Section 148 reassessment season, Nov-Dec 2026 wave is here.

• AY 2019-20 standard 4-year limit: closing on 31 March 2027. AOs issuing 148A(b) before year-end to preserve option to proceed to Section 148 before limitation.
• AY 2015-16 / 2016-17 10-year extended limit: applicable where escaped income is INR 50 lakh+ in asset form. AOs reviewing CBDT risk-based selection + FTA (Foreign Tax Authority) exchange data + search cases.
• Data sources driving notices: SFT (Statement of Financial Transactions), AIS / TIS mismatches, international tax exchange, specific industry audits, informant reports.
• Volume: significant volume of 148A(b) notices issued each November-December season. Many are mechanical and quashable.

1. AO has information suggesting income escaping assessment (SFT, AIS mismatch, international exchange, search output).
2. Section 148A(a) enquiry: optional - AO may make preliminary enquiry.
3. Section 148A(b) show-cause notice: AO issues formal show-cause with the 'information' it relies on + proposed grounds. Response window 7-30 days.
4. Taxpayer's response: can refute information, present mitigating facts, argue jurisdictional defects.
5. Section 148A(d) order: AO decides whether to proceed. Must consider taxpayer's response.
6. Section 148 formal notice: if AO proceeds, formal reassessment notice issued. Taxpayer must file return.
7. Section 147 reassessment: regular assessment follows.
8. Section 147 order appealable to CIT(A) within 30 days.

1. Immediate action (Day 1): acknowledge notice; note exact response deadline; preserve all records relevant to the year in question.
2. Information review (Day 1-3): analyse exactly what information AO relies on. RTI request for complete file if needed.
3. Classification review (Day 3-5): is this a mechanical notice (easy to quash) or substantive issue (need defence)?
4. Legal grounds assessment:
5.   — Jurisdictional: 4-year vs 10-year limit, Section 148A procedure defects.
6.   — Substantive: income was already disclosed, SFT misreporting, duplicate counting, non-taxable receipt (gift, inheritance, exempt).
7.   — Treaty: DTAA relief available, foreign tax credit, treaty-residence tie-breaker.
8. Documentary refutation: ITR extract showing disclosed income, bank statements, agreements, Section 50C compliance docs, Section 56(2)(x) relative gift docs.
9. Section 148A(b) response drafting: comprehensive written response with annexures.
10. Submission on income tax portal: electronic filing before deadline.
11. Follow-up: await Section 148A(d) order. If favourable: closure. If adverse: Section 148 notice follows.
12. Writ in High Court: if Section 148A procedure fundamentally defective, consider writ petition.

• Foreign asset disclosure gaps: FTA exchange data + Schedule FA mismatches. US + UK + Singapore + UAE financial institutions sharing with Indian tax authority under CRS / FATCA.
• Real estate transactions: SFT reports of large property purchases / sales (Form 61A) not reflected in ITR capital gain.
• Share transactions: Form 61A reports of large securities transactions not reflected in capital gain disclosure.
• Cash deposits: large cash deposits reported via SFT.
• Business receipt gaps: TDS / TCS discrepancy with ITR revenue.
• Trust / family structures: foreign trust distributions, private trust income allocation.

Last updated: 2026-10-22.