Section 148A of Income-tax Act – Inquiry Before Reassessment

Section 148A of the Income-tax Act, 1961 (inserted by the Finance Act, 2021) lays down the preliminary procedure that the Assessing Officer (AO) must follow before issuing a notice under Section 148 for reassessment of income that is believed to have escaped assessment.

Table of Contents

1. Introduction
2. The Provision
3. The Provision in Brief
4. Charge of Escapement of Income in a Notice u/s 148A(b) is Necessary
5. Whether Section 148A Covers the Concept of Reasons Recorded and Procedure Laid Down by Hon’ble Apex Court in GKN Drive Shafts (India) Ltd. v. ITO
6. Application of Procedure u/s 148A
7. Table to Show Where the Procedure u/s 148A is Required to be Followed
8. Kind and Scope of Inquiries, AO Can do u/s 148A(a)

Check out Taxmann's Law Relating to Reassessment which comprehensively explains the evolution and current framework of reassessment in Indian income-tax law, from early legislation to the latest amendments under the Finance Act 2025. It offers a deep dive into Sections 147–153, examines newly introduced provisions (148, 148A, 149), and elucidates search/survey-based reassessments. Rich with case laws, practical FAQs, and drafting strategies, it clarifies how to address escaped income, penalties, and revision powers (Section 263). Authored by D.C. Agrawal & Ajay Kumar Agrawal, the book caters to professionals, corporates, and academicians, ensuring clarity on both procedural and conceptual aspects. Its user-friendly format, comparative insights, and thorough analysis make it indispensable for understanding and handling reassessment complexities.

1. Introduction

It has been experienced in the past that notice u/s 148 used to be issued simply on any kind of information received by the AO, or on the recommendation of other authorities/agencies without applying his own mind as to whether material available before him had a live link with the escapement of income and consequently with the formation of belief. It was also felt that objections raised by the assessee against reasons recorded or on the formation of belief were used to be brushed aside by the AO on frivolous grounds or simply by passing a non-speaking order. As a result, the reopening used to be quashed by the appellate authorities on various grounds such as there is non-application of mind by the AO, notice u/s 148 being issued on borrowed satisfaction, there is no live link between material available on record, and formation of belief, or there were issues relating to limitation not considered by the AO. Thus, to simplify and strengthen the reopening, the Finance Act, 2021 introduced a new section 148A after section 148, apparently to ensure the opening of completed assessment on sound footings. To achieve this aim, the legislature has not only incorporated the principles laid down by Hon’ble Apex Court in GKN Drive shafts (India) Ltd. v. ITO^1a but also made it necessary for the AO to seek approval of senior authority before deciding to issue notice u/s 148 so that technical issues involved in reopening are taken care of. In this article, the provisions of section 148A are described in brief with different kind of implications.

2. The Provision

Conducting inquiry, providing opportunity before the issue of notice u/s 148.

“Section 148A

Conducting inquiry, providing opportunity before issue of notice u/s 148

“148A. The Assessing Officer shall, before issuing any notice u/s 148, —

(a) conduct any enquiry, if required, with the prior approval of specified authority, with respect to the information which suggests that the income chargeable to tax has escaped assessment;

(b) provide an opportunity of being heard to the assessee, by serving upon him a notice to show-cause within such time, as may be specified in the notice, being not less than seven days and but not exceeding thirty days from the date on which such notice is issued, or such time, as may be extended by him on the basis of an application in this behalf, as to why a notice u/s 148 should not be issued on the basis of information which suggests that income chargeable to tax has escaped assessment in his case for the relevant assessment year and results of enquiry conducted, if any, as per clause (a);

(c) consider the reply of assessee furnished, if any, in response to the show-cause notice referred to in clause (b);

(d) decide, on the basis of material available on record including reply of the assessee, whether or not it is a fit case to issue a notice u/s 148, by passing an order, with the prior approval of specified authority, within one month from the end of the month in which the reply referred to in clause (c) is received by him, or where no such reply is furnished, within one month from the end of the month in which time or extended time allowed to furnish a reply as per clause (b) expires –

Provided that the provisions of this section shall not apply in a case where,—

(a) a search is initiated u/s 132 or books of account, other documents or any assets are requisitioned u/s 132A in the case of the assessee on or after the 1st day of April, 2021; or

(b) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner that any money, bullion, jewellery or other valuable article or thing, seized in a search u/s 132 or requisitioned u/s 132A, in the case of any other person on or after the 1st day of April, 2021, belongs to the assessee; or

(c) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner that any books of account or documents, seized in a search u/s 132 or requisitioned u/s 132A, in case of any other person on or after the 1st day of April, 2021, pertains or pertain to, or any information contained therein, relate to, the assessee; or

(d) the Assessing Officer has received any information under the scheme notified u/s 135A pertaining to income chargeable to tax escaping assessment for any assessment year in the case of the assessee.

