A Section 122 notice means FBR intends to amend your previously filed tax return - usually to increase your taxable income or disallow claimed deductions. If you receive this notice, you have 30 days to respond with objections. Kamboh Associates prepares professional Section 122 responses and represents clients in hearings and appeals.

What is Section 122 of the Income Tax Ordinance?

Section 122 gives FBR the authority to amend any assessment that has been made, including self-assessments (your filed returns). FBR can issue a Section 122 notice if the Commissioner believes an assessment understates income, overclaims deductions, or is based on incorrect information. The notice sets out what FBR proposes to change and invites you to show cause why the amendment should not be made.

Time Limit: You must respond in writing within the time stated in the notice (usually 30 days). If you do not respond, FBR makes the amendment by default, resulting in higher tax, penalties, and default surcharge. Do not ignore this notice.

Common Reasons for Section 122 Notice

  • Undeclared income detected through third-party data (banks, property registrars, NADRA)
  • Deductions claimed that FBR believes are not allowable
  • Business expenses that appear excessive relative to revenue
  • Discrepancy between declared turnover and bank deposits
  • Return filing errors or mathematical inconsistencies
  • Discrepancy between wealth statement additions and declared income

How to Respond to Section 122 Notice

  1. Read the notice carefully - identify exactly which income items or deductions FBR is questioning
  2. Gather all supporting documents - receipts, bank statements, contracts, salary certificates, any evidence supporting your original return
  3. Draft a written response - point-by-point rebuttal of FBR's proposed amendments with legal references
  4. Submit through IRIS - file the response under the relevant notice in your IRIS account within the deadline
  5. Attend hearing if called - be prepared with documents and a qualified tax consultant
  6. Appeal if needed - if the amendment is upheld, appeal to the Commissioner Appeals within 30 days

Pricing

ServicePriceTimeline
Section 122 Written ResponseFrom Rs 15,0003-5 days
Hearing RepresentationFrom Rs 15,000As scheduled
Commissioner AppealsFrom Rs 25,000Case dependent
Appellate TribunalFrom Rs 40,000Case dependent

Section 122 Notice? Respond Before Deadline

WhatsApp the notice to 0328-4675162. Kamboh Associates prepares your full written response within 3 days.

Frequently Asked Questions

Can FBR amend a return I already filed?
Yes. Under Section 122, FBR can amend any return within 5 years of filing (10 years if fraud is alleged). The amendment increases your taxable income or disallows deductions, resulting in additional tax demand. You have the right to respond with objections before the amendment is finalized.
What happens if Section 122 amendment is upheld?
If FBR upholds the amendment after considering your response, they issue an amended assessment order. You can then appeal to the Commissioner (Appeals) within 30 days, then to the Appellate Tribunal, and ultimately to the High Court. Kamboh Associates handles appeals at all levels.