Income Tax Notice Under Section 148: Reassessment Explained (2026)

How to · Income Tax · Reassessment

Updated for 2026 · Claw Editorial

A notice under Section 148 of the Income-tax Act means the tax department wants to reopen a past year because it believes some income was not assessed. It is not a demand by itself, but it is a serious step, and it runs on a strict procedure and strict time limits. This page explains what a Section 148 notice is, the Section 148A steps that now come before it, how long the department has, and how to respond without making the position worse. Last verified October 2026.

01What a Section 148 notice means

A notice under Section 148 of the Income-tax Act, 1961 tells you that the Assessing Officer intends to reassess a past assessment year because of information that income chargeable to tax has escaped assessment. The notice asks you to file a return of income for that year within the period stated in it.

Reassessment is the formal way the department reopens a year that is otherwise closed. The notice applies to the specific person and the specific year named in it. It can follow a mismatch picked up from data the department holds, information from another agency, or a survey or search. Filing the return asked for does not mean you accept the department position. It is the first procedural step.

02The Section 148A step that comes first

Before issuing most Section 148 notices, the Assessing Officer must follow Section 148A. In short, the officer gives you a chance to explain before the year is reopened.

Under the current scheme, the officer provides you with the information suggesting that income has escaped assessment and an opportunity to respond, usually by a show cause notice that gives you a set number of days to reply. The officer then considers your reply and the material, and decides whether it is a fit case to issue a notice under Section 148. There are limited exceptions where this step is not required, such as certain search or requisition cases.

03Time limits after the Finance Act 2024

The Finance Act 2024 rewrote the reassessment time limits with effect from 1 September 2024, and removed the older very long window.

The matching Section 148A show cause notice has its own windows, broadly three years where the escaped income is below Rs 50 lakh and up to five years where it is Rs 50 lakh or more. The old ten year window has been dropped. The rules for how these limits apply to older years have been litigated, so the exact cut off for a particular assessment year should be checked against the current text of Section 149 and recent case law.

04How to respond, step by step

1. Read the notice and check the year. Note the assessment year, the section quoted, and the deadline. Check whether a Section 148A show cause notice came first.
2. Check limitation. See whether the notice is within the time limit for that year. A time barred notice can be challenged.
3. File the return asked for. File the return for that year through the income tax portal within the period stated, even if you believe no income escaped.
4. Ask for reasons and material. You are entitled to the information and material the officer relied on. Study it before you argue.
5. Reply on the merits. Address each point with documents. Keep copies of everything filed and the acknowledgements.
6. Track every deadline. Reassessment runs on fixed dates. Missing one weakens your position.

If the notice is one you received after processing of your return, also see the intimation under Section 143(1) and, where the department picks your case for detailed review, the scrutiny notice under Section 143(2).

05If you disagree: the appeal route

The Section 148 notice itself is challenged by replying, and in some cases by a writ petition before the High Court where the notice is clearly time barred or without jurisdiction. Once the reassessment is completed and an order is passed, that order can be appealed in the normal way, first to the Commissioner of Income Tax (Appeals), then to the Income Tax Appellate Tribunal (ITAT), and on questions of law to the High Court and the Supreme Court.

Faceless procedures apply to much of this, so most notices and submissions are handled electronically. If you want to correct a plain arithmetical or apparent mistake in an order rather than fight the whole reassessment, a rectification under Section 154 may be the right tool.

06Where Claw fits

Claw is an all-in-one legaltech platform for Indian advocates, law firms, and corporate legal teams, combining AI-based case search, an AI legal assistant (Legal GPT), case management, and compliance automation across all Indian courts and tribunals.

Reassessment is heavily litigated, above all on limitation and on whether the Section 148A steps were properly followed, and a completed reassessment can be carried from the Assessing Officer to the Commissioner (Appeals), the ITAT and the High Court. Claw lets you track that reading as it develops. You can search more than 30 crore judgments, reaching back to the Supreme Court in 1950 and the High Courts in 1990, to see how courts have construed Section 148 and Section 148A and when a notice has been struck down as time barred, all in under five seconds. You can also keep your own reassessment in view, by party or advocate name, across the 9,102 courts, benches and forums Claw follows.

Claw does not use customer case documents to train its AI models, so your reassessment papers are not fed into any model. Open a free Claw account to follow how Section 148 is being read and to track your matter. To research the wider body of law, see case search across Indian courts.

07Sources and further reading

• Income Tax e-filing portal: incometax.gov.in
• Income Tax Department (Act and sections): incometaxindia.gov.in
• India Code (bare Act): indiacode.nic.in
• Claw: clawlaw.in

This page is general information, not legal advice. Reassessment law changes through amendments and judgments and depends on the facts of each year, so check the current text and take advice from a tax professional before you act.

08Frequently asked questions