Old Sections 143 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Summary processing (143(1)), scrutiny (143(3)), best-judgment (144) and the reopening code (147, 148, 148A) of the 1961 Act carry into the assessment provisions of the Income-tax Act 2025. Faceless processing, the 148A pre-notice enquiry and sanction safeguards are preserved.
Overview
Assessment is how the Department examines a filed return and, where needed, reopens escaped income. Sections 143, 144, 147 and 148 of the 1961 Act governed processing, scrutiny, best-judgment and reassessment. The Income-tax Act 2025 re-numbers these into its assessment chapter while retaining the faceless framework and the reopening safeguards.
What the Old Act Said
Section 143(1) allowed centralised prima-facie adjustments (arithmetical errors, mismatches) and an intimation. Section 143(2)/(3) enabled scrutiny — a notice within the prescribed period followed by a reasoned assessment order, conducted faceless. Section 144 allowed best-judgment assessment on non-compliance. Section 147 permitted assessment of income escaping assessment; Section 148 required a notice to reopen; Section 148A (introduced in 2021) mandated a preliminary enquiry and show-cause before issuing that notice; Section 149 set time limits (broadly 3 years, extended to a longer period where escaped income crossed ₹50 lakh); Section 151 required sanction of a specified authority.
What the New Act 2025 Changes
The 2025 Act consolidates assessment into a cleaner chapter, preserving the mechanics. Centralised processing and intimation continue. Scrutiny remains faceless, with notice-based selection and reasoned orders. Best-judgment assessment survives for non-compliance. The reassessment code retains its post-2021 shape: a pre-notice enquiry and show-cause (148A-equivalent), a reopening notice, the tiered time limits keyed to the quantum of escaped income, and sanction by the specified authority. The emphasis on documentary safeguards, opportunity of being heard, and faceless conduct is carried forward.
Old → New Mapping
| Provision (1961 Act) | What it did | Position under Income-tax Act 2025 |
|---|---|---|
| Section 143(1) | Prima-facie adjustments; CPC intimation | Retained; centralised processing continues |
| Section 143(2)/(3) | Scrutiny selection and assessment (faceless) | Retained within the faceless assessment framework |
| Section 144 | Best-judgment assessment on non-compliance | Retained, conducted faceless |
| Section 147 | Assessment of income escaping assessment | Retained as the reassessment charge |
| Section 148 | Notice before reassessment | Retained |
| Section 148A | Pre-notice enquiry and show-cause | Retained as a safeguard |
| Section 149 | Time limits for reopening | Retained; tiered limits keyed to escaped-income quantum |
| Section 151 | Sanction of specified authority | Retained |
Practical Impact / Examples
A taxpayer whose return shows a TDS mismatch receives a 143(1)-equivalent intimation adjusting the refund — automated and centralised as before. If selected for scrutiny, the taxpayer receives a notice and responds through the faceless portal, with the order passed by a faceless unit. Where the Department believes ₹80 lakh of income escaped assessment, it must first issue the 148A-equivalent show-cause with the material relied upon, consider the reply, obtain sanction, and only then issue the reopening notice within the extended time limit — the same disciplined sequence introduced in 2021 and preserved in the 2025 Act.
Transition Tips
- Respond to every faceless notice within the deadline through the portal — non-response invites best-judgment assessment.
- On reopening, insist on the show-cause and the material relied upon before the notice is issued.
- Check that sanction of the specified authority exists — its absence is a common ground of challenge.
- Reconcile AIS/26AS with your return proactively to pre-empt 143(1) adjustments.