A Section 122 notice tells you that FBR wants to amend an income tax return you already filed — usually because the tax officer believes you understated income or claimed a deduction you were not entitled to. It is not automatically a disaster, but it is not something you can leave sitting in your IRIS inbox either. You typically get around 30 days to argue your case before the amendment becomes final.
Why FBR Reopens a Filed Return
Section 122 of the Income Tax Ordinance 2001 lets the Commissioner revisit a return that was already assessed, including a normal self-assessed filing. Reasons a notice gets triggered usually include:
- Bank or property data that does not match your declared turnover or income
- Deductions or expenses that look inflated compared to your revenue
- Numbers that don't reconcile between your return and your wealth statement
- Simple arithmetic or data-entry mistakes in the original filing
How Long You Have to Reply
The notice itself will state the deadline — commonly between 21 and 30 days. Missing it does not make the problem disappear; it means the Commissioner proceeds to amend the assessment without your side of the story, which almost always results in a higher demand plus penalty and default surcharge. If you genuinely need more time to pull together documents, write to the officer before the deadline and ask for an extension — most are granted for a reasonable request made early.
Building Your Response
- Pin down exactly what's being questioned — the specific income head, deduction, or figure flagged in the notice
- Collect supporting paperwork — bank statements, invoices, contracts, salary certificates covering the disputed period
- Write a point-by-point reply addressing each proposed change individually, with the relevant law cited
- File it through IRIS under the Correspondence tab linked to the notice, or courier it to the RTO with proof of delivery
- Turn up for the hearing if one is scheduled, ideally with a consultant who knows how these assessments typically get argued
If the Amendment Still Goes Through
Should the Commissioner uphold the amendment after your reply, you're not out of options. You can appeal to the Commissioner (Appeals) within 30 days of the order, and from there to the Appellate Tribunal Inland Revenue, and ultimately to the High Court on pure questions of law. Each level has its own filing window, so acting quickly at every stage matters.
When to Bring in a Professional
For smaller amendments, a well-documented self-response is often enough. Once the proposed addition crosses roughly Rs. 500,000, the stakes justify getting a tax consultant involved from the start — both to draft the reply and to sit through the hearing with you. NTNWaale reviews Section 122 notices, prepares the written objection, and represents clients where a hearing is called.