To test whether a reassessment order was passed within the statutory time limit, compare four facts: the assessment year and law that govern the proceeding, the date the initiating reassessment notice was served, the date on the final order, and any statutory extension or exclusion. The order date alone cannot answer the question.
For many proceedings under the Income-tax Act, 1961, where a section 148 notice was served on or after 1 April 2019, section 153(2) generally allows completion within twelve months from the end of the financial year in which that notice was served. The Income-tax Act, 2025 describes a different rule for its applicable proceedings: one year from the end of the financial year in which the section 280 notice was served. Transition provisions can keep an earlier-year proceeding under the 1961 Act, so identify the governing law before doing any calculation.
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What the timeliness check actually measures
A reassessment is timely only if the final reassessment order was completed by the last date permitted under the law applicable to that proceeding, after accounting for any legally permitted extension, exclusion, remand, fresh-assessment rule or court direction. The relevant clock usually starts with service of the initiating notice, not with the assessment year and not with the date you happened to download the order.
Use this sequence:
- Identify the assessment year and whether the proceeding is governed by the Income-tax Act, 1961 or the Income-tax Act, 2025.
- Find the initiating notice and prove when it was served.
- Find the final signed reassessment order and its date.
- Calculate the ordinary statutory deadline.
- Check every applicable adjustment before deciding that the order is late.
This is a records-and-law comparison, not a conclusion that can be drawn from a single date shown on the portal.
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Step 1: Identify the assessment year and governing Act
Start by writing down the assessment year (or other tax-year identifier) shown in the notice and order. Then determine which Act and version controls the proceeding.
Proceedings under the Income-tax Act, 1961
The Department’s limitation table and section 153 material describe the general rule for a section 148 reassessment notice served on or after 1 April 2019: completion is generally limited to twelve months from the end of the financial year in which the notice was served. The rule is subject to the adjustments in the Act and the Department’s current limitation guidance.
Proceedings under the Income-tax Act, 2025
The 2025 Act applies to relevant tax years beginning on or after 1 April 2026. For proceedings to which that Act applies, Department guidance describes section 279 as allowing one year from the end of the financial year in which the section 280 notice was served.
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A proceeding concerning an earlier tax year may continue under the 1961 Act even after the 2025 Act has taken effect. Do not choose the newer rule merely because the order was issued after 1 April 2026. Read the transition provision applicable to the proceeding and identify the statute cited in the notice and order.
| Question | What to record | Why it matters |
|---|---|---|
| Tax period | Assessment year or other year shown in the case record | It helps identify the statutory regime and transition provision. |
| Initiating notice | Section number, notice number and date of service | The service date generally starts the limitation calculation. |
| Final order | Date on the signed reassessment order and communication details | This is the date to compare with the calculated last permissible date. |
| Applicable law | 1961 Act or 2025 Act, including the relevant version and amendments | Different provisions use different notice sections and periods. |
Step 2: Find the initiating notice and establish service
For a 1961 Act reassessment, locate the section 148 notice. The critical fact is when it was served, with the service record that supports that date. A notice date printed on the document is not necessarily the date on which service occurred.
Where to look
Sign in to the Income Tax e-Filing portal and open the case under e-Proceedings. Department guidance says registered users can use e-Proceedings to view notices, intimations and letters. Download the initiating notice, the portal event or delivery record, and any later communication that refers to service.
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Build a service-date record
- Save the complete notice PDF, including its page showing the notice date and section.
- Save the portal entry showing when the communication was delivered or made available, where that information appears.
- Record the email, electronic delivery or other service evidence that accompanied the notice.
- Note whether the file contains more than one notice or a corrected, substituted or reissued notice.
- Keep the original downloaded files and a separate chronology; do not rely only on a screenshot.
If the record shows conflicting dates, list each date and the reason it appears. The legally relevant service date can depend on the applicable service rule and the complete procedural history, so an unresolved conflict should be taken to a tax professional rather than resolved by guesswork.
