genuineness of the taxpayerstaxpayer’s
credentials, subsequentlywhereafter the complaint is referred to the FBR for formal reply. The
FBR directs the field office holding jurisdiction over the case to respond to the complaint filed.
Written response is submitted with the office of Federal Tax Ombudsman.

The Federal Tax Ombudsman conducts hearing in private, but he may adopt such procedure as
he considers appropriate for such investigation and he may obtain information from such persons
and in such manner and make such inquiries as he thinks fit.

After conducting hearing and going through record, if the Federal Tax Ombudsman is of opinion
that the matter considered is within his jurisdiction, he shall communicate his findings with a
recommendation to the Federal Board of Revenue within a period of sixty days from the date of
receipt of the complaint..

PAST PERFORMANCE

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During the year 2021, 2821 fresh complaints were registered, as compared
to 3332 complaints during 2020. Total no of cases to be processed including 333 carry
forward cases from previous years and one reference case, comes to 3371. Oout of
these, 2867 complaints/cases were disposed off during 2021, as against 3555 cases
during 2020. Wwhereas 71 review petitions were decided, while 11 were accepted by FTO.
Ssimilarly out of 610 representations against the decisions of FTO only 23 were accepted by
the Hhon’ble Ppresident of Pakistan. Implementation status of recommendations
in 2021 was 88.14% compared to 87.20% during 2020. Wwith the help of FTO’s
intervention, stuck up tax refund claims billions were decided and due amount was paid to
the aggrieved taxpayers by the FBR.

Figure 2 Past Performance

YEAR NO. OF CARRY TOTAL COMPLAINT COMPLAINTS

COMPLAINTS FORWARD COMPLAINTS S DECIDED CARRIED
FROM FORWARD
PREVIOUS TO NEXT
YEARS YEAR

2018 1918 241 2159 1875 284

2019 2510 284 2794 2411 383

2020 3332 383 3715 3410 305

2021 2821 305 3126 2707 419

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 TOTAL 10581 1213 11794 10403 1391

6.

7.

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 8. OVERVIEW OF THE ADR TAX FRAMEWORK IN BANGLADESH

9.
INTRODUCTION
Alternative Dispute Resolution (ADR) system is common place in settling revenue disputes in
the tax administrations around the world, Bangladesh joined the club in 2011. Unlike the
conventional dispute resolution mechanism, ADR facilitates settlement of disputes in a quick and
cost-effective manner. The system seems to be working efficiently in developed countries like
the UK, Australia and other countries. In Bangladesh it is observed that though ADR system is in
operation and gradually gaining ground the success of ADR

The traditional dispute resolution system in Bangladesh is the adversarial system as developed in
England by Common Law. Taxation litigation is not an exception. But the adversarial system is
time consuming, full of procedural complexities and expensive (Caenegem, 1999). This negative
feature of the dispute resolution system provides a perception among the taxpayers that the
income tax department is nont- taxpayer and poses becomes a problem cats hurdles for a better
and friendly investment climate. Besides, a large amount of tax revenue cannot be collected
because of the pendency of the tax appeals in the higher forums (Bangladesh Protidin,
2020).These cases could have been settled easily and speedily if there would be any dispute
settling forum that facilitates quick disposal of tax litigations. Against this backdrop there is no
denyinggainsay that alternative dispute resolution system is by far the best system to resolve
revenue cases in an accelerated manner without wasting time and resources. Realizing the truth
the National Board of Revenue (NBR) of Bangladesh introduced the ADR system in 2011.

After its introduction the ADR system faces challenge since the number of cases resolved
through ADR is not very encouraging. Since the introduction of the ADR system in the income
tax department of Bangladesh, the system does not seem to be a success in terms of dispute
settlements and the collection of revenue as well.

DISPUTE SETTLEMENT PROCESS

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The normal appellate system for resolving taxation disputes, the judge plays the role of an
umpire and passes judgment in favor of the party who plays well i.e. the party who can plead and
present their case well by producing enough evidences and arguments. The present legal
frameworks and the bulk of statutes were crafted by the English jurists and parliamentarians
during the British rule in the then Indo-Pak subcontinent. Likewise in 1922 Income Tax Act was
made by the British people to impose and collect tax in the country. That law continued until
1984 when the new Income Tax Ordinance was promulgated.

