Section 282 of the Income-tax Act, 2025 bars a section 280 notice after four years and three months from the end of the relevant tax year, extended to six years and three months where escaped income is likely to be ₹50 lakh or more, with shorter limits for section 281 notices.
What section 282 does
Section 282 is the limitation provision for reassessment — the successor to section 149 of the Income-tax Act, 1961. It is short, precise, and the first thing to check when a reassessment notice arrives.
The Income-tax Act, 2025 expresses the limits in years and months rather than in whole years. A section 280 notice is barred after four years and three months from the end of the relevant tax year, extended to six years and three months where the escaped income is ₹50 lakh or more and the officer holds specified material.
The section 281 show cause notice has its own, shorter limits: four years, extended to six years on the same ₹50 lakh test. The three-month gap between the two sets is deliberate — it is the window in which the section 281 process is completed and the section 280 notice issued.
The Income-tax Act, 2025 takes effect from 1 April 2026 and applies from tax year 2026-27. The Income-tax Act, 1961 continues to govern every year up to 31 March 2026, including assessments, appeals and penalties for those years, because of the repeal and savings provision in section 536. Figures quoted here are the amounts written into the Act as enacted (with the Gazette corrigenda of 3 September 2025); the annual Finance Act can change rates and thresholds.
Old Act and new Act, side by side
The table below shows what the Income-tax Act, 1961 did and where the same ground is covered in the Income-tax Act, 2025.
| Income-tax Act, 1961 | What it did | Income-tax Act, 2025 |
|---|---|---|
| 149(1)(a) | Three-year limit for ordinary cases | 282(1)(a) — now four years and three months |
| 149(1)(b) | Ten-year limit where escaped income is ₹50 lakh or more | 282(1)(b) — now six years and three months |
| 148A | Show cause notice | 281, with its own limits in 282(2) |
| 149(1), proviso | No notice beyond the outer limit | 282(1) and 282(2) |
| 148 | Notice | 280 |
Section 282 sub-section by sub-section
Read this alongside the bare text — each heading below is a sub-section of the section as enacted.
Sub-section (1) — limits for the section 280 notice
No notice under section 280 may 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 clause (b) applies; or (b) where four years and three months but not more than six years and three months have elapsed, unless the Assessing Officer has in his possession books of account, other documents or evidence relating to an asset, expenditure, transaction or entry showing that the escaped income amounts to or is likely to amount to ₹50 lakh or more.
Sub-section (2) — limits for the section 281 show cause notice
No show cause notice under section 281 may be issued: (a) if four years have elapsed from the end of the relevant tax year, unless clause (b) applies; or (b) where four years but not more than six years have elapsed, unless the escaped income, as per the information with the Assessing Officer, amounts to or is likely to amount to ₹50 lakh or more.
The difference between the two tests
For the section 280 notice, the officer must have books of account, other documents or evidence relating to an asset, expenditure, transaction or entry. For the section 281 notice, it is enough that the information with the officer suggests the ₹50 lakh threshold. The evidentiary bar is higher at the notice stage than at the show cause stage.
Sub-section (3) — the one-year cooling period
No notice under section 280 or 281 shall be issued within one year from the end of any tax year. This prevents a reassessment being launched before the ordinary assessment machinery has had a chance to run.
How to compute the limit
The clock runs from the end of the relevant tax year. For tax year 2026-27, which ends 31 March 2027, four years and three months expires on 30 June 2031, and six years and three months on 30 June 2033. The corresponding section 281 dates are 31 March 2031 and 31 March 2033.
Worked example
Relevant tax year 2026-27, which ends on 31 March 2027.
| Notice | Escaped income below ₹50 lakh | Escaped income ₹50 lakh or more |
|---|---|---|
| Section 281 show cause | Not after 31 March 2031 (four years) | Not after 31 March 2033 (six years) |
| Section 280 notice | Not after 30 June 2031 (four years three months) | Not after 30 June 2033 (six years three months) |
| Either notice | Not before 31 March 2028 — one year from the end of the tax year, under sub-section (3) | Same |
Two practical consequences follow. First, a section 280 notice issued on 15 July 2031 for escaped income of ₹30,00,000 is time-barred, whatever its merits. Second, to use the extended period the officer must not merely assert ₹50 lakh — for the section 280 notice, sub-section (1)(b) requires books of account, documents or evidence relating to an asset, expenditure, transaction or entry.
Compliance checklist and due dates
- Compute the limit from the end of the relevant tax year, and note the limits are in years and months.
- Check the section 281 notice against the four/six year limits and the section 280 notice against four years three months / six years three months.
- Where the extended period is used, ask what books, documents or evidence the officer holds — assertion alone does not meet sub-section (1)(b).
- Verify the ₹50 lakh figure relates to the escaped income for that tax year.
- Check that no notice was issued within one year from the end of the tax year, under sub-section (3).
- For years up to 2025-26, apply the 1961 Act limits in section 149 instead — section 536 preserves them.
Common mistakes
- Applying whole-year limits and missing the additional three months for the section 280 notice.
- Computing the period from the date of the return or the assessment order rather than from the end of the tax year.
- Accepting an extended-period notice without testing whether the officer holds the material sub-section (1)(b) requires.
- Applying the new limits to a year governed by the Income-tax Act, 1961.
- Overlooking the one-year bar in sub-section (3).
This is an explanatory guide, not tax advice, and it does not reproduce the section in full. Read the bare text of the section before you rely on it, and check for later amendments, the Income-tax Rules made under the new Act, and CBDT circulars and notifications.