Reassessment Notice · Panaji, Goa
Received a notice to reopen your completed assessment? Our Chartered Accountants in Goa handle your Section 148 notice from end to end — requesting reasons for reopening, filing objections, responding to reassessment and appealing adverse orders.
Overview
A Section 148 notice initiates reassessment proceedings under Section 147 for income allegedly escaping tax. On receiving the notice, you must file a return (if directed) and are entitled to request the recorded reasons for reopening. Many reassessments are procedurally or substantively flawed — issued without proper approval, beyond the time limit, or based on a mere change of opinion rather than fresh material.
This service works closely with our Section 147 income escaping assessment and Section 143(2) scrutiny representation services for comprehensive income tax notice management.
What's covered
End-to-end notice management from receipt to resolution.
Get a fixed-fee quote →Careful examination of the 148 notice to determine its scope, the alleged escaped income and the time period involved.
Filing a formal application to the AO requesting the recorded reasons for the reopening, as you are legally entitled.
Filing the return for the reopened year if directed by the notice, to comply with procedural requirements.
Drafting and submitting legal objections challenging the validity of the reopening before the AO.
Full representation before the AO if the reassessment proceeds, with evidence to rebut the alleged escaped income.
Advising on and assisting with High Court writ petitions or CIT(A) appeals where appropriate.
Our process
We review the 148 notice and identify the reopening grounds.
We file your request for the recorded reasons for reopening.
We draft and submit legal objections to the AO within the deadline.
We handle the reassessment or challenge it before the High Court.
Frequently asked questions
A Section 148 notice is issued by the Assessing Officer to initiate reassessment proceedings for a year that has already been assessed or where no return was filed and income is believed to have escaped taxation. It formally triggers the Section 147 reassessment process and requires you to file a return for the relevant assessment year.
Generally yes, unless the AO specifically states otherwise. You must file a return for the year mentioned in the notice, treating it as if the notice were a notice to file a return. The return should reflect the true and correct income — not just accept the AO's basis for reopening.
Absolutely yes — and you should. Within 30 days of receiving the Section 148 notice, you are entitled to request the recorded reasons that form the basis for the AO's belief that income has escaped assessment. These reasons are crucial to assessing whether the reopening is legally valid.
Valid objections include: the notice is time-barred (beyond the statutory time limit); it lacks proper approval from the prescribed authority; there is no new or tangible material (it is a mere change of opinion); the alleged income was already considered in the original assessment; or jurisdictional defects. We assess which grounds apply in your case.
The reassessment must be completed within the time limits prescribed under the Income Tax Act. Proceedings under Section 148 are subject to strict timelines for issue of the notice, filing of objections, disposal of objections, and completion of the reassessment order.
If the reassessment order raises a demand that you disagree with, you can file an appeal before the Commissioner of Income Tax (Appeals) within 30 days. You can also apply for a stay of demand pending appeal to avoid coercive recovery. We handle both simultaneously.
No. A Section 148 notice relates to non-search reassessments under Section 147. Search-related assessments are handled under Section 153A or 153C, which have their own separate procedures, time limits and legal framework.
Contact N D Savla & Associates in Panaji, Goa immediately on receiving the notice. We request the recorded reasons, assess validity, file legal objections within the prescribed time, and if necessary represent you through the entire reassessment and subsequent appeal proceedings.
Related services
Book a free consultation with a qualified Chartered Accountant in Goa. We'll protect your completed assessment from invalid reopening — no obligation.