TRW Insight / Bangladesh
The NBR now picks income tax returns for audit by software, publishes the list online and must finish within tighter time limits. What you produce at audit stage decides whether the dispute ends with a letter of disposal or an appeal.
Tax audit Bangladesh in 2026: how the system now works
Tax audit Bangladesh practice changed more between 2024 and 2026 than in the previous decade. The Income Tax Act 2023 replaced the 1984 Ordinance with a self-assessment system in which most returns are accepted as filed, and then gave the National Board of Revenue (NBR) a detailed, time-bound procedure for auditing the minority it selects. In September 2024 the NBR halted fresh audit selection altogether; in 2025 it restarted with random selection; and in April 2026 it moved to automated, risk-based selection with the list of chosen taxpayers published online. The Finance Act 2026 then shortened limitation periods and cut the deposits needed to appeal.
This guide explains the tax audit Bangladesh process from the taxpayer's side of the table: selection, notices, time limits, documents, best judgement assessment, representation before the NBR, and the routes of challenge through appeal, reference and ADR, with a short note on VAT audits.

Summary: Most income tax returns in Bangladesh are deemed assessed on filing under section 180 of the Income Tax Act 2023. The NBR then selects a minority for audit, now through an automated risk-based system. An audit runs through an inquiry team, an audit team and an audit curator, ends with a draft report and a request for a revised return, and only becomes an assessment if the findings are not accepted. Appeals lie to the Commissioner of Taxes (Appeals), the Taxes Appellate Tribunal and, on questions of law, the High Court Division, with ADR available alongside.
Key point: The single most important rule in a tax audit is evidential: the Commissioner of Taxes (Appeals) will not admit documents that were not produced before the Deputy Commissioner of Taxes unless you show sufficient cause for the omission. A weak response at audit stage usually means a weak appeal. Put the full record in front of the audit team the first time.
At a glance
Self-assessment
A compliant return filed with full payment is deemed assessed on filing under section 180 of the Income Tax Act 2023.
Automated selection
In April 2026 the NBR selected 72,341 returns through a risk-based automated system, 20 to 200 per tax circle.
Two-year window
A return may be selected for audit within two years from the end of the assessment year in which it was filed.
Lower appeal deposits
The Finance Act 2026 set pre-deposits at 1%, 3% and 10% at the three appellate levels and ended waivers.
ADR route
Income tax disputes can be settled through a facilitator-led ADR process, now also against orders already decided by the Tribunal.
Table of Contents
Self-assessment: the starting point for every tax audit Bangladesh taxpayers face
Under section 180 of the Income Tax Act 2023, where a self-assessment return is filed in compliance with section 169 and the tax is paid in accordance with sections 173 and 174, the taxpayer's income, tax and other liability for that assessment year is deemed to have been automatically completed.[1] Filing a complete return with full payment is the assessment; audit is the exception that reopens it.
The return form, e-return mechanics, the Tax Day and the incentives for early filing are covered in our guide to income tax return filing in Bangladesh, and the rates themselves in income tax rates in Bangladesh.
Return processing is not an audit
Section 181 requires the Deputy Commissioner of Taxes to process a self-assessment return for arithmetical errors and for incorrect claims apparent from the return itself, such as a deduction above a statutory cap.[1] If processing produces a different figure, the Deputy Commissioner must serve a notice with a computation sheet and give the taxpayer a chance to explain or to file a revised return and pay. If the taxpayer complies, a letter of acceptance follows within 90 days; if not, a demand notice must be served within six months of the processing notice.[1]
Revising a return before selection
A taxpayer who finds an error in a self-assessment return may file one revised return with a written statement of reasons. The right is lost after 180 days from the original filing, after a first revision, or once the original return has been selected for audit under section 182.[1] That last limit matters: once the selection list is published, the voluntary correction route closes and any correction has to be made inside the audit.