Income Tax Ordinance (ITO) 1984 prescribes the legal provisions how to settle income tax
disputes between the assesseeassesse and the income tax department. The process starts from the
submission of income tax returns. Under the ITO, there are two systems of submission of return.
One is under the universal self-assessment system and the other is under the normal system.
When the assesseeassesse submits returns under the normal system the DCT goes for
administrative assessment.

Officers of the NRBR issues notice to the assesseeassesse (taxpayer), takes hearing of the
assesseeassesse and finalizes the assessment. Under the universal self-assessment system a few
number of returns are selected for audit with the prior approval of the National Board of Revenue
(NBR) and the Deputy Commissioner of Taxes (DCT) goes for making normal assessment
issuing notice of hearing to the assesseeassesse. In both the cases, if the assesseeassesse is not
satisfied with the assessment order of the Deputy Commissioner of Taxes (DCT) he/she can
prefer appeal to the first appellate authority as per legal provisions. The assesseeassesse or the
NBR may move to file a second appeal to the Taxes Appellate Tribunal. The order of the
Tribunal is final if the order relates to the question of fact. If there is any question of law then the
assesseeassesse can prefer appeal to the High Court Division (HCD). If there is any law point
and the department is aggrieved, it can prefer reference application to the HCD. The assesse can
file writ petition with the HCD in appropriate cases. In some cases a dispute can go to the
Appellate Division of the Supreme Court of Bangladesh for decision.

ADR MECHANISM IN BANGLADESH

With the successful introduction of ADR system in the formal legal system of Bangladesh, the
National Board of Revenue (NBR) goes ahead with absorption of ADR system in the income tax

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department to settle income tax disputes. Regarding the ADR, the NBR states, “Alternative
Dispute Resolution (ADR) is a process of resolving disputes within shortest possible time
beyond the regular course of business followed by Appeal/Tribunal/Court.

This is a platform for holistic and multilateral discussion with the third party in resolving
disputes. This benefits both the taxpayers and the government. It reduces the cost of trial as well
as facilitating the government in collecting revenue within shortest possible time. This is a
speedy way of resolving disputes. Following a global trend of success of ADR in tax
administration Bangladesh has introduced this method in 2011-2012 financial year.” ADR was
introduced for resolving disputes involving both direct and indirect taxes in Bangladesh.
According to provisions of the relevant laws any dispute of an assessed lying with any income
tax authority, Taxes Appellate Tribunal or Court may be resolved through ADR. It means that
cases pending at the High Court Division or Appellate Division of Supreme Court are also
qualified to apply at ADR.

Any aggrieved assesseeassesse may apply at ADR obtaining permission from the concerned
Court. The proceeding of such appeal or reference shall remain stayed till the disposal of the
application for ADR. However, where an assessed has filed an application for ADR for any
income year and for the same income year, the Deputy Commissioner of Taxes (DCT) has filed
an appeal before the Appellate Tribunal or the Commissioner has made a reference before the
High Court Division and no decision has been made in that respect by the Appellate Tribunal or
High Court Division as the case may be, the proceeding of such appeal or reference shall remain
stayed till disposal of the application for ADR. It follows that the assesseeassesse has been given
a wide range of privilege in resorting to ADR before the same is resolved by the traditional
dispute resolution forums. Before filing ADR application the assesseeassesse must pay the tax as
per the income tax return. In the ADR system a facilitator is nominated by the NBR who sits
with the taxpayer and the representative of the income tax commissioner to settle the agitated
issues. If agreement is reached the facilitator passes an order and the order is binding on the
parties. The taxpayer has to pay the tax within the stipulated time failing which the order stands
null and void. If there is no agreement the assesse can go for traditional dispute resolution as per
the provision of law.

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The ADR system in Bangladesh appears to be very brief compared to the traditional dispute
settlement system.

The following diagram shows the ADR process of disposal.

Figure 3 ADR Process

Obtain persmission from

the respective authority

Application is to be
submitted to the same
authority

Commissioner of Taxes will

nominate one officer of the
Zone and will inform the
parties

NBR will nominate one

facilitator and inform the
both parties

TAX OMBUDSMAN IN BANGLADESH

The Government of Bangladesh took concrete steps to enact the Tax-Ombudsman Act in
July 2005. The objective statement of the Tax-Ombudsman Act 2005 states that this is an
Act to appoint Tax-Ombudsman with a view to ascertaining bad governance committed by
high officials or tax employees engaged in the implementation of tax-related laws and
conducting investigations thereon and undertaking preventive or corrective actions
relating to those.

