The Statutory Brief

IT Act 1961 → 2025 / Section 149

Returns & assessment

Section 149 → Section 282

Time limit for reassessment notices (148) and show-cause notices (148A)

Section 149 of the old Income-tax Act, 1961 · new section 282 under the Income-tax Act, 2025

New reference Section 282

Income-tax Act, 1961Section 149

  • 148 notice: within 3 years 3 months from end of the assessment year
  • Up to 5 years 3 months if escaped income is ₹50 lakh or more and the AO has evidence
  • 148A show-cause: 3 years, or 5 years for ₹50 lakh+
  • Regime substituted by Finance (No. 2) Act 2024 from 1 September 2024

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

Income-tax Act, 2025Section 282

  • Section 280 notice: within 4 years 3 months from end of the tax year
  • Up to 6 years 3 months if escaped income is ₹50 lakh or more with evidence
  • Section 281 show-cause: 4 years, or 6 years for ₹50 lakh+
  • New 282(3): no notice within one year from the end of the tax year

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

What changed

No real change in the outer limit. The 2025 Act counts from the end of the tax year, which is one year earlier than the end of the assessment year, so 4 years 3 months from the tax year equals 3 years 3 months from the assessment year.

Practice notes

  • Example: tax year 2026-27 ends 31 March 2027; normal limit for a 280 notice is 30 June 2031.
  • Section 283 (order in appeal cases) was substituted by Finance Act 2026: notice to give effect to an order must be issued within three months from the end of the quarter in which the certified copy is received.
  • Reassessment procedure (147, 148, 148A) is on the 147/148 pages.

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.

Frequently asked

What is the time limit for reassessment under the new Income Tax Act?

Section 282: 4 years 3 months from the end of the tax year, extendable to 6 years 3 months if escaped income is ₹50 lakh or more and the AO has evidence. This matches the old 3 years 3 months / 5 years 3 months from the end of the assessment year.

What is section 149 called in the new Income Tax Act?

Section 282 of the Income-tax Act, 2025.

What changed in section 149 under the new Income Tax Act?

No real change in the outer limit. The 2025 Act counts from the end of the tax year, which is one year earlier than the end of the assessment year, so 4 years 3 months from the tax year equals 3 years 3 months from the assessment year.

Is section 149 still applicable for FY 2025-26?

Yes. Income of FY 2025-26 (AY 2026-27) and earlier years is governed by section 149 of the 1961 Act. Section 282 of the 2025 Act applies from tax year 2026-27.

Related sections

147→279Income escaping assessment: power to assess or reassess148→280Notice for reassessment where income has escaped assessment, and the pre-notice procedure151→284Sanction for issue of reassessment notice139B–242→263–436Tax return preparers, verification of return, faceless assessment 144B, reassessment time limits 149 and sanction 151, intimation of loss, Aadhaar fee, refunds