To check whether an Indian income-tax reassessment notice is time-barred, identify the assessment year and notice section, establish the applicable version of the law, and compare the legally relevant issue date with the deadline counted from the end of that assessment year. Under the general limits described by the Income Tax Department for the section 149 framework amended from 1 September 2024, the period depends on whether the notice is under section 148A or section 148 and whether the alleged escaped income is below ₹50 lakh or at least ₹50 lakh. Exclusions, legacy rules and the 2026 transition can change the result, so a date calculation alone does not decide whether an individual notice is valid.
What “time-barred” means in a reassessment case
A notice is time-barred when the law no longer permits it to be issued for the relevant assessment year. The ordinary starting point for the limitation calculation is the end of that assessment year—not the date you filed your return, received a refund, or first heard from the Department. The Department’s guidance puts the consequence plainly: “If an assessment is not completed within the prescribed time limit, it becomes time barred.” That statement concerns the applicable statutory deadline; it does not establish whether a particular notice falls outside it.
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In practice, there is more than one clock. Section 148A concerns the show-cause stage that generally precedes a reassessment notice; section 148 concerns the reassessment notice itself. There is also a separate deadline for completing a reassessment after a section 148 notice is served. Keep those questions separate. A section 148A communication is not a section 148 notice, and the deadline to issue either one is not the deadline to complete the assessment.
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Start with the notice and the assessment year
Identify which notice you have
Read the heading, body and cited statutory provision on the actual document. Record whether it is a section 148A(b) show-cause notice or a section 148 notice. Do not infer the section from a portal status, an email alert, or the fact that the communication asks for information. The legal effect and applicable deadline differ by notice type.
Record the date shown as the date of issue and the date it was served or received as separate facts. Save the full notice as downloaded, the portal communication, any email or SMS alert, and available delivery or envelope records. Those records may matter if the dates are disputed. The issue date is central to the general issuance-limit calculation; service also matters for procedural questions and for the separate reassessment-completion period.
Verify the assessment year
Use the assessment year (AY) stated in the notice, then check that it corresponds to the income period the Department is questioning. In the familiar pre-2026 terminology, an assessment year follows the financial year in which the income was earned. For example, income earned in financial year 2020–21 is ordinarily assessed in AY 2021–22. A mismatch between the notice’s year and the underlying income period is a reason to check the record, not a reason to substitute a year without examining the documents.
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Limitation is counted from the end of the relevant assessment year. Thus AY 2021–22 ended on 31 March 2022. The correct starting point is not the return-filing date within that year, nor the date on which the original assessment was completed. First establish the year; only then calculate a possible deadline.
General section 149 limits under the framework amended from 1 September 2024
The Department’s transition FAQ summarizes the general periods below for the amended section 149 framework. Each period runs from the end of the relevant assessment year. The threshold refers to the amount of alleged escaped income, not the amount of tax that might be due.
| Notice | Alleged escaped income | General period to issue |
|---|---|---|
| Section 148A show-cause notice | Less than ₹50 lakh | Within 3 years |
| Section 148A show-cause notice | ₹50 lakh or more | Within 5 years |
| Section 148 reassessment notice | Less than ₹50 lakh | Within 3 years and 3 months |
| Section 148 reassessment notice | ₹50 lakh or more | Within 5 years and 3 months |
These are general limits, not a stand-alone test for every assessment year. The statutory version governing the year, any legacy restriction, exclusions from the count, the evidence and conditions supporting the higher threshold, and other procedural requirements must still be examined. The Department’s published section 149 text begins: “No notice under section 148 shall be issued for the relevant assessment year”. The operative provisions and provisos that follow determine how that rule applies to a particular chronology.
Illustrative date calculation
Suppose, only to demonstrate the arithmetic, that AY 2021–22 is governed by the stated general framework and no exclusion or special restriction applies. That AY ended on 31 March 2022. A three-year period ends three years after that date; a three-year-and-three-month period ends three years and three months after it. A five-year period and a five-year-and-three-month period are calculated in the same way. For this example, those calendar endpoints would be 31 March 2025, 30 June 2025, 31 March 2027 and 30 June 2027, respectively.