Returns that are assessed regardless of audit
Not every return enjoys the deemed-assessment treatment. According to PwC's summary of the post-2026 position, returns claiming a refund under self-assessment are automatically subject to scrutiny assessment, and assessment is mandatory for delayed returns and for returns filed after selection for audit.[4] [2] KPMG's 2026 summary likewise records that self-assessment returns showing a refund are selected for assessment by the Deputy Commissioner of Taxes upon hearing.[3]
How tax audit Bangladesh selection works in 2025-26 and 2026-27
Section 182(1) allows the Board, or a subordinate authority with the Board's approval, to select self-assessment and revised returns for audit "in the manner prescribed by the Board" and forward them to the Commissioner of Taxes concerned.[1] Two statutory guardrails apply. A return cannot be selected until 60 days have passed since it was filed, and it must be selected or approved for audit within two assessment years from the end of the assessment year in which it was filed.[1] [3]
The 2024 pause
Selection policy has been unusually volatile. On 9 September 2024 the NBR instructed field offices to stop selecting new returns for audit, describing the existing system as faulty after complaints that broad discretion under the audit guidelines caused harassment. Returns already selected continued through the normal process, and the Board said it would move from manual to digital selection.[5] In May 2026 the NBR chairman confirmed that tax and VAT audit selection had been virtually halted for two years until a proper risk-based mechanism was ready.[10]
Random selection in July 2025
The first restart came in July 2025. The NBR selected 15,494 returns for the 2023-24 tax year by choosing 0.5% of the returns filed in each tax circle through a digital random-selection method. Taxpayers whose returns had been selected for audit in the previous two years were excluded, to avoid repeated audits of the same files. The Board called this a stopgap pending fully automated risk-based selection.[7]
The August 2025 audit instructions
On 17 August 2025 the NBR issued new Income Tax Return Audit Instructions. One-third of all returns selected by any tax office must now come from taxpayers whose files have never been audited; returns showing zero income or low profit can be selected; and the informal practice of not auditing new taxpayers in their first year was dropped for high-risk new files. Individual files were to be chosen by software against defined criteria rather than by hand.[6] The same report noted that the NBR aims to audit about 5% of returns but has historically averaged about 2%, out of more than 25,000 company returns and over four million individual returns a year.[6]
Risk-based automated selection in April 2026
On 28 April 2026 the NBR announced a second phase for the 2023-24 tax year: 72,341 returns chosen by an automated system applying its Risk Based Audit Criterion, with between 20 and 200 taxpayers selected from each tax circle. The Board said there was no scope for manual intervention and published the selected Taxpayer Identification Numbers on its website so that taxpayers could check their status.[8] [13] Together the two phases put roughly 88,000 returns into audit for that year.[9]
What changed for 2026-27
Two shifts matter. First, the old statutory shelter in section 182(14), under which a return showing income at least 15% higher than the previous year generally could not be selected, no longer protects taxpayers: KPMG's 2026 summary records that self-assessment returns can now be selected irrespective of income growth.[3] [1] Second, the NBR chairman has said the Board is moving to a "faceless" administration built on online returns, risk-based audits and AI-driven data analysis, using a database of around 4.5 million online returns to benchmark taxpayers.[10]
The NBR does not publish its risk indicators. The Act itself, however, has long singled out the returns that attract closer scrutiny: those of banks, insurers and finance companies; returns showing exempt income or income taxed at reduced rates; refund claims; loans above Tk 5 lakh from non-bank sources without a supporting bank statement; and taxpayers with withholding tax failures.[1] Lifestyle and bank-transaction mismatches are the other common trigger for individuals.[9] If your self-assessment return falls into any of these categories, prepare as though selection is likely.

The tax audit Bangladesh process under section 182, step by step
Section 182 sets a structured and largely time-bound procedure. It separates those who gather information from those who decide, and excludes the taxpayer's own Deputy Commissioner and Inspector of Taxes from the audit and investigation teams.[1]
Teams and the notice of audit
Within seven working days of receiving the selection list, the Commissioner of Taxes must appoint an inquiry team, an audit team and an audit curator for each case. The Deputy Commissioner of Taxes must then, within seven working days of that order, issue one notice informing the taxpayer of the audit.[1] Each audit team has at least two auditors drawn from officers not below Assistant Commissioner rank, and each inquiry team at least two tax inspectors; the audit curator is an Additional or Joint Commissioner responsible for managing the case and the audit plan.[1]
The inquiry phase
The inquiry team collects information about income, expenses, assets, liabilities, transactions, financial statements, public records and related parties, and reports on the existence and nature of the taxpayer's sources of income. Its report is due within 60 days of the audit notice, extendable by up to a further 60 days.[1]
The audit phase
The audit team then works to the Board's audit manual. It may verify claims, collect books, contracts and records, review accounting and management information systems, interview related persons, ask for written statements and analyse market, financial and lifestyle data. It must send a draft audit report to the taxpayer and take a written explanation, then submit its final audit report to the audit curator within 300 days of the inquiry report.[1] The written explanation on the draft is the taxpayer's most important document in the whole process.