Tax ombudsman was established in Bangladesh in 2005 but was abolished in 2011.
Government spending cuts and a lack of institutional capacity deterring the tax
ombudsman from being effective were cited as reasons for the abolishment. However, for
the sake of comparison and get a better understanding, we during this study evaluated

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various aspects of Tax Ombudsman Act, 2005 of Bangladesh which are detailed in coming
section.

Bad governance as defined under clause (kha) of section 2,1, 1 of the repealed Bangladesh
Act, 2005 includes the following activities:

1) (1) Undertaking or not undertaking any decision, process, recommendation or

activity which–
a) (a) is contrary to the related Act, rule or regulation,
b) (b) is unethical, discretionary, illogical or inappropriate, biased or discriminatory;
c) (c) is established on irrelevant base;
d) (d) is performed for dishonest or inconsistent purpose, e.g. bribery, brokerage,
biasedness, nepotism or abuse of administrative power;
2) (2) In carrying out the administrative duties and responsibilities, showing negligence
or delaying or demonstrating disqualification, inefficiency or incapability.
3) (3) Issuing notice or delaying in hearing without any reason to dispose the following
issues:
a) (a) determination of income or assets;
b) (b) assessment of liability regarding tax or duty;
c) (c) classification or valuation of goods;
d) (d) settlement of claiming rebate or drawback of tax or duty;
e) (e) ascertainment of matters on tax or duty exemption;
4) (4) Intentional mistake in the settlement of claiming rebate or drawback of tax or
duty;
5) (5) Intentional delay in making payment or no payment at all of the money
regarding drawback of tax or duty already determined by the appropriate
authority;
6) (6) Adopting coercive means to collect tax or duty in such cases where the failure to
make payment of such tax or duty cannot be identified on verification of record;
and
7) (7) Taking no disciplinary action against the tax employee whose order on valuation
or assessment is declared by appropriate appellate authority as vindictive,
whimsical, biased or clearly illegal .illegal.

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APPOINTMENT OF TAX OMBUDSMAN

The Tax Ombudsman appointment was dealt in section 4 of the repealed, Tax-Ombudsman Act , 2005 by
the president of Bangladesh. In case of casual vacancy or during the temporary absence, the President
may employ any person to act as temporary Tax-Ombudsman until the joining of the regular Tax-
Ombudsman (section 9). Under normal situation (i.e., unless resigned or removed), the Tax-Ombudsman
tenure was for four-year single term without any reappointment (section 5).

The remuneration, allowances and other facilities of the Tax-Ombudsman shallto be determined by the
Ggovernment of Bangladesh. During his service, these compensations cannot be changed in a manner
that may be disadvantageous to him [sections 11(2) & 11(3)]. This is apparently to make him work
independently.

ORGANIZATIONAL STRUCTURE AND APPOINTMENT SYSTEM OF KEY PERSONS.

The Tax-Ombudsman has principal seat in the capital city of Dhakaof Dhaka, however it can
establish any branch office elsewhere in the country (section 6). The organizational structure is
not decided by the Tax-Ombudsman himself but by the government [section 15(1)] which in turn
compromises the independence of the FTO office. Although, he may employ as many numbers
of officers and employees as necessary to carry out his duties efficiently and the terms and
conditions of employment, including appointment shall be determined in accordance with the
rules to be prescribed [sections 16(1) & 16(2)]. However, in order to carry out his duties properly
or in order to assist him in carrying out his duties, the Tax-Ombudsman may with or without
remuneration: (a) employ as many number of consultants, specialists, liaison officials or any
other employees as necessary; (b) set up one or more advisory committees; (c) form one or more
investigation teams consisting of his officers, employees or any other related persons [section
17(1)]. He will determine the number of members and area of functional responsibilities of the
investigation team and the advisory committee or sometimes the order under which the advisory
committee has been formed will determine its scope of functional responsibilities [sections 17(2)
& 17(5)]. After completion of investigation and carrying out of the duties assigned to them, the

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investigation team and advisory committee shall submit their reports with necessary
recommendations to the Tax-Ombudsman within the prescribed time period [section 17(3)].

RESPONSIBILITIES AND FUNCTIONS OF TAX OMBUDSMAN IN BANGLADESH.

