Answer

1. F

   Facts

   A Sec 148A show cause can be issued within 3 years from the end of the assessment year. Beyond 3 years and up to 5 years, it is allowed only if the escaped income is ₹50 lakh or more. Outside these limits no notice can be issued.

2. P

   Provisions and law

   • Sec 149 (now Sec 282)Time limit: Sec 148A notice within 3 years from the end of the assessment year, up to 5 years only if escaped income is ₹50 lakh or more
   • Sec 148A (now Sec 281)Before a Sec 148 notice, the officer must share the information, give a show cause notice and pass a reasoned order
   • Sec 148 (now Sec 280)Before reassessing, the officer issues a notice asking for a return for that year, with the Sec 148A order and approval
3. A

   Analysis

   Sec 149 (now Sec 282) sets the limits, and the Sec 148 notice itself gets an extra three months (3 years 3 months, and 5 years 3 months). AY 2021-22 ended on 31 March 2022, so the 3 year window closed on 31 March 2025; a notice now is valid only if the officer has information that escaped income is ₹50 lakh or more, and only till 31 March 2027. If the amount alleged is, say, ₹12 lakh, the notice is time barred and you should say so first in your reply. Transitional rules apply to notices from before 1 September 2024, so get the dates checked by a CA.

4. C

   Conclusion

   1. 1Find the assessment year and the end date of that year.
   2. 2Count 3 years, or 5 years if the amount alleged is ₹50 lakh or more.
   3. 3If outside the limit, raise time bar as the first ground.
   4. 4Still answer on merits in the same reply.

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