From: Asif Siddiq Kasbati <asif.s.kasbati@professional-excellence.com>
Date: September 28, 2025 at 6:01:51 PM GMT+5
Subject: TLQC3288= IT TY 2025 Return Extension inevitable as over 15 Reasons

590+ Taxes & Levies Quick Commentary - TLQC 3288

  

A.  EXECUTIVE SUMMARY

 

Owing to matters in Background (as we are constantly covering important matters in our Commentaries), over 15 reasons in ensuring paragraphs, based on our over 33 years’ core tax experience, we are of the crystal clear view that extension atleast till 31 October 2025 is inevitable. 

 

Hence, Professionals may work hard (like our team too), however, no need to feel pressure but take care of yours & team Health.  

 

We appreciate PTBA, KTBA, LTBA & Other bars in highlighting Glitches in Return Forms & IRIS issues, which lead to the resolution of several matters.

 

 

B.   BACKGROUND

 

(I)   This refers to our TLQCs in trail, in blue, in italic and after double line (a) 3287 of 27.9.25 about IT Return TY 2025 & Wealth Statement Property FMV Disclosure removed  (d) 3283 of 25.9.25 about IT Return TY 2025: IRIS Portal Glitches Hindering Tax Return Filing – PTBA, etc, etc.

 

(II)   We also refer to our several other relevant Commentaries including (a) 3279 of 23.9.25 about IT Return TY 2025: PTBA Extension request (b) 3244 of 24.8.25 about Delayed 8 Types / Categories TY 2025 IT Return Forms – SRO 1562 (c) 3243 of 24.8.25 about So-called Simplified & Delayed Salaried class (with no business) TY 2025 Form - SRO 1561 (d) 2889 of 5.9.24 about IT ATL for TY 2023 @ 5.4M and predicted @ 10M shortly (e) 1224 of 9.11.20 about Stepwise Deadlines for Timely notifying IT Return Forms vide SRO 1185 of 6.11.2020 by adding Rule 34A in Income Tax Rules, 2002 (f) PRAL Closure 2 TLQCs.

 

C.   UPDATED COMMENTARY

  

(I)   RETURN FILING DEADLINE

 

As per section 118, (a) Individuals & Associations of Persons having year from 1.7.24 to 30.6.25 and (b) Companies having year-end between 1.7.24 to 31.12.24 are required to file TY 2025 Return on or before 30.9.25.

 

(II)   EXPECTED EXTENSION REASONS

 

Based on over 33 years’ core tax experience, we understand that General Extension is likely to be allowed at least till 31 October 2025 (or 15 days Specific Extension in worst scenario) owing to the following several reasons; however, refer to Timely Filing and Extensions Paras as well: 

 

1   Return Forms Final Deadlines missed by FBR & PRAL

 

Considering Rule 34A(2)(e), (3) & (4) - TLQC 1224 in trail refers - the FBR was supposed to issue the Final return Forms SRO by 1.1.25 but late by over 6 months, as evident from below:

 

1.1 Delayed 8 types of categories of Electronic (TLQC 3244 of 24.8.25 refers) which were issued vide SRO 1562 dated 18.8.25.

 

1.2 As evident from TLQC 3243 of 24.8.25, So-Called Simplified Electronic IT Return Forms for Salaried Individual, etc (not having business income) was issued vide SRO 1561 of 18.8.25.

 

2. Flood, Rain & Slow, Internet Speed and related Effects

 

2.1 Torrential rain affected the whole country in August & early September 2025.

 

2.2 Devastating Flood affected KPK, Punjab & Sindh during August till release of this TLQC.

 

2.3 Owing to above two issues, in August & partly now too, Internet Speed Issue in the entire country, inspite of Govt Claim of Digitization.

 

2.4 Owing to above three issues, there is Cash Flow crunch in the Economy as a ground reality, though Govt is claim improvement in constant improvement in Economy and Inflation reduction.

 

2.5 The above four matters affected Offices for several days and Office work too.

 

3.   IRIS and FBR Policy Issues

 

3.1 IRIS was either not working at all OR very slow for several days in September 2025.

 

3.2 Change on to showing Fair Market Value of Property was incorporated in late September and upon PTBA & KTBA objections removed the same on 26.9.25 (TLQC 3287 of 27.9.25 in trail refers), just 4 days before the deadline.

 

3.2 IRIS is likely to be working very slowly from 29.9.25 & 30.9.25 as the Taxpayers face this issue almost every year; as we understand that IT speed system issues are still not fully resolved.

