The Statutory Brief

IT Act 1961 → 2025 / Section 148

Returns & assessment

Section 148 → Section 280

Notice for reassessment where income has escaped assessment, and the pre-notice procedure

New reference Section 280 (148A → 281)

Income-tax Act, 1961Section 148

  • Notice u/s 148 requires 'information' suggesting income has escaped assessment
  • Mandatory show-cause procedure u/s 148A before the notice
  • Time limits u/s 149; sanction u/s 151

Applies to FY 2025-26 (AY 2026-27) and earlier years.

Income-tax Act, 2025Section 280 (148A → 281)

  • Notice now under section 280
  • Pre-notice procedure (old 148A) is section 281
  • Time limit for notices under 280/281 is section 282
  • Sanction requirement in section 284

Applies from tax year 2026-27 (from 1 April 2026).

What changed

Renumbered and redrafted with 'relevant tax year' in place of 'relevant assessment year'. The information-based trigger and the pre-notice hearing continue.

Practice notes

  • A notice citing section 148 for a tax year governed by the new Act, or section 280 for an old year, is a point worth examining.
  • The time-limit rules (old 149) were overhauled by the Finance (No. 2) Act, 2024; section 282 is the place to check for current limits.

These are summaries, not the statutory text. Read the bare Act for both sections on the Income Tax Department's official site, which also has a side-by-side comparison utility.

Related sections

147→279Income escaping assessment: power to assess or reassess139→263Return of income: original, belated, revised, updated and defective returns