Reassessment Notice under Sections 281 and 280 of the Income-tax Act, 2025

Before reopening an earlier tax year, the Assessing Officer must follow the procedure in Section 281 of the Income-tax Act, 2025, which includes giving you a chance to explain. If the officer decides to proceed, a notice under Section 280 follows, and the reassessment is made under Section 279. These replace Sections 148A, 148 and 147 of the 1961 Act.

Income Tax, Income-tax Act 2025, across India

Income-tax Act, 2025

This page is for notices and orders under the Income-tax Act, 2025. If yours names the Income-tax Act, 1961, see Reassessment Notice u/s 148A / 148 (1961 Act). Not sure which Act applies? The heading of the notice names it, or call us.

What this notice means

Reassessment means the department believes income chargeable to tax has escaped assessment. The Section 281 stage is the most important opportunity to stop the reopening. A reply that deals with the facts, the time limit and the approval required can lead to the proceedings being dropped.

Common reasons it is issued

  • Information from the annual information statement, TDS or financial transaction reports
  • Cash deposits, property or share transactions flagged by the system
  • Information from a search, survey or another taxpayer’s case
  • Audit objections on an earlier assessment

Time limit to respond

Section 282 sets the time limits. A show cause notice under Section 281 cannot be issued after four years from the end of the relevant tax year, or six years where the escaped income is ₹50 lakh or more. The notice under Section 280 cannot be issued after four years and three months, or six years and three months in the ₹50 lakh cases. No notice under either section can be issued within one year from the end of the tax year. The reply to the Section 281 show cause notice must be filed within the time given in it. We check limitation and approval in every case, as many notices fail on these grounds.

Documents to keep ready

  • The show cause notice with the information relied upon
  • Return, computation and any assessment order of that year
  • Bank statements and documents explaining the flagged transaction
  • Proof of the source of any deposit or investment

How we handle it

  1. Check the Act applied, the time limit and the approval obtained
  2. Ask for any material relied upon that was not supplied
  3. File a reply on facts with evidence, and legal objections where available
  4. After a Section 280 notice, file the return in response and contest the reassessment
  5. Consider a writ or appeal where the reopening lacks jurisdiction

Points to note

  • Do not let the show cause notice go unanswered. It is your strongest protection
  • Which Act applies depends on the year being reopened. Old years generally stay under the 1961 Act
  • Limitation and approval defects are common. Get them checked

What usually comes next

Frequently asked questions

Which Act applies to reopening an old year?

Years up to assessment year 2026-27 are generally reopened under the 1961 Act provisions, so the notice will cite Sections 148A and 148. Tax year 2026-27 onwards falls under Sections 279 to 286 of the 2025 Act, with the time limits for notices in Section 282.

Can reassessment be stopped at the show cause stage?

Yes. If the reply shows that no income escaped assessment, or that the notice is time-barred or lacks proper approval, the officer may drop the matter.

Official sources

Received a notice or an order?

Call us to talk it through. Keep the notice and its response date handy.

Related services

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