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There is no single reopening period that applies to every Indian taxpayer. The answer depends first on the tax year involved and then on the date and type of notice. Tax years beginning before 1 April 2026 generally remain governed by the Income-tax Act, 1961, including its section 149 limitation rules, even when qualifying proceedings continue after 1 April 2026. The Income-tax Act, 2025 reassessment framework applies to Tax Year 2026–27 and later.
You must also separate two questions: how long the department may take to issue a notice reopening an earlier year, and how long it may take to complete reassessment after serving the new-law notice. Those deadlines are different, and the available official guidance does not support one universal number of years for all cases.
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Start with the tax year, not the date on your letter
The changeover occurs on 1 April 2026. The Income-tax Department’s transition guidance says the repealed Income-tax Act, 1961 continues to govern tax years beginning before that date. Section 536(2)(c) of the Income-tax Act, 2025 preserves the old Act for those years, including proceedings initiated on or after 1 April 2026 when the transition conditions are met.
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| Tax year involved | Governing framework | Notice limitation identified in official guidance | Completion rule identified in official guidance |
|---|---|---|---|
| Beginning before 1 April 2026 | Income-tax Act, 1961, preserved for qualifying matters by section 536(2)(c) of the 2025 Act | Old Act section 149, together with its applicable amendments, exceptions and dates | Must be calculated under the old framework and the specific proceeding; no single period is stated here |
| Tax Year 2026–27 and later | Income-tax Act, 2025, sections 279–286 | New-law provisions and the facts supporting the proposed reassessment; the official material does not reduce this to one universal number for every case | Generally, an order under section 279 must be passed within one year from the end of the financial year in which the section 280 notice was served, subject to extensions and excluded periods |
Indian tax documents may use “assessment year” for the older system and “tax year” under the newer framework. Match the label and period on the notice to the law that applies to that period before calculating anything.
Two different clocks are often confused
Clock one: issuing a reopening notice
This is the question most people mean by “how far back can the department go?” For an older year, section 149 of the 1961 Act is the controlling limitation provision. Whether a notice is in time depends on the complete statutory text in force for that year, amendments, any special exception, the income information relied on, and the date on which the relevant notice was issued or served.
The official transition FAQ identifies section 149 but does not reproduce every operative clause and exception. It would therefore be unsafe to tell a taxpayer that the department always has a fixed number of years. A year-only answer can be wrong when the law changed, a special condition applies, or the notice chronology is misunderstood.
For a year covered by the 2025 Act, the department must use the new reassessment machinery and satisfy the conditions applicable to the proposed action. The exact outer period still has to be checked against the statutory text and the facts of the case; it is not interchangeable with the later completion deadline.
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Clock two: finishing reassessment after the notice
For reassessment under section 279 of the 2025 Act, the department’s FAQ describes a completion rule: the order must be passed within one year from the end of the financial year in which the section 280 notice was served. Extensions and excluded periods can change the calculation. The FAQ specifically notes that exclusions or extensions may arise in situations such as a transfer-pricing reference or a stay granted by a court or tribunal.
This one-year rule answers how long the department generally has to finish a new-law reassessment after the specified notice. It does not say how many earlier years the department may reopen, and it does not automatically govern a proceeding for a pre-1 April 2026 tax year.
How proceedings for earlier tax years continue after 1 April 2026
The transition guidance allows the old process to continue for qualifying earlier years. It confirms that the section 148A and section 148 sequence can operate after 1 April 2026 when the proceeding was initiated before the transition date, provided the section 149 limitation is satisfied.
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- A section 148A(1) notice is issued on 20 March 2026.
- The department considers the taxpayer’s response and passes a section 148A(3) order.
- A section 148 notice is then issued in April 2026.
This is an official transition example showing how an initiated old-law proceeding can continue across the commencement date. It is not a ruling that every April 2026 notice for an older year is timely. In an actual case, you still have to verify when the proceeding began, which notices were issued and served, and whether section 149 permits the action.
What the new-law reassessment process generally looks like
For Tax Year 2026–27 and later, the FAQ describes a structured process rather than an immediate reopening in every case.
1. Information suggesting escaped income
The department must have information indicating that income may have escaped assessment or that reassessment should be considered under the 2025 Act. The information and the relevant tax year should be identified in the departmental record and subsequent communication.
2. Section 281 show-cause notice
In the general case, the department issues a show-cause notice under section 281 and gives the taxpayer an opportunity to respond. Read the notice for the response deadline, the information relied on and the proposed year. Missing the response date can forfeit the chance to correct a factual or legal error before the decision is made.
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3. Consideration of the reply
The assessing authority considers the taxpayer’s explanation and supporting material. A response should address each item, identify documents that disprove the alleged escaped income, and explain any limitation objection with dates rather than relying on a bare assertion that the notice is “too late.”