Closing the audit
Within seven working days the audit curator either recommends closure, where the return properly reflects the facts and no additional tax claim is possible, or authorises the Deputy Commissioner of Taxes to complete the audit. In the second case the Deputy Commissioner sends the audit report and a notice requiring one revised return reflecting the findings, with the resulting tax paid on or before filing. If the revised return reflects the findings and the tax is paid, the Deputy Commissioner accepts it and issues a letter of disposal of audit.[1]
Only if the taxpayer does not file, files a return that does not reflect the findings, or does not pay, may the Deputy Commissioner assess tax under section 183 or section 184. Even then, no assessment can be made until the investigation and audit phase has ended and the taxpayer has been notified of the audit report.[1] A prepared taxpayer therefore has two chances, at draft report and at revised return, to resolve issues before any assessment exists.
Confirm selection
Check the published TIN list and the audit notice, and note the date of filing, selection and service.
Test limitation
Check whether selection and any later notice fall within the statutory windows before engaging on the merits.
Build the record
Assemble an indexed file tying every line of the return to bank, contract, invoice and payment evidence.
Engage the inquiry team
Respond to information requests promptly and in writing, keeping copies of everything produced.
Answer the draft report
File a full written explanation on the draft audit report, with documents and legal argument.
Decide on the revised return
File one revised return reflecting accepted findings and pay the tax, or prepare to contest an assessment.
Choose the forum
If assessed, weigh appeal to the Commissioner of Taxes (Appeals) against ADR, and budget for pre-deposits.
Protect the timeline
Diary the 45, 60 and 90-day appeal limits and seek stays where recovery threatens.
Notices you may receive and what each one means
Not every letter from the tax office is a tax audit Bangladesh law would recognise as such. The Act uses several distinct notices, each with its own purpose and consequence, and identifying the section under which a notice is issued is the first step in answering it.
| Notice | Section | Purpose | What to do |
|---|---|---|---|
| Processing notice | s 181 | Arithmetical errors and apparent incorrect claims | Explain in writing or file a revised return and pay |
| Audit notice | s 182 | Informs the taxpayer the return is selected for audit | Prepare records and appoint a representative |
| Production notice | s 179 | Demands accounts, documents and electronic records | Produce by the stated date; up to three prior years |
| Hearing notice | s 183(3) | Requires attendance or evidence in support of the return | Attend or send an authorised representative |
| Escaped-income notice | s 212 | Reopens a year where tax is believed to have escaped | Check limitation; file and pay or contest |
| Revision proceedings | s 213 | Revises an erroneous order prejudicial to revenue | Use the hearing; appeal lies to the Commissioner (Appeals) |
| Withholding audit | s 186 | Tests deduction, deposit and certification of tax at source | Reconcile challans, certificates and returns |
Production of documents under section 179
The Deputy Commissioner of Taxes may, by written notice, require a taxpayer who has filed a return, or who has been asked to file one, to produce accounts, statements, documents, data or electronic records needed for audit or assessment, but not records earlier than three years before the income year. Records may be demanded in electronic form, and must be produced by the date the notice specifies.[1]
Hearing notices under section 183
Where the Deputy Commissioner considers the taxpayer's presence or further evidence necessary, section 183(3) requires a notice to appear, in person or by an authorised representative, or to produce evidence in support of the return. Further hearings may be called, and the notice must state the matters to be heard and the consequences of non-compliance. No expenditure may be disallowed without a hearing, and the assessment order must be notified within 30 days of being issued.[1]
Escaped-income notices under section 212
Where, from an audit, an assessment or any other source, the Deputy Commissioner has reason to believe that tax has escaped payment, section 212 allows a notice requiring a return for the relevant year and payment of the escaped amount. Escape is defined broadly to include understated income, excessive deductions or losses, wrongly claimed exemptions, misreported assets or expenditure and income taxed at too low a rate. If the taxpayer files within time, pays and addresses the issue, a letter of acceptance follows; otherwise the Deputy Commissioner proceeds to assessment.[1] Where the year was already assessed, the reassessment is confined to the issues stated in the notice.[1]
Revision and withholding audits
Two further procedures are easily missed. Under section 213 the Inspecting Additional Commissioner may revise an order of the Deputy Commissioner that is erroneous and prejudicial to the revenue, after a hearing, within four years of the order.[1] Separately, section 186 provides for audit of withholding tax returns filed under section 177, testing whether tax was deducted at the right rate, deposited on time and certified properly; no withholding return may be selected more than four years after the end of the year in which it was filed.[1] Our guide to withholding tax in Bangladesh covers the underlying obligations.
