Income tax · Notices, assessment and appeals
I received a notice under section 148 or 148A (now sections 280 and 281). What should I do?
Short answer
It means the Assessing Officer believes income for an earlier year escaped assessment. Usually you first get a show cause notice under section 148A with the information relied on, giving 7 to 30 days to reply. Reply in full and on time, check whether it is within the time limit (broadly 3 years from the end of the assessment year, or 5 years if the escaped income is ₹50 lakh or more), and take professional advice: this reply forms the record for any later challenge.
Reassessments for assessment year 2026-27 and earlier continue under the Income-tax Act, 1961, even though the 2025 Act is now in force. So a notice you receive today will normally quote the 1961 Act sections below. The matching sections of the Income-tax Act, 2025, which will apply to tax year 2026-27 onwards, are given in brackets.
| 1961 Act | 2025 Act | What it covers |
|---|---|---|
| Section 147 | Section 279 | Income escaping assessment |
| Section 148 | Section 280 | Notice for reassessment |
| Section 148A | Section 281 | Show cause notice and order before the section 148 notice |
| Section 149 | Section 282 | Time limits for the notice |
| Section 153 | Section 286 | Time limit for completing the assessment |
How reassessment works (notices from 1 September 2024)
- Show cause notice under section 148A(1) (now section 281). Unless the information comes from a search, a survey or certain other specified sources, the Assessing Officer must first issue a notice with the information suggesting that income has escaped, and give you at least 7 and at most 30 days to explain why reassessment should not start.
- Order under section 148A(3) (now section 281). After considering your reply, the officer decides whether it is a fit case.
- Notice under section 148 (now section 280), with the order, requiring a return for that year.
- Reassessment under section 147 (now section 279), which must be completed within the time limit set by section 153 (now section 286).
Time limits
Under section 149 of the 1961 Act, counted from the end of the relevant assessment year:
| Step | Ordinary cases | Escaped income of ₹50 lakh or more |
|---|---|---|
| Show cause notice under section 148A(1) | Within 3 years | Within 5 years |
| Notice under section 148 | Within 3 years and 3 months | Within 5 years and 3 months |
The longer period applies only if the income that escaped is represented by an asset, an expenditure, or entries in the books, of ₹50 lakh or more. A notice issued late, or by an officer without jurisdiction, can be challenged. Under section 282 of the 2025 Act, the limits for later years are counted from the end of the tax year instead.
What to do
- Check that the notice is genuine (its DIN, on the portal) and note the date of service and the reply date.
- Read the information relied on, usually from the AIS, an SFT report, or third-party data such as a property purchase, a cash deposit or a share sale.
- Collect the records for that year: the return, bank statements, the purchase or sale deed, and the source of funds.
- Reply in full within the time given. Explain with documents; do not simply deny facts the department can verify. Ask for an extension on the portal before the deadline if needed.
- After the section 148 notice, file the return within the time allowed, and ask for the reasons and the order under section 148A(3) if not already supplied.
Reassessment involves time limits, jurisdiction and legal questions that are often decisive. Take professional advice before the first reply, because it becomes the basis of any later appeal or writ petition.
Legal basis
- Sections 147, 148, 148A and 149, Income-tax Act, 1961, as substituted by the Finance (No. 2) Act, 2024 (notices from 1 September 2024)
- Sections 279, 280, 281 and 282, Income-tax Act, 2025 (the corresponding provisions, for tax year 2026-27 onwards)
Official sources
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