Guidelines for issuance of notice u/s 148 of the Income Tax Act, 1961
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Section 148 notice guidelines require prior section 148A procedure, specified approval, and recorded reasons for income escapement.
Guidelines prescribe the procedure for issuance of notice under section 148 after the Finance Act, 2021 and Finance Act, 2022 amendments. They require the Assessing Officer, subject to specified exceptions, to proceed under section 148A on the basis of information suggesting escapement of income, issue a show-cause notice, consider the assessee's reply, and pass a speaking order with prior approval of the specified authority before notice is issued. The instructions also set out limitation rules under section 149, the categories where section 148A does not apply, and the model notices and approval proformas.