Reassessment show-cause notice (s.148A(b)): how to reply
AO proposes to issue a s.148 reassessment notice on information suggesting escaped income
- Section
- 148A(b)
- Form names
- No form number printed
- Time to reply
- As specified in the notice, not less than 7 and not more than 30 days from the date the notice is issued
- Reply goes on
- e-Proceedings: response to the notice
What the notice is
AO proposes to issue a s.148 reassessment notice on information suggesting escaped income
Filed through e-Proceedings.
Time limit to reply
As specified in the notice, not less than 7 and not more than 30 days from the date the notice is issued. Set by the statute or rules; the date is stated in the notice.
- The time may be extended by the officer on the assessee's application.
- Reply time: on the assessee's application (s.148A(b)).
- 1961 Act s.149: the s.148A(b) notice cannot issue after 3 years from the end of the assessment year, or 5 years if the escaped income is Rs 50 lakh or more. 2025 Act s.282(2): 4 years / 6 years from the end of the tax year. The s.148A(d) order is due within one month from the end of the month in which the reply is received (or the time to reply expires).
Unverified: This is to be confirmed against the notified text.
Not confirmed
- The 7 to 30 day range and the s.148A(d) one month rule are verified for the 1961 Act only. The same figures in the 2025 Act s.281 sub-sections were not read, so no reply range is computed for tax years under the 2025 Act.
- Notices issued before 1 September 2024 are not computed.
Basis: Income-tax Act 1961, s.148A; Income-tax Act 1961, s.149 (as amended by Finance (No. 2) Act 2024); Income-tax Act 2025, s.281; Income-tax Act 2025, s.282. Rule last reviewed 2026-10-02.
What the reply must include
- s.149 limitation computation for the specific AY (3-year vs up-to-5-year test)
- s.151 sanction objection where approval is not evidenced
- demand for the underlying information/material relied on
- issue-wise reply on merits as a separate, later section
- prayer that no order under s.148A(3) or reassessment proceed
Reply outline
Raise jurisdiction and limitation as threshold objections before touching the merits: check the s.149 time limit (3 years normally, up to 5 years only if escaped income represented by an asset, or in aggregate under later amendments, is ₹50 lakh or more) and demand proof of s.151 sanction. Insist the AO has supplied the actual information suggesting income has escaped assessment and all material relied on, a bare assertion is not enough. Only then respond to the merits, issue-wise. Case law on limitation/jurisdiction is usually the strongest ground at this stage.
Documents relied on
Material supplied with the SCN, addressed point-wise, plus any rebuttal evidence.
Jurisdiction and limitation objections
s.149 time-bar and s.151 sanction objections as threshold points before the merits.
Reply on merits
Address the reasons/information supplied with the SCN.
Prayer
Request no order under s.148A(3)/no reassessment proceed.
FAQs
What is a Reassessment show-cause notice (s.148A(b))?
AO proposes to issue a s.148 reassessment notice on information suggesting escaped income
What is the time limit to reply to a Reassessment show-cause notice (s.148A(b))?
As specified in the notice, not less than 7 and not more than 30 days from the date the notice is issued. To be confirmed against the notified text. Set by the statute or rules; the date is stated in the notice.
How is the reply to a Reassessment show-cause notice (s.148A(b)) filed?
On e-Proceedings: response to the notice, through e-Proceedings.
What should the reply include?
S.149 limitation computation for the specific AY (3-year vs up-to-5-year test); S.151 sanction objection where approval is not evidenced; Demand for the underlying information/material relied on; Issue-wise reply on merits as a separate, later section; Prayer that no order under s.148A(3) or reassessment proceed.
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This page summarises the notice type for chartered accountants and is not legal advice. Check the notice and the notified text before you file.