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1Clear out junk files and repair common Windows errors2Fix the driver behind crashes, sound loss and screen glitches3Repair Windows errors before they cause bigger problemsThis example does not establish which framework applies to AY 2021–22, whether a particular notice qualifies for a longer period, or how an exclusion affects the calculation. It shows why both the year and notice type must be known before comparing dates. Do not apply these endpoints to a real case until you have checked the governing provision and chronology.
Check whether the ₹50 lakh longer-period test is actually met
Do not treat any asserted discrepancy above ₹50 lakh as automatically sufficient for the longer period. The older section 149 text ties the extended-period condition to books, documents or evidence revealing escaped income of ₹50 lakh or more in specified forms. It identifies an asset, expenditure connected with a transaction or event, or entries in books of account. Its definition of “asset” includes immovable property, shares and securities, loans and advances, and bank deposits.
That statutory test is more specific than asking whether the tax authority believes that total unreported income, a proposed adjustment, or potential tax exceeds ₹50 lakh. Read the notice and the material it identifies: what amount is alleged to have escaped assessment, what form is said to be involved, and what evidence is relied on? Then check the version of section 149 applicable to the proceeding. The applicable wording and conditions may differ with the year and statutory amendments.
If the notice relies on the higher threshold but does not make clear how the amount or specified form is established, preserve the notice and supporting correspondence for professional review. A threshold calculation is a legal and factual question; the figure alone does not resolve it.
Determine which statutory version governs
Proceedings for tax years beginning before 1 April 2026
The Department FAQ states that reassessment for a tax year beginning before 1 April 2026 remains governed by the Income-tax Act, 1961. It also says that proceedings already initiated under that Act continue under it, and that fresh proceedings for earlier years after 1 April 2026 may still be initiated under the old Act if its conditions, including section 149 limitation, are met.
That means the calendar date on which you receive or inspect a notice is not, by itself, enough to decide which Act applies. Identify the tax year and whether a proceeding had already begun. Then apply the transition explanation together with the governing provisions and limitation applicable to that year.
Tax Year 2026–27 and later
For Tax Year 2026–27 and subsequent years, the FAQ says the reassessment provisions in the Income-tax Act, 2025—sections 279–286—apply. A tax year beginning before 1 April 2026 remains under the 1961 Act for reassessment. Do not carry the section 148 and section 148A limits in this guide forward as though they automatically describe the 2025 Act’s procedure for later tax years.
The FAQ also describes an old-Act section 148A proceeding begun before 1 April 2026 whose later steps may take place after that date, subject to section 149 limitation. This is a transition rule, not a revival of a limitation period that has already expired. For a case spanning the changeover, document when the proceeding began and each subsequent step, then check the old-Act conditions applicable to it.
Look for exclusions, minimum periods and legacy restrictions
The date arithmetic can be affected by statutory rules that exclude certain time from the count. The Department’s published section 149 text includes exclusions for the time allowed to respond to a section 148A(b) show-cause notice and for the period during which a proceeding is stayed by a court. It also provides a minimum remaining period in a specified circumstance. The precise application depends on the provision and the dates in the record.
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Build a chronology rather than assuming that every day between the AY-end date and the notice date counts in the same way. Include the show-cause notice, response deadline, any extension granted, your response date, court orders and the dates when any stay began and ended. Check what the statute excludes and whether the facts meet that provision; do not simply subtract every period of delay or correspondence.
Older assessment years may also face a legacy restriction. A proviso in the earlier limitation framework can prevent reopening certain years where a notice would already have been beyond the earlier regime’s limit. This can make an apparently available period under a later amendment irrelevant to an older year. Review the applicable prior law and the year-specific provisos rather than assuming that a newer, longer period reopens every earlier assessment year.
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- Preserve the record. Download the complete notice and attachments from the income-tax portal. Save the portal timeline, delivery evidence, relevant email or SMS alerts, return and assessment records, responses, extension requests and court orders.
