A.    Executive Summary

1.   Further to matter in para B & C, All the sales registered persons are required to electronically integrate their hardware and software with FBR computerized system through License Integrator or PRAL. Consequently, will generate and transmit electronic invoices. For Corporate and Non-Corporate registered Person, the deadline is 1.5.25 and 30.6.25 respectively.

2.   We feel that it will be extremely difficult for all corporates (except earlier integrated) to arrange, test run and final run the same in just less than 7 days from the date of the SRO (as sent via KQU earlier). Hence, we expect that extension is likely to be allowed, else the matter will land into Court.

3.   As the above matter is not found in Official Gazette till a few minutes before release of this QC, and there are practical issues in SRO 709 of 24.4.25 implementation, we are afraid that the matter will land into Courts, like Affidavit issue SRO.

4. The SROs under the STA and FEA are issued without publication of draft for comments of the stakeholders, whereas it is so done in case of income tax u/s 237(3) of the ITO. It is proposed to introduce new sections in the STA and FEA for publication of draft SROs for comments of stakeholders before their implementation.

5.  Moreover, it is against the Landmark quote from the SCP judgement reported as 2009 SCMR 1279 " I wish that the law making body shall frame the laws after deliberations which is an additional duty cast upon the lawmaking body in terms of the Article 2-A of the Constitution. The same is in accordance with the Injunctions of Islam and Doctrine of Expectation of Consultations” (Hon’ble Justice Chaudhry Ijaz Ahmed).

B.   Background (BG)

This refers to the related Important TLQCs in trail, blue, italic and double line (a) 2976 of 19.12.24 about FBR Integration with Digital Invoicing System (b) 2605 of 12.12.24 about FMCGs Supply Chain to issue ST Invoices Electronically (c) 2571 of 13.12.23 about FMCGs Importers, Manufacturers & Trader EIS/POS about SRO 1525-DI of 12.12.23 inter alia covering effective or not.

2.   We also refer to over 15 TLQC/QC including (a) 2768 of 3.6.24 about ICAP Proposals for Budget 2024-25  (b) 2543 of 18.11.23 about POS Rules Changes vide SRO 1525 dated 10.11.23 Analysis. (c) 2478 of 29.8.23 about Directorate General of Digital Initiatives FA video.

C.   Updated Commentary

1.   Further to KQU 3339 of 24.4.25, being an important matter, we would inform you about SRO 709(I)/2025 22.4.25 about Electronic Integration of Registered Persons (Attachment 3096.1) in the ensuing paragraphs, with bold and underlined for quick reading.

2.   In exercise of the powers conferred by sectioned 50 of the Sales Tax Act. 1990, read with sub-rule (2) of rule 150Q of the Sales Tax Rules, 2006, the FBR has direct that the registered persons specified in column (2) of the Table below shall electronically integrate their hardware and software with Board's computerized system through license integrator or PRAL and shall generate and transmit electronic invoices with effect from the date specified in column (3) of the Table, namely:

3.   For ready reference Rule 150Q of Chapter XIV about procedure for licensing issuance of electronic sales tax invoice, s and integration of registered persons reproduced below in Italics.

150Q. Application.- (l) Subject to sub-rule (2). provisions of this Chapter shall apply to all registered persons for electronic integration of their hardware and software used for generation and transmission of electronic invoices through license integrator or otherwise as provided in these rules.

(2) The Board shall notify such registered persons or class of registered persons through a notification in the official Gazette for the purposes of sub-rule (l):

Provided that the registered persons who have already registered and integrated their point of sale with the Board's computerised system shall be treated to have been integrated with Board's computerised system under these rules.

D.   Further Details & Services 

Should you require any clarification or explanations in respect of the above or otherwise, or require Income Tax, Federal & Provincial Sales Tax or Withholding Tax Advisory, Statement or Return Filing or Review services, or related accounting matters like the above, please feel free to email Mr Amsal at amsal@kasbati.co with CC to info.kasbati@professional-excellence.com. Your Good self may continue to get other services from your current Tax & Legal Advisors.

Best regards for Here & Hereafter
Asif S Kasbati (FCA, FCMA & LLB)

Managing Partner 

Kasbati & Co (1400+ Tax, Levies, Companies, Economy, Inflation, HR, Banking, Finance, etc

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