Pre-reassessment show cause under Section 148A

What this section is

Section 148A introduced a mandatory four-stage procedure before reassessment: (a) preliminary inquiry, (b) show cause to assessee, (c) consideration of reply, (d) order on whether it is a fit case. A reassessment notice without 148A is void, except in specified search/survey cases.

When it is issued

Whenever the AO has information suggesting income may have escaped assessment, before any Section 148 notice can be issued.

What you should do

1. 1Read the 148A(b) notice and the annexure carefully — the entire reassessment is built on this 'information'.
2. 2File a detailed reply rebutting the information on the merits, with documentary evidence.
3. 3Raise procedural defences: limitation, sanction under Section 151, jurisdiction, validity of information.
4. 4Request a personal hearing — the SC in Ashish Agarwal direction emphasised the right to be heard.

Documents typically needed

• Bank statements, ledgers, third-party confirmations
• Original return, computation, and supporting evidence
• Sanctioning officer's approval (request a copy)

Common mistakes

• Treating the 148A(b) reply casually — once the 148A(d) order is passed, the issues narrow significantly.
• Not preserving the procedural objections in the reply.
• Asking for adjournments without filing a holding reply.