CA K Sanjay BhargavChartered Accountant
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Income tax notices under the new Act: recognising the section numbers

CA K Sanjay Bhargav, Chartered Accountant, Bengaluru

Membership No. 250054 · DISA (ICAI)

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Short answer: two Acts are live at the same time. A notice about AY 2026-27 or earlier correctly cites 1961 Act sections — 143(1), 143(2), 148. A notice about tax year 2026-27 onwards cites the 2025 Act — 270(1), 270(8), 280. An old number on an old year is not a defect.

Why you are seeing two systems at once

The Income-tax Act, 2025 came into force on 1 April 2026. It did not sweep away everything before it. Section 536 of the 2025 Act — a savings provision running to 22 sub-clauses, reinforced by Section 6 of the General Clauses Act — preserves rights, liabilities, approvals, registrations and pending proceedings arising before that date, and lets them run to completion under the 1961 Act.

The practical consequence is a dual track that will persist for years:

The year in questionGoverning ActNotice cites
AY 2026-27 (FY 2025-26) and earlierIncome-tax Act, 1961143(1), 143(2), 148, 154
Tax year 2026-27 onwardsIncome-tax Act, 2025270(1), 270(8), 280, 287

So the first question on receiving any notice is not "what does this section say" but "which year is this about". That determines everything else.

The notice-by-notice mapping

Notice / order1961 Act2025 Act
Inquiry before assessments.142(1)s.268
Valuation reference / special audits.142As.269
Intimation (summary processing)s.143(1)s.270(1)–(7)
Time limit for the intimations.143(1) provisos.270(4) — 9 months
Scrutiny notices.143(2)s.270(8)
Time limit to serve its.143(2) provisos.270(9) — 3 months
Assessment orders.143(3)s.270(10)
Best judgment assessments.144s.271
Faceless assessments.144Bs.273
Dispute Resolution Panels.144Cs.275
Reassessment — the cores.147s.279
Reassessment notices.148s.280
Pre-notice inquiry procedures.148As.281
Limitation for reassessments.149s.282
Sanction for issuing notices.151s.284
Rectifications.154s.287
Notice of demands.156s.289
Under-reporting penaltys.270As.439
Penalty immunity applications.270AAs.440
Appeal to Commissioner (Appeals)s.246A / s.249s.357 / s.358
Appeal to Tribunals.253s.362
Appeal to High Courts.260As.365

Two structural points behind the table:

Assessment is now one section, not several. The old 143(1), 143(2) and 143(3) were separate provisions. Under the 2025 Act all three live inside Section 270:

  • 270(1)–(7) — processing and the intimation, with the nine-month outer limit at 270(4)
  • 270(8) — the scrutiny notice, requiring you to attend or produce evidence
  • 270(9)no notice under 270(8) after three months from the end of the financial year in which the return is furnished
  • 270(10) — the assessment order itself

When a new-Act notice arrives the sub-section tells you what kind of proceeding it is. Reading only "Section 270" tells you almost nothing — and 270(9) is where a late scrutiny notice is challenged.

Demand has moved to 289 — and 156 now means something else entirely. Section 156 of the 1961 Act was the notice of demand. Section 156 of the 2025 Act is the rebate for resident individuals. Two completely unrelated provisions sharing a number across the two Acts is exactly the kind of collision that produces a confident, wrong answer.

⚠️ A fresh 1961-Act notice can still arrive today

This is the point that catches people, including some advisers. The repeal did not extinguish old years.

The department can still issue a new notice under the 1961 Act for a pre-2026 year, after 1 April 2026, subject to the 1961 Act's own limitation periods. Section 536 preserves the power, not merely the paperwork already in motion.

So "the 1961 Act has been repealed, this notice is bad" is not an argument. The argument that does work is limitation — and limitation differs between the two Acts:

Under the 2025 Act the limits are in Section 282, and they differ depending on which notice you are holding:

NoticeOrdinary limitExtended limit
Show-cause under s.281 (ex-148A)4 years from end of the tax year6 years, where escaped income is ₹50 lakh or more
Reassessment notice under s.280 (ex-148)4 years and 3 months6 years and 3 months, on the same ₹50 lakh test

Two further points from Section 282 worth having:

  • The extended window for a s.280 notice requires the Assessing Officer to have books of account, documents or evidence showing escaped income of ₹50 lakh or more — not merely information. For the s.281 show-cause the test is framed as "information with the Assessing Officer". The evidential bar is not the same.
  • Section 282(3): no notice under either section may issue within one year from the end of any tax year. There is a floor as well as a ceiling.

