The Classic Partners LLP
Section 148 Notice
A Section 148 notice reopens a past year's assessment. We file the return, demand the recorded reasons, raise objections, and defend the reassessment professionally.
Respond to 148What is a Section 148 Notice?
A notice under Section 148 of the Income Tax Act requires you to file a return of income for a past assessment year that the department has reopened under the income escaping assessment provisions of Section 147. Before issuing it, the officer must follow the Section 148A procedure — sharing the information suggesting escapement, hearing your reply, and passing a speaking order.
Receiving a 148 notice does not mean tax is automatically payable. Many notices are issued on misread data — joint accounts, exempt income, or transactions already disclosed. A precise return and strong objections at the right stage frequently close such cases without any addition.
Steps After Receiving a 148 Notice
- Verify the notice — DIN, assessment year, sanctioning authority, and limitation period.
- File the return for the reopened year within the time given in the notice.
- Seek the reasons/information relied upon for reopening, if not already provided.
- File objections to the validity of reopening where grounds exist.
- Defend on merits with reconciliations and evidence for each flagged item.
What We Handle
Validity Review
Checking limitation, sanction, and 148A compliance.
Return Filing
Accurate return for the reopened year — the mandatory first step.
Objections Drafting
Legal objections to invalid or mechanical reopening.
Transaction Evidence
Explaining each flagged deposit, investment, or property deal.
Reassessment Replies
Responses to 142(1) questionnaires in the reopened case.
Appeal Strategy
Challenging additions before CIT (Appeals) and ITAT.
Why Choose The Classic Partners
- Qualified Chartered Accountants experienced in reassessment litigation.
- Two-front defence — jurisdiction and merits argued together.
- Zero missed deadlines across the 148A and 148 timelines.
- Transparent fees and a single point of contact for your case.
Frequently Asked Questions
What should I do first after getting a Section 148 notice?
File the return for the reopened year within the time stated in the notice — even if you believe the reopening is invalid. Objections to validity are raised alongside, not instead of, filing the return.
What is Section 148A?
Section 148A mandates a pre-notice procedure: the officer must share the information suggesting escaped income, give you at least 7 days to reply, and pass an order deciding whether a 148 notice should be issued.
For how many past years can a 148 notice be issued?
Normally up to three years from the end of the assessment year. Where escaped income represented by an asset, expenditure, or entries is Rs. 50 lakh or more, the limit extends to ten years.
Can a 148 notice be quashed?
Yes. Notices issued beyond limitation, without proper sanction, without following Section 148A, or without valid information have been quashed by courts. A validity review is the first thing we do.
What happens if I ignore a Section 148 notice?
The officer will complete the reassessment ex-parte under Section 144, usually adding the entire flagged amount as income, with interest and penalty up to 200%. Never ignore a 148 notice.
Received a Section 148 notice?
Get the reopening reviewed and your defence filed by experienced CAs.
Contact Us