Service and the cost of ignoring a notice
Notices may be served by registered post, by official email to the taxpayer's specified address, or as a civil court summons, and receipt by an authorised representative counts as valid service.[1] Ignoring a notice is expensive. Failure without reasonable cause to comply with a notice under sections 167, 168, 179, 181, 183 or 212 can attract a penalty of up to the amount of tax chargeable on total income, and no penalty may be imposed without a hearing.[1]
Time limits for assessment, audit and reopening
Limitation is often the strongest point in a tax audit Bangladesh taxpayers face, and the one most often overlooked. Check the periods below against the dates of filing, selection and notice before drafting any response on the merits.
Selection and completion
Selection must occur within two assessment years from the end of the assessment year of filing.[1] As enacted and amended in 2024, section 197 then allowed two assessment years after selection to complete an audit. The Finance Act 2026 revised these limits. KPMG reports that the general period for return processing, audit cases and normal assessments has been reduced to 12 months, and that the audit of a self-assessment or revised return must now be completed within 12 months after the end of the assessment year; PwC describes the rule as completion within one year from the end of the year in which the selection notice was issued.[3] [4] [2]
Other completion periods
KPMG's 2026 table also lists 12 months from the notice for income-escaping assessments, five years from the assessment year for transfer pricing cases, 90 days from communication to the Deputy Commissioner for fresh assessments after a set-aside, and 45 days for revised orders.[3] Any period during which proceedings were stayed by a court, tribunal or other authority is excluded when computing limitation.[1]
Reopening a closed year
A section 212 notice can be issued at any time where no return was filed and no assessment made for the year, and otherwise for any year back to the sixth preceding assessment year. Undisclosed wealth acquired earlier than that is deemed acquired in the sixth year.[1] The Finance Act 2026 widened this further: undisclosed income or expenditure detected in a reassessment can now be assessed even if older than six years, and reassessment extends to discontinued businesses.[2] A return filed in response to a reassessment notice is now treated as a delayed return, carrying additional tax of 15% of tax payable or Tk 10,000, whichever is higher.[2]

Documents to prepare for a tax audit Bangladesh officers will examine
An audit is won or lost on documents. The audit team tests each figure in the self-assessment return against third-party evidence, and anything not produced now may never be admitted on appeal.[1] Build a single indexed file that ties every line of the return to its support.
Individuals
- Salary certificates and tax deduction certificates for every source.
- Bank statements for all accounts, with explanations for large deposits or withdrawals.
- Fixed deposit receipts, savings certificates and investment records.
- Purchase and sale deeds for land or flats, and loan documents.
- Business accounts and records where there is business income.
- Tax payment challans and the statements of assets, liabilities and lifestyle expenses filed with the return.
Officers test whether declared income is consistent with spending and asset purchases, so prepare a short cash-flow reconciliation in advance.[9]
Companies and other entities
- Audited financial statements and the certified income computation statement filed with the return.[4]
- The ledger and a reconciliation of accounting profit to taxable income, with contracts, invoices and payment evidence for material and related-party expenses.
- Withholding tax returns, deposit challans and certificates issued to payees.
- Transfer pricing documentation for international transactions with associated enterprises.
- VAT returns and purchase and sales registers, which officers increasingly reconcile with income tax figures.
How long to keep records
The Finance Act 2026 tied income tax record retention to company law: companies keep supporting records for the period the Companies Act 1994 prescribes and other taxpayers for six years.[4] Section 181(5) of the Companies Act sets that period at not less than twelve years before the current year.[12] Our tax compliance checklist for Bangladesh sets out the annual retention and filing routine; this guide assumes it has been followed and focuses on using the records once a notice arrives.
