By Bilal Saeed, Advocate (Punjab Bar Council), Lahore High Court and District Courts Lahore. Reviewed and last updated 28 June 2026.
This article is general information, not legal advice.
Freshness note: This guide reflects the law and FBR practice as of June 2026. Consult the FBR website before you respond to ensure you have the current procedures.
If you have received a notice from the Federal Board of Revenue (FBR), your immediate priority is to respond before the deadline. The notice will identify which section of the Income Tax Ordinance 2001 applies to you. Different sections mean different things: some are routine requests for your income tax return, others signal an audit or a penalty claim. This guide decodes the five most common notice types, shows you how to respond, and explains when you must hire a lawyer.
Key facts at a glance
| Item | Detail |
|---|---|
| Where notices come from | Federal Board of Revenue (FBR) |
| Where you respond | IRIS portal (iris.fbr.gov.pk) or by registered post |
| Common sections | 114 (file a return), 122 (amend assessment), 176 (provide documents), 177 (audit), 182 (penalty) |
| Typical response deadline | 7 to 30 days from date of notice |
| Governing law | Income Tax Ordinance 2001 |
| Appeal authority | Commissioner (Appeals), then ATIR, then Lahore High Court |
| When you must hire a lawyer | Appeals at ATIR and Lahore High Court (Bar-Council lawyer only) |
Key takeaways
- FBR notices are legal documents; ignoring them triggers penalties, interest, and asset seizure.
- Different sections (114, 122, 176, 177, 182) require different responses: file a return, submit documents, attend an audit, or object to a penalty.
- Respond on time via IRIS or registered post; keep a copy for your records.
- For simple notices (114, 176), you may handle the response yourself; for amendments, audits, and appeals, hire a lawyer.
- Only a Bar-Council lawyer can represent you at the Appellate Tribunal Inland Revenue (ATIR) or Lahore High Court (LHC); a tax consultant cannot.
What are the five common FBR notice sections?
The notice you received will cite a section of the Income Tax Ordinance 2001. Here is what each section means and how to respond.
| Section (ITO 2001) | What It Means | Deadline to Respond | What You Must Do |
|---|---|---|---|
| 114 | Notice to file a return because FBR believes you should be filing but have not. You are not on the Active Taxpayer List (ATL) or your return was never submitted. | Typically 7 to 10 days from the date of the notice. The notice will state the exact deadline. | File a return immediately on the IRIS portal, or submit a written explanation if you believe you are genuinely not required to file (e.g. your income is below the taxable threshold). Do not ignore this notice; failure to respond leads to a best-judgment assessment. |
| 122 | Amendment of assessment. FBR has reviewed your return and found a discrepancy (unreported income, incorrect deductions, assets not reconciled with reported income). They are proposing to amend your tax liability upward. | Typically 14 to 30 days to object or provide clarification. The notice will state the exact period. | Respond with documentary evidence (salary certificates, bank statements, invoices, investment proof) showing your original return was correct. If FBR is right, you may accept the amendment and remit the additional tax. If you dispute it, a lawyer can help you lodge a formal objection. |
| 176 | Notice to obtain information or records. FBR suspects unreported income or inflated deductions and needs proof. They are asking for specific documents (bank statements, invoices, property deeds, expense receipts). | Typically 7 to 15 days from the date of the notice. | Compile the requested documents and submit them via the IRIS portal or by registered post. Include a cover letter, cite the notice reference, and keep a photocopy for yourself. Non-compliance triggers further notices and penalties. |
| 177 | Audit notice. Your return has been selected for a detailed audit examination under the Income Tax Ordinance 2001. FBR will examine all aspects: income sources, deductions, depreciation, assets, liabilities, and wealth reconciliation. | Initial response deadline is typically 7 to 10 days. The audit itself spans weeks or months. | Respond to all information requests promptly (many are issued under section 176). Cooperate with the audit officer. If you want to challenge the audit findings, hire a tax lawyer to lodge an objection or prepare an appeal. Do not ignore audit notices. |
| 182 | Penalty or default surcharge notice. You have defaulted on a payment deadline, failed to respond to a prior notice, or provided false information on your return. The penalty can be up to 50 to 100 percent of the tax shortfall, or a fixed amount set by the FBR, depending on the breach. | Typically 7 to 10 days to object; 30 days to pay if you do not object. | Object in writing with evidence (proof of prior payment, mitigating circumstances, or documents showing the FBR made an error). If the amount is disputed, a lawyer can help you lodge a penalty appeal. If you accept the penalty, remit the amount by the deadline. |
What happens if you do not respond?
