Reassessment Notices Under Sections 148A and 148: Time Limits, the 30-Day Floor and How to Reply

A reassessment starts with a show-cause notice under section 148A, which must enclose the information suggesting that income escaped assessment and gives you the period stated in the notice to reply. If the Assessing Officer then finds it a fit case, a notice under section 148 follows with a copy of that order, and you must file a return within the period it states: at least thirty days from the notice, as the Finance Act 2026 now requires, and at most three months from the end of the month of issue. The notices are time-barred after three years (show cause) and three years and three months (section 148 notice) from the end of the assessment year, or five years and five years and three months where the escaped income is ₹50 lakh or more.

Sources checked: 22 October 2026

Facts checked on 22 October 2026 against sections 148, 148A, 149, 153 and 246A of the Income-tax Act 1961 (as amended by the Finance Act 2026, on incometaxindia.gov.in), sections 280 to 284 and 536 of the Income-tax Act 2025, the Finance Act 2026 in the Gazette of India, and the e-Proceedings help pages on incometax.gov.in.

Key facts

Point	What applies	Where it comes from
Which Act	The 1961 Act for AY 2026-27 and earlier, whenever the notice issues	Section 536(2)(c), Income-tax Act 2025
Step 1: show cause	Notice under section 148A(1) with the information enclosed; reply within the period specified in the notice	Section 148A(1), (2)
Step 2: section 148 notice	Issued with a copy of the 148A(3) order; return within the period in the notice: at least thirty days (Finance Act 2026), at most three months from the end of the month of issue	Section 148(1)
Limit for the section 148 notice	3 years 3 months from the end of the AY; 5 years 3 months where escaped income is ₹50 lakh or more	Section 149(1)
Limit for the show cause	3 years; 5 years where escaped income is ₹50 lakh or more	Section 149(2)
Reassessment order	Within twelve months from the end of the FY in which the section 148 notice was served	Section 153(2)
2025-Act equivalents	148 → 280; 148A → 281; 149 → 282; specified authority 284	Department's 1961-to-2025 mapping utility

Which Act applies to a reassessment notice issued now?

Section 536(2)(c) of the Income-tax Act 2025 keeps the repealed 1961 Act in force for proceedings, including notices, reassessment and appeals, in respect of any tax year beginning before 1 April 2026, whenever they are initiated. A reassessment notice for AY 2026-27 or any earlier year is therefore under sections 148A, 148 and 149 of the 1961 Act, as amended by the Finance Act 2026. The 2025 Act's equivalents are section 281 (show cause), section 280 (notice), section 282 (time limits) and section 284 (the specified authority). Section 282 counts from the end of the tax year rather than the assessment year, so its limits read four years and three months (six years and three months for ₹50 lakh or more) for the notice and four years (six years) for the show cause, from tax year 2026-27.

What is a show-cause notice under section 148A?

Where the Assessing Officer has information suggesting that income chargeable to tax has escaped assessment, section 148A(1) requires him to first serve a notice to show cause why a notice under section 148 should not be issued, accompanied by the information on which it rests. Under section 148A(2) you may reply within such period as may be specified in the notice: the Act fixes no number of days. The officer then passes an order under section 148A(3), on the material on record and your reply, with the prior approval of the specified authority under section 151, deciding whether it is a fit case for a section 148 notice; the current text states no time limit for that order. There is no show-cause stage where the information came under the section 135A scheme. "Information" is defined in section 148(3): risk-management-strategy flags, audit objections, treaty information, orders of a Tribunal or court, and survey information under section 133A.

What does a section 148 notice require?

A notice under section 148(1) is issued with a copy of the section 148A(3) order and requires you to furnish a return within the period specified in the notice, which may not be less than thirty days from the date of the notice and may not exceed three months from the end of the month in which it is issued. The 30-day floor was inserted by section 10 of the Finance Act 2026 and is deemed in force from 30 March 2026. A return filed after the period in the notice is not deemed a return under section 139.

The Finance Act 2026 also opened an updated-return route: an updated return under section 139(8A) may be filed in response to a section 148 notice within the period in the notice, after which no other return can be filed for that notice. The additional income-tax under section 140B is increased by a further 10% of the tax and interest, and income on which it is paid cannot be the basis of a section 270A penalty.

What are the time limits under section 149?

Section 149, substituted by the Finance (No. 2) Act 2024 with effect from 1 September 2024, sets two sets of limits:

• Section 148 notice (section 149(1)): not after three years and three months from the end of the relevant assessment year; up to five years and three months only where the Assessing Officer holds books, documents or evidence showing escaped income of ₹50 lakh or more.
• Section 148A show-cause notice (section 149(2)): not after three years from the end of the assessment year; up to five years where the information shows escaped income of ₹50 lakh or more.

For AY 2022-23, which ended on 31 March 2023, the show-cause notice could issue until 31 March 2026 (or 31 March 2028 for ₹50 lakh and above) and the section 148 notice until 30 June 2026 (or 30 June 2028). Separately, section 150 as substituted by the Finance Act 2026 lets a section 148 notice to give effect to an appellate or court order issue within three months from the end of the quarter in which the certified copy of the order is received, but never for a year already time-barred when the original order was made.

How do I reply to a section 148A notice?

The notice reaches your registered e-filing account under Dashboard, then Pending Actions, then e-Proceedings, grouped as "Notices issued by the AO or other Income Tax Authority". Read the information enclosed with the notice and answer it point by point, dealing with the specific transactions or figures the department relies on and attaching the supporting documents. "Submit Response" accepts a Partial or Full response with remarks of up to 4,000 characters and attachments of 5 MB each (up to 10 files); a Transaction ID confirms the filing, and a response cannot be edited or withdrawn afterwards. If you need more time, use "Seek/View Adjournment" before the date in the notice. Our notice decoder explains what the heading of your communication means.

What happens after the section 148 notice?

File the return within the period stated in the notice, which is at least thirty days. The reassessment then proceeds like an assessment: notices under sections 142(1) and 143(2) may follow, each with its own reply date (see our guide to intimations and scrutiny notices), and the order under section 147 must be made within twelve months from the end of the financial year in which the section 148 notice was served (section 153(2)). A reassessment order is appealable under section 246A(1)(b) within thirty days of service of the notice of demand (section 249(2)(b)); our guide to the notice of demand, stay requests and appeal windows covers that stage.

What if I do not respond?

If no reply is filed to the show-cause notice, the section 148A(3) order is passed on the material on record without it. A return filed after the period in the section 148 notice is not a section 139 return, and the reassessment proceeds under sections 142, 143 and 144. Failing to comply with a section 142(1) or 143(2) notice carries a penalty of ₹10,000 for each default under section 272A(1)(d).

Does a missing DIN help?

Not on its own. CBDT Circular 19/2019, which said a communication without a DIN was invalid, ceased to have effect when Circular 4/2026 was issued on 31 March 2026; the current rule is that a communication must be referenced by a DIN in some manner, with listed exceptions, and the new section 292BA says an assessment is not invalid for a DIN defect if the order is referenced by the number in any manner. Raise a missing DIN as a point in your reply, not as a complete answer.

Getting help

Our income-tax support covers replies to section 148A show-cause notices, returns in response to section 148 notices and the reassessment that follows, and the compliance calendar keeps the return dates in view. For the new Act's section numbers, see the Income-tax Act 2025 for small businesses. To have our expert team read the information enclosed with your notice, book a consultation or ask for a quote.