FBR sends various types of notices to taxpayers in Pakistan — for verification, audit, unpaid tax demands, or Section 111 unexplained income. Ignoring any FBR notice is dangerous. This guide explains every type of FBR notice and exactly how to respond to each one correctly.
Types of FBR Notices in Pakistan
| Notice Type | Section | What It Means | Response Time |
|---|---|---|---|
| Unexplained income notice | 111 | FBR cannot explain your wealth increase with declared income | 21–30 days |
| Audit notice (desk/field) | 177 | Your return has been selected for detailed examination | 30 days |
| Amendment of assessment | 122 | FBR wants to change a previous assessment | 30 days |
| Non-filing notice | 114(4) | You have not filed a return despite obligation | 15–30 days |
| Demand notice | 137 | Tax demand is pending payment | 30 days or payment |
| WHT default notice | 161/162 | You failed to deduct/deposit WHT as a withholding agent | 30 days |
| GST show-cause notice | Sales Tax Act Sec 11 | FBR alleges incorrect GST return or missing GST | 15–30 days |
| Penalty notice | 182/183 | Penalty being imposed for late filing or other default | 30 days |
General Rules for Responding to Any FBR Notice
- Never ignore it: Ignoring a notice allows FBR to pass an ex-parte order (against you without your input)
- Note the deadline: Mark it in your calendar immediately. Request an extension in writing if you need more time
- Respond in writing: All responses must be in writing with supporting documents. Oral responses have no legal weight
- Keep copies: Keep a copy of your response with the receiving stamp or registered mail receipt
- Engage a consultant early: The earlier a qualified tax consultant reviews the notice, the better the outcome
How to Respond to an FBR Section 111 Notice (Unexplained Income)
This is the most common serious notice. Respond by:
- Identifying which amount FBR is questioning
- Gathering documentary evidence for the source: salary certificate, loan agreement, gift deed, property sale proceeds
- Filing any missing returns for the years in question
- Drafting a point-by-point reply addressing each questioned amount with attached evidence
- Submitting to the relevant Commissioner before the deadline
How to Respond to an FBR Audit Notice (Section 177)
- Identify the scope: which tax years are included and what specifically is being examined
- Compile all documents: returns, wealth statements, bank statements, business records
- Do not submit anything before your consultant reviews it — once submitted, it becomes the official record
- Attend hearings with complete documentation and your consultant
- Respond to the draft order within the deadline given
How to Respond to a Non-Filing Notice (Section 114)
The simplest response: file your income tax return immediately. Once the return is filed, the non-filing notice is resolved automatically. File late returns with payment of late filing penalty (Rs. 1,000/day, max Rs. 50,000 for individuals).
What if FBR Issues a Tax Demand You Disagree With?
You have the right to appeal within 30 days:
- First appeal: Commissioner Inland Revenue (Appeals) — Section 127
- Second appeal: Appellate Tribunal Inland Revenue — Section 131
- High Court: Reference on points of law only — Section 133
- ADR: Alternative Dispute Resolution under Section 134A — faster settlement
Frequently Asked Questions
What should I do if I receive an FBR notice but I have already paid all my taxes?
Respond to the notice by submitting your filed returns, payment receipts, and any other evidence showing compliance. Even correctly filed taxpayers get selected for audit. Your clean records will resolve the matter. Never ignore a notice even if you are fully compliant.
Can I hire a lawyer or consultant to respond to an FBR notice on my behalf?
Yes. You can authorize a tax consultant or lawyer through a signed Power of Attorney to represent you before FBR. They can appear at hearings, submit documents, and file appeals on your behalf. This is highly recommended for Section 111 notices and audit proceedings.
How long does FBR take to close a notice after I respond?
It depends on the notice type. Simple non-filing notices close within days of filing the return. Audit proceedings can take 3–6 months. Section 111 cases vary — with a strong response and proper documentation, many are resolved within 60–90 days. Complex cases may go to appeal and take longer.
Received an FBR Notice? Act Within 48 Hours
WhatsApp Kamboh Associates a photo of your FBR notice. We review it for free and tell you exactly how to respond. Our team has resolved hundreds of FBR notices across Pakistan.
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