Best judgement assessment and how to avoid it
A best judgement assessment is the Deputy Commissioner's estimate of tax when the taxpayer has not engaged. Section 184 allows it where a person has failed to comply with a notice to file a return and has filed none, or has failed to comply with a notice under sections 172, 175, 183(3) or (5), 193 or 212.[1] Section 182(12) also routes failed audits to section 183 or 184, and section 183(8) allows best judgement where a hearing notice is ignored.[1]
The Act requires the Deputy Commissioner to consider the facts and evaluate the legal and factual aspects before fixing best judgement tax, and to notify the order in writing or electronically within 30 days.[1]
Why it is so damaging
Three features make best judgement assessments hard to unwind. First, where no return was filed, an appeal is not admissible unless at least 10% of the tax determined has been paid.[1] Second, the Commissioner of Taxes (Appeals) will not admit evidence that was not produced before the Deputy Commissioner unless the taxpayer was prevented by sufficient cause.[1] Third, an order of assessment may be set aside on appeal only where the notice was not properly served.[1]
Practical safeguards
Monitor the email address registered with the NBR, because electronic service is valid. If a deadline cannot be met, apply in writing for more time before it expires and keep proof. Attend every hearing, in person or by an authorised representative, and file indexed written submissions so the record shows exactly what was produced.
Representation before the NBR: who may act for you
Section 327 allows any taxpayer entitled or required to appear before an income tax authority or the Taxes Appellate Tribunal to appear through an authorised representative, except where personal attendance is specifically required.[1] The representative must be authorised in writing and be a close family member, a full-time regular employee, or a "tax lawyer".
A tax lawyer for this purpose includes an advocate enrolled with the Bangladesh Bar Council, a practising chartered accountant, cost and management accountant or chartered secretary, a former income tax authority of at least five years' service not below Deputy Commissioner rank, or a person certified as a tax lawyer by the Board, and every tax lawyer must belong to a Taxes Bar Association registered with the Board.[1]
What an NBR lawyer adds
During the inquiry and audit phases the work is largely evidential: assembling records, reconciling figures and answering the draft audit report. As soon as a legal question appears, such as the characterisation of income, the deductibility of a related-party charge, an exemption's conditions, limitation or service, the written explanation should be framed with the appeal in mind. That is where counsel experienced before the Commissioner of Taxes (Appeals), the Taxes Appellate Tribunal and the High Court Division adds most value, because the issues and evidence fixed at audit define what can be argued later.
TRW's tax disputes practice acts on audits, hearings, appeals, references and ADR, working alongside the client's auditors and in-house finance team.
Deputy Commissioner of Taxes
Issues the audit notice, hearing notices and section 212 notices, and makes any assessment.
Inquiry team, audit team and audit curator
Gather information, audit the return and recommend closure or further action under section 182.
Inspecting Additional Commissioner
May revise an erroneous order prejudicial to revenue within four years under section 213.
Commissioner of Taxes (Appeals)
Hears appeals within 45 days of the demand notice; deemed allowed after 150 days.
Taxes Appellate Tribunal
Hears appeals within 60 days of the first appellate order; deemed allowed after 180 days.
High Court Division
Decides questions of law referred within 90 days of the Tribunal's order.
Challenging the outcome: appeals after a tax audit
If an audit ends in an assessment you do not accept, the Income Tax Act 2023 provides a three-tier appellate ladder with a final appeal to the Appellate Division. Each tier has its own deadline, fee and pre-deposit, and the Finance Act 2026 changed the deposits significantly.[2]
Commissioner of Taxes (Appeals)
Section 286 allows an appeal against an assessment, the computation of tax, loss set-off, penalty or interest, surcharge, refund and tax credit. Appeals by companies, against section 213 revision orders and against international-transaction adjustments go only to the Commissioner of Taxes (Appeals).[1] The appeal must be filed within 45 days of service of the demand notice, with a fee of Tk 200, and is not admissible unless the admitted tax liability has been paid.[1] From 2026-27 a pre-deposit of 1% of the disputed tax also applies at this level, where previously there was none.[2] [3]
The appellate authority may confirm, reduce, enhance, set aside or annul the assessment, but may not enhance without giving the appellant a chance to show cause. If no order is made within 150 days from the end of the month in which the appeal was filed, the appeal is deemed allowed.[1] The Finance Act 2026 also expressly confirmed the appellate authority's power to set aside cases.[2]
Taxes Appellate Tribunal
Either the taxpayer or, with the Commissioner's approval, the Deputy Commissioner may appeal to the Taxes Appellate Tribunal within 60 days of communication of the first appellate order. The taxpayer's appeal carries a fee of Tk 1,000.[1] The Finance Act 2026 cut the pre-deposit from 10% to 3% of the disputed tax, and the discretion to waive or reduce it has been discontinued.[2] A taxpayer's appeal is deemed allowed if the Tribunal makes no order within 180 days from the end of the month of filing, or 240 days where a third member is appointed after a split decision.[1]
Reference to the High Court Division
Within 90 days of receiving the Tribunal's order, either side may refer a question of law arising from it to the High Court Division. The taxpayer pays a fee of Tk 2,000, and the pre-deposit, previously 15% or 25% depending on the size of the demand, is now 10% under the Finance Act 2026, with no waiver.[1] [2] The reference is heard by a bench of at least two judges; section 5 of the Limitation Act 1908 applies; and tax remains payable under the assessment unless the High Court Division stays recovery.[1] A further appeal lies to the Appellate Division where the High Court Division certifies the case as fit for appeal.[1]
The reference route is confined to law. Findings of fact made by the Tribunal are, in practice, final, which is another reason to build the factual record at audit and first appeal. Our guide to the High Court Division of Bangladesh explains how the court is organised.
