A scrutiny notice examines a return you already filed; a reassessment notice reopens an earlier tax year because the Assessing Officer has information suggesting that income escaped assessment. Under the Income-tax Act, 1961, scrutiny is commonly started with section 143(2), while ordinary reassessment uses section 148A before a section 148 notice. For tax years beginning on or after 1 April 2026, the Income Tax Act, 2025 uses sections 281 and 280 for the preliminary process and reassessment notice. The year covered by the notice—not simply the date printed on it—determines which Act applies.
The difference in one table
| Point | Scrutiny notice | Reassessment notice |
|---|---|---|
| Basic purpose | Examine a return that has already been filed through scrutiny assessment. | Reopen a tax year when information suggests that income escaped assessment. |
| Common reference under the Income-tax Act, 1961 | Section 143(2). | Section 148A preliminary procedure, followed ordinarily by section 148. |
| New-law reference for new tax years | The official transition material confirms that section 143(2) scrutiny for AY 2026-27 and earlier remains under the 1961 Act; it does not establish a replacement scrutiny section in the material reviewed. | Sections 281 (show-cause and reasoned preliminary decision) and 280 (notice) of the Income Tax Act, 2025. |
| What starts the case | The Department selects the filed return for scrutiny and serves a notice. | The Department identifies information indicating possible escaped income and begins the reopening procedure. |
| What you are being asked to do | Support figures, claims and disclosures already made in the return, and answer the issues raised during scrutiny. | Respond first to the proposed reopening, then deal with the reassessment issues if a notice to reassess is issued. |
| Transition rule | For a tax year beginning before 1 April 2026, the 1961 Act continues to govern, even if the proceeding occurs after the new Act starts. | The 2025 Act’s reassessment provisions apply to tax years beginning on or after 1 April 2026; earlier years remain under the 1961 Act. |
This is the broad distinction described in Income Tax Department FAQs. Individual notices can involve statutory exceptions, different facts and additional provisions, so the exact section and year on your notice control the next step.
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What a scrutiny notice under section 143(2) does
A section 143(2) notice brings a filed return into the scrutiny assessment process. The Department is checking whether the income, deductions, exemptions, tax credits or other particulars in that return are supported and correctly reported. It is not, by itself, an allegation that you concealed income or that the return is false.
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What scrutiny can cover
The notice or subsequent communications may ask for records such as bank statements, salary or business accounts, invoices, investment proofs, property documents, withholding-tax information, foreign-income details or explanations for differences between the return and information available to the Department. The scope depends on the notice and the issues selected. Do not assume that every scrutiny is a comprehensive investigation of every item, or that every case follows the same sequence.
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What scrutiny does not mean
Scrutiny is not another name for reassessment. It starts with the return that was filed for the relevant assessment year or tax year. A scrutiny notice does not automatically mean that a prior assessment has been cancelled or that a new source of income has been discovered. The eventual assessment may accept the return, seek an adjustment, or require further explanation according to the facts and applicable law.
What a reassessment notice does
Reassessment is a reopening mechanism. It is used when the Assessing Officer has information suggesting that income for an earlier tax year escaped assessment. The purpose is to revisit that year’s tax position, rather than simply examine a return in the ordinary scrutiny process.
Ordinary sequence under the 1961 Act
For the ordinary case under the Income-tax Act, 1961, the Department generally uses the section 148A preliminary procedure before issuing a section 148 notice:
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- A preliminary opportunity is given. A show-cause communication under section 148A ordinarily tells you why reopening is being considered and gives you an opportunity to respond.
- Your reply is considered. Submit the explanation and supporting material requested, using the channel and format stated in the communication.
- A decision is made. The Assessing Officer decides whether it is fit to issue a reassessment notice, subject to the statutory approval process.
- A section 148 notice may follow. If the decision permits reopening, the section 148 notice starts the reassessment proceedings for that year.
The preliminary procedure has statutory exceptions. Therefore, do not assume that every reassessment matter will contain identical documents or that the sequence is exceptionless.
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What the section 148 stage means
A section 148 notice is more than a request to clarify one line of a return. It signals that the Department is reopening the tax year’s assessment under the applicable reassessment provisions. You may need to file or confirm the return in the manner directed, answer the reasons and issues identified, and provide evidence for the relevant income and deductions. The notice itself and subsequent communications determine the precise action required.
The 2026 change: which Act governs your notice?
The Income Tax Department’s transition FAQs state that reassessment provisions in sections 279 to 286 of the Income Tax Act, 2025 apply to tax years beginning on or after 1 April 2026. Reassessment for a tax year beginning before 1 April 2026 remains governed by the Income-tax Act, 1961.
The Department also explains that proceedings initiated or continued after 1 April 2026 for an earlier tax year remain under the 1961 Act through the repeal-and-savings framework. It specifically confirms that a section 143(2) scrutiny assessment for AY 2026-27 or an earlier assessment year continues under the old Act, even though the new Act is in force when the notice or proceeding occurs.
Why the date on the proceeding can mislead you
A notice issued after 1 April 2026 can still display an old-Act section number and be valid when it concerns a pre-1 April 2026 tax year. Conversely, a notice for a tax year beginning on or after 1 April 2026 must be read against the new Act’s terminology and provisions. The commencement date of the law and the year being examined are separate questions.
| Year covered | Likely governing framework described by the Department | Examples of section references |
|---|---|---|
| Tax year beginning before 1 April 2026 | Income-tax Act, 1961 continues, including proceedings occurring after 1 April 2026. | Scrutiny: 143(2). Reassessment: 148A and ordinarily 148. |
| Tax year beginning on or after 1 April 2026 | Income Tax Act, 2025 provisions apply to reassessment. | Reassessment preliminary process: 281. Reassessment notice: 280. |
The reviewed transition material does not provide a new-Act scrutiny section number. For a scrutiny notice, rely on the section printed on the notice and the Department’s current instructions rather than guessing a cross-reference.
How to identify which notice you received
Before preparing a reply, make a short record of the notice’s identifying details. This prevents a common error: answering a different year or treating a preliminary reassessment communication as the final reopening notice.
- Read the statutory section. Look for section 143(2), section 148A or section 148 under the 1961 Act, or sections 281 and 280 under the 2025 Act.
- Record the year. Note the assessment year or tax year exactly as written. If both labels appear, preserve both.
- Check the issuing authority and document number. Keep the complete notice, annexures and electronic-delivery record together.
- Find the response deadline. Use the date and time stated in that notice or portal task. The cited Department FAQs do not establish one universal deadline for every notice.
- List the requested action. Determine whether you must explain a proposed reopening, upload documents, file or confirm a return, attend a hearing, or answer a questionnaire.
- Verify the communication in the official portal. Use the Department’s authenticated account or e-filing workflow, not an unverified message or payment link.
How to respond to a scrutiny notice
Build a return-to-evidence map
Make a working table with one row for every issue or document requested. Match each return figure to its source: payslip, Form 16 or withholding statement, ledger, invoice, bank entry, contract, investment proof or other record. Mark whether the amount is fully supported, partly supported or requires correction.
Reconcile third-party information
Compare the return with information available to the Department, such as withholding records, reported financial transactions and bank data. If a difference is caused by timing, duplicate reporting, a wrong identifier or an omitted item, explain the cause and attach the evidence. Do not silently change a figure without explaining the reconciliation.
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Answer the exact question
Use a numbered response that follows the notice. State the figure, the legal or factual basis, the supporting document and the conclusion requested. Upload legible files in the prescribed format and retain the acknowledgement. If a document does not exist, say so and explain what alternative evidence is available instead of submitting an unrelated file.
Protect the record
Save the original notice, your submitted response, upload receipts and later communications. If the notice refers to a hearing or further submission, diarise it immediately. A complete record is important if the Department later proposes an adjustment or you need professional advice.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to respond to a reassessment communication
First decide which stage you are in
A section 148A show-cause communication under the 1961 Act, or the preliminary section 281 process under the 2025 Act, is an opportunity to challenge or clarify the proposed reopening. A section 148 notice under the 1961 Act, or section 280 notice under the 2025 Act, is the subsequent reassessment notice. The response strategy and documents may differ, so label every submission with the stage and year.
Test the information identified
Read what information is said to indicate escaped income. Check whether it relates to you, the correct year and the correct transaction. Common explanations include a transaction belonging to another person, a duplicated report, a gross amount mistaken for taxable income, a reversed transaction, a lawful exemption or income already included elsewhere. Support the explanation with contemporaneous records.
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Reconstruct the year’s tax position
Prepare a complete schedule for the relevant year, not only the line mentioned in the notice. Reconcile income, withholding, advance tax, self-assessment tax, deductions and losses to the filed return and books or statements. This helps identify whether the alleged omission is real, misstated or already taxed.
Respond within the stated channel and time
Use the portal, email, hearing process or other method specified in the notice. Keep proof of submission. Because there is no single deadline established for every notice by the cited FAQs, never rely on a general internet statement about the number of days; follow the actual communication and current law.
Common mistakes and how to avoid them
- Confusing the two procedures: A section 143(2) scrutiny notice is not automatically a reassessment. A section 148 or 280 notice is not merely a routine request for scrutiny documents.
- Using the wrong law: Do not switch to the 2025 Act solely because you received the notice after 1 April 2026. Check the tax year first.
- Ignoring the preliminary stage: A reasoned response to a section 148A or section 281(1) communication can address whether reopening is justified before the later notice stage.
- Assuming a universal deadline: The deadline, extension rules and response method must be taken from the actual notice and applicable law.
- Uploading unsupported explanations: A bare denial is weaker than a concise explanation tied to bank, accounting, contract or tax records.
- Answering only one discrepancy: In reassessment, review the whole year’s tax position; in scrutiny, answer every item listed in the notice.
- Missing a portal acknowledgement: Keep the submission receipt and a copy of every file. A draft saved online is not the same as a submitted response.
When professional advice is sensible
Consider a qualified Indian chartered accountant or tax lawyer when the notice concerns several years, substantial amounts, foreign income or assets, complex business or property transactions, alleged undisclosed income, a proposed penalty, a hearing, a jurisdiction issue, or uncertainty about whether the statutory procedure was followed. Professional review is particularly useful when the year and section appear inconsistent, when records are incomplete, or when a preliminary response could affect whether reassessment proceeds.
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This explanation is a general guide, not case-specific legal advice. The Income Tax Department FAQs describe the high-level distinction and transition, but they do not provide a complete statement of limitation periods, service requirements, every exception, or all available objections. For an actual notice, read the full document, annexures and current law governing that year.
Quick Recap
A practical decision path
- Section 143(2) shown? Treat it as scrutiny of the filed return, identify the requested evidence and respond to each issue.
- Section 148A or section 281(1) shown? Treat it as the preliminary reassessment stage; test the information, explain the facts and submit evidence before the stated deadline.
- Section 148 or section 280 shown? Treat it as the reassessment notice stage; follow the filing or confirmation instruction and prepare the year’s complete tax reconciliation.
- Year beginning before 1 April 2026? The 1961 Act generally continues to govern, even if the notice arrives after the new Act starts.
- Year beginning on or after 1 April 2026? Read the notice under the 2025 Act provisions identified by the Department, including sections 281 and 280 for reassessment.
- Still unclear? Preserve the deadline, do not ignore the notice, and obtain case-specific professional advice.
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