Section 148A Notice: Show Cause Before Reassessment
A notice under Section 148A gives you an opportunity to show cause why a notice under Section 148 should not be issued, and must be accompanied by the information relied on. You get not less than seven days to reply. The officer must then pass a reasoned order deciding whether it is a fit case to reopen. This is the stage at which a reopening is most often stopped.
What is this notice?
Section 148A, introduced by the Finance Act 2021 and amended since, requires the Assessing Officer to put the information suggesting escaped income to the taxpayer and to consider the reply before issuing a reassessment notice. It replaced the earlier practice of reopening first and supplying reasons afterwards, and it creates a written record that any later challenge is built on.
Common reasons it is issued
- Information flagged under the risk-management strategy or received under Section 135A
- Cash deposits, property transactions or high-value purchases not matching the return
- Information from a search or survey on a third party naming you
- A return not filed for a year in which taxable income is alleged
How to reply — step by step
- Demand the material, not the conclusion. If the notice describes information without supplying it, ask for it in writing — a reply cannot meaningfully be made to an allegation whose basis is withheld.
- Check limitation against the period applicable to that assessment year, including the higher threshold for escaped income above the statutory limit. The time limits have changed more than once, so apply the ones in force for that year.
- Verify sanction. Approval under Section 151 by the specified authority is a condition, and approval by the wrong authority or given mechanically has repeatedly vitiated reopenings.
- Answer the information factually — a bank credit that is a loan repayment, or a transaction already offered to tax, ends the matter at this stage if evidenced.
- Reply within the stated period, which cannot be less than seven days, and press for the reasoned order under Section 148A(d) before any 148 notice issues.
Draft your 148A reply in minutes
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Draft my reply free →Frequently asked questions
How much time do I get to reply to a 148A notice?
Not less than seven days, as specified in the notice. Where the material is voluminous, ask for an extension in writing at once, citing what has only just been supplied.
Can reopening be based on a change of opinion?
No. Reopening requires information suggesting escaped income, not a fresh view of material already considered. A mere change of opinion has consistently been held not to sustain a reopening.
What if the 148 notice is issued without the 148A procedure?
The procedure is mandatory except in the cases the statute itself excludes, such as certain search-related situations. A reopening that skips it is open to challenge on that ground.
Does replying to a 148A notice mean the reassessment will still happen?
Not necessarily. The officer must pass an order under Section 148A(d) deciding whether it is a fit case, and a reply that answers the information factually frequently ends the matter there.
Related notices
This page is general information, not legal advice. Every notice turns on its own facts — verify with a professional or draft a fact-checked reply on Yukti.