FBR Notice 122(5A) Pakistan: Step-by-Step Response Guide 2026

A notice under section 122(5A) of the Income Tax Ordinance, 2001 means the Commissioner Inland Revenue thinks the assessment of your return for a particular tax year is wrong in a way that costs the government tax, and proposes to amend it. You get the chance to explain before any amended order is made, and you can appeal if an order goes against you. This guide covers what the notice means, how to reply step by step, and what happens next.

What is a section 122(5A) notice?

Section 122 of the Income Tax Ordinance, 2001 lets the Commissioner amend an assessment. Once you file your return, it normally stands as your assessment. Sub-section (5A) covers the case where the Commissioner considers that assessment erroneous in a way that is prejudicial to the revenue: in plain terms, the officer believes too little tax was assessed.

The notice will usually point to something specific, for example:

• a mismatch between your return and third-party data (bank transactions, property records, utility bills)
• expenses or assets that look out of line with the income you declared
• a return that doesn't reconcile with your financial statements or wealth statement
• a deduction, exemption or rate that the officer thinks was applied wrongly
• information that reached FBR after your return was filed

You must be heard before an adverse order. Section 122(9) says no amended assessment against you can be made without giving you an opportunity of being heard. So the first thing most people receive is a show-cause notice. It sets out the proposed amendment and asks you to explain, by a set date, why it should not be made. Your reply at this stage is your best chance to settle the matter.

If the proposed amendment is based on unexplained income or assets, section 111 is usually involved as well. An adviser can check whether the officer has followed the correct procedure for that section.

Why you might receive one

FBR matches the returns it receives against data from banks, NADRA, provincial revenue authorities, customs and other sources. Common triggers are:

• Information mismatches: income, bank credits or tax deducted under your CNIC that don't line up with your return.
• Undeclared assets or income: a property, vehicle or investment that isn't in your wealth statement, or an income source missing from your return.
• Spending above declared income: lifestyle or expenditure data that doesn't fit what you declared.
• Questionable deductions or exemptions: claims the officer thinks are not allowed or not supported by evidence.
• Past non-compliance: it doesn't cause a notice by itself, but it can attract closer scrutiny.

For how this data matching works, see why FBR sends notices.

Two stages, two deadlines

People often mix up these two stages, so keep them separate:

If you don't reply at stage 1, the officer can pass the amended order on the information already held. Reply before the date on the notice. If you genuinely need more time, apply for an extension in writing before that date and give your reasons. Granting it is up to the officer.

Step-by-step: responding to the notice

Step 1: Read the notice carefully

Check that the notice appears in your IRIS inbox. It should show:

• the tax year concerned
• what the officer thinks is wrong and why (for example, unexplained bank credits or an unverified expense)
• the income or tax the officer proposes instead of your declared figures
• the date by which you must reply, and any hearing date

Write down each point the officer raises. Your reply should answer every one of them.

Step 2: Gather your evidence

Collect documents for the tax year in question that support your return and answer the officer's points:

• your filed return and wealth statement for that year
• bank statements for all personal and business accounts
• salary certificates, profit certificates and withholding tax certificates
• invoices, receipts and payment vouchers for expenses
• sales records and books of account, if you run a business
• property documents, vehicle registration and investment records
• loan agreements, gift deeds and inheritance documents that explain where money came from

Organise the documents by the points in the notice, not by date. Make sure every copy is clear and easy to read. If a bank credit was a loan, a gift or a transfer between your own accounts, the paperwork that proves it is what counts.

If the notice is about your assets or where the money came from, reconcile your wealth statement first. Our wealth statement reconciliation guide explains how.

Step 3: Decide your position and draft the reply

Your reply will usually take one of these positions:

1. You disagree. Answer each point in turn: what the officer says, why it's wrong, and which attached document shows it. Say what the correct figure is.
2. The officer is partly right. Accept the part that is correct, explain how the error happened, and contest the rest with evidence. Being straight about a genuine mistake usually helps your credibility on the points you dispute.
3. The officer is right. Say so. Whether you can still revise your return once proceedings have started depends on your case and may need the Commissioner's approval, so get advice before you try.

