How to Appeal to the PRA Appellate Tribunal in Punjab: 60 Days, Rs 2,000 Fee

If the Commissioner (Appeals) of the Punjab Revenue Authority (PRA) rules against you, the next step is an appeal to the Appellate Tribunal within 60 days of receiving the order. The fee is Rs 2,000, the Tribunal must decide within six months, and its decision is final unless a High Court reference applies.

The first appeal is lost, or only half won, and the tax demand is back on the table. Many businesses stop here because the second step feels like going to court. It is a tribunal with its own fixed rules, and the rules are short. This page sets them out for sales tax on services in Punjab.

We read sections 66 to 68 of the Punjab Sales Tax on Services Act, 2012 on 21 October 2026, and the PRA home page at pra.punjab.gov.pk. Figures come from that text. The first stage is explained in the guide on appealing a PRA order to the Commissioner (Appeals).

You have 60 days from receipt of the order and pay Rs 2,000

Section 66 lets the taxpayer, or a PRA officer not below Additional Commissioner, appeal to the Tribunal against an order of the Commissioner (Appeals). The time limit is 60 days from receipt. The fee for a taxpayer is Rs 2,000. An appeal by an officer carries no fee.

Like the first appeal, the Tribunal can admit a late appeal if you show sufficient cause in writing. The Act does not define it, so treat the 60 days as firm.

An appeal that sat too long at the first stage moves up on its own

You may not need to file at all. If the Commissioner (Appeals) has not decided within 180 days from the end of the month in which your appeal was lodged, section 65(7) transfers it to the Appellate Tribunal. It is decided as if filed against a Commissioner (Appeals) order.

The Commissioner (Appeals) must attach a report explaining why the appeal was not decided. If you get a transfer notice, watch for the hearing date rather than assuming a new filing is due.

The Tribunal can stay recovery for 30 days, then up to 90 days in all

Under section 67(3), the Tribunal may stop recovery of the tax you are appealing. The first order lasts at most 30 days while a notice goes to PRA. After hearing both sides, the Tribunal may confirm or change it, but the stay cannot run beyond 90 days in total, including any earlier stay.

Section 68 still applies. While your appeal is pending you must deposit the admitted amount of tax based on your return, or the amount the Tribunal decides if you filed none. Late or missing returns also add default surcharge, as explained in the guide to the late sales tax return penalty.

The Tribunal decides within six months and cannot raise the tax without notice

Section 67(2) requires a hearing for both sides. If a party does not appear, the Tribunal may dismiss the appeal in default or decide it without them on the record. So a missed hearing can end the case. The appeal must be decided within six months of filing.

1. Get the Commissioner (Appeals) order and note the date of receipt.
2. Count 60 days and file before the last day, with the Rs 2,000 fee.
3. Attach the order, the original order of the officer and your grounds.
4. If recovery is due, apply for a stay in the same filing.
5. Deposit the admitted tax while the appeal is pending.
6. Attend every hearing, in person or through a representative.

The Tribunal can affirm, change or cancel the order, or send the case back to the officer or the Commissioner (Appeals) for inquiry. It cannot increase tax, penalty or default surcharge unless you have had a reasonable chance to show cause.

The Tribunal decision is final under this Act

Section 67(7) says the decision of the Appellate Tribunal is final, save as provided in any other law. We did not read what other law provides a reference to the High Court for Punjab services tax, so ask an adviser before assuming the case ends here.

Common questions about a PRA Appellate Tribunal appeal

How long do I have to appeal to the Tribunal?

You have 60 days from receiving the Commissioner (Appeals) order, under section 66(2)(d).

What does a PRA Tribunal appeal cost?

The fee is Rs 2,000 for a taxpayer, set by section 66(3).

Can I skip the Commissioner (Appeals) and go straight to the Tribunal?

Not in general. Section 66 covers orders of the Commissioner (Appeals). An order passed by the Commissioner personally on a case may be different, so check the Act with an adviser.

How long can the Tribunal stop PRA from recovering the tax?

A first stay lasts up to 30 days. After a hearing, the total stay cannot go beyond 90 days.

What happens if I miss the hearing?

The Tribunal may dismiss the appeal or decide it on the record without you, under section 67(2).

Can PRA appeal too?

Yes. An officer not below Additional Commissioner can appeal against a Commissioner (Appeals) order, without a fee.

How we verified this

What we checked, where we read it, and what we could not confirm.

Last checked 21 October 2026. We read sections 65 to 69 of the Punjab Sales Tax on Services Act, 2012 and the PRA home page on that date. We could not verify later amendments to the fee or time limits, the current Tribunal procedure rules, or whether a High Court reference exists for this tax. We did not file an appeal. Confirm figures with the Tribunal registry or a tax adviser.