Chapter XVI - Procedure for Assessment
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.
On this page
Need advice on Section 282?
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) No notice under section 280 shall be issued for the relevant tax year,—
(a) if four years and three months have elapsed from the end of the relevant tax year, unless the case falls under clause (b);
(b) if four years and three months, but not more than six years and three months, have elapsed from the end of the relevant tax year, unless the Assessing Officer has in his possession books of account or other documents or evidence related to any asset or expenditure or transaction or entry which shows that the income chargeable to tax, which has escaped assessment, amounts to or is likely to amount to fifty lakh rupees or more.
(2) No notice to show cause under section 281 shall be issued for the relevant tax year,—
(a) if four years have elapsed from the end of the relevant tax year, unless the case falls under clause (b);
(b) if four years, but not more than six years, have elapsed from the end of the relevant tax year, unless the income chargeable to tax which has escaped assessment, as per the information with the Assessing Officer, amounts to or is likely to amount to fifty lakh rupees or more.
(3) No notice under section 280 or 281 shall be issued within one year from the end of any tax year.
Introduction
Section 282 sets separate outer time limits for a reassessment notice under section 280 and a preliminary show-cause notice under section 281.
The longer windows depend on the stated ₹50 lakh escaped-income condition; subsection (3) also bars either notice within one year from the end of a tax year.
Key takeaways
Separate notice clocks
The section sets distinct normal and extended limits for section 280 reassessment notices and section 281 show-cause notices.
One-year earliest point
A notice under either section cannot be issued within one year from the end of the relevant tax year.
Check the date and threshold
The longer window depends on the statutory monetary and evidence conditions, not merely on the Assessing Officer’s suspicion.
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.
Step-by-step flow for checking the time limit under Section 282
- 1
Which notice is being checked?
Section 282(1) governs a reassessment notice under Section 280. Section 282(2) governs a show-cause notice under Section 281. The two have different periods.
- 2
Has one year passed from the end of the relevant tax year?
Under Section 282(3), no notice under Section 280 or 281 can be issued within one year from the end of any tax year.
- No: The notice cannot be issued yet.
- Yes: Go to the next step.
- 3
Is the notice within the normal period?
Section 280 notice: up to four years and three months from the end of the relevant tax year. Section 281 show-cause notice: up to four years from the end of the relevant tax year.
- Yes: The Section 282 time limit is met. The other conditions of Sections 280 and 281 still apply.
- No: Go to the next step.
- 4
Is the notice within the extended period?
Section 280 notice: more than four years and three months but not more than six years and three months. Section 281 notice: more than four years but not more than six years.
- No, it is later than that: No notice can be issued under Section 282.
- Yes: Go to the next step.
- 5
Is the ₹50 lakh condition met?
For a Section 280 notice, the Assessing Officer must have books of account, other documents or evidence about an asset, expenditure, transaction or entry showing escaped income of, or likely to be, fifty lakh rupees or more. For a Section 281 notice, the escaped income as per the information with the Assessing Officer must be, or be likely to be, fifty lakh rupees or more. If the condition is not met, the notice is time-barred.
Practical checklist
Do
- Calculate the relevant dates from the end of the tax year for both the section 281 show-cause and section 280 notice.
- For a notice in the longer window, check the statutory escaped-income threshold and underlying evidence.
Avoid
- Apply one identical limitation period to both the show-cause notice and the reassessment notice.
Illustrative example
Worked example: working out the dates for tax year 2026-27
Hypothetical facts (illustration only, not a real taxpayer): A trading firm's tax year 2026-27 ended on 31 March 2027. The Assessing Officer is considering reopening that year in respect of an unexplained purchase entry of ₹35 lakh (assumed figure).
Earliest date
Under Section 282(3), no notice under Section 280 or 281 can be issued within one year from 31 March 2027, that is, up to 31 March 2028.
Normal window for the show-cause notice
Four years from 31 March 2027 ends on 31 March 2031 (Section 282(2)(a)).
Normal window for the Section 280 notice
Four years and three months from 31 March 2027 ends on 30 June 2031 (Section 282(1)(a)).
Extended window
The extended limits would run to 31 March 2033 (show-cause notice) and 30 June 2033 (Section 280 notice). They need escaped income of fifty lakh rupees or more. ₹35 lakh is below that, so the extended windows are not available on these facts.
Outcome
- On these facts, a show-cause notice is in time only up to 31 March 2031, and a Section 280 notice only up to 30 June 2031.
- A notice issued after those dates would be outside Section 282 unless the escaped income is, or is likely to be, ₹50 lakh or more and the evidence condition is met.
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.
Need help applying this provision to your situation?
Check whether your reassessment notice is within the time limitLast updated 9 October 2026