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ITA 1961 → ITA 2025Reassessment

Section 148 Section 166

Issue of notice where income has escaped assessment

RetainedCritical - Sets the limitation period for tax uncertainty.

Quick Answer

Section 148 of the Income Tax Act, 1961 (Issue of notice where income has escaped assessment) corresponds to Section 166 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.

What changed for Section 148

Section 148 of the 1961 Act sets out the rules on issue of notice where income has escaped assessment. Requirement to serve a notice before starting reassessment under 147.

Under the Income-tax Act, 2025 (effective 1st April 2026), Section 148 is retained and renumbered as Section 166 of the Income-tax Act, 2025. Retained. Notice can only be issued if there is 'Information' as defined in the Act and after following 148A procedure.

The transition impact on Section 148 is assessed as Critical. Sets the limitation period for tax uncertainty.

Old Law (ITA 1961)Ch: XIV

Sec 148

Provision Summary

Requirement to serve a notice before starting reassessment under 147.

New Law (ITA 2025)Ch: XV

Sec 166

Provision Summary

Retained. Notice can only be issued if there is 'Information' as defined in the Act and after following 148A procedure.

Key Changes & Highlights

  • Notice period generally 3 years, extendable to 10 years only if income escaping tax exceeds Rs. 50 Lakhs.

Related Sections

Frequently Asked Questions

Which subject does Section 148 of the 1961 Act cover?

Section 148 of the Income Tax Act, 1961 covers issue of notice where income has escaped assessment. Requirement to serve a notice before starting reassessment under 147.

What is the new section number for Section 148 under the Income-tax Act, 2025?

Section 148 of the Income Tax Act, 1961 maps to Section 166 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. Notice can only be issued if there is 'Information' as defined in the Act and after following 148A procedure.

How does the Income-tax Act, 2025 affect Section 148 in practice?

The transition impact for Section 148 is rated Critical. Sets the limitation period for tax uncertainty.

What is new about Section 148 under the Income-tax Act, 2025?

Notice period generally 3 years, extendable to 10 years only if income escaping tax exceeds Rs. 50 Lakhs. These points are specific to Section 148 (Issue of notice where income has escaped assessment).

Disclaimer: This mapping of Section 148 (Issue of notice where income has escaped assessment) to Section 166 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 148 is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.

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