Silence is the worst response. If you miss the deadline in a section 114 notice, the FBR issues a best-judgment assessment, calculating your tax based on estimates and comparable taxpayers' returns rather than your actual income. You will be assessed for the full amount plus interest and penalties, even if your real income was lower. If you miss a section 176 deadline, the FBR views the non-response as evasion and escalates the case: further notices, penalties, and a referral to the Federal Investigation Agency (FIA) for fraud investigation. If you miss a section 182 deadline to pay a penalty, the FBR freezes your bank accounts and seizes assets.
The stakes are high. Always respond before the deadline, even if the notice is wrong or you disagree with it. If you believe the FBR is mistaken, respond with your evidence and then appeal.
How to respond to an FBR notice
There are two routes: respond via the IRIS portal or by registered post.
Respond via IRIS (faster): Log into your account on the IRIS portal with your NTN and password. Most notices allow you to upload documents or file a return directly in the system. Attach your response letter and all supporting documents. You will receive an acknowledgment immediately. Save the reference number.
Respond by registered post (traditional): If the notice specifies a mailing address or if IRIS is unavailable, prepare a typed letter on your letterhead. Include your NTN, the notice reference, and the deadline. State your response clearly (e.g. "I enclose my income tax return in response to the section 114 notice dated [date]"). List all attached documents. Mail the letter and documents by registered post to the FBR office that issued the notice. Obtain the postal receipt and keep it for 7 years.
Whether you respond via IRIS or post, keep a photocopy of everything you submit.
Understanding the audit process (section 177)
If you receive a section 177 audit notice, your return has been flagged for closer scrutiny. Here is what to expect.
An audit begins when the FBR's Audit Assessment Officer (AAO) is assigned to your case. The AAO will issue a series of information requests (typically under section 176). They will ask for bank statements, profit-and-loss accounts, invoices, salary certificates, property documents, asset lists, and loan statements. The AAO will examine whether your reported income matches your spending, savings, asset purchases, and wealth. This process can take weeks or months.
During the audit, you may be invited to a show-cause hearing. This is an opportunity to explain your income and answer the AAO's questions in person. You may bring a lawyer or a tax advisor. The AAO will then issue an audit report with findings. If the report is unfavorable, the FBR issues an assessment order amending your tax.
Example (illustrative): You file a return showing PKR 1.5 million income. The FBR audits you and finds that you purchased property worth PKR 8 million and a vehicle for PKR 1.2 million during the year. Your reported income cannot account for these purchases. The AAO asks where the money came from. You explain that PKR 5 million was a loan from your father and PKR 3 million was savings from prior years. The AAO asks for evidence: a loan deed, bank statements, or a letter from your father. You provide these documents. The AAO then issues a report, either accepting your explanation or proposing an adjustment. If an adjustment is made, you may appeal.
The appeal ladder: Commissioner, ATIR, and Lahore High Court
If the FBR issues an assessment order that you believe is wrong, you have the right to appeal. The appeal process has three tiers.
First tier: Commissioner (Appeals). Within 30 days of the assessment order, file an appeal to the Commissioner Inland Revenue (CIR). Your appeal must state the grounds: why the FBR's assessment is incorrect, what law they misapplied, and what evidence you have. You may hire a tax consultant or a lawyer to prepare this appeal. The Commissioner will review the case and issue an order upholding, modifying, or reversing the FBR's assessment.
Second tier: Appellate Tribunal Inland Revenue (ATIR). If you disagree with the Commissioner's order, you may appeal to the ATIR within 60 days. ATIR is a quasi-judicial tribunal, not an administrative review. At this stage, you must be represented by a lawyer admitted to a provincial bar (a Bar-Council lawyer). A tax consultant or accountant cannot appear on your behalf at ATIR. This is the critical threshold: once your case enters ATIR, you must hire a lawyer.
Third tier: Lahore High Court. If ATIR's decision is wrong on a question of law, you may file a reference to the Lahore High Court under section 133 of the Income Tax Ordinance 2001. This is rare and requires a lawyer. The High Court will review the legal question and issue an order. Decisions of the Lahore High Court are binding on all lower authorities.
Throughout the appeal process, you may request a stay application. This asks the court to delay (stay) recovery of the disputed tax while the appeal is pending. A stay is not automatic; you must show that the case raises genuine questions and that paying the tax now would cause undue hardship.
When you must hire a tax lawyer
You can handle these notices yourself:
- Section 114 (notice to file a return)
- Section 176 (notice for documents)
If the notice is straightforward and you have the documents, you may respond directly.
