15 January 2026
A notice under Section 148 signals that the Assessing Officer believes income has escaped assessment for a prior year. Before any reply is drafted, it is worth understanding what the notice is actually alleging — and what it is not.
Since the amendments to the reassessment framework, the department is required to issue a show-cause notice under Section 148A(b) before the Section 148 notice itself. This preliminary notice sets out the information or material the AO relies upon — and the reply to it is frequently the single most consequential document in the entire proceeding, because it shapes whether the reassessment is even initiated.
The taxpayer typically has a short window — often as little as seven to thirty days — to respond to the 148A(b) notice. Missing this window does not end the matter, but it does narrow the options available and shifts the burden onto subsequent appellate stages.
An effective response addresses three things: whether the information relied upon is correct on facts, whether it genuinely suggests escapement of income within the meaning of the section, and whether the notice itself has been issued within the permissible time limit. Each of these can independently be a complete answer to the notice.
Where the reassessment proceeds despite a considered reply, the response filed at this stage continues to matter — it becomes part of the record that any subsequent appeal before the CIT(A) or the ITAT will refer back to.