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Reassessment notice under sections 148A and 148: time limits and how to reply

A 148A show cause notice is your chance to stop a reassessment before it starts. The time limit is often the strongest defence.

Reviewed by Vijay Dhawan, Managing Partner, LexVerge LLP, on · Published

Quick answer

Before reopening an assessment, the officer must serve a show cause notice under section 148A with the information he relies on and hear you. Only then can a section 148 notice follow, generally within three years and three months from the end of the assessment year, or up to five years and three months only if escaped income is ₹50 lakh or more and he holds evidence of it. Reply to the 148A notice within the time it gives; a return in response to a 148 notice is due within three months from the end of the month of issue. In the 2025 Act these are sections 281 and 280.

How reassessment works now

The officer has information that income chargeable to tax escaped assessment for an earlier year, often from AIS, third-party data or an audit objection. He serves the 148A(1) notice with that information, considers your reply, and passes an order under 148A(3) with prior approval of the specified authority. If he decides to proceed, the section 148 notice follows.

Check it is genuine. Every income-tax notice issued since 1 October 2019 carries a Document Identification Number (DIN). Verify it on the e-filing portal’s pre-login service “Authenticate notice/order issued by ITD”. The department’s own FAQ says a notice without a DIN is invalid and needs no response. Genuine notices also appear after login under Pending Actions, e-Proceedings.

Time limits

NoticeNormal limitExtended limit
Section 148A show cause notice3 years from the end of the assessment yearUp to 5 years, if escaped income is ₹50 lakh or more
Section 148 notice3 years and 3 months from the end of the assessment yearUp to 5 years and 3 months, only with evidence of escaped income of ₹50 lakh or more

The reassessment order is due within 12 months from the end of the financial year in which the 148 notice was served. Under the Income-tax Act, 2025, section 282 counts the limits from the end of the tax year, which works out to the same periods.

Which Act? The Income-tax Act, 2025 applies from tax year 2026-27. Returns and proceedings for assessment year 2026-27 (financial year 2025-26) and earlier years continue under the Income-tax Act, 1961, so a notice for those years cites the old section. Look up any section in our section finder.

How to reply to a 148A notice

  1. Check the year and whether the notice is within the time limit; a notice out of time should say so in reply.
  2. Read the information enclosed and match it with your records.
  3. Show where the income was already disclosed, or explain the transaction with documents such as sale deeds, bank statements or loan papers.
  4. Where the extended limit is used, test whether the escaped income really reaches ₹50 lakh.
  5. Reply on the portal under e-Proceedings within the time given, and keep the acknowledgement.

If a 148 notice is issued

File the return within the period in the notice, which cannot exceed three months from the end of the month of issue; a return filed later is not treated as a valid return. Then take part in the reassessment. Penalty proceedings for under-reporting or misreporting can follow an addition.

Frequently asked questions

What is the time limit for a section 148 notice?

Three years and three months from the end of the assessment year, extendable to five years and three months only where escaped income is ₹50 lakh or more and the officer has evidence of it.

Is a 148A notice compulsory before a 148 notice?

Yes. The officer must serve a show cause notice under section 148A with the information relied on and consider your reply before issuing a section 148 notice.

How long do I have to reply to a 148A notice?

The period stated in the notice; the current section does not fix a number of days.

When is the return due after a 148 notice?

Within the period in the notice, which cannot exceed three months from the end of the month in which the notice was issued.

What are sections 148 and 148A in the new Act?

Section 280 (notice) and section 281 (show cause procedure) of the Income-tax Act, 2025, with time limits in section 282.

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Reviewed by Vijay DhawanManaging Partner, LexVerge LLP · reviewed on · How we write and check our guides

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