Section 282 · Assessment
Section 282 of the Income-tax Act, 2025 — Time Limit for Reassessment Notices Under Sections 280 and 281 (Income Escaping Assessment)
By CA Rajat Agrawal
Updated 05 Jul 2026
Chapter XVI
📜 What the law says — Section 282, Income-tax Act 2025
282. (1) No notice under section 280 shall be issued for the relevant tax year,—
(a) if four years and three months have elapsed from the end of the relevant
tax year, unless the case falls under clause (b);
(b) if four years and three months, but not more than six years and three
months, have elapsed from the end of the relevant tax year, unless the
Assessing Officer has in his possession books of account or other docu-
ments or evidence related to any asset or expenditure or transaction or
entry which shows that the income chargeable to tax, which has escaped
assessment, amounts to or is likely to amount to fifty lakh rupees or more.
(2) No notice to show cause under section 281 shall be issued for the relevant tax
year,—
(a) if four years have elapsed from the end of the relevant tax year, unless
the case falls under clause (b);
(b) if four years, but not more than six years, have elapsed from the end
of the relevant tax year, unless the income chargeable to tax which has
escaped assessment, as per the information with the Assessing Officer,
amounts to or is likely to amount to fifty lakh rupees or more.
(3) No notice under section 280 or 281 shall be issued within one year from the
end of any tax year.
[Provision for cases where assessment is in pursuance of an order on appeal,
60
etc.
283. (1) Irrespective of anything contained in section 282, the notice under section
280 may be issued at any time for the purpose of making an assessment or
reassessment or recomputation in consequence of, or to give effect to,—
(a) any finding or direction contained in an order passed by any authority.
Tribunal or Court in any proceeding under this Act or any other law; or
60. Substituted by the Finance Act, 2026, w.e.f. 1-4-2026. Prior to its substitution, section 283
read as under :
“283. Provision for cases where assessment is in pursuance of an order on appeal, etc.—(1)
Irrespective of anything contained in section 282, the notice under section 280 may be issued
at any time for the purpose of making an assessment or reassessment or recomputation in
consequence of or to give effect to—
(a) any finding or direction contained in an order passed by any authority, Tribunal or
court in any proceeding under this Act by way of appeal, reference or revision or by
In plain language
What Section 282 actually deals with
Section 282 of the Income-tax Act, 2025 is the "limitation" or time-bar provision for reassessment. It fixes the outer deadlines within which the Income-tax Department can issue a notice to reopen a past year and tax income that "escaped assessment" (income you did not declare, or that was under-taxed). It works hand-in-hand with two sister sections:
- Section 280 — the section under which the Assessing Officer (AO) issues the actual reassessment notice (equivalent to the old Section 148 of the 1961 Act).
- Section 281 — the pre-notice "show-cause" procedure, where the AO must first share the information he has and give you a chance to reply before issuing a Section 280 notice (equivalent to old Section 148A).
In the Income-tax Act, 1961, this limitation function was performed by Section 149. So Section 282 (2025) is the re-drafted successor of Section 149 (1961). It does not create the power to reopen — it only tells you how far back the department can go.
The two-tier time limit (the heart of the section)
Section 282 uses a normal limit and an extended limit that turns on a ₹50 lakh money threshold:
- Normal period: A show-cause notice under Section 281 cannot be issued once four years have elapsed from the end of the relevant tax year; and the consequential Section 280 notice cannot be issued once four years and three months have elapsed (the extra three months is the buffer for completing the Section 281 procedure).
- Extended period: The window stretches to six years (Section 281) / six years and three months (Section 280) from the end of the relevant tax year, but only if the AO has in his possession books of account, documents or evidence showing that the escaped income is (or is likely to be) ₹50,00,000 or more for that year.
- Minimum cooling period: No notice under Section 280 or 281 can be issued within one year from the end of any tax year. This stops the department from reopening a year that has barely closed.
This is a major structural change from the 1961 regime. Under old Section 149 (as amended by the Finance Act, 2021 and later the Finance Act, 2024), the outer limit for serious cases had already been pulled down from the earlier 10 years to broadly a 5-year-3-month ceiling. The 2025 Act settles the design at roughly six years plus a short buffer for the high-value ₹50 lakh-plus cases, and about four years for ordinary cases.
Who it applies to
- Every taxpayer whose past-year assessment the department wants to reopen — salaried individuals, businesses, professionals, companies, firms, HUFs and NRIs.
- It is enforced by the Assessing Officer, but the extended-period reopening also requires sanction from a specified authority (such as an Additional/Joint Commissioner or Director) under the Section 281 machinery, adding a supervisory check.
How the ₹50 lakh threshold is measured
The ₹50 lakh test is about the quantum of escaped income for that single tax year, not the tax on it. The AO must have tangible material — bank entries, purchase/sale documents, information flagged by the risk-management system, foreign asset data, or entries in books — that reveals income of ₹50 lakh or more has escaped. Below ₹50 lakh, only the shorter (roughly four-year) window is available; the older years become time-barred and safe.
Exclusion of certain periods
Consistent with the 1961 approach, periods lost to court stays, injunctions, and the time given to the assessee to respond to a show-cause notice are generally excluded when computing the limitation — so the clock effectively pauses during those stretches. Because the precise wording of these carve-outs is technical, always read the exact sub-section text or take professional advice before assuming a year is closed.
