A section 148 notice means the Income Tax Department wants to reopen your assessment for a past year, because it has information that some income may have escaped tax. This is called reassessment. Before a 148 notice, the law requires a show cause notice under section 148A and a chance to reply, except in one case. A 148 notice follows only if the officer then decides it is a fit case.
What is a section 148 notice?
A notice under section 148 of the Income-tax Act, 1961 asks you to file your income tax return again for an old year. Except in one case (explained below), the officer can send it only after the section 148A process, and it comes with a copy of the order passed under section 148A(3).
The notice gives you a period to file the return. By law, that period cannot go beyond three months from the end of the month in which the notice was issued. After you file, the officer can reassess your income for that year.
A 148 notice is not the same as a 143(1) intimation, which is the result of normal processing, or a scrutiny notice under section 143(2), which examines the return you filed and has a much shorter time limit.
What is reassessment under section 147?
Section 147 is the power to reopen. In the words of the department: "If any income of an assessee has escaped assessment for any assessment year, the Assessing Officer may ... assess or reassess such income." Sections 148 to 153 set out how and when this can be done.
Section 148 vs 148A: what is the difference?
| Section 148A | Section 148 | |
|---|---|---|
| What it is | A show cause notice: why should your case not be reopened? | The reopening notice itself |
| When it comes | First | Only after a 148A order says it is a fit case |
| What comes with it | The information that suggests income escaped tax | A copy of the order passed under section 148A(3) |
| What you do | Reply within the period given in the notice | File your return for that year within the period given in the notice |
| Time limit for the department (normal case) | Within 3 years from the end of the assessment year | Within 3 years and 3 months from the end of the assessment year |
How reassessment works, step by step
- The officer has information. The law lists what counts as information (see below).
- Show cause notice under section 148A(1). It comes with that information and asks why a 148 notice should not be issued.
- Your reply under section 148A(2). You reply within the period given in the notice.
- Order under section 148A(3). The officer looks at the record and your reply, if any, and decides whether it is a fit case. This order needs the prior approval of the specified authority: an Additional or Joint Commissioner, or an Additional or Joint Director (section 151).
- Notice under section 148. If it is a fit case, the notice comes with a copy of that order and asks you to file a return.
- Your return. You file it within the period in the notice.
- Reassessment. The officer examines the case and passes a reassessment order.
There is one exception. The show cause step in section 148A does not apply where the officer has received the information under the scheme notified under section 135A. In that case, the 148 notice needs the prior approval of the specified authority instead.
Time limit for a section 148 notice (section 149)
These limits apply from 1 September 2024. They run from the end of the assessment year concerned.
| Escaped income | Last date for the 148A show cause notice | Last date for the 148 notice |
|---|---|---|
| Less than ₹50 lakh | 3 years from the end of the assessment year | 3 years and 3 months from the end of the assessment year |
| ₹50 lakh or more | 5 years from the end of the assessment year | 5 years and 3 months from the end of the assessment year |
The longer limit applies only if the escaped income is, or is likely to be, ₹50 lakh or more, and the officer has books of account, documents or evidence about an asset, expenditure, transaction or entries that show it.
Worked example. Take AY 2023-24 (the financial year 2022-23). That assessment year ends on 31 March 2024.
| Case | 148A show cause notice by | 148 notice by |
|---|---|---|
| Less than ₹50 lakh | 31 March 2027 | 30 June 2027 |
| ₹50 lakh or more | 31 March 2029 | 30 June 2029 |
For notices issued before 1 September 2024, and for some search or survey cases, older rules can apply. If your notice is about an older year, get the dates checked for your case.
What counts as "information" for reopening
Section 148 lists six kinds of information that can start the process:
- Information flagged under the risk management strategy of the Central Board of Direct Taxes
- An audit objection saying your assessment was not made as per the Act
- Information received from another country under a tax treaty (section 90 or 90A)
- Information under the scheme notified under section 135A
- Information that needs action because of an order of a Tribunal or a Court
- Information from a survey under section 133A carried out on or after 1 September 2024
The 148A notice must come with the information the officer has. Read it first. It tells you exactly what the department thinks was left out.
How to reply to a section 148A notice
- Check the notice is genuine. Every notice carries a DIN (Document Identification Number). Check it on the e-filing portal under "Authenticate Notice/Order issued by ITD". No login is needed. A communication without a DIN is invalid.
