Received a Notice Under Section 148A?
This is your critical opportunity to stop reassessment before it formally begins. Don’t file a mechanical reply—challenge the validity on legal grounds.
What is Section 148A?
Introduced by the Finance Act, 2021, Section 148A acts as a safeguard for taxpayers. Before issuing a formal notice under Section 148 for reopening an assessment, the Assessing Officer (AO) is legally mandated to:
- Conduct an inquiry with prior approval.
- Provide the “information” suggesting income escapement.
- Grant an opportunity of being heard (Show Cause Notice).
The Workflow
Receive 148A(b) Notice
AO shares information regarding escaped income.
Your Reply
Crucial stage to rebut facts and challenge jurisdiction.
Order under 148A(d)
AO decides whether to reopen the case or drop proceedings.
How We Defend You
A mechanical reply is not enough. We analyze specific legal loopholes.
Limitation Period
We check if the notice is time-barred under Section 149. Notices issued beyond 3 years require strict compliance with the Rs. 50 Lakh threshold.
Tangible Information
Reopening cannot be based on “borrowed satisfaction” or vague data. We demand the underlying evidence (Insight Portal / AIS data).
Approval Validity
Approval under Section 151 must be from the Specified Authority. Mechanical approvals without applying mind are valid grounds for challenge.
Consult Indian Tax Planning
Don’t let the deadline lapse. Send us the notice for a preliminary review. We specialize in tax litigation and assessment support.