Responsibilities and Functions of the tax ombudsman in Bangladesh before it was abolished in
2011 include, inter alia, making investigation into a complaint made by an aggrieved person
against the misdeeds of tax officials in matters relating to assessment of income tax or customs
duty, classification of commodities or valuation thereof, or on the basis of reference from the
president, prime minister, finance minister, parliament, or on the order of the Supreme Court. He
may also institute suo moto inquiry against the NBR or any of its officials for any misdeeds.

If, after investigating a complaint, the tax ombudsman is of the opinion that injustice has been
done to the complainant, he will send his written recommendation(s) to the NBR, which has to
implement the recommendations within 60 days from the date of receipt of such
recommendations and inform the tax ombudsman.

If the NBR is unable to implement the recommendations, it will inform the tax ombudsman the
reasons for non-implementation of the recommendations. The tax ombudsman will then bring
such cases to the notice of the finance minister who may (i) direct the NBR to implement tax
ombudsman's recommendation(s); (ii) request the tax ombudsman to reconsider his
recommendation(s); (iii) take such actions as he deems fit. The tax ombudsman under the Act of
2005 had following powers before it was abolished:

Acceptance of complaints, investigation and taking oath (sections 18 and 22):

The Tax Ombudsman shall accept any complaint only in writing and not from any
disguised person within the stipulated period of six months from date of the concerned
event. But in case of appropriate reason, the Tax-Ombudsman may extend this time-limit.
He, then, on the basis of the complaint, will issue a written notice to the person against
whom the complaint is made and one copy of such notice shall be provided to the NBR’s
Chairman. In case of failure to comply with such notice given, the Tax-Ombudsman may
start the investigation activities. The investigation by the Tax-Ombudsman shall generally
be conducted confidentially but where necessary, it may be done openly. However, any
such investigation shall not influence any arrangement made by the NBR and decline the
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NBR’s power to make additional arrangement regarding any matter under its
investigation. Tax-Ombudsman may direct any tax-employee to provide the relevant and
useful information or document for the sake of the investigation and all such information
and document shall be considered as confidential. In case of any investigation, the Tax-
Ombudsman or any person authorized by him shall have some special authority such as,
issuance of summon to the witness and ensuring his/her presence, revealing any documents
and production thereof, taking evidence on oath, issuance of warrant for interrogating the
witness and examining the documents, and undertaking any other actions as required.

Suggesting recommendations (sections 20 and 21) to NBR : If after undertaking all

necessary investigation, the Tax-Ombudsman is of the opinion that there has been “bad
governance” or certain tasks have been accomplished through bad governance, he shall
submit the recommendations in writing to the NBR within fifteen days after the completion
of such investigation. The NBR is liable to implement the recommendations within sixty
days of intimating these ones or to inform the Tax-Ombudsman duly in case of failure to
implement those and in this case of failure, the NBR will be held liable and the Finance
Minister may be informed and the recommendations will be incorporated into the
concerned person’s (i.e., the tax official/employee against whom the complaint was made)
‘Annual Confidential Report (ACR)’ after giving an opportunity of hearing.

Power to enter into premises and search (section 24): If the Tax-Ombudsman or his
authorized person is of the belief that there is a chance to get any documents, materials or
accounts in any premises, then they can enter into that premises and conduct necessary
search and confiscate those and collect required copies or comments.

Power to authorize (sections 26 and 27): In case of necessity, the Tax-Ombudsman can
authorize any person within his office or from other agencies in writing to conduct any
required tasks under the Act. ● Request for assistance from other person/authority (section
29): The Tax-Ombudsman maycan request other person or authorities to assist him in
order to exercise his power and to carry out his functions and those persons or authorities
will also assist him according to their power and ability.

Power to order for submitting affidavit and facing the lie-detector (section 30): The Tax
Ombudsman or any official in his office maycan give the order to any person who

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filesmaking the complaint or to any party related to the complaints or investigation or
reference to submit the attested or notarized affidavit. He maycan also give orders to the
concerned person to face the lie-detector.

Rewarding for exceptional services or special assistance (section 32): The Tax-Ombudsman
can arrangemay make arrangements to give an award to anybody for exceptional services or
special assistance and the award-recipient’s identity may be kept confidential aton his
request.

