Via Facsimile and U.S. Mail
Mail Stop 6010


March 14, 2006


Mr. Peter T. Kissinger
President, Chairman and CEO
Bioanalytical Systems, Inc.
2701 Kent Avenue
West Lafayette, Indiana  47906

      Re:	Bioanalytical Systems, Inc.
		Form 10-K for Fiscal Year Ended September 30, 2005
		Filed January 18, 2006
	File No.  0-23357

Dear Mr. Kissinger:

      On February 21, 2006, we received your letter February 16,
2006
letter in response to our February 9, 2006 letter.  We have
reviewed
your letter and have the following comments.  Where indicated, we
think you should revise your documents in response to these
comments.
If you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is unnecessary. Please be
as
detailed as necessary in your explanation.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended September 30, 2005

Management`s Discussion and Analysis, page 17
Liquidity and Capital Resources, page 22
Comparative Cash Flow Analysis, page 22
1. Please revise your filing to provide the disclosure provided in
your response to our comment 1.


Note 3. Acquisitions, page 40
2. Please refer to your response to our comment 2. It does not
appear
that the lab sites meet the definition of an intangible asset as
defined in FAS 142.  This asset would appear to be property and
equipment that should be depreciated over its estimated useful
life
in accordance with your accounting policy disclosed in Note 1.h.
Please revise your filing or tell us why you believe a revision is
not applicable.
*    *    *    *
      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the
amendments to expedite our review. Please furnish a cover letter
with
your amendments that keys your responses to our comments and
provides
any requested information. Detailed cover letters greatly
facilitate
our review.  Please file the letter on EDGAR under the form type
label CORRESP.  Please understand that we may have additional
comments after reviewing your amendment and responses to our
comments.

      You may contact Sasha Parikh, Staff Accountant, at (202)
551-
3627 or Mary Mast, Review Accountant, at (202) 551-3613 if you
have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 551-3679.

							Sincerely,


							Jim B. Rosenberg
							Senior Assistant Chief
Accountant



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Peter T. Kissinger
Bioanalytical Systems, Inc.
March 14, 2006
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