- Note the reply date. The law says you reply within the period given in the notice, so the date in your notice is the one that counts.
- Read the information attached. Match it with your own records: bank statements, sale deeds, contract notes, your AIS and the return you filed for that year.
- Prepare your reply with documents. Explain the transaction, show where it was already taxed, or show why the amount is lower than the officer thinks. If the case depends on the ₹50 lakh limit or on the time limit, say so in the reply.
- Submit on the portal. Log in and go to Pending Actions > e-Proceedings, click View Notice, then Submit Response. You can send a partial response (more than one submission) or a full response. A single attachment can be up to 5 MB.
- Ask for more time if you need it. Use "Seek/View Adjournment" on the same screen and give a reason.
You can also add an Authorised Representative on the portal to reply for you, so you do not share your password with anyone.
If you do not reply, the officer can still pass the 148A(3) order on the material on record. Replying is your chance to stop the case at this stage.
How to file your return after a 148 notice
- File within the period in the notice. A return filed after that period is not treated as a return under section 139.
- Give the notice details. The ITR asks for the DIN and date of the notice when you file in response to a section 148 notice. (The ITR-3 validation rules for AY 2026-27 require them, for example.)
- Expect a close look. The CBDT's guidelines for FY 2026-27 list returns filed in response to a section 148 notice among the cases picked for compulsory complete scrutiny. See our guide to the income tax scrutiny notice.
Can you file an updated return (ITR-U) after a 148A notice?
The department's page on updated returns gives these rules:
- If the 148A show cause notice is issued after 36 months from the end of the assessment year, you cannot file an updated return for that year. The exception: if the officer passes a 148A(3) order saying it is not a fit case, the bar does not apply.
- You cannot file an updated return while an assessment or reassessment for that year is pending or completed, with one exception added in 2026: after a section 148 notice, you can file an updated return in response to it, within the period given in the notice. The additional tax is then 10% more than the usual rate.
If your 148A notice came within 36 months and no 148 notice has followed yet, the official page does not say whether you can still file an updated return. Get advice before filing one in that case. See our guide to the updated return (ITR-U).
Can a 148 notice be challenged?
Yes, in more than one way.
- In your 148A reply. This is the first place to raise any problem: the income did not escape, it was already taxed, the amount is below ₹50 lakh so the longer time limit cannot apply, or the notice is out of time.
- By appeal after the order. An order of assessment, reassessment or recomputation passed after reopening under section 147 can be appealed to the Commissioner (Appeals) in Form 35. The appeal is due within 30 days of the date the demand notice is served.
- In the High Court. Taxpayers can also ask a High Court to quash a notice through a writ petition. This is a legal step, and it needs a lawyer.
Who can issue the notice: a live question in the courts. Since the faceless system came in, courts have been asked whether a reassessment notice can come from the local (jurisdictional) Assessing Officer or only through the faceless unit. The Finance Act 2026 added section 147A, with effect from 1 April 2021, to say the local officer can issue it. On 11 September 2026 the Punjab and Haryana High Court struck section 147A down. The Central Government has taken the matter to the Supreme Court, which had not decided it as of 27 September 2026. If your notice came from a local officer, ask your adviser whether this affects your case.
Time limit for the reassessment order
Once the 148 notice is served, the officer has 12 months from the end of the financial year in which the notice was served to pass the reassessment order (section 153(2)). If the case is referred to a Transfer Pricing Officer, 12 more months are added.
For example, if the 148 notice is served in June 2027, the financial year ends on 31 March 2028, so the order is due by 31 March 2029.
148A(b) and 148A(d): the old rules before September 2024
You may see notices or articles that mention section 148A(b) or 148A(d). Those were clauses of the older section 148A, which applied from 1 April 2021 until 31 August 2024.
| Step | Before 1 September 2024 | From 1 September 2024 |
|---|---|---|
| Enquiry before the show cause notice | 148A(a), with prior approval | No separate clause |
| Show cause notice | 148A(b) | 148A(1) |
| Time to reply | Not less than 7 days and not more than 30 days | The period given in the notice |
| Considering the reply | 148A(c) | 148A(3) |
| Order: fit case or not | 148A(d), within one month from the end of the month the reply was received | 148A(3), with prior approval, no fixed month in the section |
The department's own "Limitation periods" chart still shows the old 7 to 30 days and the one-month rule. The current section text on the same website says the reply period is the one given in the notice. We follow the section text.
