A notice from FBR is not an emergency — but ignoring one usually creates an emergency. Here are the five notices practitioners see most, what each section means, and how a well-run firm responds.
114(4) — Return not filed
A notice calling on a person to file a return for a specified year. It carries a deadline; non-compliance can lead to a best-judgement assessment under 121 and penalties. Response: file the return (with accounts/wealth statement as applicable) within the time allowed, or seek an extension in writing before the deadline.
120 — Assessment on the return
Strictly an intimation: your filed return is treated as an assessment order. Where FBR's automated system finds arithmetic or apparent errors, an adjustment notice may follow — respond within the stated days or the adjustment goes through.
122(9) — Amendment of assessment
The serious one. The Commissioner intends to amend your assessment because definite information suggests income was under-declared or the return needs revisiting. Response: read the grounds carefully, gather documentary evidence point by point, and reply within the deadline — every allegation answered, every annexure referenced. This is where professional drafting earns its fee.
176 — Notice to obtain information or evidence
A demand for records: bank statements, contracts, ledgers, third-party information. Compliance is mandatory; the scope, however, must stay relevant to the proceedings. Supply what is asked, in order, with a covering letter listing every document.
161/205 — Withholding default
Issued to withholding agents: tax that should have been deducted/deposited wasn't (161), plus default surcharge (205). Response: reconcile the withholding statements against payments first — many 161 notices die at the reconciliation stage because the deposits exist but were mismatched.
The response checklist
- Diarise the deadline the day the notice arrives — and a reminder a week before.
- Identify the section and the specific allegations or demands.
- Gather evidence per point; never reply with rhetoric where a document will do.
- File within time, keep the acknowledgement, and brief the client in writing.