A Section 143(2) notice opens a scrutiny assessment of a return you have already filed. A Section 148 notice starts a different route. Before the Assessing Officer can assess or reassess income under Section 147, it requires you to file a return in connection with income that may have escaped assessment. The two notices have different purposes, so they do not call for the same response.
Timing is where the two are most often confused. Under the Income-tax Act, 1961, a Section 148 return must be filed within the period the notice specifies, and that period cannot run beyond three months from the end of the month in which the notice is issued. For a Section 143(2) notice, official Income Tax Department guidance does not give one deadline that applies to every case. The date printed on the notice and the assessment year decide what applies to you.
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What each notice is for
| Question | Section 143(2) | Section 148 |
|---|---|---|
| Core purpose | Scrutiny assessment of a return already filed | Starts the reassessment route for possible income escaping assessment |
| Where it sits in the process | Examination of a return on file | Comes before any assessment or reassessment under Section 147 |
| What it asks of you | A response to the scrutiny, with the documents or information the notice lists | A return, filed within the period the notice states |
| Act for earlier years (tax years beginning before 1 April 2026) | Old-Act scrutiny assessments for AY 2026–27 and earlier continue under the Income-tax Act, 1961 | Reassessment continues under the Income-tax Act, 1961 |
| Act for Tax Year 2026–27 and later | Not stated in the Department guidance cited here | Sections 279–286 of the Income-tax Act, 2025 apply to reassessment |
| First action | Read the notice, note the assessment year, the listed issues and the response date | Confirm the assessment year and governing Act, then prepare the return |
The statutory role of a Section 148 notice
The wording of the statute explains why a Section 148 notice is a return demand rather than a scrutiny notice. Section 148 of the Income-tax Act, 1961 provides: “Before making the assessment, reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish” a return. If you quote this in print, keep the surrounding wording of the section. The Department’s own explanation of reassessment proceedings is on its reassessment proceedings page, and the statutory text is available from India Code.
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The practical consequence is that a Section 148 notice can arrive even where you filed a return for the same year earlier. The return it requires is filed in answer to the notice. It is not a reply to a scrutiny query on the return already on record.
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Which Act governs your notice
The governing law depends on the tax year the notice concerns, not on the date the notice reaches you. The Department states that Sections 279–286 of the Income-tax Act, 2025 apply to reassessment for Tax Year 2026–27 and later, while the 1961 Act continues to govern earlier years. The transition rules are set out in the Department’s objective and scope FAQ for the new Act.
Tax years beginning before 1 April 2026
For these years the 1961 Act governs reassessment. Under Section 536(2)(c), the repealed Act also continues to govern pending proceedings, and proceedings initiated on or after 1 April 2026 that concern earlier tax years. A notice received after the transition date can therefore still be an old-Act notice, and both Acts can be relevant at the same time for different years.
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Tax Year 2026–27 and later
Reassessment for these years falls under Sections 279–286 of the Income-tax Act, 2025. The Department guidance cited here does not separately set out how a Section 143(2) scrutiny notice works for these years, so the section cited on your notice and the Act it names are the reference points to check.
Timing: the clocks that matter
Section 148: the return period
For an old-Act Section 148 notice, the return must be filed within the period the notice states, subject to the three-month limit described above. The Department gives this example: a Section 148 notice for AY 2022–23 issued in February 2026. The taxpayer must file within the period stated in that notice, which can run no later than three months after the end of February 2026, or 31 May 2026. The taxpayer uses the corresponding old-Act return form. A shorter period stated on the notice controls.
The Department also says that an old-Act Section 148A sequence begun before 1 April 2026 may continue under the old Act after that date. That remains subject to the limitation requirements in Section 149.
Section 143(2): no single date to quote
Department guidance confirms that old-Act scrutiny assessments for AY 2026–27 and earlier continue under the 1961 Act. It does not set out one deadline for issuing a Section 143(2) notice that you can apply to every case. The statute does limit how late a scrutiny notice can be served, and that limit depends on the assessment year and the version of the law that applies. Use the notice’s own date and your return filing date as your starting points, and confirm the applicable provision before relying on any date. For your reply, the response date printed on the notice is the one that matters.
Keep the clocks separate
Several different periods can appear in the same file. Each one runs on its own rule:
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- the period a Section 148 notice gives you to file the return;
- the Department’s deadline to issue a notice;
- the time limit to complete a reassessment;
- the response period stated in any other notice type;
- the Section 149 limitation that applies to a Section 148A sequence.
What to do, in order
- Identify the section and assessment year. Confirm whether the notice cites Section 143(2) or Section 148, and note the assessment or tax year it concerns and the document identification number printed on it.
- Read the dates and requests. Note the date of issue or service, the response due date, the documents or information requested, and any portal or communication instructions.
- Decide which Act governs. Check whether the year begins before 1 April 2026, in which case the 1961 Act applies, or on or after that date, where the 2025 Act governs reassessment.
- For a Section 148 notice under the 1961 Act, file the return within the period stated. Use the corresponding old-Act return form. The Income Tax Returns FAQs cover return filing. Keep the acknowledgement.
- For a Section 143(2) notice, respond with the requested documents through the channel the notice specifies, by the response date printed on it.
- Use e-Proceedings where it applies. The e-Proceeding service on the e-Filing portal lets you view the notice and submit your response and attachments. The Department says an authorised representative can respond on the taxpayer’s behalf.
- Keep a complete record. Save copies of the return or response, all attachments, the acknowledgement and all correspondence with the Department.
- Involve a qualified Indian tax professional early if the notice raises complex factual questions, limitation issues, or questions about which authority has jurisdiction. A general guide cannot settle the facts of a particular case.
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