Explanation.—For the purposes of this section, specified authority means the specified authority referred to in section 151.

3. The Provision in Brief

Before the issue of notice u/s 148, in certain cases, the AO has to take following steps –

(i) To examine the information as to whether it fulfils the conditions of section 147.

(ii) To conduct inquiries, wherever required.

(iii) Such inquiry has to be in respect of information which suggests that income chargeable to tax has escaped assessment.

(iv) After carrying out inquiries, the AO has to provide an opportunity of being heard to the assessee.

(v) For this purpose, he has to issue a show cause notice asking the assessee to explain as to why notice u/s 148 be not issued against him (a) on the basis of information which suggest that income chargeable to tax has escaped assessment and (b) and on the basis of result of inquiries, if any conducted by him.

(vi) He has to give a minimum time not exceeding 7 days but not more than 30 days to the assessee for furnishing his explanation.

(vii) He may extend the time for furnishing the explanation on an application made by the assessee in this behalf.

(viii) To consider the reply, if any, submitted by the assessee in respect of show cause notice.

(ix) To decide on the basis of material available on record, including the reply furnished by the assessee, whether it is a fit case for the issue of notice u/s 148 or not.

(x) Such decision has to be made by passing an order (in writing).

(xi) This order has to be passed within one month from the end of the month in which time or extended time allowed to the assessee to furnish the reply expires.

(xii) Prior approval of the specified authority has to be taken before passing such an order.

(xiii) The above procedure of carrying out inquiries, issuing show cause notice and passing order under section 148A (d) is not required to be followed in the following cases –

i. In cases of searches carried out u/s 132(1) on or after 1-4-2021.

ii. In requisition cases u/s 132A, where books of account or other documents or assets are requisitioned on or after 1-4-2021.

iii. In search/requisition cases where the AO is satisfied with the prior approval of PCIT/CIT that money, bullion, jewellery or other valuable article or thing seized in the search/requisition (against person searched) carried out after 1-4-2021, or requisitioned u/s 132A after 1-4-2021 belongs to “other person”.

iv. In search/requisition cases where the AO is satisfied with the prior approval of PCIT/CIT that books of account or documents seized in the search/requisition (against person searched) carried out on or after 1-4-2021 or requisitioned u/s 132A on or after 1-4-2021 pertains to or pertain to, or any information contained therein relates to the “other person”.

v. Where information is received in a scheme framed by the Government u/s 135A.

(xiv) Specified authority for the purposes of this section is the authority referred to in section 151.

4. Charge of Escapement of Income in a Notice u/s 148A(b) is Necessary

Necessity of Specific Allegation in Notice – The notice issued under section 148A must contain information that income chargeable to tax has escaped assessment. There must be some material supporting allegation of escapement of income. A bald assertion about the escapement of income is not sufficient to validate the issuance of notice u/s 148A.

Insufficiency of Mere Transactions as Evidence – Therefore, wherever AO receives information about a transaction such as cash deposited in a bank, the mere fact of deposit of cash will not lead to an inference that cash so deposited was of income character and that it was chargeable to tax in the hands of the assessee in the relevant assessment year. The inference of the AO that an income equal to a deposit in the bank has escaped assessment of income, proceeds on the fallacious assumption that the bank deposits constitute undisclosed income and overlooks the fact that the sources of deposit need not necessarily be an income of the assessee. The AO has to put up some more material after carrying out inquiries that the cash deposits may be an undisclosed income of the assessee and hence income chargeable to tax has escaped assessment².

Prohibition Against Reopening for Mere Verification – Thus, no reopening is permissible merely for verifying the source of cash deposited in the bank particularly when AO did not contend that said cash deposits were not reflected in the return of income³. The verification part must be done before issuing SCN u/s 148A.