  

4   Similar Deadlines of 30.9.25 or near Deadlines lead to load on IRIS

 

4.1 Annual Sales Tax Return deadline on 30.9.25 (TLQC 3266 of 13.9.25 refers) & 

 

4.2 E-Invoicing & Integration deadline for Public Companies, Other Companies having turnover of over One billion, etc is 15.10.25 viz near to 30.9.25.

 

5   Return Quantity matters

 

5.1   As per Former FM Shaukat Tarin, there were 15M Non-Filers data with FBR as per video (click on the link to watch video). As per News Clipping of 29.6.21 (Attachment 2910.1), the Former FM stated that there are 15M Potential Taxpayers.

 

5.2   As per Former SA to PM Dr Waqar Masood stated earlier that there are 7.4M expected Non-Filers in Press (Attachment 2910.2).

 

5.3   Having stated above, we expect that minimum 10M returns (TLQC 1961 of 3.12.24 refers) will be filed for TY 2024.

 

5.4 ATL Analysis from Tax Years 2021 to TY 2023

 

Sr No	Tax Year	Date of ATL	Number of Return Filed	% increase / (decrease) over previous year highest / available data	TLQC Reference
a	2021	28.2.2023	4,009,315	-	2235
b	2023	1.3.2024	3,348,031	(16.49)	2594
c	2023	29.7.2024	5,145,987	53.70	2859
d	2023	26.8.2024	5,418,226	5.29	2889
e	2023	30.1-.24	6,753,532	24.68	2983 (para B)

 

 5.5  Tax Year 2023 VS TY 2024 

 

Sr No	Date of ATL	Tax Year	Number of Return Filed	% increase/	TLQC / Reference	Para
				(decrease) over previous year highest
a	30.10.2024	2023	6,752,531	24,68	2943	B
b	30.11.2024	2024	5,637,103	-16.52	2961	IIC
c	26.09.2025	2024	8,095,800	43.62	3288	II 5.5

 

5.6   Present Coalition Govt Quantitative Plan

 

As covered in our TLQC 2847 of 26.7.24, we reiterate the PM Orders FBR to Immediately Bring 4.5 Million Non-Filers into Tax Net (Attachment 2961.1) on 5.7.24 in addition to 5.4M NTRN holder as per TLQC 2859 of 2.8.24. Hence, 10M as per our prediction, as per Govt too, though reach at 8.1M till 26.9.25 and about 43.62% increase over last year, which is highly appreciated (however, income tax collections from new taxpayer has not increased to this %).

 

6.  Expected returns filed and Non-Compliance issues

 

6.1   Based on our over 33 years’ pure tax experience, we anticipate less than 30% would have been filed, even if keep the bench mark of 8.1 million of TY 2024. In line of its proper disclosure and declaration, the remaining time is not sufficient for the tax filers to arrange their payment of tax and file their proper and correct declarations even though 90% of the demand has already been paid by the tax filers by way of withholding taxes and advance taxes.

 

6.2 Considering the aforesaid circumstances, we strongly acknowledge the contributions of the tax filers whose names are appearing in the latest ATL, by giving them relief if by any chance they are unable to file their tax returns before the deadline of filing i.e. 30.9.25.

 

6.3 We are of the view the aforesaid granting one month extension will enhance the tax filers confidence on the Government, reduce the trust deficit and they will reiterate their commitment to Pakistan by paying their due shares of taxes, even at the cost of their depleting financial health.

 

7. FBR & PRAL Differences and PRAL Closure by December

 

7.1 It was covered in TLQC 3235 of 10.8.25 about Hacking & KC Recommendations and PM orders PRAL closure in 6 months (Attachment 3235.1) owing as the government had also taken a foreign loan in 2019 to upgrade technology systems, but all deadlines have since lapsed.   

 

7.2 The government has been attempting to modernise the FBR's information technology infrastructure, set up new data centres, and implement an automated income tax refund system with the help of a $400 million World Bank loan. Out of the $400 million, $80 million was earmarked for technology upgradation. However, the systems could not be upgraded due to divided responsibilities and authority as Two FBR wings. Reforms and Information Technology, were looking after affairs, diluting both authority and responsibility.

 

7.3  PM had then further instructed that a new organisation should be composed of top-notch professionals and should have full functional and financial autonomy. He ordered that the new body must serve as the pivot for FBR's digital transformation and provide world-class, end-to-end user experience for both the FBR and taxpayers.

