A Section 148 notice is the most serious type of income tax notice you can receive. It means the IT Department believes you have concealed or under-reported income in past years — and they want to reopen your assessment.
How Far Back Can They Go?
- Up to 3 years for normal cases
- Up to 10 years if alleged escaped income exceeds ₹50 lakh (post 2021 amendment)
- The relevant Assessment Year is clearly mentioned in the notice
The New 148A Procedure (Post 2021)
After Budget 2021, the department must first serve a Section 148A show-cause notice, conduct an inquiry, and hear your reply before issuing the actual Section 148 notice. This is your first opportunity to present your case and potentially prevent the reopening entirely.
What Must You Do?
- Respond to the 148A show-cause within the given time (usually 15–30 days)
- If 148 is issued despite your reply, file a fresh ITR for the relevant year
- Attend all scheduled hearings with full documentation
- If additions are made, file an appeal within 30 days of the order
Common Reasons for 148 Notices
- Cash deposits not matching declared income (especially post-demonetisation)
- High-value property purchases or sales vs. disclosed income
- Foreign remittances reported by banks or through CRS/FATCA cross-border reporting but not included in ITR
- NRI income from Indian sources not filed — especially relevant if your residency status changed during the relevant year
- Third-party information from banks, registrars, or brokers
Immediate action is critical. Do not respond to a Section 148 notice without professional CA guidance. Emergency consultation is available within 24 hours. See also: complete guide to all income tax notice types and how Section 143(2) scrutiny differs from 148.