Keep the tone factual and professional. Put in your NTN or CNIC, the notice number and date, and the tax year. End with a list of the documents you've attached. If you want a personal hearing, ask for one in the reply.

Step 4: Submit through IRIS and keep proof

Replies are normally filed online through the IRIS portal (iris.fbr.gov.pk), against the specific notice in your inbox. Attach your supporting documents as PDFs and check that each file has uploaded. Save the acknowledgement IRIS generates. If you hand in anything at a tax office, get a stamped copy of your covering letter. Our IRIS digital notices guide explains how to find and open notices in the portal.

Step 5: Attend the hearing and follow up

After you reply, the officer may:

• accept your explanation and drop the proposed amendment, or reduce it
• call a hearing to ask for more explanation or documents (you or your authorised representative can attend)
• pass an amended assessment order if not satisfied, usually followed by a demand for the extra tax

Keep checking your IRIS inbox for further notices or the order.

If an amended order is passed

Read the order and the tax demanded. You then have two options:

• Pay if, after advice, you accept the order. Paying on time avoids further default surcharge and recovery action.
• Appeal to the Commissioner Inland Revenue (Appeals) within 30 days of receiving the order. Your grounds of appeal need to be supported by facts and law. If the first appeal fails, you can appeal to the Appellate Tribunal Inland Revenue (ATIR), within 30 days of receiving the Commissioner (Appeals) order. After that, questions of law can go to the High Court. Each stage has its own procedure, so a tax adviser or lawyer is worth having from the first appeal onwards.

For the wider audit and appeal process, see our FBR audit notices guide.

Common mistakes to avoid

• Ignoring the notice. The officer can then amend your assessment on the information already held, and penalties and recovery action can follow.
• Missing the date. A late reply, or one sent without first asking for an extension, weakens your position.
• Saying things you can't prove. A reply without documents rarely changes the outcome.
• Confusing the stages. The date on the show-cause notice and the 30-day appeal window are separate deadlines.
• Getting emotional. Keep every letter factual and polite.
• Misstating anything. Deliberate misrepresentation can lead to penalties and, in serious cases, prosecution.

Reducing the chance of a notice

• Declare all income, assets and liabilities, and make sure your wealth statement reconciles with your income and spending.
• Check that tax deducted from you, and the income behind it, matches what you declare.
• Keep receipts, invoices and bank statements for at least six years after the end of the tax year.
• Check your IRIS inbox regularly and keep your contact details up to date so notices reach you.
• For salary income, you can recheck the tax on your declared figures with our income tax calculator.

Frequently asked questions

What if I miss the reply date on the notice?

The officer can go ahead and pass an amended assessment order without your explanation. Reply as soon as you can anyway, and speak to an adviser. If an order has already been passed, your remedy is an appeal to the Commissioner (Appeals) within 30 days of receiving it.

Is the section 122(5A) notice itself a tax demand?

Usually not. The first notice normally proposes an amendment and asks you to explain. A demand generally comes after an amended assessment order is passed. Read the heading and wording of your notice to see which one you have.

Can I file a revised return instead of replying?

Don't assume you can. Once proceedings have started, revising a return may need the Commissioner's approval and depends on the facts. Get advice first, and still reply to the notice by its date.

Do I need a tax consultant?

It isn't compulsory. But it's strongly advisable if the amount is large, the notice involves unexplained income or assets, or you are heading for an appeal.

How do I check what happened to my reply?

Log in to IRIS and check the notice and your inbox for any further notice, hearing date or order. Keep your submission acknowledgement.

This is general information, not advice for your case. Tax rules change, so check FBR's current notifications or ask a tax adviser.