Reassessment after 3 years under the Income-tax Act, 1961 is not automatic and can be initiated only if strict statutory conditions are satisfied. Many reassessment notices are issued after 3 years from the end of the relevant assessment year.
Such cases are subject to stricter conditions.
What the law says
After 3 years, reassessment is permitted only if:
- Income escaping assessment exceeds the statutory threshold
- There is failure on the part of the assessee to disclose material facts
- Conditions under sections 148, 148A and 151 are strictly followed
When reassessment is NOT allowed
- Mere change of opinion
- Audit objections without new material
- Issues already examined earlier
- Vague or borrowed satisfaction
Practical checklist
Before replying:
- Check date of original assessment
- Verify years elapsed
- Examine reasons / information relied upon
- Look for disclosure in original proceedings
Related reading
- Received a 148A Notice? What to Do Within 48 Hours
- How to Reply to a 148A(b) Notice – Practical Reply Structure
- Difference Between Section 148, 148A and 151 – Explained Simply
- Can an Assessment Be Reopened Only on Audit Objection?
- Section 148A Reassessment Quashed – Key Case Laws on Defective Procedure
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