If FBR has emailed or posted a notice asking for your tax returns for 2022, 2023, 2024 and 2025, you are looking at a Section 114(4) notice, and the most common trigger is a recently created NTN. The notice is automated and it goes to thousands of people in the same position. It is not an accusation, but it is not ignorable either: the lawful fix is to file the returns it names, which for most students and new earners are nil returns that close the matter completely.
Key facts from the section itself:
- Section 114(4) lets the Commissioner require, by notice in writing, any person who was required to file a return for a tax year but did not, to file it within 30 days of service of the notice (or the period the notice allows).
- Section 114(5) limits the reach: normally the last five completed tax years. If you filed none of the last five, the notice can cover up to the last ten completed tax years.
- The time limit does not apply where the Commissioner records reasons that the person has foreign income or foreign assets.
- A person who has obtained an NTN is among the persons required to furnish a return under Section 114(1), which is why registration itself brings the earlier years into view.
Why the notice arrives right after a new NTN
The sequence confuses people because it runs backwards. You register, perhaps because a job, a bank account, a car purchase or a client required an NTN. Registration puts you inside the system with a start date of now, but the system's checks run backwards from that point: it can see bank activity, vehicle and property records and withholding credits from earlier years against a person who, on paper, has never filed anything.
From FBR's side this is not personal. A fresh NTN with silent earlier years looks identical whether the person was a student with no income or a trader who never filed. The 114(4) notice is how the department asks which one you are. Your answer is the returns themselves.
What to file for each year the notice names
Work year by year, and let each year's facts decide that year's return:
- Years with no income, or income below the taxable limit. File a nil return. For an individual, the basic threshold under which no tax is chargeable has been Rs 600,000 of taxable income in recent years, and a student with no income at all is simply at zero. A nil return is a real return: it states the position formally instead of leaving the year blank.
- The wealth statement must tell the truth. This is where people make their one avoidable mistake. If your bank account held a couple of hundred thousand rupees in those years, the wealth statement should show that balance, not zero. A modest balance honestly declared creates no tax and no problem. Invented zeros, copied from someone else's return, create a wealth record that contradicts your own bank statements and will not reconcile with the following year.
- Years where income was actually taxable. File the true return for that year and pay the tax with it. Voluntary filing in response to the notice is materially cheaper than the alternative: if the department proceeds without your return, it can frame a best judgment assessment under Section 121 on its own estimate of your income, and penalties under Section 182 attach to the default. A correct return filed late almost always beats an estimated assessment defended later.
Example 1. You were a university student until 2025, opened your NTN in 2026 when you started earning, and received a notice covering 2022 to 2025. Your bank balance in those years stayed around two to three hundred thousand rupees, gifts and pocket money from family. The response is four nil returns, each with a wealth statement showing the actual closing balance of that year, increasing from one year to the next roughly as the account did. No tax arises on any of them, and the notice is answered in full.
Example 2. Same notice, but in 2024 you were already freelancing and earned about Rs 900,000 that year, above the taxable threshold, and never filed. That year's return is not nil. It declares the income, claims the withholding the bank deducted, and pays the balance. Filing it inside the notice period, before any assessment, is the cheapest version of this outcome you will ever be offered.
The response, step by step
1. Open the notice in IRIS and note exactly which tax years it names and the deadline it sets. Work to that list, not to your memory of it.
2. For each year, prepare the return for that year in IRIS. Past years are filed under their own tax year, with that year's forms and rates.
3. Attach the wealth statement for each year, with opening wealth for the earliest year set to your actual position then, and each later year flowing from the one before.
4. Submit each return and save the acknowledgment. A submitted return for a named year is what closes that year in the notice.
5. If any year shows tax payable, pay it through the normal PSID route and keep the CPR with the return record.
6. If the notice gave a hearing or compliance date in the notice tab, confirm compliance there as well where IRIS asks for it.
If a year's facts are genuinely complicated (business income, property, foreign receipts), that year deserves proper preparation rather than a hurried nil. Filing a false nil to make a notice disappear converts a paperwork problem into a misdeclaration, which is a worse category of problem. Our guide on what happens after a missed deadline covers the late filing consequences in more detail, and the ATL surcharge guide explains how late filing interacts with your Active Taxpayer List status.
Mistakes that turn a routine notice into a real problem
Ignoring it because "it is just an email". The notice is also in your IRIS account, and its clock runs from service, not from when you read it. Ignoring is the only response that reliably makes things worse.
Filing only the current year. The notice names specific years; a 2026 return does not answer a demand for 2023.
Copying a friend's nil return wholesale, including their wealth figures. Your bank record is yours, and it is the first thing any later check will compare.
Declaring zero wealth for years when you demonstrably held an account with a balance. Honest small numbers are safe. Round, invented zeros are the one detail in a nil return that can be disproved from a single statement.
FAQs
I had no income in those years. Do I still have to file?
Yes, once a Section 114(4) notice names those years, filing is the required response, and a nil return is the correct filing for a year with no taxable income. The notice exists precisely because the department cannot see from outside whether your missing years were empty or taxable. The nil return is how you put "empty" on record.
How many years back can FBR legally ask for?
Under Section 114(5), one or more of the last five completed tax years. If you filed none of the last five, up to the last ten completed tax years. The only open-ended case is where the Commissioner records reasons that you have foreign income or foreign assets; for ordinary domestic cases, five and ten are the limits.
Last updated: October 19, 2026
Disclaimer: This article is general guidance on Section 114(4) notices. If your notice covers years with substantial business, property or foreign income, the returns for those years should be prepared on their actual facts, with advice where needed.
Official references: FBR; IRIS portal; Income Tax Ordinance 2001, Sections 114(1), 114(4) and 114(5).