You should hire a lawyer for these:
- Section 122 (amendment of assessment): a lawyer can argue that your return was correct and submit persuasive evidence.
- Section 177 (audit): a lawyer can attend show-cause hearings and prepare objections to the audit report.
- Section 182 (penalty): a lawyer can appeal the penalty and argue for mitigation.
You must hire a Bar-Council lawyer for appeals at:
- Appellate Tribunal Inland Revenue (ATIR)
- Lahore High Court (LHC)
A tax consultant, accountant, or unqualified agent cannot represent you at ATIR or the High Court. Only a lawyer admitted to the Punjab Bar Council or another provincial bar may appear. This is non-negotiable. If you cannot afford a lawyer, some pro bono legal clinics in Lahore may assist, but you should contact us to explore your options.
The cost of hiring a lawyer varies. For a simple response to a 122 notice, a lawyer may charge a fixed fee. For an appeal to ATIR, the fee is higher because the work spans months. In our Lahore practice, we handle tax disputes on a stage-based model: a lower fee for preparation, a higher fee if the case reaches the tribunal.
Frequently asked questions
What is a section 114 notice? A section 114 notice is an order from the FBR to file an income tax return because they believe you are not on the Active Taxpayer List or your return was never submitted. The deadline is typically 7 to 10 days. You must file your return on the IRIS portal immediately, or submit a written explanation if you are genuinely not required to file (e.g. your income is below the taxable threshold).
What is a section 122 notice? A section 122 notice is an amendment of assessment. FBR has found discrepancies in your return (unreported income, incorrect deductions, or assets not reconciled) and is proposing to change your tax liability. You have typically 14 to 30 days to object with evidence or accept the amendment. A lawyer can help you prepare a strong objection.
What is a section 176 notice? A section 176 notice is a demand for documents. FBR suspects unreported income or inflated deductions and is asking for bank statements, invoices, property deeds, or expense receipts. You have typically 7 to 15 days to submit the documents via IRIS or registered post. Non-compliance triggers further notices and penalties.
What is a section 177 notice? A section 177 notice is an audit selection. Your return has been selected for a detailed examination of your income, deductions, assets, and wealth. The audit spans weeks or months. You must respond to all information requests and cooperate with the audit officer. If you want to challenge the audit findings, hire a lawyer.
What is a section 182 notice? A section 182 notice is a penalty or default surcharge for missing a deadline, failing to respond to a prior notice, or providing false information. The penalty is typically 7 to 10 days to object; 30 days to pay if you do not object. You may object with evidence or accept the penalty. A lawyer can help you appeal if the amount is disputed.
Can I ignore an FBR notice? No. Ignoring an FBR notice is a serious mistake. If you miss the deadline, the FBR issues a best-judgment assessment, freezes your bank accounts, or seizes assets. You will be charged interest and penalties on top. Always respond before the deadline, even if you disagree with the notice. Then appeal if necessary.
What happens if I cannot file my response on time? Some notices allow a request for extension before the deadline expires. This is not guaranteed, but you may write to the FBR explaining why you need more time. Extensions are rare and require a strong reason (e.g. you are hospitalized or traveling abroad). If you miss the deadline without an extension, the FBR treats it as non-compliance.
Do I need a lawyer to respond to every FBR notice? Not every notice requires a lawyer. For a section 114 or 176 notice, you may handle it yourself if you have the documents and understand what is required. For a section 122, 177, or 182 notice, hiring a lawyer is wise. For appeals at ATIR or the High Court, you must hire a Bar-Council lawyer; this is not optional.
When to reach out to a tax lawyer
If you have received an FBR notice and are unsure how to respond, do not delay. Tax deadlines are strict, and silence is costly. Contact us or call our Lahore office for immediate advice on your notice. We can review the notice, advise you on the next steps, and handle your response or appeal. Saeed Law Firm also offers guidance on how to file an income tax return in Pakistan and how to become a filer in Pakistan to help you avoid future notices.
Speak to a tax lawyer in Lahore
If you have received an FBR notice or are facing an audit, Saeed Law Firm has handled tax disputes in Lahore since 1975. We understand the FBR's procedures and can represent you at every stage: from responding to the initial notice to appealing at ATIR or the Lahore High Court. We offer a free initial consultation to discuss your case. Contact us to arrange a meeting, or call our office directly.
Saeed Law Firm, Y Block Main Market, Sector Y, DHA Phase 3, Lahore 54793. Phone: +92-319-4959420.