 

7.4.   However, it will be challenging for the government to establish a whole new organisation by December this year to seamlessly take over PRAL's responsibilities without disrupting tax-related functions. This is especially difficult given that authorities failed to hire a chief information security officer for PRAL despite multiple attempts.

 

7.5 Sources said PM Sharif had instructed that PRAL's new data centres be inaugurated soon. The FBR had targeted August 14 for the launch, but the servers are not yet ready, and there is a possibility the PM may not be able to inaugurate fully equipped centres on Independence Day.

 

7.6 As covered in TLQC 3246 of 25.8.25 we covered about the PM reaffirmed news that PRAL to be Shutdown by December 2025 (Attachment 3246.1).

 

8. Extension requests from various quarters

 

8.1 Owing to several reasons, PTBA, KTBA, LTBA & other Bar have applied for extension of one month.

 

8.2 Moreover, certain Trade bodies have also already applied for similar extension.

 

8.3 We expect more applications from several Bars, Trade & Industry Bodies too shortly.

 

(III)   TIMELY FILING

 

Having stated above, in order to avoid any Default Surcharge, Penalty & Notices, we recommend you submit your Income Tax Return as soon as possible by 30.9.25, however, without taking stress.

 

(IV)   EXTENSION APPLICATION

 

If your Goodself could not file a return by 30.9.25, we recommend submitting an online extension application with applicable reason from this TLQC and keeping in view Section 119 which is reproduced below for ready reference:

 

119. Extension of time for furnishing returns and other documents.— (1)  A person required to furnish —

 

(a) a return of income under section 114 or 117;

(b) & (c) Omitted

(d) a wealth statement under section 116, may apply, in writing, to the Commissioner for an extension of time to furnish the return, or statement, as the case may be.

 

(2) An application under sub-section (1) shall be made by the due date for furnishing the return of income, statement to which the application relates.

 

(3) Where an application has been made under sub-section (1) and the Commissioner is satisfied that the applicant is unable to furnish the return of income, statement to which the application relates by the due date because of —

 

(a) absence from Pakistan; 

(b) sickness or other misadventure; or

(c) any other reasonable cause, the Commissioner may, by order, in writing, grant the applicant an extension of time for furnishing the return, or statement, as the case may be.

 

(4) An extension of time under sub-section (3) should not exceed fifteen days from the due date for furnishing the return of income, employer’s certificate, or statement, as the case may be, unless there are exceptional circumstances justifying a longer extension of time:

 

Provided that where the Commissioner has not granted extension for furnishing return under sub-section (3) or sub-section (4), the Chief Commissioner may on an application made by the taxpayer for extension or further extension, as the case may be, grant extension or further extension for a period not exceeding fifteen days unless there are exceptional circumstances justifying a longer extension of time.

 

(5) Omitted

 

(6) An extension of time granted under sub-section (3) shall not, for the purpose of charge of default surcharge under sub-section (1) of section 205, change the due date for payment of income tax under section 137.

 

(V)   SHARING THIS EMAIL TO FBR & MEDIA

 

We are concurrently sharing this email with FBR officials to consider the same and grant general extension in order to avoid non-compliance at large by over 5M extension letters and approval thereof. 

 

For the public benefits at large, we are sharing this comprehensive email to Print & Electronic Media Representative.

 

(VI) CONCLUDING REMARKS

 

Knowing that Great Tax Consultants are working hard (including our team is working till late night for several days, even working on Sunday 28.9.25 too and has plans in the next few days), however, we recommend that no need to feel pressure but take care of yours, theirs & team Health too.  

 

(VII)   MULTIPLICATION ALLOWED

 

Although all the Commentaries are for the Subscribed IDs only, however, your Goodself is allowed to share this QC (with trail) for the Noble Cause to Impart Knowledge to maximum.

 

  

(VII)   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 OR call r Amsal at 0313 9233 1111. Your Goodself 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

    Quick Commentary Service Provider and High Level 440+ Tax & Levies Laws Consultants) 

Head of Tax & Professional Excellence Services (Symbols of High Quality Practical Tax, Levies &        Corporate Training for Beginners to High Levels' Professionals) PTCL: 92-21-34329108 Mobile: 0334 322 3161 Website: kasbati.co Facebook:  https://www.facebook.com/taxexcellence/ Google Map link: Tax Excellence  YouTube Channel Tax Excellence