Power to resolve dispute in an alternative way (section 35): Notwithstanding anything

contained in the Tax-Ombudsman Act, before filing any complaint or issuance of a formal
notice to any party, the Tax-Ombudsman or any authorized officer or employee shall have
the authority to resolve any dispute or arbitration in any alternative way

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 10. OVERVIEW OF THE ADR FOR RESOLUTION OF TAX DISPUTES IN
INDIA
INTRODUCTION

Over the years, India has experienced delayed justice and prolonged litigation in resolving tax
disputes. The resolution of Resolving legal dispute becomes very expensive and due to
procedural complexities; the way for Alternative Dispute Resolution (herein after referred to as
‘ADR’) isare open. ADR is kind of a private remedy. ADR is a process in which parties at
dispute seek remedy without the recourse to litigation.

Section 245B of Income Tax Act, 1961 of India provides for settlement of cases through ADR
mechanism viz a viz Income Tax Settlement Commission (herein after referred to as ITSC) was
set up in the year 1976 on the recommendation of Direct Tax Enquiry Committee headed by
former Chief Justice of India, Shri K. N. Wanchoo. The purpose, intent and necessity of
Settlement Commission is revealed by recommendation in para 2.32 to 2.34 of Chapter of the
report: “2.32 Thisthis, however, does not mean that the door for compromise with the errant tax
payer should forever remain closed. In the administration of fiscal laws, whose primary objective
is to raise revenue, there has to be room for compromise and settlement. A rigid attitude would
not only inhibit a onetime tax evader or an un intending defaulter from making a clear breast of
his affairs, but would also unnecessarily strain the investigational resources of the department in
cases of doubtful benefit to revenue, while needlessly proliferating litigation and holding up
collections. We would, therefore, suggest that there should be a provision in the law for a
settlement with the taxpayer at any stage of the proceedings. The repost relies on the confession
method in UK which is in vogue since 1923. In the U. S. law also, there is a provision for
compromise with the taxpayer as to his tax liabilities. A provision of this type facilitating
settlement in individual cases will have this advantage over general disclosure scheme that
misuse thereof will be difficult and the disclosure will not normally breed further tax evasion.
Each individual case can be considered on its merits and full disclosures not only of the income
but of the modus operandi of its build up can be insisted on thus sealing off chances of
continued evasion through similar practice. 2.33 To ensure that the Settlement is fair, prompt and

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independent, we would suggest that there should be a high level machinery for administering the
provisions, which would also incidentally relieve the field officer of an onerous responsibility
and risk of having to face adverse criticism which, we are told, has been responsible for the slow
rate of disposal of disclosure petitions.”

DISPUTE SETTLEMENT PROCESS

In India, the procedures of tax matters are governed by ‘Income Tax Act, 1961’ (hereinafter
referred to as ‘ITA’). All the methods of tax collection are governed as prescribed by ITA.
According to the ITA, every tax payer has to perform self-assessment in which the burden of
filing onus of file income-tax return is on the tax payer. After filing an income-tax return, it will
go to the assessing officer according to the valid jurisdiction and then the assessing officer will
examine all the documents of income-tax return and either he may accept or reject the income-
tax return. And if the tax payer is dissatisfiednot satisfied with the reviewexamination of
assessing officer’s order of rejection then the taxpayer then may go for adjudication fromin
commissioner of income-tax (hereinafter referred to as ‘CIT’). If aany party is disnot satisfied
with the order of CIT then that partythey may prefer an appeal in the Income Tax Appellate
Tribunal (hereinafter referred to as ‘ITAT’). ITAT is a quasi-judicial body. Appeal from the
ITAT is lies in the High Court according to the jurisdiction of the parties. And then last appellate
court is Hon’ble Supreme Court of India. However, any party can directly approached High
Court or Supreme Court through writ petition. This process can be followedflowed in the
following manner;as follows;

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Figure 4 Dispute Settlement Process

Return is assessed by the

Assessing Officer, if rejects
then can file appeal

Commissioner of Income
Tax (CIT)

Income Tax Appellate

Tribunal

High Court

Supreme Court

DISPUTE SETTLEMENT THROUGH INCOME TAX SETTLEMENT COMMISSION

Income Tax Settlement Commission has certain unique features, such as: It is a quasi
judicialquasi-judicial body (as per section 245L) and is a premier Alternative Dispute Resolution
(ADR) body in India. Only assesseeassesse can approach the settlement authority. The
application for settlement/dispute resolution can be made only during the pendency of the
assessment proceedings. An institution, though, though within the Tax Department, but
independent of the same to settle tax liability to give quietus to a dispute. In other words, the
commission functions independently of the Department. It settles disputes relating to tax liability
totally and finally. The ITSC is empowered to grant immunity from prosecution for any offence
and also to grant immunity from imposition of any penalty under the laws relating to Income Tax
and Wealth Tax. The allAll proceedings before the ITSC are confidential. The proceedings are
not open to public. Confidentiality of assessee’sassesses disclosure is maintained as the same
could be used only in the Settlement Commission except as provided in section 245HA (3) of the
Act. The order of the Settlement Commission is not answerable to audit, executive or parliament.
The orders of the ITSC are final and not appealable. The orders are only subject to judicial

