A Section 143(2) notice concerns scrutiny of a return you have already filed. A Section 148 notice is part of reassessment proceedings over possible income that escaped assessment and requires you to file a return. They are different processes, with different response steps. Which law applies—and what deadline matters—depends on the tax year and the notice.
What is the difference between a Section 143(2) and Section 148 notice?
| Point | Section 143(2) | Section 148 |
|---|---|---|
| Purpose | Scrutiny of a return already filed. | A notice in the reassessment route concerning possible income escaping assessment; it calls for a return before action under Section 147. Section 148 of the Income-tax Act, 1961 describes the Assessing Officer serving a notice requiring the assessee to furnish a return. Read the statutory text. |
| What it asks you to do | Respond to the scrutiny notice, including any information or documents requested, by the specified date and through the stated channel. | File the required return within the period specified in the notice, under the law applicable to that tax year. |
| Deadline to keep in view | There is no single deadline that can safely be applied to every assessment year. Check the notice and the rule applicable to its year. | For a notice under the 1961 Act, the Department says the notice specifies the filing period, which cannot exceed three months from the end of the month in which it was issued. The notice’s actual due date is the one to act on. Department guidance on reassessment proceedings. |
Do not treat Section 148 as another kind of scrutiny notice. One is associated with scrutiny of a filed return; the other initiates the return-filing step in a reassessment process.
Which Income-tax Act applies after 1 April 2026?
The date you receive a notice does not, by itself, tell you which Act governs it. The Income Tax Department says reassessment provisions in Sections 279–286 of the Income-tax Act, 2025 apply to Tax Year 2026–27 and later. For a tax year beginning before 1 April 2026, proceedings continue under the Income-tax Act, 1961, including qualifying proceedings initiated after that date. Section 536(2)(c) preserves the old Act for pending proceedings and proceedings initiated on or after 1 April 2026 concerning earlier tax years. See the Department’s New Act FAQs.
As a result, both Acts may be relevant at the same time for different tax years. For example, the Department says an old-Act Section 148 notice for AY 2022–23 issued in February 2026 requires a return within the period stated in that notice, subject to the old-Act maximum of three months from the end of the issue month, using the corresponding old-Act return form. The Department also says an old-Act Section 148A process begun before 1 April 2026 may continue under the old Act after that date, subject to Section 149 limitation requirements. The reassessment guidance explains these transition cases.
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How much time do you have to respond?
For a Section 148 notice under the 1961 Act
Use the filing period and due date written in the notice. The Department’s guidance sets a maximum of three months from the end of the month in which the notice was issued; it does not mean every recipient automatically has the full three months. The period stated in your notice may be shorter. Keep the notice and your return-filing acknowledgement.
This is the taxpayer’s return-filing period. It is not the Department’s deadline to issue a notice, the time allowed to complete a reassessment, or a response period for a different notice type. Those are separate time limits.
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For a Section 143(2) notice
Check the assessment year, notice date, requested material and response date shown in your notice. A universal issue deadline is not established here: the applicable deadline depends on the assessment year and statutory version. The Department confirms that scrutiny assessments under the old Act for AY 2026–27 and earlier continue under that Act, but that does not establish one deadline for every year. See the Department’s Income Tax Returns FAQs.
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What should you do when a notice arrives?
- Confirm what you received. Check the document identification number and verify the notice through the Income Tax Department’s e-Filing portal. Note the section cited, assessment or tax year, issue and service dates, and any response or filing date.
- Identify the governing law. Determine whether the tax year began before 1 April 2026 or is Tax Year 2026–27 or later. If the year is earlier, proceedings may remain under the 1961 Act even when the notice or later action occurs after the transition date.
- Follow the section-specific instruction. For Section 143(2), prepare a response to the issues and documents requested. For an old-Act Section 148 notice, file the required return by the notice’s stated due date and use the applicable return form.
- Submit through the specified channel. Where applicable, use the portal’s e-Proceedings service to view the notice and upload your response and attachments. The Department says an authorized representative may respond on your behalf. Department guide to e-Proceeding.
- Keep a complete record. Save the notice, filed return or response, attachments, acknowledgement and related correspondence.
- Get case-specific advice when needed. Ask a qualified Indian tax professional to review the notice and records if the matter raises complex factual, limitation or jurisdictional issues.
What to check before submitting
- The assessment or tax year and the Act cited in the notice.
- The notice’s document identification number and any portal verification details.
- The exact due date, requested information and submission instructions.
- For a Section 148 notice, whether a return is required and which year-specific form applies.
- Whether each attachment is complete and whether you have saved proof of submission.
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