By S&S Co. Advocates & Solicitors · Published 11 March 2026 · Informational content, not legal advice
About this article: A general explainer prepared by S&S Co. Advocates & Solicitors on a recurring type of dispute. It does not report a specific judgment or order, names no parties and gives no case citation, so it should not be cited as authority. Law and practice change; please verify against the current statute and primary sources before relying on it.
Since the reforms of 2021, reopening an assessment under Section 147 of the Income-tax Act, 1961 follows a structured procedure. The Assessing Officer must conduct an inquiry and give the taxpayer an opportunity to respond under Section 148A, pass an order under Section 148A(d) deciding whether the case is fit for notice, and obtain the approval of the specified authority before a notice under Section 148 is issued. Section 149 sets the time limits.
The ordinary time limit for reopening has been three years from the end of the relevant assessment year. A longer period is available only where the Assessing Officer has books of account, documents or evidence showing that income represented in the form of an asset, expenditure or an entry has escaped assessment and the amount is ₹50 lakh or more. For the longer period a higher authority is generally required to approve. The time limits and approval authorities were amended by the Finance Act, 2024, so the version applicable to the date of notice must be checked, as must the corresponding provisions of the Income-tax Act, 2025 for later periods.
High Courts have set aside notices issued beyond the ordinary period where the Section 148A(d) order did not quantify the escaped income, or the approval came from the wrong authority, treating these as jurisdictional defects that are not cured by later reasoning in the reassessment order.