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review in terms of Articles 136 and 226 of the Constitution of India. Thus, time consuming
litigation in regular appellate procedure is avoided by Department and assesseeassesse as well.
The constitution of the ITSC is done by the Central Government from amongst “persons of
integrity and outstanding ability, having special knowledge of, and experience in, problems
relating to direct taxes and business accounts” as specifically laid down in the statute itself.
Advantages for the Applicant: Immunity from Penalty and Prosecution under the IT Act. Avoid
prolonged litigation time. Advantages for the Department: The tax and interest on the additional
income is paid in full before filing the application to ITSC. Cost and efforts of the department is
substantially reduced, as the applicant is revealing full and true disclosures. The Settlement
Commission is a platform to avoid never ending litigation. ‘Telescoping theory’, ‘Peak Credit
Theory’, ‘Real Income Theory’, Primary objective, tThe door for compromise should not be
closed for an errant taxpayer permanently.

Through the Finance Bill, 2009, ITA has been added by ‘Dispute Resolution Panel’ (DRP). “The
DRP is an Alternative Dispute Resolution (ADR) mechanism for resolving disputes related to
Transfer Pricing in International Transactions. This Panel has been established with the
objective of ensuring the expeditious resolution of matters in a fair and equitable manner.set up
with a view to providing speedy disposal of cases in a fair and just manner.” DRP is a panel of 3
commissioner of Income-tax. DRP is mainly for the dispute relating to transfer pricing disputes.
However these dispute resolutions are also kind of ADR but it has no private remedy because it
is established by ITA.

Though some ADR mechanism is available in India, however, the number of disputes and
pendency in courts requires much more to be done in this respect. The taxpayers have been kept
waiting for decades to resolve their tax related issues which is causinges serious harm a great
prejudice to the business environment.

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 11. SELECTION OF THE MODEL COUNTRY

It is observed that in recent years ADR in tax matter is becoming popular around the world.
Countries like India, Bangladesh, Pakistan and the others in Asia are gradually promoting ADR
in tax disputes to reduce the time and financial cost of both the taxpayers and the governments.
However, the NBR could not achieve the desired outcome of establishing the ADR in the tax
framework as limited number of the cases are brought to the ADR platform, most of which were
relates to the individual income tax matters. The NBR is working hard to make the ADR system
popular among the taxpayers. Accordingly, taxpayers, particularly the income tax practitioners
do not feel interested to go to ADR forum and even if they go and agree with the ADR decisions
they do not abide by the order of the ADR facilitator. Under the circumstances ADR can be seen
as another forum to protract the litigations. For Aas mentioned earlier the other options of taking
the litigation to the traditional forums are not closed. So if a taxpayer feels that the ADR order
might not be in favor,favourfavor he may opts out of the ADR. One important issue is the
neutrality of the facilitator of the ADR proceeding. So far there are no complaints is no complain
regarding the neutrality of the facilitators. But there should be a system of monitoring in this
respect. Among the weaknesses of the ADR system some important issues have been identified
by the researchers. For example, Islam (2019) identities inter alia absence of proper institutional
tricks, lack of appropriate training of the lawyers and judges, lack of proper education of the
people, negative attitude of the lawyers towards ADR system, lack of awareness among the
stakeholders and to some extent corruption in the mechanism.

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 12. ABBREVIATIONS:

13.

14.

15.

16.

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 17.

18.

19. REFERENCE:
Income Tax Ordinance, 2001 Pakistan

Income Tax Rules, 2002 Pakistan

Income Tax Ordinance, 1984 Bangladesh

Income Tax Act, 1922 Indo-Pak

Income Tax Act, 1961 India

Sales Tax Act, 1990 Pakistan

Sales Tax Rules, 2004 Pakistan

Federal Excise Act, 2005 Pakistan

English Pages.cdr (fto.gov.pk)

FEDERAL TAX OMBUDSMAN (fto.gov.pk)

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