Notice for reassessment under Section 148

What this section is

Section 148 is the operative reassessment notice. It is issued only after the AO has passed an order under Section 148A(d) holding that it is a fit case for reassessment. The notice asks the assessee to furnish a return for the year in question.

When it is issued

After completion of 148A procedure and within the limitation prescribed under Section 149.

What you should do

1. 1File the return in response to 148 within the time allowed — even if you intend to challenge the notice, file the return without prejudice.
2. 2Once the return is filed, ask for the reasons recorded for reopening if not already supplied.
3. 3File detailed objections within 30 days of receiving the reasons. Per GKN Driveshafts (SC), the AO must dispose of these objections by a speaking order before proceeding.
4. 4If the objections are rejected, evaluate a writ petition in the High Court — many recent reassessments have been quashed at this stage.

Documents typically needed

• The 148A(b) notice and 148A(d) order
• The information / annexure supplied
• Original return and assessment order
• Evidence rebutting the alleged escaped income

Common mistakes

• Not filing the return in response — this can later be used against the assessee.
• Not asking for reasons recorded.
• Skipping the GKN Driveshafts step (objection-disposal) and directly going to scrutiny.