Income Tax Notice Under Section 148: Reassessment Time Limits, 148A Procedure and How to Reply (2026)

Quick answer box

A Section 148 notice is a reassessment notice. It means the tax department thinks some income was missed in an earlier year. Before sending it, the department must run the Section 148A procedure – a show-cause notice and a reasoned order. The time-bar for escaped income is 3 years 3 months if the amount is below ₹50 lakh, and 5 years 3 months if it is ₹50 lakh or more. The notice also tells you how long you have to file a return for that year (at least 30 days).

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What “income escaping assessment” means

The law uses the phrase “income escaping assessment” for any income that was not taxed earlier.
Typical examples are:

• Salary or business income that was not shown in the return.
• Interest earned on a fixed deposit that does not appear in the AIS (Annual Information Statement).
• Large cash deposits that have no supporting documents.
• No return filed at all for the assessment year.

If any of these are detected, the Assessing Officer (AO) may consider that income as escaped.

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The 148A safety net

Since the Finance Act 2021 the department cannot jump straight to a 148 notice.
It must first follow the 148A procedure. The steps are:

1. Pre-liminary inquiry – the AO may start a brief inquiry after getting approval.
2. Show-cause notice (148A-b) – the AO writes to you, saying what information suggests escaped income.
3. Reply window – you get minimum 7 days, up to 30 days to answer. You can ask for more time in writing.
4. Reasoned order (148A-d) – the AO must issue an order within 1 month from the end of the month in which your reply is received. The order either drops the matter or approves the 148 notice.
5. Authority approval – the order must be signed by a Joint Commissioner or a higher authority.

Why this helps you: it forces the department to state its case in writing. You get a chance to explain before any reassessment is opened.

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Time limits: how far back can they go

The Finance (No. 2) Act 2024 changed the time-bars.

Escaped income amount	Time limit for issuing a 148 notice*
Less than ₹50 lakh	3 years 3 months from the end of the assessment year
₹50 lakh or more	5 years 3 months from the end of the assessment year

*If the notice is issued after these periods, it can be done only in a search or survey case and needs approval of a specified authority.

The practical deadlines for the recent assessment years are:

Assessment Year (AY)	Normal deadline for a 148 notice
2021-22	30 June 2025 (now time-barred for normal cases)
2022-23	30 June 2026 (now time-barred for normal cases)
2023-24	30 June 2027 (still open)
2024-25	30 June 2028 (still open)

If the notice arrives after the listed date, it is usually considered time-barred unless it falls under the special search/survey rule.

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Old numbers vs. new numbers

From Tax Year 2026-27 the Income-tax Act, 2025 replaces the old section numbers. The substance of the law stays the same.

Old section	New section (2025 Act)	What it deals with
147	279	Income escaping assessment
148	280	Issue of reassessment notice
148A	281	Procedure before notice
149	282	Time limits
150	283	Notice in consequence of appellate/court orders
151	284	Sanction
153	286	Time limit for completion

For assessment years before 2026-27 the department will still cite the old numbers (147, 148, 148A). For FY 2026-27 and later, you will see the new numbers (279-286).

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How to reply: step-by-step

1. Do not ignore the notice – the moment you get a 148A or 148 notice, start working on it.
2. Check the reasons recorded – the notice should list the information that led the AO to believe income escaped. If the reasons are vague or missing, write to the AO asking for a detailed list. Keep the request in writing.
3. Prepare your reply – gather bank statements, TDS certificates, invoices, or any other proof that explains the income. Write a clear answer addressing each reason. Stick to the 7-30 day window. If you need more time, send a written request before the deadline.
4. Send the reply – use the e-proc portal or the method mentioned in the notice. Keep a copy of the acknowledgment.
5. If you agree – file or confirm the return for the relevant assessment year as soon as possible. The return must be filed within the period mentioned in the 148 notice (minimum 30 days).
6. If you disagree – raise objections in your reply. Explain why the notice is time-barred or why the reasons are weak. If the AO still issues a 148 notice, you can appeal to the Commissioner of Income Tax (Appeals) and later to the ITAT.

Remember: a well-documented reply can stop the reassessment at the 148A stage itself.

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What happens if you ignore it

If you do not reply, the AO can pass a best-judgment assessment. This means the department will estimate your income and tax.

• Interest under the former Sections 234A, 234B, 234C (now Sections 423, 424, 425) will start accruing from the original due date.
• You can still appeal the assessment, first to the Commissioner of Income Tax (Appeals) and then to the ITAT.
• Ignoring the notice also invites penalty provisions and may affect future compliance checks.

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What changed vs. stayed the same

Changed

• Section numbers for 147-153 are now 279-286 from Tax Year 2026-27.
• Finance (No. 2) Act 2024 added a 3-month extension to the normal time-bar, making it 3 years 3 months and 5 years 3 months.

Stayed the same

• The ₹50 lakh threshold for the longer time-bar remains.
• The 148A safety-net procedure (show-cause, reply window, reasoned order, authority sign-off) is still required before any 148 notice.
• The core idea of a reassessment – reopening an assessment year where income escaped – is unchanged.

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FAQ

1. What is a notice under Section 148 of the Income Tax Act?
   It is a reassessment notice. The tax department believes some income was missed in an earlier year and wants to reopen that year’s assessment.

2. How much time do I get to reply to a 148 notice?
   The notice itself will give you at least 30 days to file a return for that year. For a 148A show-cause notice, you have 7 to 30 days to reply, with a possible extension if you ask in writing.

3. What is the time limit for issuing a reassessment notice?
   If the escaped income is below ₹50 lakh, the department has 3 years 3 months from the end of the assessment year. For ₹50 lakh or more, the limit is 5 years 3 months.

4. Can a reassessment notice be issued after 3 years?
   Yes, if the escaped income is ₹50 lakh or more, the limit is 5 years 3 months. Also, in a search or survey case with proper authority approval, a notice can be issued even later.

5. What is Section 148A of the Income Tax Act?
   It is the procedure that must be followed before a 148 notice is issued. It includes a show-cause notice, a reply period of 7-30 days, and a reasoned order signed by a Joint Commissioner or higher.

6. What happens if I do not respond to a 148 notice?
   The department can make a best-judgment assessment. Interest and possible penalties will be added. You can still appeal, but the process becomes more costly and time-consuming.

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Documents to keep ready

When a 148/148A notice arrives, gather these before you reply:

• Bank statements for the assessment year in question.
• Form 26AS and AIS for that year – to show what income was already on record.
• The filed return and computation for that year.
• TDS certificates (Form 16/16A of that year).
• Proofs for any deduction or exemption you claimed (80C receipts, HRA rent receipts, etc.).
• Sale/purchase documents if the AO’s information relates to a property or share transaction.

When the 148A procedure is skipped

The law allows the Assessing Officer to skip the show-cause stage in a few specific situations, such as cases arising from a search or seizure. In normal cases – AIS mismatches, cash deposits, unfiled returns – the full 148A procedure with the reasoned order applies.

Official sources

• Income-tax Act 1961 – Sections 147-153
• Income-tax Act 2025 – Sections 279-286
• Finance (No. 2) Act 2024
• https://www.incometax.gov.in – e-proceedings portal

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This article gives general information. It is not personal tax advice. Please consult a qualified chartered accountant or tax lawyer for advice on any notice you receive.