The New Framework for Reassessment Notices, Balancing Revenue Powers and Taxpayer Rights : Clause 281 of Income Tax Bill, 2025 Vs. Section 148A of the Income-tax Act, 1961

Pre-notice hearing requirement: show cause with disclosed information, supervisory approval required before reassessment notices.

Clause 281 requires that where the AO has information suggesting income has escaped assessment, the AO must serve a show cause notice accompanied by that information, allow the assessee to reply within the period specified, and, after considering the record and any reply, obtain prior approval of the specified authority before passing an order on whether to issue a notice under section 280. The clause omits explicit timelines, does not define the specified authority within the clause, and provides broader exceptions to the pre-notice requirement.