Tax ADR and Audit Changes: Rectification, Reconstitution and Re-audit

Full Article

A mistake apparent in an ADR decision and a disagreement over its merits are different issues. The new rectification provision should not be described as an unrestricted second appeal.

ADR rectification and vacancies

Section 134A(10A) permits correction of an apparent record mistake within thirty days of receipt of the decision by the taxpayer or Commissioner, notwithstanding dissolution of the committee. Where a member becomes unavailable, the amendment provides replacement within fifteen days and further time for the reconstituted committee, subject to the statutory period rules.

Specialist re-audit and valuation

The income-tax audit amendments allow a direction for specialist re-audit or inventory valuation on stated grounds, with a reasonable opportunity of hearing and prior Chief Commissioner approval. The nomination process provides a fifteen-day objection opportunity after the first nomination; a change of nominee depends on acceptance of the objection.

Keep the timelines distinct

Record receipt dates, the relevant statutory provision, submissions and acknowledgements. A period allowed for one ADR step should not be assumed to extend an unrelated appeal deadline.

A useful response file

Preserve the original decision, identify the exact apparent mistake and attach the supporting record. For a re-audit direction, identify scope, nominated professional and requested records, and raise any supported objection promptly.

Source and scope

Finance Act 2026, official FBR gazette, PDF pages 39-48. Text reviewed on 14 October 2026. This explains the enacted amendment; a notification-dependent procedure must be checked separately before use.