Requirement of Allegation and Material Substantiation – So also, reopening only on the basis that there are huge cash withdrawals towards purchases and the SCN (reasons recorded earlier) did not indicate that any income chargeable to tax has escaped assessment cannot be sustained⁴. If there is no allegation and material substantiating that income chargeable to tax has escaped assessment provided to the assessee alongwith notice u/s 148A(b), and/or there is no quantification of escaped income, in the notice u/s 148A(b), passing of order u/s 148A(d) or issue of notice u/s 148 will not be valid⁵.

Duty of AO to Examine the Information – When information about cash deposited in a bank is received by the AO, it is his duty to examine whether said cash deposit is reflected in return or not. Without examining the information about cash deposit as to whether it reflects income chargeable to tax or not, reopening will not be justified⁶. Now even the issue of notice u/s 148A (b) may not be justified.

Consideration of Assessee’s Explanation – Issuing notice u/s 148 cannot be sustained when the explanation of the assessee that the source of cash deposit post demonetisation was a withdrawal of cash from the same bank and the withdrawals and deposits closely matched were not considered by the AO⁷.

Charge of Escapement in Cases of Recomputation – Even in cases where recomputation is required on account of grant of excessive depreciation allowance, loss, deduction, or relief, the charge of escapement of income would be necessary for acquiring jurisdiction u/s 147.

5. Whether Section 148A Covers the Concept of Reasons Recorded and Procedure Laid Down by Hon’ble Apex Court in GKN Drive Shafts (India) Ltd. v. ITO⁸

Under the new law, there is no requirement anymore for recording reasons, supplying them to the assessee, inviting objections from him, and passing an order disposing of such objections before proceeding to make reassessment. Such procedure has been practically incorporated in section 148A which provides that, before the issue of notice u/s 148, the AO is required to carry out inquiries u/s 148A, if required, with prior approval of specified authority, provide an opportunity of being heard, consider the reply furnished by the assessee to the show cause notice issued by the AO and pass an order u/s 148A (d) with prior approval of specified authority within the time limitation provided thereunder. Thus, if an assessee has objection as to whether –

(i) there is an income chargeable to tax

(ii) such income has escaped assessment, or

(iii) any recomputation of loss, depreciation allowance, or any other allowance or deduction is required

(iv) AO has correctly assumed jurisdiction to issue notice u/s 148,

(v) a particular issue on which ld. AO intends to issue notice u/s 148 is covered in appeal, reference, or revision, he can raise such objections in the reply to be furnished in response to the show cause notice issued u/s 148A(b).

Thus, order u/s 148A(d) would have all the trappings of reasons recorded, objections raised by the assessee, and disposal of such objections through speaking order which is required to be enclosed with the notice u/s 148.

6. Application of Procedure u/s 148A

The procedure laid down u/s 148A is applicable in following two circumstances. They are –

(i) When AO receives information, which falls within Explanation 1 to section 148 – It is mentioned in the Explanation 1 that for the purposes of issuance of notice u/ss 148 and 148A, the information with the AO which suggests that income chargeable to tax has escaped assessment means –

(i) the information which is received in the case of the assessee for the relevant assessment year as per Risk Management Strategy formulated by the CBDT from time to time and

(ii) audit objection to the effect that assessment in the case of the assessee for the relevant assessment year has not been made in accordance with the provisions of the Act.

(iii) information received as per agreements u/s 90/90A.

(iv) information received under a scheme framed by the Government u/s 135A and

(v) information contained in an order of Court/Tribunal. This procedure is to be followed for all ten relevant assessment years.

(ii) Where survey operation is carried out u/s 133A, in case of the assessee on or after 1-4-2021 – Even though carrying out a survey is treated as deemed information with the AO which suggest that income chargeable to tax has escaped assessment in the case of the assessee, but procedure laid down u/s 148A has to be followed for all the ten years including three initial relevant assessment years.

It may be noted that the procedure laid down u/s 148A will not be applicable in cases of search and requisitions carried out on or after 1-4-2021 in the cases of “person searched” and in the cases of “other person” as covered in Clauses (a), (b) and (c) of Proviso to section 148A.