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A free scan shows the junk files, broken settings and background clutter dragging Windows down - then fixes them in one click.Free scan · Windows 10 & 11Step 3: Locate the final reassessment order
Find the final signed reassessment order, not merely a draft, show-cause notice, demand notice or portal message stating that an order is available. Download the order and preserve the proceeding details displayed with it.
Dates to capture from the order
- The date printed on the signed order.
- The order number and the section under which it was passed.
- The date and method by which the order was communicated, if separately shown.
- Any reference to a remand, fresh assessment, transfer-pricing reference, court direction or earlier order.
When the order PDF and the portal event show different dates, do not silently select the earlier one. Preserve both records and identify which date the governing provision treats as completion or passing of the order. That issue can require interpretation of the full file.
Step 4: Calculate the ordinary statutory deadline
The calculation is calendar-based. First identify the financial year in which the initiating notice was served. Its last day is 31 March. Add the period specified by the applicable provision from that financial-year end.
1961 Act: section 148 notice and section 153(2)
For the general rule described by the Department for section 148 notices served on or after 1 April 2019, count twelve months from the end of the financial year of service.
| Notice served | Financial year of service | End of that financial year | Ordinary twelve-month endpoint |
|---|---|---|---|
| 15 November 2022 | 1 April 2022–31 March 2023 | 31 March 2023 | 31 March 2024 |
| 31 March 2024 | 1 April 2023–31 March 2024 | 31 March 2024 | 31 March 2025 |
| 2 April 2024 | 1 April 2024–31 March 2025 | 31 March 2025 | 31 March 2026 |
These are illustrations of the counting method, not determinations of any taxpayer’s case. The applicable limitation table, amendments and special rules must still be checked.
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2025 Act: section 280 notice and section 279
For a proceeding governed by the 2025 Act, Department guidance describes a one-year period from the end of the financial year in which the section 280 notice was served. Apply this only after confirming that the 2025 Act and its transition rules govern the proceeding.
| Notice served | Financial year of service | End of that financial year | Ordinary one-year endpoint under the described rule |
|---|---|---|---|
| 20 July 2026 | 1 April 2026–31 March 2027 | 31 March 2027 | 31 March 2028 |
| 1 April 2027 | 1 April 2027–31 March 2028 | 31 March 2028 | 31 March 2029 |
The table does not convert an earlier-year case into a 2025 Act case. A transition rule may keep that case under the 1961 Act.
Compare the order date with the endpoint
- On or before the endpoint: the order falls within the ordinary calculated period, subject to any issue about which date legally counts as completion.
- After the endpoint: the order appears out of time under the ordinary calculation, but do not reach a final conclusion until all statutory adjustments and court directions are checked.
- Unclear date: obtain the signed order, delivery record and complete chronology before calculating.
Step 5: Check exclusions, extensions and special proceedings
The ordinary twelve-month or one-year calculation is not a universal answer. The Act and the Department’s limitation material contain special rules that can alter the endpoint.
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Transfer-pricing references
A proceeding involving a reference to a transfer-pricing officer may have a different timetable or an adjustment to the ordinary period. Identify whether the file contains such a reference, when it was made, and what subsequent orders or directions were issued. Use the complete statutory text and the current limitation table for the applicable version.
Specified proceedings and excluded periods
The limitation provisions can contain exclusions or extensions for specified proceedings and events. Check the chronology for every event listed in the relevant provision rather than assuming that a general administrative delay extends the deadline. Record the legal basis, start date, end date and resulting number of days or months for each adjustment.
Remand, fresh assessment and court orders
A remand or fresh-assessment direction can place the matter under a different limitation rule from the original order. A court order may also pause, extend or otherwise affect the period. Keep the judgment or direction, the date it took effect and the proceeding to which it refers. Do not add an adjustment merely because litigation occurred; it must be one that the applicable law recognizes.
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Amendments and version control
Use the statutory text and limitation guidance that apply to the relevant period, including amendments in force for that proceeding. A table copied from an older year can produce the wrong deadline even when the arithmetic is correct.
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The portal is useful for assembling the record, but the portal label alone does not decide limitation.
- Sign in to the Income Tax e-Filing portal with the registered taxpayer or authorized representative account.
