FBR Notice Reply: A Practical Guide

A clear FBR notice reply, filed on time, can stop a routine query from becoming a tax demand.

A notice from the Federal Board of Revenue (FBR) does not always mean you have done something wrong, but it should never be ignored. Silence can lead to an order based on incomplete information.

Read the notice carefully

Check:

• the law and section quoted
• the tax year
• what exactly is being asked for
• the deadline and date of service
• who issued it, and whether it appears genuine in your IRIS account

Common notices under the Income Tax Ordinance, 2001

• Section 114 concerns filing a return.
• Section 116 concerns a wealth statement.
• Section 122 concerns amendment of an assessment.
• Section 176 concerns a request for information.
• Section 177 concerns audit.

Sales tax notices come under the Sales Tax Act, 1990.

How to prepare a reply

1. Record the deadline.
2. Gather returns, bank statements, invoices and contracts.
3. Check whether the department’s figures are correct.
4. Identify legal points, such as whether the notice is within time and within the officer’s jurisdiction.
5. Draft a clear reply and attach indexed documents.
6. File through the correct channel and keep proof.

If you need more time

Ask in writing before the deadline, and give reasons. Do not rely on an extension until it is confirmed.

If an order is passed

An adverse order may be appealable, and strict time limits apply. Appeals are commonly taken to the Commissioner (Appeals) and Appellate Tribunal Inland Revenue, with legal questions going further. The Tax Laws (Amendment) Act, 2024 and later changes affected this system, so check the forum that applies to your order.

Common reasons people receive notices

• no return was filed even though the person falls within filing requirements
• bank, property or vehicle data does not match the return
• wealth changed without a clear source
• withholding tax claims do not match
• sales tax invoices do not reconcile

What a good reply looks like

A good reply is short, factual and organised. It identifies the notice, answers each query in order, explains any difference in the figures and attaches indexed documents. It should not include unnecessary admissions. If a query is legally defective, state the objection without refusing to engage.

If you cannot find old records

Ask your bank for statements, check your IRIS history, and contact your accountant, withholding agents or suppliers. Explain clearly what remains unavailable and why. Never create or backdate documents.

Keep a compliance file

Save each year’s return, wealth statement, computation, bank statements and tax certificates together. If you run a business, reconcile sales, purchases and withholding every month. Good records make most notices much easier to answer.

FBR notice reply checklist

Before submitting your FBR notice reply, confirm that you have answered each question, attached indexed documents, checked the figures against your return, signed where required, and saved proof of filing. Keep a full copy in your records.

When to involve a lawyer

Get legal help if the notice raises a large demand, involves several years, alleges concealment, or follows an audit. Our tax lawyers in Islamabad and Rawalpindi can help you respond.

Official source: Federal Board of Revenue