FBR Issues Clarification on Balance Sheet Submission for Businesses (Despite SRO 350 Postponement)

The Federal Board of Revenue (FBR) has issued a new document clarifying questions raised by taxpayers regarding a recent regulation on balance sheet submission (SRO 350 issued on March 7, 2024). It’s important to note that while these clarifications are being issued, reports indicate the Prime Minister has directed a postponement of SRO 350.

Key Points of the Clarification

  • Automatic Approval: Balance sheets submitted electronically will receive automatic approval. Commissioners will no longer need to manually review each submission.
  • Updating Balance Sheets: Taxpayers can modify their submitted balance sheets at any time. However, FBR recommends doing so only once per month.
  • Scrutiny by Tax Officers: While automatic approval is in place, tax officers can still request clarifications or question any discrepancies in the balance sheet.
  • Deadline for Response: Taxpayers must respond promptly to any inquiries from tax officers to avoid delays in tax return processing.
  • Use of Accurate Data: The importance of using accurate and up-to-date data when preparing the balance sheet is emphasized. This ensures a smooth tax return filing process and avoids unnecessary delays or inquiries from FBR.
  • Retroactive Implementation: The clarification applies to balance sheets already submitted. Taxpayers can update these if necessary.


Prior to this clarification, concerns existed about the burden placed on businesses, especially smaller ones, with the new balance sheet submission requirement. Additionally, the lack of a clear deadline for submission and the process for updating the balance sheet caused confusion.

Impact on Businesses:

The automatic approval system and the ability to update the balance sheet should streamline the process for businesses. However, businesses should still be prepared to answer any questions that may arise from tax officers.

FBR’s Challenges:

The automatic approval system represents a shift in processes for FBR and may require adjustments as they adapt to the new workload.


The FBR’s clarification addresses key concerns regarding balance sheet submission, even though the implementation of SRO 350 itself may be postponed. Businesses are encouraged to carefully review the document and ensure they are using accurate data when preparing their balance sheets. They should also stay informed about any further developments regarding SRO 350.

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