Section 148 Reassessment After Finance Act 2021: Know Your Rights
The 148A procedure, sanction under Section 151, your right to the recorded reasons, and how to object to an invalid reopening.
Reassessment under Section 148 was overhauled by the Finance Act 2021. Before a notice is issued, the Assessing Officer must ordinarily follow the Section 148A procedure — share the information, give you a chance to explain, and pass a speaking order — and obtain sanction under Section 151.
Your right to the reasons
You are entitled to the recorded reasons and to file objections before the reassessment proceeds — a principle settled by the Supreme Court. Ask for them if not supplied.
Grounds to object
Common grounds include the absence of fresh tangible material (a mere change of opinion), a defective or missing Section 151 sanction, and limitation. Each turns on the assessment record.
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