Recovery while an appeal is pending
While an appeal against an assessment is undisposed of, the Deputy Commissioner must treat the taxpayer as not in default.[1] That protection does not extend to a High Court reference, where a stay must be sought from the court.[1]

Alternative dispute resolution for income tax disputes
Chapter III of Part 20 of the Income Tax Act 2023 creates a statutory ADR route for income tax disputes, and it is often the fastest way to close an audit-driven assessment.[1] A "dispute" for this purpose is an objection to an assessment, or an appellate order, that fixes income above the amount declared in the return. The taxpayer may apply where the dispute is pending before an appellate income tax authority, the Tribunal or the Supreme Court, though a matter already brought as a writ petition is excluded and permission of the court is needed for a case pending there.[1]
How the process runs
The taxpayer must have paid the admitted tax liability for the year, and must file a statement of documents, evidence and legal basis with the application. A facilitator appointed by the Board conducts the process between the taxpayer, alone or with an authorised representative, and a Commissioner's representative not below Deputy Commissioner rank.[1] A departmental appeal or reference on the same year is stayed while the ADR application is pending.[1] If no agreement is reached within three months from the end of the month of application, none is deemed to have been reached.[1]
Effect of an agreement
An agreement signed by the taxpayer, the Commissioner's representative and the facilitator binds both sides and cannot be challenged before any authority, tribunal or court, though it is void if obtained by fraud or misrepresentation and is subject to post-verification by the Board.[1] If ADR fails, the taxpayer may still appeal, and the time spent in ADR is excluded from limitation.[1] KPMG notes that the process is governed by the Income Tax Alternative Dispute Resolution Rules 2024 and that payment under a settlement is capped at six months.[3]
The 2026 changes
The Finance Act 2026 made ADR available against orders already disposed of by the Tribunal, not only pending appeals, introduced a mechanism to involve the NBR more directly, and tightened recovery of tax agreed in ADR.[2] For a broader view of mediation and arbitration outside tax, see our guide to alternative dispute resolution in Bangladesh.
VAT audits: a parallel track
VAT is audited separately from income tax, by different officers under the Value Added Tax and Supplementary Duty Act 2012, and a business can face both at once. Section 90 empowers the Commissioner or the Director General to audit and investigate all affairs of a taxpayer's economic activities to prevent evasion, following an audit manual, and to fix any liability and interest the audit report identifies.[11] Authorised officers may demand information and documents, copy, seize or seal records and, in prescribed cases, freeze bank accounts.[11]
Three protections are worth knowing. A registered person may not be audited twice for the same tax period unless the Commissioner has reliable information of fraud through false information or fake documents; a tax determination generally cannot be made more than five years after the tax period, absent non-filing, fraud or concealment; and the Finance Act 2026 codified VAT audit timelines, with documents due within two months of the notice, a possible one-month extension, and completion expected within one year of submission.[11] [2] VAT appeal pre-deposits fell to 1% before the Commissioner (Appeals) and the Appellate Tribunal and 2% before the High Court Division.[2]
Registration, Mushak forms, input tax credit, the return calendar and the penalty schedule are covered in our guide to VAT compliance in Bangladesh. Where an income tax audit and a VAT audit overlap, make sure the two responses tell the same story about turnover and expenses.
