Instruction Instruction 1/2022 — Procedure for 148A enquiry before reopening
Date: 2022-05-11 Status: ACTIVE Category: Reassessment / Reopening Binding on Department: Yes (Section 119 / Section 400 IT Act 2025)
Summary
Detailed procedural guidelines for conducting preliminary enquiry under section 148A before issuing reassessment notice. Mandatory for all reopenings beyond 3 years.
Key Directions
- Prior approval of specified authority mandatory before issuing 148A notice.
- AO must provide information/material to assessee and consider reply.
- Order deciding whether to issue 148 notice must be passed with PCIT/CIT approval.
- Entire 148A process to be conducted through faceless mechanism.
Applicability Under IT Act 2025
Saving Clause: Section 536 of IT Act 2025 saves circulars issued under the 1961 Act “so far as not inconsistent” with the new Act.
| Old Section (1961 Act) | New Section (2025 Act) | Consistent? |
|---|---|---|
| 148A | 283 | Yes |
Cross-References
Act Sections
Related Circulars
- None identified
Key Case Law (Circular Supremacy)
- To be populated — cases where this circular was cited/applied
Full Text
Full text to be added — see raw/circulars/ for PDF when available
Source
- Official: incometaxindia.gov.in/circulars