SecProbe.io

March 2, 2015

Via E -mail
Jeffrey Potrzebowski
Chief Financial Officer
Bioanalytical Systems,  Inc.
2701 Kent Avenue
West Lafayette, Indiana  47906

Re: Bioanalytical Systems,  Inc.
 Form 10 -K for the Fiscal Year Ended Sept ember  30, 201 4
 Filed December 29 , 2014
Form 10 -Q for the Q uarterly Period Ended December 31, 2014
 Filed February 17, 2015
 File No. 000-23357

Dear Mr. Potrzebowski :

We have limited our review to only your fi nancial statements an d related disclosures  and
have the following comments .  In our comments, we ask you to provide us with information so
we may better understand your disclosure.

Please respond to this letter within 10 business days by  providing the req uested
information  or by advising us when you will provide the requested response.  If you do not
believe a comment  applies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label  CORRESP that keys your
response s to our comment s.

After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing s.

Form 10 -K for the Fiscal Year Ended September 30, 2014
Financial Statements

Note 4. Income (Loss) per Share, page 50

1. You state that you compute diluted earnings per share using the if -converted method
for warrants.  Please tell us why you use the if -converted method and not the treasury
stock method.   Reference supporting authoritative literature in your response.

Jeffrey Potrzebowski
Bioanalytical Systems , Inc.
March  2, 2015
Page 2

 Note 11. Segment Information, page 58

2. Please p rovide us proposed disclosure to be included in future periodic reports that
presents sales to external customers and long -lived assets located in the United Stat es
separately from other North American countries as specified by ASC 280 -10-50-41.

Form 10 -Q for the Quarterly Period E nded December 31, 2014
Liquidity and Capital Resources, page 18

3. Provide us proposed disclosure to be included in future periodic reports that explains
why days’ sales in accounts receivable increased to 59 days at December 31, 2014
from 49 days at September 30, 2014 (based on prior quarter’s revenue).

We urge all persons who are responsible for the accuracy and adequacy of the disc losure
in the filing s to be certain that the filin gs include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s dis closure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In responding to our comment s, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy and accurac y of the disclosure in the filing s;
 staff comment s or changes to disclosure in response to staff comment s do not foreclose
the Commission from taking any action with respect to the filing s; and
 the company may not assert staff commen ts as a defense in any proceeding initia ted by
the Commission or any person under the federal securities laws of the United States.

You may contact Lisa Vanjoske , Assistant Chief  Accountant, at (202) 551 -3614 or
Sharon Blume, Accounting Branch Chief, at (202) 551 -3474 if you have any questions regarding
the comment s. In this regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

  /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant