Scrutiny checks a return that has been filed. Reassessment reopens an earlier tax position when statutory conditions indicate that income chargeable to tax may have escaped assessment. That difference determines the notice you receive, what you must submit, which deadline matters, and which Income-tax Act applies.
The transition on 1 April 2026 makes the first step especially important: identify the relevant assessment year or tax year before relying on any section number or time limit. Earlier-year matters generally remain under the Income-tax Act, 1961, while tax years beginning on or after 1 April 2026 move to the Income-tax Act, 2025.
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Scrutiny and reassessment are not the same proceeding
A tax scrutiny assessment starts with a return already filed by the taxpayer. The department examines whether the figures, claims, deductions, exemptions and supporting documents are correct. Under the Income-tax Act, 1961, scrutiny is commonly associated with a notice under section 143(2), followed by information requests such as those issued under section 142(1).
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Reassessment is different in purpose. It is a reopening process used when the Assessing Officer proceeds on statutory information and conditions indicating that income chargeable to tax may have escaped assessment. For old-Act matters, the main framework is in sections 147 to 151, with the pre-notice procedure generally found in section 148A and the reassessment notice in section 148.
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A scrutiny notice does not, by itself, mean that the department has decided that income escaped assessment. A reassessment proceeding, by contrast, is built around the possibility that the earlier tax position was incomplete or incorrect in a way covered by the reopening provisions.
| Point | Scrutiny assessment | Reassessment |
|---|---|---|
| Basic purpose | Examine the correctness of a return that was filed. | Assess or recompute income that the Assessing Officer considers may have escaped assessment. |
| Typical old-Act notice | Section 143(2), commonly followed by information requests under section 142(1). | Generally, a section 148A pre-notice process followed by a section 148 notice, subject to statutory exceptions and the version of the law applicable to the matter. |
| What starts the case | Selection of a filed return for examination. | Information and statutory conditions indicating possible escaped income. |
| First deadline to check | The response date printed in the scrutiny notice or information request. | The reply date in the section 148A communication, or the return-filing date specified in the section 148 notice. |
| Completion rules | Section 153 and its assessment-year-specific amendments, extensions and exclusions. | Section 153 for old-Act matters; sections 279 to 286 for tax years governed by the 2025 Act. |
| Effect of 1 April 2026 | Scrutiny for AY 2026–27 or an earlier year remains under the 1961 Act. | Earlier-year proceedings remain under the 1961 Act; tax years beginning on or after 1 April 2026 use the 2025 Act framework. |
The section printed on the notice is therefore more useful than the tone of the letter. A request for documents may sound similar in both cases, but the statutory route and the available challenges can be different.
Which law applies after 1 April 2026?
The Income-tax Act, 2025 commenced on 1 April 2026. The repeal of the Income-tax Act, 1961 does not move every existing case into the new Act. The Department’s transition guidance states that proceedings concerning a tax year beginning before 1 April 2026 continue under the repealed 1961 Act, including proceedings initiated on or after 1 April 2026 for those earlier years. Section 536 of the 2025 Act preserves that continuity.
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AY 2026–27 is still an old-Act year
AY 2026–27 relates to income earned in FY 2025–26. Because that financial year began before 1 April 2026, a scrutiny or reassessment concerning AY 2026–27 remains governed by the 1961 Act. The Department has specifically confirmed that scrutiny for AY 2026–27 and earlier assessment years continues under the old Act.
Tax Year 2026–27 is a new-Act period
Tax Year 2026–27 refers to income from FY 2026–27, which begins on 1 April 2026. Reassessment provisions in sections 279 to 286 of the 2025 Act apply to that period and later tax years.
A notice received after the transition date is not enough
A notice served after 1 April 2026 does not automatically make the 2025 Act applicable. Determine, in this order:
- The income period involved.
- The assessment year or tax year printed on the notice.
- The section under which the notice was issued.
- Whether the proceeding was already pending or is being initiated for an earlier period.
- Any savings or transitional provision preserving the 1961 Act.
Do not replace an old-Act section 143(2), 148A or 148 analysis with the corresponding 2025 Act provisions merely because the envelope or portal communication is dated after 1 April 2026.
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How an old-Act scrutiny assessment works
1. A return is selected for examination
Scrutiny begins with a return that has been filed. The department seeks to verify the return’s correctness rather than treating the case as a reopening for escaped income. The selection itself does not establish that the taxpayer concealed income or made an invalid claim.
2. Section 143(2) identifies the scrutiny route
For a 1961 Act case, a section 143(2) notice is the familiar marker of scrutiny. Read the assessment year, the date of issue and service, the response deadline, and any issue description in the notice. The notice may direct the taxpayer to participate through the department’s electronic proceedings system.
3. Information requests follow
The Assessing Officer may ask for explanations, schedules, books, invoices, bank information, investment evidence, withholding-tax records or other documents. Such requests are commonly made under section 142(1). Each request can carry its own response date and document list.
4. The assessment is completed under section 153 rules
The completion period is not the same as the time to answer a notice. Section 153 contains the assessment time limit, along with amendments, extensions and exclusions. The India Code text states a twelve-month period for orders under sections 143 or 144 relating to assessment years commencing on or after 1 April 2019, but the statute also contains detailed exceptions and year-specific rules.
That twelve-month wording should not be turned into a universal personal deadline. Confirm the exact assessment year, the version of section 153 that applies, the kind of order being made, and any exclusion or extension before calculating the last day.
How an old-Act reassessment works
1. Information indicates possible escaped income
Reassessment starts from information and statutory conditions suggesting that income chargeable to tax may have escaped assessment. It is not simply a second scrutiny questionnaire. The taxpayer should identify what information has been communicated and which income year it concerns.
2. The section 148A opportunity to respond
For the general old-Act route, section 148A establishes a pre-notice process. The taxpayer receives the relevant information and an opportunity to respond. The Assessing Officer considers the reply and makes the determination required by the applicable law before issuing a section 148 notice, subject to statutory exceptions and the version of the provisions governing the case.
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The response date in the communication controls the immediate task. Preserve the communication, attachments, portal record and proof of submission. If the information is incomplete or the period appears outside the applicable limitation rules, raise that point in the response rather than waiting for the final reassessment order.
3. A section 148 notice starts the reassessment return stage
Where the process proceeds, the section 148 notice requires the taxpayer to furnish a return for the relevant assessment year. The return must be filed within the period specified in the notice. Department guidance states that the specified period cannot exceed three months from the end of the month in which the notice is issued.
The three-month figure is a statutory maximum for the period that may be specified; it is not an automatic three-month extension in every case. If the notice gives an earlier date, that date is the one to meet unless it is formally extended or otherwise changed.
4. Reassessment and information requests continue
After the return stage, the department may seek explanations and supporting records and may assess or recompute the income covered by the reopening. The fact that a return was filed in response to section 148 does not convert the proceeding into ordinary scrutiny; the case remains rooted in the reassessment provisions.
5. Section 149 limitation must be checked separately
Section 149 limits the issue of old-Act reassessment notices. The exact reopening window depends on the applicable version of the law and the circumstances of the case. The available official material does not support one universal number of years, monetary threshold or outer date for every notice.
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How reassessment works under the Income-tax Act, 2025
For Tax Year 2026–27 and later tax years, the Department places reassessment in sections 279 to 286 of the 2025 Act. Its general description is a sequence in which information suggests escaped income, the taxpayer receives a show-cause opportunity, the reply is considered, a reasoned determination is made with the required prior approval, and a section 280 notice is issued. The Department also identifies statutory exceptions in which the section 281 process is bypassed.
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New-Act completion period
Under section 286, the general completion period is one year from the end of the financial year in which the section 280 notice was served. The rule is subject to extensions and exclusions, including specified transfer-pricing references and periods during which a court or tribunal stay affects the proceeding.
This is a completion rule, not a taxpayer-reply rule and not necessarily the deadline for issuing the initial communication. Keep those dates in separate columns when reviewing a live case.
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Notice-issue limitation
This asks: by what date could the department legally issue the notice? For old-Act reassessment, section 149 is central. For scrutiny, the section 143(2) issuance rule depends on the assessment year and the relevant statutory version. The material available here does not establish one cutoff that safely applies to every assessment year.
Taxpayer response deadline
This asks: by what date must you answer? Use the date printed in the actual communication. A section 148A opportunity has its own reply date. A section 148 notice has its own return date, capped by the old-Act three-month rule described above. A scrutiny notice or section 142(1) request can set a different date.
Assessment-completion deadline
This asks: by when must the department pass the order? Old-Act scrutiny and reassessment completion rules are generally found in section 153, with amendments, exclusions and extensions. New-Act reassessment uses section 286’s framework, generally linked to the end of the financial year in which the section 280 notice was served.
These deadlines do not replace one another. A taxpayer can have a valid response deadline even while disputing whether the notice itself was issued within the statutory limitation period.
What to do when a notice arrives
- Download the complete record. Save the notice, annexures, relied-on information, portal message, email alert and service details.
- Identify the tax period. Write down the assessment year or tax year and the financial year to which it relates.
- Read the section number. Distinguish section 143(2), section 142(1), section 148A, section 148 or a 2025 Act provision.
- Record every date. Make separate entries for issue, service, reply, return filing and proposed order or hearing.
- Classify the proceeding. Decide whether the communication is ordinary scrutiny, a pre-notice reassessment opportunity, a reassessment notice or a follow-up information request.
- Check the governing Act. For an earlier period, test the transition and savings rules before applying new-Act terminology.
- Prepare a document index. Match each requested item to a file name, page range and explanation. State clearly when a document does not exist or is held by someone else.
- File through the required channel. Follow the e-Proceedings or other channel specified in the communication and retain the acknowledgement.
- Address threshold objections promptly. If limitation, service, jurisdiction or the wrong assessment year appears to be involved, raise it in the response and obtain professional advice where necessary.
- Monitor for follow-up. A submission does not end the case. Watch the portal and correspondence for additional questions, hearing notices and the final order.
Common mistakes and how to avoid them
- Treating every department letter as scrutiny. Check the section. Reassessment has a different statutory trigger and sequence.
- Using the new Act for AY 2026–27. AY 2026–27 concerns FY 2025–26 and remains an old-Act year.
- Assuming three months is always available for a section 148 return. The notice’s specified date controls, and the law describes three months as the maximum period that may be specified.
- Confusing the reply deadline with the order deadline. A department completion period does not give extra time to answer a live notice.
- Relying on a generic section 153 date. Assessment-year amendments, exclusions and extensions can change the calculation.
- Ignoring service evidence. Keep portal timestamps, email headers, downloaded files and acknowledgement numbers.
- Submitting documents without an explanation. Tie each file to the question asked and identify the relevant transaction, period and amount.
- Missing a follow-up request. Check the designated electronic proceedings area regularly while the matter remains open.
Scrutiny versus reassessment: a decision guide
| If the notice says… | Likely route | Immediate focus |
|---|---|---|
| Section 143(2) | Scrutiny of a filed return under the 1961 Act. | Confirm the assessment year, issues listed, requested records and response date. |
| Section 142(1) | Information request, often during scrutiny or another assessment proceeding. | Answer each numbered request and retain proof of submission. |
| Section 148A | Old-Act pre-notice reassessment opportunity, subject to exceptions. | Review the information relied on, limitation and the reply deadline. |
| Section 148 | Old-Act reassessment notice requiring a return. | File by the date specified, then address the underlying information and jurisdictional issues. |
| Section 280 under the 2025 Act | New-Act reassessment notice for a tax year governed by that Act. | Identify the tax year, the section 281 stage or exception, and the response instructions. |
The table is a triage aid, not a substitute for reading the notice. A communication can refer to more than one provision, and transitional provisions can preserve the 1961 Act for an earlier period.
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Questions about specific time limits
What is the time limit for a scrutiny notice?
There is no single cutoff that can safely be stated for every assessment year. The section 143(2) issuance rule has changed over time and must be tied to the assessment year and the statutory version in force. Check the notice’s assessment year and the applicable text rather than applying a general calendar rule.
How much time do I have to reply to a section 148 notice?
For an old-Act section 148 notice, file the return within the time specified in that notice. Department guidance says the specified period cannot exceed three months from the end of the month in which the notice is issued. That maximum does not guarantee three months in every notice.
Does a notice after 1 April 2026 use the 2025 Act?
Not necessarily. The relevant income period and transitional rules control. Earlier-year proceedings, including those concerning AY 2026–27 or an earlier year, remain under the 1961 Act even if the communication is issued after 1 April 2026.
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Is the section 153 period the same for scrutiny and reassessment?
Old-Act scrutiny and reassessment completion rules are governed by section 153, but the applicable calculation depends on the assessment year, amendments, exclusions and extensions. The new-Act reassessment framework uses sections 279 to 286, with section 286 generally tying completion to one year from the end of the financial year in which the section 280 notice was served, subject to stated exceptions.
What records should be preserved?
Keep the original notice, every attachment, portal and email service record, replies, uploaded files, acknowledgements, hearing communications and any subsequent order. These records help establish what was received, when it was received and how the taxpayer responded.
Bottom line for taxpayers
Start with the section and the tax period, not the word “notice.” Scrutiny examines a filed return, while reassessment reopens a tax position on the statutory basis that income may have escaped assessment. For an old-Act matter, distinguish section 143(2) scrutiny from the section 148A and 148 reassessment sequence, check section 149 for notice limitation and use the date actually specified for your response. For a new-Act tax year, use sections 279 to 286 and the section 280 and 286 timing framework. The 1 April 2026 transition means that AY 2026–27 and earlier years generally remain under the 1961 Act.
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