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Repair Windows errors before they cause bigger problemsFix Now →Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →Clear out junk files and repair common Windows errorsFree Scan →A Section 143(2) notice concerns scrutiny of a return already filed; a Section 148 notice starts the return-filing step in a reassessment process involving possible income that escaped assessment. They are not interchangeable. The right response depends on the notice, the relevant assessment or tax year, and which Income-tax Act applies. In particular, a notice received after 1 April 2026 is not necessarily governed by the new Act.
What is the difference between a Section 143(2) and Section 148 notice?
The sections mark different procedural stages. Section 143(2) is associated with scrutiny of a return that has been filed. Section 148 is part of the reassessment route: under the Income-tax Act, 1961, it requires the taxpayer to furnish a return before an assessment, reassessment or recomputation under Section 147. The statutory text describes it as a notice requiring the assessee to furnish a return; see Section 148 of the Income-tax Act, 1961.
| Question | Section 143(2) | Section 148 |
|---|---|---|
| Purpose | Scrutiny of a return already filed. | Calls for a return in the reassessment process concerning possible income escaping assessment. |
| Immediate response | Read the notice’s issues, document requests and response instructions, then respond by the stated date. | Identify the applicable Act and tax year, then file the required return within the period specified in the notice where the old Act applies. |
| Relevant timing question | The applicable notice-issuance deadline depends on the assessment year and statutory version; there is no single safe deadline to assume. | For an old-Act notice, the return period specified in the notice cannot exceed three months from the end of the month in which it is issued. |
Which Act applies after 1 April 2026?
The Income Tax Department says the Income-tax Act, 2025 reassessment provisions in Sections 279–286 apply to Tax Year 2026–27 and later. For a tax year beginning before 1 April 2026, reassessment remains under the Income-tax Act, 1961. Section 536(2)(c) preserves the old Act for pending proceedings and proceedings initiated on or after 1 April 2026 concerning earlier tax years. Accordingly, the date a notice arrives does not by itself determine which Act governs it. See the Department’s New Act FAQs and reassessment guidance.
The Department gives an example of a Section 148 notice under the old Act issued for AY 2022–23 in February 2026: the taxpayer must file within the period stated in that notice, subject to the three-month cap, and use the corresponding old-Act return form. It 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. These are transition rules for the specified circumstances, not a general rule that every notice received after the transition uses the old Act.
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How much time do you have to respond?
Section 148 under the 1961 Act
The Income Tax Department’s guidance says to file the return within the period specified in the notice. That period cannot exceed three months from the end of the month in which the notice is issued. Use the due date written in your notice as the immediate deadline, and keep the filing acknowledgement. The Department’s Income Tax Returns FAQs describe this requirement.
Section 143(2)
Do not apply the Section 148 return-filing period to a Section 143(2) notice. The applicable Section 143(2) notice-issuance deadline can depend on the assessment year and the version of the law. The Department confirms that old-Act scrutiny assessments for AY 2026–27 and earlier continue under the 1961 Act, but the guidance cited here does not establish one universally applicable issuance date. Check the rule for the specific year and the date and response instructions in your notice.
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Keep different deadlines separate
The time allowed to file a return in response to a Section 148 notice is not the same as the Department’s deadline to issue a notice, the time limit to complete reassessment, or a response period for another notice type. Confirm which clock a date refers to before relying on it.
Quick Recap
What should you do when either notice arrives?
- Verify the notice. Check its document identification number and confirm the assessment or tax year.
- Read the operative details. Note the statutory section, issue and service dates, response due date, requested information and any portal or communication instructions.
- Identify the governing Act. Determine whether the matter concerns a tax year beginning before 1 April 2026 or a Tax Year beginning on or after that date; transitional proceedings for earlier years may still use the 1961 Act.
- For an old-Act Section 148 notice, file the required return on time. Follow the notice’s stated period, within the Department’s three-month maximum measured from the end of the issue month, and retain the acknowledgement.
- Use the Department’s response channel where applicable. The Income Tax Department’s e-Proceeding service lets taxpayers view applicable notices and submit responses and attachments. The Department says an authorized representative can respond on the taxpayer’s behalf.
- Get case-specific advice when needed. Ask a qualified Indian tax professional to review the notice and records if factual, limitation or jurisdictional issues are complex.
- Keep a complete record. Preserve the notice, return or response, attachments, acknowledgement and related correspondence.
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