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ITA 1961 → ITA 2025Reassessment

Section 148A Section 167

Inquiry and opportunity before issue of notice under section 148

RetainedHigh - Reduces arbitrary reopening of old tax files.

Quick Answer

Section 148A of the Income Tax Act, 1961 (Inquiry and opportunity before issue of notice under section 148) corresponds to Section 167 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.

What changed for Section 148A

Under the Income Tax Act, 1961, Section 148A governs inquiry and opportunity before issue of notice under section 148. Mandatory 'Show Cause' and preliminary inquiry before reopening an old case.

Under the Income-tax Act, 2025 (effective 1st April 2026), Section 148A is retained and renumbered as Section 167 of the Income-tax Act, 2025. Retained. Provides a 'Pre-reopening' shield to taxpayers to explain their case.

The transition impact on Section 148A is assessed as High. Reduces arbitrary reopening of old tax files.

Old Law (ITA 1961)Ch: XIV

Sec 148A

Provision Summary

Mandatory 'Show Cause' and preliminary inquiry before reopening an old case.

New Law (ITA 2025)Ch: XV

Sec 167

Provision Summary

Retained. Provides a 'Pre-reopening' shield to taxpayers to explain their case.

Key Changes & Highlights

  • Approval of specified authority (PCIT) is mandatory at the stage of passing the 148A(d) order.

Related Sections

Frequently Asked Questions

Which subject does Section 148A of the 1961 Act cover?

Section 148A of the Income Tax Act, 1961 covers inquiry and opportunity before issue of notice under section 148. Mandatory 'Show Cause' and preliminary inquiry before reopening an old case.

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

Section 148A of the Income Tax Act, 1961 maps to Section 167 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. Provides a 'Pre-reopening' shield to taxpayers to explain their case.

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

The transition impact for Section 148A is rated High. Reduces arbitrary reopening of old tax files.

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

Approval of specified authority (PCIT) is mandatory at the stage of passing the 148A(d) order. These points are specific to Section 148A (Inquiry and opportunity before issue of notice under section 148).

Disclaimer: This mapping of Section 148A (Inquiry and opportunity before issue of notice under section 148) to Section 167 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 148A is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.

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