Section 148 / 148A · Reassessment of income that escaped assessment
Got a 148 notice? The department thinks income escaped tax.
- 148A
- Show-cause stage
- 148
- Reassessment notice
- Standard time-limit
- 3 years 3 months from end of AY
- Extended time-limit
- Up to 5 years 3 months (income ≥ ₹50L)
In plain English
When the tax officer believes some income skipped assessment, the law requires them to first give you a chance to explain (Section 148A), and only then issue a formal reassessment notice u/s 148. Time-limits depend on how much income is alleged to have escaped.
| Meaning | Number |
|---|---|
| Standard time-limit | 3 years 3 months from end of AY |
| Extended time-limit | Up to 5 years 3 months (income ≥ ₹50L) |
How the reassessment process now works
- Step 1 — Information flagged — AO gathers info suggesting escaped income
- Step 2 — 148A(b) notice — Show-cause: taxpayer gets minimum 7 days to reply
- Step 3 — 148A(d) order — AO decides whether it's a fit case for reassessment
- Step 4 — 148 notice — Formal reassessment notice; file return in response
- Step 5 — Assessment u/s 147 — Final reassessment order
What this section covers
Section 148 enables the Assessing Officer to issue a notice for reassessment where income chargeable to tax has escaped assessment. Section 148A (introduced by Finance Act, 2021) makes a prior show-cause and a speaking order mandatory before any 148 notice. The standard time-limit is 3 years 3 months from the end of the relevant AY; this extends to 5 years 3 months where the income alleged to have escaped is ₹50 lakh or more (represented in the form of an asset, expenditure or entry). The AO must have 'information' suggesting escapement and follow the procedure laid down in 148A — failure to do so makes the notice liable to be quashed (see Ashish Agarwal and Rajeev Bansal Supreme Court rulings).
The legal text
“Before making the assessment, reassessment or recomputation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish… a return of his income…”
Old Act vs New Act
| Aspect | Act, 1961 | Act, 2025 |
|---|---|---|
| Section | 148 / 148A | 281 / 280 |
| Topic | Reassessment of income that escaped assessment | |
| Verdict | Renumbered — procedural safeguards retained | |
| Notes | Restated as Sections 280 (show-cause) and 281 (reassessment notice) under the Income-tax Act, 2025. The 3-year and 5-year windows and the mandatory show-cause stage are retained. | |
Common confusion
Section 148A is the show-cause stage and is NOT itself a reassessment notice. Only when the AO passes a 148A(d) order can a Section 148 notice follow.
Who should know this
Related sections
Based on the official Income-tax Act, 1961 and the published Income-tax Act, 2025 as available on the Income Tax Department website. Always verify against the published Act and consult a qualified professional.