7. Table to Show Where the Procedure u/s 148A is Required to be Followed

Following table shows in which cases procedure u/s 148A is required to be followed –

8. Kind and Scope of Inquiries, AO Can do u/s 148A(a)^8a

Section 148A(a) gives power to the AO to conduct any inquiry, if required, with prior approval of specified authority, with respect to the information which suggest that the income chargeable to tax has escaped assessment. Such inquiries can be carried out under section 148A(a) in respect of the information covered in Explanation 1 of section 148 (except clause (iv) thereof) and in respect of survey cases. These inquiries may be –

(i) Verification from own records of the assessee.

(ii) Verification from other AO.

(iii) Verification with various statutory statements filed by the assessee and other taxpayers.

(iv) Verification from other Departments such as GST, SEBI.

(v) Verification from books of accounts by summoning books.

(vi) To exercise power u/s 131(1) read with sub-section (2) to collect information, to record statements, to compel the production of books or other documents, or to issue commissions.

(vii) Verification from other taxpayers u/s 133(6) or by summoning them and recording their statements.

(viii) Collecting other information in terms of section 133, sub-section (1) to sub-section (5).

(ix) Collection of data from banks and other financial institutions.

(x) Downloading data from MCA/ROC/SEBI portals.

(xi) Carrying out survey u/s 133A at the premises of the assessee or other taxpayers for verifying or supplementing the information.

(xii) Invoking power u/s 133B for collecting certain information.

(xiii) Invoking power or taking assistance u/s 133C.

(xiv) Invoking power u/s 134 to inspect registers of certain companies.

(xv) Asking the investigation wing to collect information/carry out inquiries to supplement information received under Explanation 1 to section 148.

All the above steps/actions/procedures are part of inquiries. Even verification with the assessee’s records is an inquiry.

8.1 Scope of Inquiries u/s 148A(a)

An inquiry should be confined to the domain of information and should not be extended to the issues not arising from the information. The inquiry should be specific. Even though there are no fetters on the power of the AO to carry out preliminary inquiries (before the issue of notice u/s 148 under old law as held in Aishwarya Dying Mills (P.) Ltd. v. DCIT⁹), but under the new law, as envisaged u/s 148A(a), inquiries are restricted to what arises from the information and for every kind of inquiry, he has to seek approval from the specified authority.

8.2 Extent of Inquiries is Within Discretion of AO

So far as inquiries u/s 148A(a) is concerned assessee has no role to play. It is for the AO to decide on the basis of information under Explanation 1 or Explanation 2(ii) to section 148 as to what kind of inquiries he has to carry out so that all the elements of escapement of income are brought on record before issue of show cause notice u/s 148A(b). These inquiries by the AO are apparently independent inquiries behind the assessee. However, the AO is duty bound to disclose the contents of information and results of inquiries to the assessee in a show cause notice issued u/s 148A(b). In response to this assessee can ask to produce his witness as there is no restriction as to the extent and manner of reply. Assessee can also ask to allow cross examination of witness if charge in show cause notice is based on statement of a witness. If such cross examination is demanded by the assessee and is not allowed by the AO, the reopening of the assessment may be held as bad in law.¹⁰

Assessee can also ask the AO to allow personal hearing before deciding to issue notice u/s 148.^10a

8.3 Approval for General/Open Inquiries

As per Finance Act, 2022 no approval for inquiries u/s 148A(a) is required. Thus, AO has been given free hand to carry out inquiries to collect material and evidence about escapement of income before issue of notice u/s 148A(b).

8.4 Inquiry Through Other Officers

It is possible to interpret the phrase, “the AO shall…. Conduct any inquiry” to cover the carrying out of inquiries through other officers of the Department as the scope of this phrase may not be restricted to merely carrying out inquiries by self and not taking assistance of other Departmental officers. When an inquiry is carried out through an inspector, it is the inquiry through others. Therefore, inquiry through other officers would also be covered in the above phrase.

8.5 Whether Verification from Records is an Inquiry

When information is received as per Explanation 1 to section 148, or deemed information under Explanation 2 (ii), any further mention of facts, in the show cause notice issued u/s 148A(b), other than those contained in the information received as per Explanation 1 would mean that the AO has carried out inquiries as a result of which further facts have been collected. The collection of additional facts other than those mentioned in the information cannot be done without the approval of the specified authority. The AO is required not only to send the information proper along with show cause notice but also the additional facts as collected on inquiries to the approving authority for seeking approval to issue SCN.

