Chapter XVI - Procedure for Assessment
Section 279
Section 279: income escaping assessment
Section 279 is the reopening/reassessment provision of the Income-tax Act, 2025. Where income chargeable to tax has escaped assessment for a tax year (called the "relevant tax year" in Sections 280 to 286), it lets the Assessing Officer assess or reassess that income, or recompute a loss, depreciation allowance or other deduction - always subject to the safeguards laid out in Sections 280 to 286.
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This article is for general information. Refer to the Income-tax Act, 2025 as amended by the Finance Act, 2026 and the Taxation and Other Laws (Amendment) Act, 2026 for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
(1) If, in the case of an assessee, any income chargeable to tax has escaped assessment for any tax year (herein and in sections 280 to 286 referred to as the relevant tax year), the Assessing Officer may, subject to the provisions of sections 280 to 286, assess or reassess such income or recompute the loss or the depreciation allowance or any other allowance or deduction for the relevant tax year.
(2) For the purposes of assessment or reassessment or recomputation under sub-section (1), the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, irrespective of the fact that the provisions of section 281 have not been complied with.
(3) The “Assessing Officer” for the purposes of sections 280 and 281 shall mean to be an Assessing Officer other than the National Faceless Assessment Centre or any assessment unit referred to in section 273(3).
Introduction
Section 279 gives the power to assess or reassess income that escaped assessment, subject to the procedural notice and limitation safeguards in nearby sections.
The reassessment may cover other escaped income that comes to the officer’s notice during the proceeding, within the statutory scope.
Key takeaways
Escaped income can be assessed
Subject to sections 280–286, the Assessing Officer may assess or reassess income chargeable to tax that escaped assessment.
Other issues may surface
During a valid proceeding, the officer can address another escaped-income issue that comes to notice, as the section permits.
Procedure still controls
The power operates with the notice, approval and time-limit safeguards in the adjoining provisions.
The core power to reassess
If any income chargeable to tax has escaped assessment for any tax year in the case of an assessee, the Assessing Officer may, subject to sections 280 to 286, assess or reassess such income, or recompute the loss, depreciation allowance or any other allowance or deduction, for that tax year.
Sections 280 to 286 refer to that tax year as the "relevant tax year".
Assessing issues that surface during the proceedings
While making the assessment, reassessment or recomputation, the Assessing Officer may also assess or reassess income on any other issue that has escaped assessment and comes to his notice during the course of these proceedings - even if the procedure in section 281 (show-cause before issuing notice) has not separately been followed for that issue.
Which Assessing Officer applies
For the purposes of sections 280 and 281, the "Assessing Officer" means an Assessing Officer other than the National Faceless Assessment Centre or any assessment unit referred to in section 273(3).
Step-by-step flow for reassessment under Section 279
- 1
Has any income chargeable to tax escaped assessment for a tax year?
That year is the "relevant tax year" for sections 279 to 286.
- No: Section 279 gives no power to reassess.
- Yes: Go to the next step.
- 2
Follow sections 280 to 286
The power in Section 279(1) is subject to those sections. For sections 280 and 281, the AO is one other than the National Faceless Assessment Centre or an assessment unit referred to in section 273(3) (Section 279(3)).
- 3
What can the AO do?
Assess or reassess the escaped income, or recompute the loss, depreciation allowance or any other allowance or deduction for the relevant tax year (Section 279(1)).
- 4
Did another escaped issue come to notice during the proceedings?
Under Section 279(2), the AO may assess or reassess it as well, even though section 281 was not complied with for that issue.
Practical checklist
Do
- Identify the tax year, original assessment position and information cited for reopening.
- Track the show-cause, notice and assessment stages separately.
Avoid
- Assume a notice alone proves escaped income has been finally assessed.
Illustrative example
Worked example: reopening for one item and finding another
Hypothetical facts (illustration only, not a real taxpayer): For tax year 2026-27, the AO has information that a capital gain of ₹15 lakh earned by Mr. Verma was not offered to tax. He follows section 281 and issues a notice under section 280. During the proceedings he finds that interest of ₹2 lakh was also not offered. Amounts are assumed for illustration.
Escaped income
The ₹15 lakh capital gain is income chargeable to tax that has escaped assessment for the relevant tax year 2026-27 (Section 279(1)).
Who issues the notice
The notice and the section 281 procedure are handled by an AO other than the National Faceless Assessment Centre or an assessment unit (Section 279(3)).
New issue
The ₹2 lakh interest came to notice during the proceedings, so it may be assessed too, even though section 281 was not followed for it (Section 279(2)).
Amount reassessed
Escaped income assessed = ₹15 lakh + ₹2 lakh = ₹17 lakh, subject to the time limits and procedure in sections 280 to 286.
Outcome
- Both items can be brought to tax in the same reassessment.
- Section 279 gives the power; the notice, procedure and time limits come from sections 280 to 286.
Frequently asked questions
What does "income escaping assessment" mean?
It refers to income chargeable to tax that was not assessed for a tax year. Section 279 lets the Assessing Officer assess or reassess such income, or recompute a loss, depreciation allowance or deduction for that year, subject to the procedure in sections 280 to 286.
Can the Assessing Officer add a new issue discovered during reassessment proceedings?
Yes - under Section 279(2), if a further issue of escaped income comes to the Assessing Officer's notice during the reassessment proceedings, he may assess or reassess that issue too, even without separately following the show-cause procedure in section 281 for it.
Need help applying this provision to your situation?
Get help responding to an income-escaping-assessment noticeLast updated 9 October 2026