How to Reply to a Section 148 Income Tax Notice 2026

A section 148 notice means the Income Tax Department believes income chargeable to tax has escaped assessment for an earlier year, and you must respond on time or face an ex-parte reassessment with extra tax, interest and penalty. This guide explains the law, the new 2026 deadlines and the exact steps to protect yourself.

A section 148 notice is a formal communication that the Income Tax Department wants to re-open and re-assess an earlier year because it has information suggesting income escaped assessment. It is issued under the income-escaping-assessment scheme of the Income Tax Act, 1961, and starts a fixed-deadline process you must follow carefully.

Reassessment of escaped income is governed by sections 147, 148, 148A and 144B of the Income Tax Act, 1961. The authority is the Income Tax Department and the Central Board of Direct Taxes (CBDT), which frames the procedure.

Section 148A (enquiry before notice). Before issuing a section 148 notice, the Assessing Officer must, with the prescribed approval, give you a show-cause notice and an opportunity to be heard. The officer then passes an order under section 148A deciding whether it is a fit case to issue a section 148 notice. If this enquiry stage is skipped where it applies, the notice is open to challenge.

New time limits from 1 September 2024. Under the Finance (No.2) Act, 2024, a section 148 notice can be issued within 3 years and 3 months from the end of the relevant assessment year if the escaped income is likely to be less than ₹50 lakh, and within 5 years and 3 months if the escaped income is ₹50 lakh or more. These shorter windows replaced the earlier 3-year and 10-year limits.

The GKN Driveshafts procedure. In GKN Driveshafts (India) Ltd v ITO (2003) 259 ITR 19 (SC), the Supreme Court settled the steps: on receiving a section 148 notice you file the return, then ask the Assessing Officer for the recorded reasons; the officer must furnish them within a reasonable time; you may then file objections; and the officer is bound to dispose of those objections by a speaking order before completing the reassessment. An assessment passed without disposing of objections by a speaking order is liable to be set aside.

Faceless and challengeable. Reassessment is now generally faceless under section 144B, handled through the e-proceedings portal. A jurisdictionally defective or time-barred notice can be challenged by a writ petition under Article 226 of the Constitution before the High Court.

1. Read the notice carefully. Note the section quoted, the assessment year, the issuing officer or unit, the document identification number (DIN) and the exact deadline.
2. Verify it on the portal. Log in to the income tax e-filing portal and check the notice under e-Proceedings or Pending Actions so you are sure it is genuine.
3. If it is a section 148A show-cause notice, reply on the portal with facts and documents explaining why no income escaped, before any section 148 notice is issued.
4. If it is a section 148 notice, file the income tax return for the relevant year within the time allowed in the notice, even if you had filed earlier.
5. After filing, write to the Assessing Officer asking for the recorded reasons for reopening.
6. On receiving the reasons, file written objections setting out why the reopening is wrong on facts or law.
7. Insist that the officer dispose of your objections by a speaking order before continuing the reassessment.
8. Respond to every faceless notice and questionnaire under section 144B within the timelines, keeping copies of all submissions.
9. If the notice is time-barred or issued without the section 148A enquiry, consult a tax professional about a writ petition under Article 226.

• Copy of the section 148 or 148A notice with the DIN
• Acknowledgement of the return filed for the relevant assessment year
• Form 26AS, the Annual Information Statement (AIS) and the Taxpayer Information Summary (TIS)
• Bank statements, purchase or sale deeds, and investment proofs for the year in question
• Books of account, computation of income and earlier assessment orders, if any
• Your written request for reasons and your objections, with proof of submission

• Ignoring the notice or missing the deadline, which invites an ex-parte best-judgment reassessment.
• Not filing the return after a section 148 notice, which weakens your position under section 148.
• Arguing the merits before asking for the recorded reasons, losing the GKN Driveshafts protection.
• Forgetting to file written objections, so the officer never has to pass a speaking order.
• Treating a faceless section 144B notice as spam and not replying through the portal.
• Rushing to the High Court when a portal reply would resolve the matter, or delaying so long that the time limit defence is lost.

The Right to Information Act, 2005 lets you seek general records and policy from a public authority, but the recorded reasons for your reassessment are obtained through the assessment process itself, by writing to the Assessing Officer as the GKN Driveshafts procedure requires, not through an RTI application. RTI is still useful for broad records such as CBDT instructions, circulars or office procedures that are not personal to your file.

To,
The Central Public Information Officer
Office of the Principal Chief Commissioner of Income Tax

Subject: Information under the RTI Act, 2005

Sir/Madam,
Under section 6(1) of the RTI Act, 2005, please provide:
1. Copies of CBDT instructions and circulars in force on the conduct
   of faceless reassessment under section 144B of the Income Tax Act, 1961.
2. The standard operating procedure followed for disposal of objections
   to notices issued under section 148.

I enclose the prescribed fee. Please furnish the information within the
period under section 7(1) of the Act. If any part is denied, kindly give
reasons and inform me of my right of first appeal under section 19(1).

Yours faithfully,
Name, address and date

You can prepare a clean request fast with the AI RTI Drafter, and if a reply is delayed or denied, build a first appeal with the First Appeal Builder.

Section 148A is the enquiry stage. The Assessing Officer gives you a show-cause notice and a hearing, then passes an order on whether it is a fit case to reopen. Section 148 is the actual notice that starts the reassessment once that stage is cleared.

From 1 September 2024, a notice can be issued within 3 years and 3 months from the end of the relevant assessment year if the escaped income is likely to be less than ₹50 lakh, and within 5 years and 3 months if it is ₹50 lakh or more.

Yes. You must file the income tax return for the relevant assessment year within the time allowed in the notice, even if you had already filed one for that year earlier.

Yes. After filing the return, write to the Assessing Officer asking for the recorded reasons. Under the GKN Driveshafts procedure the officer must furnish them, and you can then file objections.

The officer is bound to dispose of your objections by a speaking order before completing the reassessment. An assessment passed without doing so is liable to be set aside in appeal or by writ.

Yes, reassessment is generally faceless under section 144B and handled through the e-filing portal, so you should reply to every notice and questionnaire online within the stated timelines.

Yes. A jurisdictionally defective or time-barred notice, or one issued without the required section 148A enquiry, can be challenged by a writ petition under Article 226 before the High Court, usually after exhausting the portal response.

No. The recorded reasons specific to your case come through the assessment process by writing to the Assessing Officer. RTI is for general records and policy, such as CBDT circulars and standard procedures.

• Income Tax Department, official portal: https://www.incometax.gov.in
• Income Tax Department, sections of the Income Tax Act, 1961: https://www.incometaxindia.gov.in
• GKN Driveshafts (India) Ltd v ITO (2003) 259 ITR 19 (SC), Indian Kanoon: https://indiankanoon.org/search/?formInput=gkn+driveshafts
• Finance (No.2) Act, 2024, time limits for reassessment

• How to file an ITR rectification under section 154
• Fixing an AIS or Form 26AS mismatch for property sale, FD interest and salary
• When a property capital gains exemption is questioned by an income tax notice
• AI RTI Drafter tool
• First Appeal Builder tool
• The RTI Playbook
• RTI Act, 2005