Show-cause notice before reassessment: section 148A notice

Which law applies? The Income-tax Act, 2025 applies to the tax year 2026-27 onwards. Section 536(2)(c) of that Act says the repealed Income-tax Act, 1961 continues to apply to proceedings, including notices, assessment, reassessment, rectification, penalty and appeals, for any tax year beginning before 1 April 2026, that is the financial year 2025-26 (assessment year 2026-27) and earlier. Each notice page below gives both: the 2025 Act first, then the 1961 Act as printed by the Income Tax Department on 22 May 2026. For the oldest assessment years (up to 2021-22) the reassessment time limits in force before 1 September 2024 may apply, and that earlier text was not read.

The Assessing Officer has information that income has escaped assessment and, before issuing the reassessment notice, asks why that notice should not be issued.

What it means under the Income-tax Act, 2025 (tax year 2026-27 onwards)

Under section 281(1), before issuing a notice under section 280 the officer must give you an opportunity of being heard through a notice to show cause, accompanied by the information. You may reply within the period specified. The officer then passes an order, with prior approval, on whether it is a fit case to issue the notice (section 281(3)). The step does not apply where the information comes from a notified scheme, the Approving Panel, or a finding or direction in an order of an authority, Tribunal or court (section 281(4)).

Time limits under the 2025 Act

You reply within the period specified in the notice. A show-cause notice cannot be issued after four years from the end of the tax year, or six years where the escaped income is likely to be Rs 50 lakh or more, and not within one year from the end of any tax year (section 282(2) and (3)).

Under the Income-tax Act, 1961 (tax years before 2026-27)

Section 148A. Section 148A (as substituted from 1 September 2024): before issuing a notice under section 148 the Assessing Officer serves a notice to show cause, accompanied by the information that suggests income has escaped assessment. You may reply within the period specified in the notice. The officer then passes an order, with prior approval of the specified authority, on whether it is a fit case to issue a notice under section 148. The section does not apply where the information comes under the scheme notified under section 135A.

Time limits. You reply within the period in the notice. A show-cause notice cannot be issued after three years from the end of the relevant assessment year, or five years where the escaped income is likely to be ₹50 lakh or more (section 149(2)).

What to do first

Read the information that accompanies the notice.
Check the tax year and the date against the limits with the calculator.
Reply with facts and documents before the period ends.
Keep the order passed after your reply: it decides whether a reassessment notice follows.

An outline for a reply

State the tax year, deal with each item of information in turn with documents, say that the income was disclosed or is not taxable as the case may be, and ask that no notice under section 280 be issued.

Check the deadline

This is a general outline, not a reply to your own notice: facts and documents differ, and the deadline is short. Ask a chartered accountant.

Common questions

What section of the new Act replaces section 148A?

Section 281 of the Income-tax Act, 2025, for the tax year 2026-27 onwards. For earlier tax years the 1961 Act continues to apply to notices (section 536(2)(c)) and the notice quotes section 148A of that Act.

Source

The Income-tax Act, 2025, as published in the Gazette of India Extraordinary: sections 252, 263, 268, 270, 279 to 282, 287, 289, 357, 358, 411, 412 and 536. The enacted text was read on 13 November 2026.
The Income-tax Act, 1961 (text with amendments, printed by the Income Tax Department on 22 May 2026): sections 133, 139(9), 142, 143, 148, 148A, 149, 150, 154, 156, 220 and 249(2). Downloaded from incometaxindia.gov.in and read on 13 November 2026.
Old-section to new-section mapping: the Income Tax Department’s section navigator, checked against the Act (see the Income-tax Sections section of this family).

Rules read on 13 November 2026 from the Income-tax Act, 2025. This site explains notices in general terms. It is not legal advice and does not replace a chartered accountant or tax lawyer. A notice has a deadline: do not rely on a web page for your own case, and ask a professional soon.