- Open e-Proceedings and select the relevant assessment or reassessment case.
- List every notice, intimation, letter, response and order in chronological order.
- Open and download the initiating notice, proof of service, final order and any document referring to extension, exclusion, remand or a court direction.
- Compare the downloaded PDFs with the event dates shown in the portal and note discrepancies.
- Store the files with descriptive names and keep an unedited copy for the case record.
Department guidance describes e-Proceedings as a way for registered users to view notices, intimations and letters. If a document is missing, use the portal’s available communication history and request the missing record through the appropriate official channel; do not infer a service date from an absent entry.
Step 7: Authenticate the notice or order’s DIN
Communications issued by the Income Tax Department on or after 1 October 2019 should bear a unique Document Identification Number (DIN), according to Department guidance. Use the Department’s notice/order authentication service to verify the DIN and the communication details.
Authentication answers a genuineness question: whether the communication corresponds to Department records. It does not answer the limitation question. A genuine order can still require a separate date calculation, and a date calculation cannot substitute for authentication.
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A worked file review
Illustrative 1961 Act chronology
Assume a file identifies a section 148 notice served on 15 November 2022. The notice was served in the financial year ending 31 March 2023. Applying the described general section 153(2) method gives an ordinary endpoint of 31 March 2024. If the signed reassessment order is dated 28 March 2024, it is within that ordinary endpoint. If it is dated 5 April 2024, it appears late under the ordinary calculation and requires a review of any applicable exclusion, extension, remand or court order.
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The example does not decide whether the order is legally valid because it assumes, rather than proves, the service date, governing provision and absence of adjustments.
Illustrative transition issue
Suppose an order is issued after 1 April 2026 but concerns an earlier assessment year and the file continues under the 1961 Act pursuant to transition rules. Using the 2025 Act’s section 279 calculation simply because of the order’s issue date would be a category error. The proceeding’s governing law must be established first.
Evidence checklist before alleging that an order is late
- Assessment year or other tax-year identifier.
- Act and provision cited in the initiating notice.
- Complete initiating notice PDF.
- Reliable service evidence and the date you are using.
- Final signed reassessment order and its printed date.
- Portal communication history and downloaded event details.
- DIN and result of the Department’s authentication check.
- Any transfer-pricing reference or specified proceeding.
- Any remand, fresh-assessment direction or court order.
- The limitation table, statutory text and amendments applicable to the proceeding.
- A written calculation showing the financial year end, ordinary endpoint and each adjustment.
Common mistakes that produce the wrong answer
Starting with the assessment year
The assessment year identifies the case, but the ordinary clock described here is tied to service of the initiating notice. Two taxpayers with the same assessment year can have different deadlines if their notices were served in different financial years.
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Using the date you first saw the order
Discovery or download date is not automatically the date the order was passed. Use the signed order and the legally relevant communication records.
Ignoring transition rules
The 2025 Act’s commencement does not automatically move every open case to its limitation rule. Earlier-year proceedings can remain under the 1961 Act.
Treating DIN verification as a limitation ruling
A valid DIN supports authenticity only. It does not calculate the last permissible date.
Adding informal extensions
Administrative delay, a portal outage or a request for more time should not be counted as an extension unless the applicable law or a binding court direction gives it that effect.
Relying on one document
The notice, proof of service, order, portal history and any special-proceeding documents must be read together. A single PDF can omit the event that changes the calculation.
What to do when the order appears out of time
- Preserve the original notice, service proof, order, portal history, DIN result and all intervening directions.
- Prepare a date table showing the ordinary endpoint and every claimed adjustment separately.
- Check the current statutory text, Department limitation table and transition provision for the proceeding’s exact Act and version.
- Identify the procedural route and deadline for raising a limitation objection in the case; those remedies depend on the order, jurisdiction and applicable law.
- Take the complete record to a qualified tax professional before making a filing or relying on the apparent date discrepancy.
An apparent late date is a reason to investigate promptly, not proof by itself that the reassessment is void or that every demand is unenforceable. The outcome turns on the governing provision, service evidence and any legally recognized adjustment.
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