8.6 Examples

8.6.1 About Explanation 1(i) of Section 148

(i) Cash deposit in the bank – Information as per clause (i) of Explanation 1 to section 148 is that assessee ‘X’ in his bank account xxxxxxxxx1234 in …………. Bank, made a deposit of ` 25 lakhs in cash during the FY 2021-22.

In this information, the name of the assessee, the relevant financial year, and the amount of deposit are mentioned. Further, information required is whether it is chargeable to tax or not. For this purpose, he needs to –

(i) collect bank statement for the relevant year

(ii) verify the return of income of the assessee for the relevant year, as to whether the bank account is disclosed

(iii) to send the inspector to verify from the books of account of the assessee whether the deposit of cash is entered in the books and what is the nature of such receipts.

It is for the assessee, in response to show cause notice issued u/s 148A(b) to explain with evidence the nature of the deposit, whether it constitutes exempted income or is a sale proceed, etc.

(ii) Purchase of property – Information is received that assessee has purchased a property for a sum of ` 5 crores. Further facts required are, when the property was purchased, whether it is residential or commercial, what is the source of investment, and whether such investments are accounted for. Then inquiries required to be carried out are to find out –

(i) location of property

(ii) identification of seller

(iii) whether declared in the return of income

(iv) whether declared as business property or house property

(v) if house property, whether income there from is declared

(vi) what is the investment declared in the return.

For collecting these facts inquiries required are –

(i) verification of return

(ii) collecting bank statement declared by the assessee in the return

(iii) collecting data/deed from Registrar of properties. They are sufficient to issues how cause notice and to decide whether it would be a fit case to issue notice u/s 148¹¹.

(iii) Assessee being beneficiary of accommodation entries – The information received from the investigation wing through RMS that the assessee has obtained accommodation entries from Mr. ‘X’ as revealed in the search/survey against Mr. ‘X’ and his companies and the assessee is one of the beneficiaries. For fortifying the inference that the assessee has paid unaccounted cash and obtained accommodation entries by way of loan/share application money from a company of Mr. ‘X’, information required would be –

(i) a statement/document linking the assessee as a beneficiary

(ii) bank statement of investing/lender company

(iii) the assessment orders of the investing/lender companies

(iv) verification from SEBI, whether investing/lender company are declared as shell companies. The verification/inquiries can be done through the investigation wing to obtain the above documents and from the bank of the lender/investing company to obtain a bank statement to know whether any cash was deposited therein¹².

(iv) Receipt of information as contained in the charge sheet filed by CBI – Information received (through RMS) that as per the charge sheet filed by CBI assessee has received certain share application money at a high premium from his blood brother. In such a case there is no need to carry out further inquiries u/s 148A(a) as the charge sheet itself provides –

(i) amount of share premium

(ii) relevant assessment year

(iii) unaccounted money (bribe money) involved in this transaction.

The AO can issue show cause notice under section 148A(b) without carrying out inquiries u/s 148A(a)¹³.

(v) Receipt of unaccounted profit from the firm – Information received through RMS that there has been distribution of unaccounted money by the firm to the retiring partner. Such information can come as T.E.P. but it has to be routed through RMS for becoming information as per Explanation 1. Once received by the AO, it requires inquiries which can be done through the investigation wing, which can exercise its power to record the statement of other partners and collect evidence, whether the firm had unaccounted profit which was distributed among partners. For carrying out these inquiries the AO has to seek approval from the specified authority u/s 148A(a)¹⁴.

(vi) Case of bogus purchases – Information received through RMS that the assessee had made huge bogus purchases to suppress profits, the AO is expected to carry out preliminary inquiries u/s 148A(a) such as –

(i) verification of the return to know purchases shown in the relevant previous year

(ii) whether huge credits in the balance sheet are existing in the name of sellers

(iii) profits and rates of the profit shown in earlier years

(iv) if the name and address of the seller is available, then verification from the record of such sellers as to how he could have made sales to the assessee

(v) his source of purchases

(vi) his financial position to make big purchases and then sale to assessee

(vii) movement of stock.

