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.
FBR IRIS is the online portal for all Pakistani tax compliance: NTN registration, income tax returns, wealth statements, WHT payments, and FBR notice defense responses. Register free at iris.fbr.gov.pk.
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
- Read the notice carefully - identify exactly which income items or deductions FBR is questioning
- Gather all supporting documents - receipts, bank statements, contracts, salary certificates, any evidence supporting your original return
- Draft a written response - point-by-point rebuttal of FBR's proposed amendments with legal references
- Submit through IRIS - file the response under the relevant notice in your IRIS account within the deadline
- Attend hearing if called - be prepared with documents and a qualified tax consultant
- Appeal if needed - if the amendment is upheld, appeal to the Commissioner Appeals within 30 days
How to Draft a Reply to a Section 122 Notice
A reply to a Section 122 notice must be formal, point-by-point, and in writing. It should be submitted through the FBR IRIS portal under the "Correspondence" section linked to the specific notice, or alternatively delivered by courier to the issuing Regional Tax Office (RTO) with proof of receipt. The reply must address each proposed amendment individually — stating the legal grounds for your objection and referencing the relevant provisions of the Income Tax Ordinance 2001. Attach all supporting documents directly: bank statements covering the period in question, salary slips, business invoices, property purchase receipts, and any other evidence that substantiates the figures in your original return.
If the proposed amendment amount exceeds Rs. 500,000, it is strongly advisable to engage a qualified tax consultant or FBR-registered tax practitioner. At higher amendment values, the legal and financial stakes are significant enough to warrant professional representation — both in preparing the initial written reply and in attending the hearing before the commissioner. Kamboh Associates handles Section 122 replies from document collection through final submission, and represents clients in hearings where required. WhatsApp the notice to 0328-4675162 for a free assessment.
Time Limits on Amendment
An assessment can generally be amended under section 122 within five years from the end of the financial year in which the return was filed or deemed assessed. Notices issued outside this period can be challenged on that ground alone. Check the date of your original return before drafting any reply.
Show-Cause Before Amendment
Before amending, the officer must issue a show-cause notice explaining the proposed changes and giving you a chance to respond. An order made without this opportunity is open to challenge. Your reply should address each point raised, attach evidence and ask for a hearing if the issues are complex.
Our FBR notice service starts from Rs 5,000, with the exact fee depending on the issues involved.
Official sources: Federal Board of Revenue (fbr.gov.pk), FBR IRIS portal. Rates and dates on this page follow the Income Tax Ordinance 2001 as amended by the Finance Act 2026.
Frequently Asked Questions
How many years back can FBR amend an assessment under section 122?
Generally within five years from the end of the financial year in which the return was filed or deemed assessed.
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.
Section 122 Notice? Respond Before Deadline
WhatsApp the notice to 0328-4675162. Kamboh Associates prepares your full written response within 3 days.