Common mistakes that turn a tax audit into a tax dispute
- Treating the draft audit report as a formality. The written explanation on the draft is the taxpayer's best chance to correct the findings before they become the basis of a demand.
- Holding back documents for the appeal. The first appellate authority will not admit new evidence without sufficient cause, so a strategy of "saving" documents usually fails.[1]
- Missing a notice. Email service is valid, and non-compliance invites both a penalty and a best judgement assessment.[1]
- Filing a revised return that does not match the findings. A revised return that only partly reflects the audit report allows the Deputy Commissioner to proceed to assessment.[1]
- Not budgeting for pre-deposits. Since the Finance Act 2026, the 1%, 3% and 10% deposits apply with no waiver.[2]
Where this guide fits in TRW's tax coverage
Pre-filing obligations are covered elsewhere: the annual calendar in our tax compliance checklist, company rates in corporate income tax in Bangladesh, and the overall framework in tax law in Bangladesh. For ongoing compliance support, see TRW's tax compliance practice.
The direction of travel for tax audit Bangladesh practice in 2026-27 is clear: fewer, better-targeted audits chosen by software, shorter limitation periods, cheaper appeals and a stronger ADR route, set against wider reassessment powers for undisclosed income.
Frequently asked questions
How do I know if my return has been selected for audit?
Does selection for a tax audit Bangladesh taxpayers receive mean extra tax is due?
How long does the NBR have to select a return for audit?
Can I revise my return after it is selected for audit?
Not voluntarily. The right to file a revised return under section 180 ends once the return is selected for audit. Inside the audit, however, you will be asked to file one revised return reflecting the audit findings.[1]
How far back can the tax authority reopen a year?
What is a best judgement assessment?
It is an assessment made by the Deputy Commissioner of Taxes under section 184 when a taxpayer fails to file a return or to comply with specified notices, including hearing notices. It must be notified within 30 days of the order.[1]
What is the deadline to appeal an assessment?
45 days from service of the demand notice to the Commissioner of Taxes (Appeals), 60 days from the first appellate order to the Taxes Appellate Tribunal, and 90 days from the Tribunal's order for a reference to the High Court Division.[1]
How much must be deposited to appeal in 2026-27?
Who can represent me before the NBR?
An authorised representative under section 327: a close relative, a full-time employee, or a tax lawyer, which includes an advocate, a practising chartered accountant, cost and management accountant or chartered secretary, certain former tax officials and persons certified by the Board.[1]
Is an ADR settlement final?
Yes. A signed ADR agreement binds both sides and cannot be challenged before any authority, tribunal or court, unless it was obtained by fraud or misrepresentation. If no agreement is reached, you may still appeal.[1]
Source register
Primary legal and regulatory sources
Materials checked on 20 October 2026. Confirm the current official text before relying on any provision.
- Income Tax Act 2023 (Act No. XII of 2023), authentic English text, SRO No. 404-Law/2025 — National Board of Revenue
- PwC Bangladesh, 2026 — Finance Act 2026: Key Amendments
- KPMG in Bangladesh (Rahman Rahman Huq) — Bangladesh Tax 2026
- PwC Worldwide Tax Summaries — Bangladesh: Corporate tax administration (reviewed 31 July 2026)
- The Financial Express, 9 September 2024 — NBR asks taxmen not to select tax return afresh for auditing
- The Business Standard, 18 August 2025 — Never-audited taxpayers must account for one-third of audit selection
- The Financial Express (UNB), 16 July 2025 — NBR picks 15,494 tax files for audit in random move on evasion
- The Business Standard, 28 April 2026 — NBR selects 72,341 tax returns for automated audit
- Prothom Alo English, 17 May 2026 — What to do if income tax return is selected for audit
- The Business Standard, 16 May 2026 — NBR chief vows 'faceless' tax system to curb harassment
- Value Added Tax and Supplementary Duty Act 2012 — Authentic English Text (Laws of Bangladesh)
- Companies Act 1994, section 181 (books of account and preservation) — Laws of Bangladesh
- Dhaka Tribune, 28 April 2026 — NBR selects 72,341 returns for audit
Related TRW assistance
Move from information to a defined next step
TRW represents taxpayers through income tax and VAT audits, hearings, appeals to the Commissioner of Taxes (Appeals) and the Taxes Appellate Tribunal, High Court references and ADR. Explore our tax disputes practice or contact TRW to discuss a notice you have received.