Which law applies: the 1961 Act or the 2025 Act?
The Income-tax Act, 2025 came into force on 1 April 2026. But reassessment for any tax year that began before 1 April 2026 still runs under the Income-tax Act, 1961, even if the notice is issued after that date. That is why this page uses sections 147, 148, 148A and 149.
For tax year 2026-27 onward, the 2025 Act applies. There, the show cause notice is under section 281(1), the reopening notice under section 280, and reassessment under section 279. The reassessment order is due within one year from the end of the financial year in which the section 280 notice was served.
Need help with a reassessment notice?
A reassessment case starts with the 148A reply, and that reply can decide whether the case goes further. Our income tax notice reply service handles 148A and 148 notices under the Scrutiny and reassessment plan: from ₹19,999 + GST, with a fixed quote once we have read your notice.
- We act as your Authorised Representative on the e-filing portal, so you do not share your password.
- A chartered accountant checks every reply before it is submitted.
- Online hearings are included in the plan.
Free notice replies for returns we filed cover only Simple and Correction notices. They do not cover reassessment.
Frequently asked questions
What is a section 148 notice?
It is a notice that reopens your assessment for a past year because the department has information that some income escaped tax. It asks you to file a return for that year within the period given in the notice, and it comes with a copy of the order passed under section 148A(3).
What is the purpose of a notice under section 148 of the Income Tax Act?
Its purpose is to let the Assessing Officer assess or reassess income that escaped assessment, under section 147. The officer cannot reassess without first serving this notice.
What is the difference between 148 and 148A?
A 148A notice is a show cause notice that comes first, with the information the officer has, and asks why your case should not be reopened. A 148 notice is the reopening notice itself, issued only after a 148A order finds it a fit case.
What is the time limit for issuing a 148A notice?
For notices issued from 1 September 2024, within 3 years from the end of the assessment year. If the escaped income is ₹50 lakh or more, up to 5 years.
What is the time limit for a 148 notice?
Within 3 years and 3 months from the end of the assessment year, or up to 5 years and 3 months if the escaped income is ₹50 lakh or more. These limits are in section 149.
How to respond to a section 148A notice?
Check the DIN, read the information attached, and reply with documents within the period given in the notice. You reply on the e-filing portal under Pending Actions > e-Proceedings, and you can ask for an adjournment there.
How many days do I get to reply to a 148A notice?
The period written in your notice. Before 1 September 2024 the law fixed 7 to 30 days, but the current section 148A says only "within such period, as may be specified in the notice".
What happens if I file the return late after a 148 notice?
A return filed after the period in the notice is not treated as a return under section 139. File within the period given.
Can ITR-U be filed after a 148A notice?
Not if the 148A notice was issued more than 36 months after the end of the assessment year, unless the officer's 148A(3) order says it is not a fit case. After a section 148 notice, an updated return can be filed in response to it, within the period in the notice, with 10% more additional tax.
Can a 148 notice be challenged?
Yes. Raise your objections in the 148A reply first. After a reassessment order, you can appeal to the Commissioner (Appeals) within 30 days of the demand notice. A writ petition in the High Court is also possible, with a lawyer.
What is reassessment under section 147?
It is the reopening of a past year's assessment when income chargeable to tax has escaped assessment. Section 147 gives the Assessing Officer the power to assess or reassess that income, following the steps in sections 148 to 153.
How long does the department have to finish a reassessment?
12 months from the end of the financial year in which the 148 notice was served, with 12 more months if the case goes to a Transfer Pricing Officer.
Hinglish mein sawaal
148 notice kya hota hai?
148 notice ka matlab hai ki income tax department aapka kisi purane saal ka assessment dobara khol raha hai, kyunki uske paas information hai ki kuch income par tax nahi laga. Isse pehle 148A ka show cause notice aata hai.
148A notice ka jawab kaise dein?
Notice ka DIN check karein, saath aayi information padhein, aur notice mein di gayi date tak documents ke saath jawab dein. Jawab e-filing portal par Pending Actions > e-Proceedings mein jaata hai.
Last reviewed: 29 September 2026
FilingSetu is the brand of ANR Consultancy, a partnership firm.
GSTIN: 07ACOFA0324K1ZG
This page explains the law as it stands on the review date. It is not advice on your specific case.