4. Reasoned order
After considering the response, the authority passes a reasoned order where the statutory process requires one. The order should make clear why the proposed reassessment will or will not proceed.
5. Section 280 notice and reassessment
Where the case proceeds, the department issues the notice under section 280. The one-year completion clock described by the FAQ is measured from the end of the financial year in which that section 280 notice was served, not simply from the date of the first information request or from the end of the tax year under examination.
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Why the year alone cannot answer whether a notice is valid
A limitation calculation normally requires more than the year printed in the heading. Check all of the following:
- The relevant period: identify the assessment year or tax year and the dates on which that year began and ended.
- The governing Act: determine whether the year falls before 1 April 2026 and is preserved under section 536(2)(c), or falls under the 2025 Act.
- The notice type: distinguish an information request, a section 281 show-cause notice, a section 148A notice or order, a section 148 notice, and a section 280 notice.
- Issue and service dates: a date printed on a notice may differ from the date it was electronically served or otherwise made available.
- The information alleged to show escaped income: the applicable limitation clause can depend on the nature and amount of the alleged escaped income and other statutory conditions.
- Amendments and exceptions: use the version of section 149 or the relevant 2025 Act provision that applies to the proceeding, including any saving or special rule.
- Excluded periods: for completion under the 2025 Act, account for statutory exclusions and extensions, including those connected with transfer-pricing references or court and tribunal stays where applicable.
A practical method for checking a notice
- Copy the year exactly. Record the assessment year or tax year shown on every communication. Do not convert it from memory.
- Build a notice timeline. List the date of each notice, order, reply, service event and stay. Keep electronic delivery records, not just downloaded PDFs.
- Classify the proceeding. Decide whether it is an old-Act section 148A/148 matter or a 2025 Act sections 281/280 matter.
- Apply the transition rule. If the year began before 1 April 2026, test whether section 536(2)(c) keeps the 1961 Act in control even though a step occurred after that date.
- Check section 149 for an old-Act case. Use the complete text and amendments applicable to the year and notice, including every exception that could extend or restrict the period.
- For a new-Act case, identify the section 280 service year. Calculate one year from the end of that financial year, then adjust for any documented extension or excluded period.
- Raise objections promptly. If you believe the notice is outside time, state the dates and legal basis in the response instead of waiting for the final order.
Worked timeline examples
Earlier year, post-transition notice
Suppose the notice concerns assessment year 2022–23 and the first section 148A(1) notice was issued on 20 March 2026. The transition guidance indicates that the department may complete the section 148A process and issue a section 148 notice in April 2026 under the old Act, but only if the old-law limitation in section 149 is met. The April date alone neither validates nor invalidates the notice.
New-law completion calculation
Suppose a section 280 notice is served during financial year 2027–28. The ordinary endpoint described by the FAQ is one year from the end of that financial year, subject to any applicable extension or excluded period. That calculation concerns completion of reassessment; it does not determine how far back the underlying tax year could be reopened.
Common mistakes that create avoidable disputes
- Using a fixed “four-year” or “six-year” rule without checking the case. Different statutory versions and exceptions can produce different results.
- Assuming every notice issued after 1 April 2026 uses the 2025 Act. Earlier tax years can remain under the 1961 Act.
- Confusing service with preparation. Preserve the actual service record because the relevant clock may depend on when the notice was served.
- Treating the one-year completion period as the reopening period. It starts from the end of the financial year in which the section 280 notice was served and addresses completion only.
- Ignoring the pre-notice opportunity. A section 281 response can be the stage at which limitation, wrong-year allegations or missing information are first clearly presented.
When professional review is worthwhile
A chartered accountant or tax lawyer experienced in reassessment proceedings can reconstruct the timeline, identify the correct statutory version and test the notice against section 149 or the 2025 Act provisions. Professional review is especially important when multiple notices exist, the department relies on an exception, a court or tribunal stay affected time, or the disputed amount is substantial.
Bring the original return, assessment order, all departmental communications, portal service records, replies, orders and evidence relating to the alleged escaped income. A reviewer cannot reliably calculate limitation from the latest notice alone.
Quick Recap
What to remember
- The governing Act changes at the 1 April 2026 boundary, but the date of a later notice does not automatically move an earlier tax year into the 2025 Act.
- For pre-boundary years, section 149 of the 1961 Act remains the key limitation provision when the transition rule preserves that Act.
- For Tax Year 2026–27 onward, reassessment follows sections 279–286, ordinarily beginning with the section 281 opportunity to respond and, where applicable, a section 280 notice.
- The new Act’s stated one-year period is a completion deadline measured from the end of the financial year in which the section 280 notice was served, with possible extensions and exclusions.
- A defensible answer requires the exact year, notice chronology, service dates, alleged escaped-income information and the complete law applicable to that proceeding.
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