Section 282
Section 282: time limit for notices under Sections 280 and 281
Section 282 puts an outer time limit on reopening a case. It uses a two-tier structure: a shorter general limit, and a longer limit that only applies when the escaped income is large - and, separately, a minimum one-year cooling-off period before any such notice can be issued at all.
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.
Time limit for a Section 280 notice
No notice under section 280 can be issued for the relevant tax year if four years and three months have elapsed from the end of that tax year, unless the case falls in the extended-limit category below.
If four years and three months, but not more than six years and three months, have elapsed, a notice can still be issued only if the Assessing Officer has in his possession books of account, other documents or evidence relating to an asset, expenditure, transaction or entry showing that the escaped income amounts to, or is likely to amount to, fifty lakh rupees or more.
| Time elapsed since end of relevant tax year | When a Section 280 notice can still be issued |
|---|---|
| Up to 4 years 3 months | Can be issued (subject to sections 280 and 281 conditions) |
| More than 4 years 3 months, up to 6 years 3 months | Only if escaped income is, or is likely to be, ₹50,00,000 or more, based on books/documents/evidence in the Assessing Officer's possession |
| More than 6 years 3 months | Cannot be issued |
Time limit for a Section 281 show-cause notice
No show-cause notice under section 281 can be issued if four years have elapsed from the end of the relevant tax year, unless the extended-limit category applies.
If four years, but not more than six years, have elapsed, the show-cause notice can still be issued only if the escaped income, as per the Assessing Officer's information, amounts to, or is likely to amount to, fifty lakh rupees or more.
Minimum cooling-off period
No notice under section 280 or 281 can be issued within one year from the end of any tax year.
Frequently asked questions
How far back can a reassessment notice go under the Income-tax Act, 2025?
Ordinarily up to four years and three months from the end of the relevant tax year for a Section 280 notice. This extends to six years and three months only if the escaped income is, or is likely to be, ₹50,00,000 or more, based on books, documents or evidence in the Assessing Officer's possession.
Does the same ₹50 lakh threshold apply to the Section 281 show-cause notice?
Yes - the same monetary yardstick (income escaping assessment of ₹50,00,000 or more) extends the time limit for issuing a Section 281 show-cause notice from four years to six years from the end of the relevant tax year.
Is there a minimum waiting period before a reassessment notice can be issued?
Yes - Section 282(3) bars issuing a notice under section 280 or 281 within one year from the end of any tax year.
Related sections
Want this applied to your actual filing, not just explained?
Check whether your reassessment notice is within the time limitLast updated 9 September 2026