Find
148 means the AO believes income escaped assessment in a previously filed and processed return. They want to reopen that assessment year and tax the escaped income.
Tax notices + litigation · Income Tax Notice
Section 148 (now 280), Reassessment notice: they want to reopen old years
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Provisions
IT Act 1961, Sec 147 (now 279), 148 | Finance Act 2021 amended | Time limit: 3 years (income escaped ≤50L); 10 years (income escaped >50L + specific conditions)
Analysis
Finance Act 2021 reforms: Major change, AO now requires prior approval from PCIT/CIT before issuing 148 notice. Also must provide an "information" that suggests escapement. The old unlimited fishing expeditions are now restricted. Key defence under Sec 148A (now Sec 281, Income-tax Act 2025): Before issuing 148 notice, AO must issue a Sec 148A(b) (now Sec 281) show cause notice giving you 7-30 days to respond. If your response satisfies the AO, no 148 notice is issued. This is your best opportunity to stop the reassessment before it starts.
Close
- Check if information cited is valid, AO must cite specific information (AIS data, SFT data, etc.)
- Respond within the deadline, Sec 148A (now Sec 281) gives 7-30 days, request extension if needed
- Provide documentary evidence that income was fully disclosed in the original return
- Challenge the validity of the "information", generic AIS entries are not sufficient grounds
- If 148 notice still issues despite Sec 148A (now Sec 281) response → file a writ petition in High Court challenging the order
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