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Compliance · effective 1 April 2026

Section 148 under the
Income-tax Act, 2025

Notice where income has escaped assessment

Income-tax Act, 1961
148
Income-tax Act, 2025
280
ConfirmedTaken from the ICAI Direct Taxes Committee concordance and independently checked against the bare statutory text of the Income-tax Act, 2025.

Topic

Notice where income has escaped assessmentCompliance provisions under the Income-tax Act, 2025 (Act 30 of 2025).

What carried over

The substance of this provision was not changed by the re-write. What moved is the citation.

The pre-notice show-cause procedure (old 148A) is s.281, and s.280 is expressly cross-referenced by the under-reporting penalty at s.439(2)(b) for first-time returns. Time limit for notices under s.280/281 is s.282.

Source

ICAI concordance row '280 | Issue of notice where income has escaped assessment. | 148'. Corroborated by CAclubindia ('S. 148 -> S. 280', 'S. 148A -> S. 281').

Open the source document →

CBDT publishes its own correspondence utility on incometaxindia.gov.in and that is the authority. Spot-check anything high-stakes there before you rely on it.

Still cite section 148 for
Income earned up to 31 March 2026 — that is FY 2025-26, Assessment Year 2026-27, governed by the Income-tax Act, 1961 even though you file it during 2026.
Cite 280 for
Income earned from 1 April 2026 — Tax Year 2026-27 onwards, governed by the Income-tax Act, 2025. Tax deducted on payments made on or after 1 April 2026 must be reported under the new section 393 table references and new challan/return codes. Quoting a legacy section such as 194C or 194J triggers validation failure.
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147 · Income escaping assessment (reassessment)
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234A · Interest for default in furnishing return of income
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This is a navigational aid for the 1961 → 2025 transition, not tax advice. It helps you find the right place in the new Act when you already know the old section. Confirm every citation against the bare Act and against CBDT's own correspondence utility before relying on it in a return, certificate, notice reply or opinion. The source text used here is the Act as passed, so any rate or threshold amended by the Finance Act, 2026 is not reflected; section numbers are unaffected.

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