148A Notice Reply Format 2026
To,
{{officer_designation}}
Date: 1 October 2026
Reply to Show-Cause Notice under Section 148A(1) of the Income-tax Act, 1961
Assessee: {{client_name}} | PAN: {{client_pan}} | Assessment Year: {{assessment_year}}
Ref: Show-cause notice dated
Respected Sir / Madam,
1. We act as the authorised representative of the above assessee; the letter of authority is enclosed as Annexure A. This reply is furnished under section 148A(2) within the period specified in the notice, in response to the proposal to issue a notice under section 148 for AY {{assessment_year}} on the footing that income of ₹ {{escaped_income}} has escaped assessment.
2. The assessee filed its return of income for AY {{assessment_year}} on ____________ (acknowledgement no. ____________) declaring total income of ₹ ____________. The return was ____________ [processed u/s 143(1) on ____________ / assessed u/s 143(3) by order dated ____________].
A. Information and material supplied with the notice
3. Section 148A(1) requires the show-cause notice to be accompanied by the information which suggests that income chargeable to tax has escaped assessment. The assessee has received the following with the notice: ____________ [list what was actually supplied — e.g. a one-page summary of a high-value transaction, an extract of a third-party statement, an audit objection].
4. The following material, on which the proposal evidently rests, has not been supplied: ____________ [e.g. the underlying statement, the source report, the transaction-wise data]. The assessee requests copies and reserves the right to file a further reply once they are supplied. This reply is made on the material presently available and without prejudice to that right.
B. Preliminary objections
5. Without prejudice to the reply on merits, the assessee raises the following objections to the assumption of jurisdiction:
(a) Limitation — under section 149, no show-cause notice under section 148A can be issued after three years from the end of the relevant assessment year, unless the income that has escaped assessment, as per the information with the Assessing Officer, amounts to or is likely to amount to ₹50 lakh or more, in which case the outer limit is five years. AY {{assessment_year}} ended on 31 March ____________; the notice is dated . ____________ [state the result — e.g. 'the notice is issued in the fourth year and the income alleged to have escaped, correctly computed, is ₹ ____________, being below ₹50 lakh; the notice is therefore barred'].
(b) No "information" in the statutory sense — the material relied upon does not fall within the meaning of information given in the Explanation to section 148: ____________ [state why — e.g. it is not a flag under the risk management strategy, an audit objection, or any other category listed there; or it relates to a different person / a different year].
(c) Issue already examined — the transaction now referred to was specifically examined in the assessment completed under section 143(3) on ____________; the query dated ____________ and the reply dated ____________ are enclosed. There is no fresh information, only a second look at material already on record.
(d) Defect in the notice — ____________ [e.g. the notice does not bear a valid Document Identification Number; it is addressed to an entity that ceased to exist on amalgamation with effect from ____________, a fact on the department's record; it names the wrong assessment year].
(e) Authority issuing the notice — the assessee places on record its objection that the notice has not been issued in the manner required by section 151A and the scheme notified under it. The assessee is aware of section 147A inserted by the Finance Act, 2026 and of the proceedings pending before the Hon'ble Supreme Court on its validity; the objection is taken so that it is preserved, and the assessee craves leave to rely on the final outcome.
- Drafting hint: keep only the objections that are real on your facts and delete the rest. A reply that leads with five weak objections buries the one that matters.
- Drafting hint: jurisdictional objections must be raised now, in this reply. An objection first taken in appeal is far harder to sustain.
- Drafting hint: for the limitation ground, measure from the end of the assessment year, not the financial year, and compare the ₹50 lakh threshold against the income alleged to have escaped — not the gross value of the transaction.
C. Reply on merits
6. Each item of information is dealt with below. In every case the transaction is recorded in the books of account and has been considered in computing the returned income.
| Sl. | Information / allegation in the notice | Amount (₹) | Assessee's explanation | Where reflected in the return / books | Annexure |
|---|
| 1 | ____________ [reproduce the allegation verbatim] | ____________ | ____________ [answer in the first sentence — e.g. 'the deposits represent sale proceeds already included in turnover'] | ____________ [ITR schedule, ledger account, Form 3CD clause] | ____ |
| 2 | ____________ | ____________ | ____________ | ____________ | ____ |
| 3 | ____________ | ____________ | ____________ | ____________ | ____ |
Reconciliation of the amount alleged to have escaped assessment
| Particulars | Amount (₹) |
|---|
| Amount alleged in the notice to have escaped assessment | {{escaped_income}} |
| Less: already offered to tax in the return of income (see table above) | ____________ |
| Less: not in the nature of income (e.g. loan, capital receipt, transfer between own accounts, amount belonging to another person) | ____________ |
| Less: duplicated or wrongly attributed in the information | ____________ |
| Balance, if any | ____________ |
7. On the above facts there is no income chargeable to tax which has escaped assessment for AY {{assessment_year}}. The information, read with the assessee's explanation and the evidence enclosed, does not suggest escapement; it reflects transactions that are fully accounted for.
- Drafting hint: a section 148A reply is won on documents. For every line of the table, enclose the bank statement page, ledger extract, contract note, sale deed or confirmation that proves the explanation.
- Drafting hint: where the information is a gross figure (total credits in a bank account, total value of a property, total F&O turnover), show the bridge from the gross figure to the income actually returned.
- Drafting hint: if part of the income was genuinely missed, say so and quantify it. Consider whether an updated return is still open for that year before conceding in this reply.
PRAYER
8. It is prayed that: (i) an order be passed under section 148A(3) holding that this is not a fit case for the issue of a notice under section 148; (ii) if any adverse view is proposed, the material referred to in paragraph 4 be supplied and a personal hearing (including through video conferencing) be granted before the order is passed; and (iii) a copy of the order under section 148A(3), together with the approval of the specified authority under section 151, be furnished to the assessee.
Thanking you,
Yours faithfully,
For {{firm_name}}
Chartered Accountants
Firm Registration No.:
_______________________________
{{engagement_partner}}
Partner | Membership No.: {{icai_membership_no}}
Authorised Representative of {{client_name}}
Annexure Index
| Annexure | Document | Pages |
|---|
| A | Letter of authority in favour of the authorised representative | ____ |
| B | Return of income, computation and acknowledgement for AY {{assessment_year}} | ____ |
| C | Intimation u/s 143(1) / assessment order u/s 143(3) with the queries and replies on the issue | ____ |
| D | Bank statements for the relevant period with the transactions highlighted | ____ |
| E | Ledger extracts, contracts, confirmations and other evidence for each item | ____ |
| F | ____________ | ____ |
