Reply to Reassessment Notice u/s 148A and 148

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

Before reopening an assessment, the Assessing Officer must give you an opportunity to explain through a show cause notice under Section 148A2025 Act: s. 281. If the officer is not satisfied, an order is passed and a notice under Section 1482025 Act: s. 280 follows. Under the Income-tax Act, 2025, these provisions correspond to Section 279 (reassessment), Section 280 (notice) and Section 281 (procedure before the notice), with the time limits in Section 282.

Income Tax, across India (faceless)

Income-tax Act, 1961

This page is for notices and orders under the Income-tax Act, 1961. If yours names the Income-tax Act, 2025, see Reassessment u/s 281 / 280 (2025 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 that income chargeable to tax has escaped assessment for an earlier year. The 148A stage is the most important opportunity to stop the reopening. A well-drafted reply on facts, limitation and jurisdiction can result in the proceedings being dropped.

Common reasons it is issued

  • Information from AIS, SFT, TDS or other agencies about transactions not reflected in the return
  • Cash deposits, property transactions or share transactions flagged by the system
  • Information from a search, survey or another taxpayer’s case
  • Audit objections raised on an earlier assessment

Time limit to respond

Under Section 1492025 Act: s. 282 of the 1961 Act (substituted by the Finance (No. 2) Act, 2024 from 1 September 2024), a show cause notice under Section 148A2025 Act: s. 281 cannot be issued after three years from the end of the relevant assessment year, or five years where the escaped income is ₹50 lakh or more. The notice under Section 1482025 Act: s. 280 cannot be issued after three years and three months, or five years and three months in the ₹50 lakh cases. The reply to a 148A notice must be filed within the time given in the notice. Check limitation and sanction carefully, as many notices fail on these grounds.

Documents to keep ready

  • The 148A notice with the information and material relied upon
  • Return, computation and assessment order (if any) of that year
  • Bank statements and documents explaining the flagged transaction
  • Proof of source for any deposit or investment

How we handle it

  1. Check limitation, approval of the specified authority, and whether the information was supplied
  2. Prepare a reply on facts with evidence, and legal objections where available
  3. After a 148 notice, file the return in response and seek the reasons and the 148A order
  4. File objections and respond to the reassessment notices that follow
  5. Evaluate a writ or appeal where the reopening is without jurisdiction

Points to note

  • Ask for all the material relied upon if it is not attached to the notice
  • Respond within time. The 148A reply is your strongest protection
  • Limitation and sanction defects are common. Get them checked

What usually comes next

Frequently asked questions

Can reassessment be stopped at the 148A stage?

Yes. If your reply shows that no income escaped assessment, or that the notice is time-barred or without proper approval, the officer may drop the proceedings.

Should I file a return after the 148 notice?

Yes, a return in response to the 148 notice should be filed within the time allowed. Not filing can lead to a best judgment assessment.

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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