Reassessment notices are among the most litigated documents in Indian tax. Under the Income-tax Act, 2025 the whole reassessment block moves from sections 147 to 152 into sections 279 to 285.
Quick answer: the mapping
| Income-tax Act, 1961 | Subject | Income-tax Act, 2025 |
|---|---|---|
| 147 | Income escaping assessment | 279 |
| 148 | Issue of notice | 280 |
| 148A | Procedure before issuing notice | 281 |
| 149 | Time limit for notice | 282 |
| 150 | Assessment in pursuance of an appellate order | 283 |
| 151 | Sanction for issue of notice | 284 |
| 152 | Other provisions | 285 |
The Income-tax Act, 2025 received Presidential assent on 21 August 2025 and takes effect from 1 April 2026. The Income-tax Act, 1961 continues to govern every tax year up to 31 March 2026, and all assessments, appeals, penalties and prosecutions relating to those years are completed under the old Act by virtue of the repeal and savings provision in section 536. The mapping on this page is drawn from the section-wise concordance published with the Act, including the corrigenda notified in the Gazette on 3 September 2025.
What the 1961 provision did
Section 147 of the Income-tax Act, 1961 allowed the Assessing Officer to reassess income that had escaped assessment. Section 148 was the notice, section 148A the mandatory pre-notice procedure introduced in 2021, section 149 the time limit and section 151 the sanction requirement.
Where it sits in the Income-tax Act, 2025
Section 279 of the Income-tax Act, 2025 carries income escaping assessment. Section 280 is the notice, section 281 is the procedure before issuing that notice, section 282 sets the time limit for notices under sections 280 and 281, and section 284 carries the sanction requirement.
What actually changed
- The structure is preserved. The 2021 architecture — inquiry, show cause, order, then notice — is carried into sections 281 and 280 rather than being rewritten.
- The time limit provision now names both notice sections. Section 282 is headed “Time limit for notices under sections 280 and 281”, which makes the link explicit in a way section 149 did not.
- Sanction is a standalone section. Section 284 carries section 151, the provision at the centre of a large body of litigation on who may approve a notice.
- Completion time limits are elsewhere. Section 286 (old section 153) governs the time limit for completing the reassessment.
What to do about it
- When a notice arrives, first identify the tax year. Notices for years up to 2025-26 are issued under the 1961 Act; section 536 preserves it for those years.
- Check the sanctioning authority against section 284 for new-Act years, and against section 151 for old-Act years.
- Search-related assessments follow a separate route — sections 292 to 301 carry the block assessment code that was the 158B series.
The sections around it in the new Act
Renumbering is easier to absorb in context. The table below lists the neighbouring provisions of the Income-tax Act, 2025 with the 1961 sections each of them carries forward, so you can see where this provision sits and what moved with it.
| New section (2025) | Provision | Corresponding 1961 section(s) |
|---|---|---|
| 279 | Income escaping assessment | 147 |
| 280 | Issue of notice where income has escaped assessment | 148 |
| 281 | Procedure before issuance of notice under section 280 | 148A |
| 282 | Time limit for notices under sections 280 and 281 | 149 |
| 283 | Provision for cases where assessment is in pursuance of an order on appeal, etc | 150 |
| 284 | Sanction for issue of notice | 151 |
| 285 | Other provisions | 152 |
| 286 | Time limit for completion of assessment, reassessment and recomputation | 153 |
How to read a section mapping
- A corresponding section is not always an identical section. Where several 1961 sections map to one new section, conditions that used to sit apart are now read together.
- Where one 1961 section maps to several new sections, the old provision was split, and each new section carries only part of what you used to cite.
- Some new sections have no 1961 equivalent at all — the registered non-profit code in sections 332 to 355 is the largest example.
- Always cite by year. The Act that applies is decided by the tax year in question, not by the date you are writing on.
This page is a structural mapping guide, not tax advice. A corresponding section is not always an identical section — several provisions were merged, split or re-worded when they were carried over. Always read the actual text of the new section before relying on it, and check for later amendments, rules and CBDT notifications.