For old years the 1961 Act governs, and its limits were themselves recast with effect from 1 September 2024: 3 years 3 months ordinarily, extending to 5 years 3 months where the officer holds material showing escaped income of ₹50 lakh or more. The 10-year outer limit that a great deal of commentary still quotes belonged to the 2021 scheme and does not apply to notices under the recast provisions — see Section 148 reassessment notices: time limits and defences, which works through which version governs a given notice.

Checking a 1961-Act notice against 2025-Act time limits, or the reverse, produces the wrong answer in both directions. Our note on Section 148 reassessment notices works through the old-Act limitation position, which is the one that governs most notices arriving now.

The portal runs both years side by side

During FY 2026-27 the e-filing portal carries AY 2026-27 (FY 2025-26 income, 1961 Act) and tax year 2026-27 (2025 Act) at the same time. When paying tax you must select the right one.

A challan tagged to the wrong year does not fail — it sits against the wrong demand, leaves the intended demand outstanding, and generates interest and recovery follow-up until someone unpicks it. It is avoidable and tedious to fix.

What to check on any notice, in order

  1. Which year is it about? That fixes the Act.
  2. Is the section right for that year? An old number on an old year is correct. A new number on an old year is worth questioning.
  3. Is it within limitation under that Act's rules?
  4. Does it carry a DIN, and was it validly served?
  5. What is the deadline to respond, and the appeal window if it is an order?

Steps 3 to 5 are where replies are won or lost, and they are independent of the renumbering. For the substance of specific notices, see Section 143(1) intimation, Section 143(2) scrutiny and Section 142(1) inquiry.

For sections beyond the notice provisions, the full old-to-new mapping is the quick reference, and pending assessments and appeals after the repeal covers what happens to matters already in progress.

This is a working reference, not the statute. For anything you are filing or relying on, confirm the section text against the Act or the department's official 1961-vs-2025 comparison utility.

Frequently asked questions

My notice quotes Section 148, not Section 280. Is it invalid?

Almost certainly not. Reassessment for a year up to AY 2026-27 runs under the Income-tax Act, 1961, and the correct citation for it is Section 148. The 2025 Act's equivalent, Section 280, applies to tax year 2026-27 onwards. A notice carrying an old section number for an old year is right, not out of date — and the savings provision at Section 536 of the 2025 Act expressly preserves it.

Can the department still issue a fresh 1961-Act notice after April 2026?

Yes. This surprises people, but the repeal of the 1961 Act did not close the door on old years. A fresh notice under the old Act can still issue for a pre-2026 year, subject to that Act's own limitation periods. Section 536 preserves the power along with the proceedings. So the question to ask of a 1961-Act notice is never 'is this Act still alive' — it is 'is this notice within its own time limit'.

What is Section 143(1) called now?

Section 270(1) of the 2025 Act. The whole of assessment now sits in one section, so the sub-section is what tells you which proceeding you are in. Processing and the intimation are Section 270(1) to (7), with the nine-month outer limit at 270(4). The scrutiny notice — the old Section 143(2) — is Section 270(8), and the three-month limit on serving it is 270(9). The assessment order itself, the old Section 143(3), is Section 270(10).

Have the reassessment time limits changed?

Yes, and this is a substantive change rather than renumbering. Under the 2025 Act, Section 282 gives four years and three months for a Section 280 reassessment notice, extending to six years and three months where escaped income is ₹50 lakh or more, with a separate four-year and six-year pair for the Section 281 show-cause. Under the 1961 Act, as recast from 1 September 2024, the corresponding periods are three years and three months and five years and three months. Note that the ten-year outer limit many sources still quote was the 2021 scheme and no longer applies to notices under the recast provisions. Which set applies depends on the year and the date of the notice, so limitation has to be checked against the right version — using the wrong one is how a good objection gets missed.

Why does the portal ask me to pick between AY 2026-27 and TY 2026-27?

Because both exist at once during FY 2026-27. AY 2026-27 is the assessment year for FY 2025-26 income under the 1961 Act. Tax year 2026-27 is the first year of the 2025 Act. They run in parallel on the e-filing portal, and a payment tagged to the wrong one lands against the wrong demand. It is a common and irritating error to unwind.

How long do I have to appeal?

Thirty days to the Commissioner (Appeals) — Section 249 of the 1961 Act, now Section 358 — and sixty days to the Tribunal, Section 253, now Section 362. An appeal to the High Court is 120 days, Section 260A, now Section 365. These limitation periods are the first thing to check on any notice or order, because everything else becomes academic once they lapse.

Received a notice and unsure which Act it is under?

Send a photo or PDF of the notice on WhatsApp. Which Act governs it, whether it is within limitation, and what the reply needs to establish are set out before anything is filed. The first review is free.

Related service: Tax Notices & Assessments