Chartered Accountants in India, working with clients across the UK

Section 147 Income Escaping
Income Tax · Reassessment

Reassessment:when a past year is reopened.

Under section 147, the department can reopen a past year if it has information that income escaped assessment. It must follow a set procedure and act within strict time limits. For NRIs, reopening often relates to property deals or deposits from years ago. We check whether reopening is valid and represent you throughout.

Validity of reopening checkedFees agreed in writingRepresented throughout
WhatReopening a past year
Normal limit3 years
Extended limit5 years if ₹50 lakh or more
Before noticeShow-cause and order

What reassessment is.

Reassessment lets the department assess income that escaped assessment in an earlier year. It must have information suggesting this, and it must follow the procedure before issuing a section 148 notice.

Escaped incomeTime limit for reopening
Below ₹50 lakh3 years from the end of the relevant year
₹50 lakh or more, represented in assets, expenditure or entries5 years from the end of the relevant year
Old and new section numbers

From 1 April 2026 the Income-tax Act, 2025 has renumbered these provisions. Notices for tax years before 2026-27 still refer to the Income-tax Act, 1961 sections, which is why this page uses them. We check which Act applies to your notice.

These limits apply to notices issued after the 2024 changes. Older cases may follow earlier rules. We check which applies.

The procedure.

01
Information

Officer has information

Suggesting income escaped assessment.

02
Show-cause

Notice with the information

You are given the information and a chance to reply.

03
Order

Decision on reopening

A reasoned order on whether it is a fit case.

04
Notice

Section 148 notice

If reopened, you are asked to file a return.

05
Assessment

Reassessment

Then assessment, with the usual rights and remedies.

Grounds to challenge reopening.

  • Time limitNotice issued after the allowed period.
  • No real informationReopening based on suspicion, not information.
  • Explained alreadyIncome already disclosed or explained.
  • Below thresholdEscaped income below ₹50 lakh in a year beyond 3 years.
  • Procedure not followedNo show-cause or no reasoned order.
  • Wrong officerLack of jurisdiction or approval.

Why clients trust us with notices.

Every notice read in full

We read the notice, the AIS and your return together before advising.

Replies on time

Deadlines tracked from the day you send us the notice.

Plain-English explanation

What the notice means, what is at stake and what we recommend.

Faceless and online

Most proceedings are handled online, so you never need to travel to India.

Chartered Accountants

Replies and representation by Chartered Accountants.

Fees agreed in writing

A written scope and fee before we start.

Reassessment support for clients across the UK.

We handle Indian income tax notices for NRIs, returning Indians and UK-owned businesses throughout the UK. Faceless proceedings are online, so it makes no difference where you live.

London

City of LondonCanary WharfHarrowWembleySouthallHounslowIlfordEast HamCroydonEdgware

South East

ReadingSloughMilton KeynesOxfordWatfordLutonCrawleyGuildford

Midlands

BirminghamLeicesterCoventryNottinghamWolverhamptonDerbyNorthampton

North of England

ManchesterLeedsBradfordSheffieldLiverpoolNewcastlePreston

East and South West

CambridgePeterboroughBristolSwindonSouthamptonBath

Scotland, Wales, NI

EdinburghGlasgowAberdeenDundeeCardiffSwanseaBelfast

Section 147 FAQs.

Generally 3 years from the end of the relevant year, or 5 years where the escaped income is ₹50 lakh or more.
Yes. A show-cause notice with the information must be issued, and a reasoned order passed, before a section 148 notice.
Yes, for example on time limits, lack of information or procedure, and through appeal or writ in suitable cases.
Often because of old property transactions or deposits reported to the department but not explained in a return.

Is a past year being reopened?

Send us the notice. We will check the time limit and procedure, then respond.

This page is general guidance based on the Income-tax Act, 2025 and the rules and return forms as they stand. It is not legal or financial advice for your situation. Forms, eligibility and due dates can change each year, so please check with us before filing.