Appeal before Sindh Revenue Board

BEFORE THE COMMISSIONER (APPEALS) - SINDH REVENUE BOARD, KARACHI

Appeal No. _____ of year Under Section 57 of the Sindh Sales Tax on Services Act 2011 In the matter of:

appellant_name, having NTN No. appellant_ntn and SRB Registration No. srb_registration_number, having its registered office at appellant_address ... Appellant

VERSUS

The Commissioner / Assistant Commissioner / Deputy Commissioner, Sindh Revenue Board, respondent_office ... Respondent

APPEAL UNDER SECTION 57 OF THE SINDH SALES TAX ON SERVICES ACT 2011

Respectfully sheweth:

1. That the present appeal is being preferred against the Order-in-Original No. order_number dated order_date, passed by officer_designation, Sindh Revenue Board, in respect of the tax period from period_from to period_to, whereby the appellant has been adjudged liable to pay sales tax on services of Rs. principal_demand, default surcharge of Rs. default_surcharge, and penalty of Rs. penalty_amount, aggregating to Rs. total_demand.

2. That a brief background of the case is as follows: background_facts. The appellant is a registered person under the Sindh Sales Tax on Services Act 2011 (the 'Act') in respect of the taxable services of services_provided, and has at all material times complied with the obligations cast upon it under the Act and the Rules made thereunder.

3. That, aggrieved by the impugned Order-in-Original, the appellant prefers this appeal on, inter alia, the following grounds, without prejudice to one another:

GROUNDS OF APPEAL

(a) That the impugned order is illegal, contrary to the record, and based on a misconception of the facts of the case as detailed under: facts_grounds.

(b) That the impugned order is contrary to the Sindh Sales Tax on Services Act 2011 and the Rules made thereunder, in particular statutory_grounds.

(c) That the principles of natural justice have not been observed; the appellant was not afforded an adequate opportunity of hearing, and material evidence produced by the appellant has not been considered, as set out under: natural_justice_grounds.

(d) That the calculation of the principal demand, default surcharge, and penalty is erroneous and stands rebutted by the appellant's records, as is evident from the working annexed: computation_grounds.

(e) That the impugned order is also bad in law for the additional reasons set out hereunder: additional_grounds.

4. That the appellant craves leave of this Honourable Forum to add, alter, amend, or delete any of the above grounds with prior leave.

5. That the appellant has, in compliance with Section 57 of the Act, paid / undertakes to pay the admitted tax in the sum of Rs. admitted_tax_paid along with the appeal, and the receipt thereof is annexed for ready reference. The appeal is filed within the prescribed period of limitation, the impugned order having been received on order_received_date.

PRAYER

It is, therefore, most respectfully prayed that this Honourable Forum may be pleased to:

(a) Set aside the Order-in-Original No. order_number dated order_date;

(b) Hold that the appellant is not liable to the demand raised in the impugned order;

(c) Stay the recovery of the disputed demand of Rs. disputed_demand pending the disposal of the present appeal;

(d) Award costs of the appeal in favour of the appellant; and

(e) Pass any further order which this Honourable Forum may deem just and proper in the circumstances of the case.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of the above appeal are true and correct to the best of the appellant's knowledge and belief, and nothing material has been concealed therefrom.

_____________________________ appellant_name (Through authorised_representative) Through: _____________________________ counsel_name Advocate