Representation in Reassessment Proceedings (Section 147)

Sections of the Income-tax Act, 2025 are shown next to the 1961 Act sections.

After a notice under Section 148 (Section 280 of the 2025 Act), the reassessment proceeds like a scrutiny assessment, but with additional legal issues of jurisdiction, limitation and sanction that can decide the case.

Income Tax, across India (faceless)

Overview

A reassessment must stay within the scope of the information and order under Section 148A2025 Act: s. 281. Additions on unrelated issues and orders on defective notices are frequently challenged.

When this applies

  • Notice u/s 1482025 Act: s. 280 issued after the 148A procedure
  • Reopening based on information from other agencies

Time limit

As stated in each notice. Reassessment orders are subject to statutory time limits.

Documents needed

  • 148A notice, reply, order and 148 notice
  • Return filed in response to 148
  • Evidence on the issues under enquiry

How we handle it

  1. Review jurisdiction, limitation and sanction
  2. Respond on merits with evidence while preserving legal objections
  3. Challenge additions beyond the scope of reopening
  4. Advise on appeal or writ where needed

Points to note

  • Legal objections must be raised at the earliest stage
  • Keep the record complete for appeal

What usually comes next

Frequently asked questions

Can reassessment be challenged in High Court?

Where the reopening is without jurisdiction, a writ petition is possible. This requires an advocate; we prepare the tax analysis and coordinate.

Official sources

Received a notice or an order?

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

Related services

← All Income Tax Assessments