Section 281
Section 281: procedure before issuance of notice under Section 280
Section 281 builds in a hearing before reopening: before issuing a notice under Section 280, the Assessing Officer must first serve a show-cause notice explaining why a Section 280 notice should not be issued, give the assessee a chance to reply, and then pass a reasoned order (with the specified authority's approval) on whether to proceed.
This explanation is AI-assisted and pending review by our CA/CS team. It is general information, not professional advice - always cross-check against the bare law text above or talk to our tax team for guidance specific to your situation.
The show-cause notice
Where the Assessing Officer has information suggesting income has escaped assessment for the relevant tax year, he must, before issuing a notice under section 280, give the assessee an opportunity of being heard by serving a notice to show cause as to why the section 280 notice should not be issued.
This show-cause notice must be accompanied by the information suggesting escaped income, and the assessee may furnish a reply within the period specified in the notice.
The Assessing Officer's decision
Based on the material on record and the assessee's reply (if any), the Assessing Officer must pass an order, with the prior approval of the specified authority, deciding whether or not it is a fit case to issue a notice under section 280.
When this show-cause step does not apply
This section does not apply where the Assessing Officer has received information under the scheme notified under section 260, directions from the Approving Panel under section 274(6), or a finding/direction in an appellate, revision or other-law court order - in these cases a notice under section 280 can be issued directly.
Frequently asked questions
Do I get a hearing before a reassessment notice is issued against me?
Yes, in most cases. Section 281 requires the Assessing Officer to serve a show-cause notice, along with the information suggesting escaped income, and consider your reply before deciding whether to issue a formal notice under section 280.
When can the Assessing Officer skip the show-cause step?
Under Section 281(4), the show-cause step is skipped where the Assessing Officer already has information under the section 260 scheme, directions from the Approving Panel under section 274(6), or a finding/direction contained in an appellate, revision or court order.
Related sections
Want this applied to your actual filing, not just explained?
Get help replying to a Section 281 show-cause noticeLast updated 9 September 2026