Income Tax Notice, Audit and Appeal in Bangladesh: Which Notice You Have Received, How to Reply, and Where to Appeal

In this guide: The notices and what each one means · How an audit runs (s.182) · Revised returns and paying what is due · The appeal ladder · Our approach when a notice arrives

The short answer

Find the section number on the notice. It tells you what is being asked and how long you have. A notice under s.172 requires a return you have not filed; under s.176 your return is incomplete and will be void unless you supply what is missing; under s.181 the system found an arithmetical difference or an incorrect claim and you may explain or revise; under s.182 your return has been selected for audit; under s.212 the Deputy Commissioner alleges that tax has been evaded. Each has a procedure and a clock, set out below. Reply in writing, within time, with documents; ask for an extension in writing before the date if you need one; and never ignore a notice, because silence leads to a best-judgment assessment under s.184 that is far harder to unwind than the original question.

The notices and what each one means

Two things people search for and will not find: there is no “s.280 notice” — s.280 sits in the penalty part of the Act, not the notice provisions — and there is no longer a Tax Ombudsman; the 2005 Act was repealed in 2011 and nothing replaced it. The s.212 power reaches back six years where a return was filed and assessed, and is unlimited where no return was filed; the 2026 amendments confirmed that undisclosed income older than six years can still be brought to charge.

How an audit runs (s.182)

Audit selection is by the Board under its own published method — since late 2024 an automated, risk-based selection, with a random component; the 2026 round selected 72,341 returns. A return cannot be selected within 60 days of filing, and the Deputy Commissioner must notify you within seven working days of the audit team being appointed.

1. Inquiry. The team has 60 days, extendable by 60, to examine the return, the books and third-party data (banks, land registry, card issuers, customs). Expect a s.200 request for bank statements, deeds, invoices and the wealth-statement working.
2. Draft report. You receive the findings and respond in writing. This is where the case is won: a reconciliation of every flagged item, with documents, usually narrows the report to one or two points.
3. Final report within 300 days of selection, and a notice under s.182(10) inviting a revised return with the tax and interest; the whole process must end within 24 months.
4. If you disagree, the officer proceeds to assessment under s.183 after a hearing, and you appeal (below).

The statute’s safe harbour, as enacted: a return showing income at least 15% higher than the previous year from the same sources, with evidence of exempt income, no donations received, no refund claim and the withholding obligations met, is not selectable. We are checking whether the 2026 Finance Acts altered that paragraph.

Revised returns and paying what is due

A self-assessment return may be revised once, within 180 days of filing and before selection for audit, on paying the shortfall with simple interest at 5% a month (s.180). An ordinary return may be revised before assessment but cannot reduce the liability shown in the original (s.175). After an audit report or a processing notice you may be invited to file a revised return under s.182(10) or s.181(2); the 2026 amendments also allow a revised return where an appellate order sets an assessment aside. A revised return that is accepted ends the matter; one that is not leads to assessment.

Penalties sit alongside: s.266 for failure to file, s.270 for non-compliance with a notice, and the concealment penalties in the same part. The amounts under s.270 are in the Act’s penalty part, which we are confirming against the 2026 text; the practice is that a prompt, documented reply to a notice is almost never penalised.

The appeal ladder

Company assessments, orders under s.213 and transfer-pricing cases go to the Commissioner (Appeals) only. The deposits (1% / 3% / 10%) are as enacted by the Finance Act 2026; the previous waiver and relaxation powers were removed at the same time. The Commissioner (Appeals) may now set an assessment aside, a revised return is permitted after a set-aside order, and ADR is available against Tribunal orders, not only pending appeals. On the assessment side, undisclosed income or expenditure found in a reassessment can be assessed beyond the six-year reach, reassessment extends to discontinued businesses, and assessment is mandatory for delayed returns and for returns selected for audit. We are confirming the enacted percentages against the gazette.

Alternative dispute resolution. The Act provides an ADR route, now governed by the Income Tax ADR Rules 2024, with an NBR-appointed facilitator and the leave of the forum where the appeal is pending; the 2026 amendments extended it to Tribunal orders. ADR suits a dispute about facts and figures rather than law, and a taxpayer who can live with a negotiated number. A settlement is binding and the tax must be paid as agreed.

Our approach when a notice arrives

We ask for three things on the first day: the notice itself, every return and statement for the years it mentions, and the bank statements for those years. From those we build a reconciliation before we write a word to the circle. A reply that explains the gap with documents, concedes what is genuinely owed and pays it, and contests only what is wrong, is the reply officers accept. Where the officer will not accept it, a well-prepared file is already most of the appeal.