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How reopening works now
- The officer shares the information and issues a show-cause notice under 148A, giving you time (usually 7–30 days) to reply
- After considering the reply, an order under 148A decides whether it is a fit case
- Only then is a notice under 148 issued, asking you to file a return for that year
- Assessment follows like scrutiny, with full opportunity of hearing
What a good 148A reply contains
- Point-by-point explanation of each transaction in the information (often from AIS, SFT or bank data)
- Documents: bank statements, purchase/sale deeds, gift deeds, loan confirmations
- Legal objections: time limit, sanction, whether the information actually shows escapement
- Request for personal hearing through video conference if needed
Budget 2026 change
An updated return (ITR-U) can now be filed even after a reassessment notice is issued, with an additional 10% tax — a way to settle genuine omissions without penalty on that income. Decide only after legal advice; it is an admission.
Worked example
Example: A notice for AY 2022-23 cites a ₹38 lakh cash deposit. A 148A reply showing the cash came from recorded business sales, backed by GST returns and books, can close the matter before a 148 notice is issued.
Common mistakes
- Missing the 148A reply window
- Replying with a general denial without documents
- Not checking whether the notice is beyond the time limit
Frequently asked questions
Under the rules applying from 1 September 2024, generally no — the outer limit is 5 years from the end of the assessment year, and only where escaped income is ₹50 lakh or more.
Last reviewed on 11 November 2026 by Vinay Jaglan, VJ & Associates. Law and portal screens change — verify before acting, or ask the office.