- Write down the statutory section and dates. Mark whether the document is under section 148A or section 148. Record its stated issue date, actual service or receipt date, and any earlier show-cause or related notice dates separately.
- Confirm the year and income period. Compare the assessment year in the notice with the financial year or tax year to which the alleged income relates. Note the last day of the relevant assessment year under the applicable terminology.
- Select the governing law. Determine whether the relevant tax year begins before or on/after 1 April 2026, whether the 1961 Act applies, and whether the proceeding is part of a pre-transition process. For earlier years, check amendments and legacy restrictions rather than relying on a current summary alone.
- Identify the alleged amount and its basis. Note the stated escaped-income amount and the evidence or category cited. If the longer period is invoked, examine whether the statutory conditions for that period are met under the version applying to the year.
- Calculate the applicable issuance period. Use the period for the correct notice type and threshold. Count from the end of the AY as the applicable provision directs. Keep the calculation on a calendar with the assumed rule stated beside it.
- Test the chronology for statutory adjustments. Review any response period, court stay or other circumstance that the applicable provision excludes or treats specially. Keep the source document and exact start/end dates for each event.
- Compare the legally relevant date with the adjusted deadline. Do not substitute the receipt date for the issue date without checking the legal rule relevant to the question. If issuance and service dates differ, preserve both and flag the difference for advice.
- Check other statutory requirements separately. Section 149(2) makes issuance subject to section 151. Being within a calculated date range does not, by itself, establish that authorization or other procedural requirements were met.
- Get a file-specific review where facts are disputed. An Indian chartered accountant or tax lawyer can review the full notice history, year, evidence, exclusions, transition issues and approvals. The Department’s general guidance cannot decide an individual case without that chronology and record.
Do not confuse notice issuance with reassessment completion
A timely notice does not answer how long the Department has to complete the reassessment. The Income Tax Department’s limitation guidance, marked as amended by Finance Act, 2026, generally gives 12 months from the end of the financial year in which a section 148 notice was served to make the reassessment, subject to specified extensions. This completion period is a different clock from the section 149 deadline for issuing a notice.
For this second calculation, retain the service date because the stated starting point is the end of the financial year in which the section 148 notice was served. Then check the applicable statutory extensions and any other conditions. A notice may be within the issuance period while a later reassessment order raises a separate completion-limitation question, or vice versa; assess each event against its own rule.
Common mistakes that lead to the wrong answer
- Counting from the return date. The general starting point is the end of the relevant assessment year, not the day you filed your return.
- Calling every communication a section 148 notice. A section 148A show-cause notice has a different role and general issue period from the section 148 reassessment notice.
- Using “three years” as a universal rule. The general periods differ by notice type and alleged escaped-income threshold; legacy provisions, exclusions and transition rules also matter.
- Comparing the threshold to tax payable. The ₹50 lakh threshold concerns alleged escaped income, and the relevant statutory conditions and evidence must be checked.
- Using the receipt date as the only date. Keep issue and service dates distinct. They can matter to different questions, and a discrepancy should be reviewed under the applicable law.
- Assuming the 2025 Act either applies to every notice after 1 April 2026 or revives old cases. The Department’s transition explanation distinguishes tax years and ongoing proceedings; it does not say that an expired limitation period is revived.
- Treating a date calculation as a complete validity opinion. Authorization, the statutory basis, evidence and procedural compliance require separate review.
Official materials to consult
For a case-specific calculation, use the Income Tax Department’s published text of section 149 of the Income-tax Act, 1961, its “Time limit for issuing different income-tax notices and completion of the assessment” guidance, and its FAQs on Interplay and Transition under the Income-tax Act, 2025. The limitation guidance is identified as amended by Finance Act, 2026; the transition FAQ explains the post-1 September 2024 section 149 periods and the 2026 changeover. Read the text and amendments relevant to the particular assessment year rather than treating a summary table as a substitute for the applicable provision.
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