Thus, two kinds of inquiries are required –

(i) verification from the record of the assessee and

(ii) inquiry through the investigation wing or directly by the AO either u/s 133A or u/s 131¹⁵.

(vii) Receipt of information about a bank account in a foreign country – The Assessing Officer received information from the Investigation Wing, through RMS that the assessee had operated an undeclared account with HSBC Bank located in Switzerland and carried out unaccounted transactions and made deposits in them during the relevant assessment years. The preliminary inquiries u/s 148A(a) required may be –

(i) verification from the return of income about the existence of any bank account in a foreign country

(ii) calling for bank statements of declared bank accounts of the assessee and family members and to find out expenses on foreign visits or receipt of money on the transfer of funds from foreign countries, either in his account or in the account of his family members.

(iii) examination of passport of the assessee and family members as to how many times they have visited Switzerland.

(iv) where interest is paid by foreign banks, whether such interest is declared in the return¹⁶.

1. This provision is applicable only in those cases where order u/s 148A(d) has been passed or notice u/s 148 has been issued on or before 31-08-2024 in view of new scheme of reassessment introduced by Finance (No. 2) Act, 2024 and as provided in section 152 of the Act. Detailed discussion in respect of this new scheme is provided in Chapter No. 25.

1a.  [2002] 125 Taxman 963 (SC)

2. Based on Bir Bahadur Singh Sijwali v. ITO [2015] 53 taxmann.com 366 (Delhi – Trib.); Amrik Singh v. ITO [2016] 70 taxmann.com 26 (Amritsar – Trib.); Gurpal Singh v. ITO [2016] 71 taxmann.com 108 (Amritsar – Trib.)

3. Sunrise Education Trust v. ITO [2018] 92 taxmann.com 74 (Guj.)

4. ITO v. Amit K. Shah [2016] 71 taxmann.com 256 (Ahd. – Trib.)

5. Bikash Dev v. DCIT [2023] 102 ITR (Trib) 701 (ITAT – Ctk)

6. CIT v. Indo Arab Air Services [2015] 64 taxmann.com 257 (Delhi)

7. Based on Swati Malove Divetia v. ITO [2018] 98 taxmann.com 447 (Guj.)

8. [2002] 125 Taxman 963 (SC)

8a. As per new scheme of reassessment introduced by Finance (No. 2) Act, 2024, no inquiries are required to be carried out under new section 148A and a notice u/s 148A(1) on the basis of information, which suggest that income chargeable to tax has escaped assessment, can be issued by the AO on or after 01-09-2024.

9. [2018] 94 taxmann.com 430 (Guj.)

10. CIT v. Pradeep Kumar Gupta [2008] 303 ITR 95 (Delhi)

10a. Studio Virtues v. ITO [2023] 156 taxmann.com 94 (Gujarat)

11. Smt. A. Sridevi v. ITO [2018] 100 taxmann.com 434 (Mad.)

12. Kottenz India Manufacturing (P.) Ltd. v. DCIT [2018] 95 taxmann.com 291 (Guj.); Etiam Emedia Ltd. v. ITO [2019] 101 taxmann.com 231 (MP); MSK Real Estates (P.) Ltd. v. DCIT [2018] 95 taxmann.com 241 (Guj.); Khatu Shyam Processors (P.) Ltd. v. DCIT [2018] 94 taxmann.com 429 (Guj.); Peass Industrial Engineers (P.) Ltd. v. DCIT [2016] 73 taxmann.com 185 (Guj.)

13. Dayanidhi Maran v. ACIT [2018] 98 taxmann.com 202 (Mad.); South Asia FM Ltd. v. ACIT [2018] 98 taxmann.com 200 (Mad.)

14. Atul Ratilal Makadia v. ITO [2018] 94 taxmann.com 435 (Guj.)

15. PCIT v. Paramount Communication (P.) Ltd. [2017] 79 taxmann.com 409 (Delhi); Choksi Vachharaj Makanji & Co. v. ACIT [2016] 76 taxmann.com 17 (Guj.)

16. Pradeep Dayanand Kothari v. ACIT [2016] 69 taxmann.com 408 (Chennai – Trib.); Ambrish Manoj Dhupelia v. DCIT [2017] 87 taxmann.com 195 (Mum. – Trib.)

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