How it interacts with related sections
- With Section 281: The four-year / six-year measurement for the show-cause stage feeds the slightly longer Section 280 window, ensuring the AO has time to finish the procedure.
- With Section 280: Even if the department has grounds to reopen, a notice issued after the Section 282 deadline is void and can be quashed.
- With assessment sections (e.g. Section 279/reassessment): Once a valid notice is issued in time, the actual reassessment order is completed under the assessment machinery, subject to its own separate time limits.
Practical implications for taxpayers
- Keep records for at least seven years. Because high-value reopening reaches roughly six years plus a buffer, your bank statements, investment proofs, sale deeds and books should be retained well beyond that.
- Check the date on any reassessment notice. If it is issued beyond the Section 282 outer limit, it is legally time-barred — a strong ground of objection.
- Small under-reporting ages out faster. If the alleged escaped income is under ₹50 lakh, only the shorter window applies, so older years cannot be reopened.
💡 Example
Worked example 1 — small case (under ₹50 lakh): Ravi is a salaried employee. For Tax Year 2026-27 (year ending 31 March 2027), the department later finds he failed to report ₹8 lakh of interest income. Since ₹8 lakh is below the ₹50 lakh threshold, only the normal window applies. The show-cause notice under Section 281 must be issued within four years — i.e. by 31 March 2031 — and the Section 280 notice within four years three months, i.e. by around 30 June 2031. A notice served on Ravi in, say, September 2032 for TY 2026-27 would be time-barred and liable to be quashed.
Worked example 2 — big case (₹50 lakh or more): Meera Textiles Pvt Ltd is found to have suppressed sales of ₹1.2 crore in Tax Year 2026-27. Because the escaped income exceeds ₹50 lakh and the AO holds supporting invoices and bank evidence, the extended window applies. The Section 281 show-cause can be issued up to six years from year-end (by about 31 March 2033) and the Section 280 notice up to six years three months (by about 30 June 2033), subject to sanction from the specified authority. Note that no notice could have been issued before one year had passed from year-end — i.e. not before 1 April 2028.
A relatable story: In 2031, Anil receives an intimidating reassessment notice for the year ending March 2027, alleging he under-reported ₹12 lakh of freelance income. Panicking, he almost pays up. His CA instead pulls out a calendar: the escaped income is well below ₹50 lakh, so the department only had until roughly mid-2031 under the normal limit — and the notice was actually dated August 2031. The CA files an objection that the notice is barred by Section 282. The proceeding is dropped. The lesson: before arguing the merits, always check whether the department was even in time.
| Situation | Escaped income | Section 281 show-cause limit | Section 280 notice limit |
|---|
| Normal case | Below ₹50 lakh | Within 4 years from end of tax year | Within 4 years 3 months from end of tax year |
| High-value case | ₹50 lakh or more (with evidence) | Up to 6 years from end of tax year | Up to 6 years 3 months from end of tax year |
| Minimum cooling period | Any amount | No notice under Section 280 or 281 within 1 year from end of any tax year |
| 1961 Act equivalent | Section 149 (limitation); Section 148 → 280; Section 148A → 281 |
Related sections
Section 280 — Issue of notice where income has escaped assessment (old Sec 148) Section 281 — Procedure and show-cause before issuing a reassessment notice (old Sec 148A) Section 279 — Income escaping assessment / reassessment power Section 149 (Act of 1961) — Old time limit for reassessment notices Section 268 — Time limit for completing assessments and reassessments Section 287 — Sanction of specified authority for issue of notice
Frequently asked questions
What is the maximum time the department can go back to reopen my income under Section 282?
For serious cases where the escaped income is ₹50 lakh or more, the reassessment notice under Section 280 can be issued up to about six years and three months from the end of the relevant tax year. For smaller amounts, the limit is roughly four years.
Which old section does Section 282 replace?
Section 282 of the Income-tax Act, 2025 is the successor of Section 149 of the Income-tax Act, 1961, which laid down the time limits for issuing reassessment notices.
Why is there both a four-year and a four-year-three-month limit?
The four-year limit applies to the Section 281 show-cause stage, and the extra three months is a buffer that lets the Assessing Officer complete that procedure and then issue the actual Section 280 notice in time.
What is the ₹50 lakh threshold for?
It is the trigger for the extended (six-year) window. The department can only reopen the older years if it holds evidence that the income escaping assessment for that year is, or is likely to be, ₹50 lakh or more.
Can the department issue a notice immediately after a tax year ends?
No. Section 282 bars any notice under Section 280 or 281 within one year from the end of any tax year, giving a minimum cooling-off period.
What happens if a reassessment notice is issued after the Section 282 deadline?
A notice issued beyond the prescribed time limit is barred by limitation and can be challenged and quashed as invalid, even before arguing the merits of the case.
How long should I keep my tax records because of this section?
Since high-value cases can be reopened for roughly six years plus a buffer, it is prudent to retain bank statements, investment proofs and books for at least seven years.
C
CA Rajat Agrawal
Chartered Accountant, EaseValue · Reviewed 05 Jul 2026
This explainer is prepared and reviewed by EaseValue's tax team, based on the text of the Income-tax Act, 2025 (as amended by the Finance Act, 2026).
Disclaimer: This page explains the law in general terms for education and is not professional advice. The Income-tax Act, 2025 takes effect from 1 April 2026; provisions, thresholds and interpretations may change. Please confirm your specific position with our team before acting.
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