Sections 121 & 122
Assessment Time Limit Calculator
FBR has 5 years from the end of the financial year of your assessment to amend it, 1 year from a show-cause notice to pass the order, and 6 years after a tax year to make a best judgment assessment. A return filed on 30 September 2021 can be amended until 30 June 2027.
| Time limit | Last date |
|---|---|
| Amend the original assessment (s.122(2)) | 30 June 2027 |
| Further amend after the revised return (s.122(4)) | 30 June 2028 |
| Order after the show-cause notice (s.122(9)) | 14 May 2028 |
| Best judgment assessment (s.121(3)) | 30 June 2022 |
| Best judgment after a notice under the s.114(5) proviso | 30 June 2029 |
Reading the result
Is the notice I received time-barred?
Section 122(2): an assessment order cannot be amended after 5 years from the end of the financial year (30 June) in which it was issued or treated as issued. The clock runs from the order, not from the tax year the income belongs to. A complete return is treated as an assessment order issued on the day it was furnished (s.120(1)), so for most taxpayers the original assessment order date is the filing date; once FBR notifies the date under section 120(2A), where adjustments are made under (2A) the order date is the date they are complied with. A revised return is treated as an amended assessment order issued on the day it was furnished (s.122(3)). A return filed on 30 September 2021 was an order in the financial year ending 30 June 2022, so the limit is 30 June 2027.
A revision or amendment can reopen the window
Section 122(4): once an assessment has been amended (including by a revised return), it may be further amended, as many times as necessary, within the later of 5 years from the end of the financial year of the original order and 1 year from the end of the financial year of the amended order. Read literally, a revised return filed late in the window reopens it. In the example, the revised return filed on 10 August 2026 moves the limit to 30 June 2028.
The show-cause notice has its own clock
Section 122(9): no assessment may be amended without a hearing, and the order must be made within 1 year of the show-cause notice (Finance Act 2025; it was 180 days), or within a further period of no more than 90 days the Commissioner allows for reasons recorded in writing. The proviso applies to notices issued on or after 1 July 2021. Time during which the proceedings are adjourned because of a stay order, Alternative Dispute Resolution or agreed assessment proceedings under section 122D is left out of the count, and so are adjournments taken by the taxpayer up to 60 days (the page reads the 60-day cap as reaching only the taxpayer's adjournments). For a notice issued before the Finance Act 2025, whether the 1-year period or the earlier 180 days applies is not stated; the page shows both.
Best judgment assessments
Section 121: a best judgment assessment follows a failure to answer a notice to file a return (s.114(3), (4)) or a notice under section 117(3), to furnish a wealth statement, or to produce records for audit (s.121(1)); in the last case it can displace an assessment treated as made on a filed return. It can be issued only within 6 years after the end of the tax year (s.121(3); 5 before the Finance Act 2022). A notice to file can normally reach only the last five completed tax years (s.114(5)); for a person who has not filed for any of the last five, it can reach the last ten, and a best judgment assessment on such a notice must be issued within 2 years from the end of the tax year in which the notice was issued (proviso to s.121(3)). There is no time limit on the notice where the Commissioner records that the person has foreign income or foreign assets (second proviso to s.114(5)).
Where this stops
An assessment may be amended only on the basis of audit or definite information showing that income escaped assessment, was under-assessed or assessed at too low a rate, received excessive relief or refund, or was misclassified (s.122(5)), or where the Commissioner considers the order erroneous and prejudicial to revenue (s.122(5A)), within the same time limits (s.122(5B)). Being out of time can be raised in reply to the notice and in appeal against the order. The page works the dates out from the dates you enter: one year is taken to the same calendar date (29 February to 28 February), and extension and excluded days are added after it. It does not decide whether a stay or an adjournment counts, whether an assessment was complete, matters under the repealed 1979 Ordinance (s.122(4A)), a special or transitional tax year (s.74), or the separate limits for orders giving effect to appellate orders (s.124) and revisions (s.122A(5)). Days left are counted from your device's date.
FAQs
Assessment time limit FAQs
How long can FBR amend an income tax assessment?
Section 122(2): an assessment order cannot be amended after 5 years from the end of the financial year (30 June) in which it was issued or treated as issued. The clock runs from the order, not from the tax year the income belongs to. A return filed on 30 September 2021 can be amended until 30 June 2027.
When does the five-year period start?
A complete return is treated as an assessment order issued on the day it was furnished (s.120(1)), so for most taxpayers the original assessment order date is the filing date; once FBR notifies the date under section 120(2A), where adjustments are made under (2A) the order date is the date they are complied with. A revised return is treated as an amended assessment order issued on the day it was furnished (s.122(3)).
Can an amended assessment be amended again?
Section 122(4): once an assessment has been amended (including by a revised return), it may be further amended, as many times as necessary, within the later of 5 years from the end of the financial year of the original order and 1 year from the end of the financial year of the amended order. Read literally, a revised return filed late in the window reopens it. In the example, a revised return filed on 10 August 2026 moves the limit to 30 June 2028.
How long does the Commissioner have after a show-cause notice?
Section 122(9): no assessment may be amended without a hearing, and the order must be made within 1 year of the show-cause notice (Finance Act 2025; it was 180 days), or within a further period of no more than 90 days the Commissioner allows for reasons recorded in writing. The proviso applies to notices issued on or after 1 July 2021. Time during which the proceedings are adjourned because of a stay order, Alternative Dispute Resolution or agreed assessment proceedings under section 122D is left out of the count, and so are adjournments taken by the taxpayer up to 60 days (the page reads the 60-day cap as reaching only the taxpayer's adjournments).
What is the time limit for a best judgment assessment?
Section 121: a best judgment assessment follows a failure to answer a notice to file a return (s.114(3), (4)) or a notice under section 117(3), to furnish a wealth statement, or to produce records for audit (s.121(1)); in the last case it can displace an assessment treated as made on a filed return. It can be issued only within 6 years after the end of the tax year (s.121(3); 5 before the Finance Act 2022). A notice to file can normally reach only the last five completed tax years (s.114(5)); for a person who has not filed for any of the last five, it can reach the last ten, and a best judgment assessment on such a notice must be issued within 2 years from the end of the tax year in which the notice was issued (proviso to s.121(3)). There is no time limit on the notice where the Commissioner records that the person has foreign income or foreign assets (second proviso to s.114(5)).
On what grounds can an assessment be amended?
An assessment may be amended only on the basis of audit or definite information showing that income escaped assessment, was under-assessed or assessed at too low a rate, received excessive relief or refund, or was misclassified (s.122(5)), or where the Commissioner considers the order erroneous and prejudicial to revenue (s.122(5A)), within the same time limits (s.122(5B)).
What should I do if the notice is out of time?
Being out of time can be raised in reply to the notice and in appeal against the order.
Sources
Where the rules come from
Read in FBR’s Ordinance amended up to 30 June 2026 on .
Related tools
Appealing the amended order?
Check the deadline for each appeal forum.
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