# Reassessment Notice — Section 148 / 148A (Sections 280 / 281 from 2026)

> A reassessment notice says the department believes income has escaped assessment. Before issuing it, the officer must give a show-cause notice with the information relied on (Section 148A of the 1961 Act; section 281 of the Income-tax Act, 2025 for new proceedings) and consider your reply; only then can a notice under Section 148 (section 280 of the new Act) be issued. Time limits generally allow reopening within three years, extended up to five years where the escaped income is ₹50 lakh or more.

Practice: Tax Notices & Litigation — https://www.industax.com/services/tax-litigation/

The reply to the show-cause notice is decisive: it is where you show that the information doesn't lead to escaped income (for example, the transaction was already reported, belongs to someone else, or is fully explained). A weak reply means a full reassessment.

Proceedings for earlier years continue under the 1961 Act provisions, while notices for tax year 2026-27 onwards follow the reassessment sections of the Income-tax Act, 2025 — so the section numbers on your notice depend on the year involved.

We check the time limit and the approval obtained, request the information relied on if it wasn't supplied, and draft the reply with evidence; if reassessment proceeds, we represent you through it.

## Key facts

| Item | Detail |
| --- | --- |
| Before reopening | Show-cause notice with information relied on (148A / new section 281) |
| Reassessment notice | Section 148 (new section 280) |
| Time limit | Generally 3 years; up to 5 years if escaped income ≥ ₹50 lakh |
| Older years | Continue under the Income-tax Act, 1961 |

## Who needs this

- Taxpayers with a 148A show-cause notice
- Taxpayers whose assessment has been reopened
- Taxpayers with unreported high-value transactions from earlier years

## What's included

- Limitation and approval check
- Information request
- Show-cause reply with evidence
- Representation in reassessment

## Documents

- 148A / 148 notice and information relied on
- ITR and computation for the year
- Evidence for the transactions cited

## Process

1. **Check** — Time limit, approval and information verified.
2. **Reply** — Evidence-led reply to the show-cause notice.
3. **Represent** — Reassessment handled if the case proceeds.

## Also covers

- **148A notice reply** — Show-cause replies before a reassessment notice is issued.

## FAQs

### How old can a year be for a reassessment notice?

Generally up to three years from the end of the assessment year, and up to five years where the income that escaped is ₹50 lakh or more, under the limits applying since 1 September 2024.

### Have the section numbers changed?

Yes for proceedings under the Income-tax Act, 2025 from 1 April 2026: the show-cause procedure is section 281 and the notice is section 280. Older years remain under sections 148A and 148.

### Can a reassessment be stopped at the show-cause stage?

Yes, if the reply convinces the officer that no income escaped assessment; the officer must pass an order considering your reply.

## Official sources

- Income Tax e-Filing portal (e-Proceedings): https://www.incometax.gov.in/
- Income Tax Department — Acts, rules and circulars: https://incometaxindia.gov.in/

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Canonical page: https://www.industax.com/services/tax-litigation/reassessment-notice-148
Publisher: Indus Tax — CA-led tax and compliance firm (https://www.industax.com). Contact: info@industax.com, 9059139258.
This is general information, not advice for your specific facts.