Reply to notice under section 148A(1) of the Income-tax Act, 1961 · AY 2021-22
To,
The Income Tax Officer, Ward 21(3)(1), Mumbai
From: Rajan Mehra, proprietor, Mehra Traders · PAN •••••4821Q
Subject: Reply to show cause notice dated 12/09/2025 under section 148A(1) for AY 2021-22
Reference: DIN ITBA/AST/F/148A/2025-26/•••
Respected Sir,
1. The assessee refers to the notice above and replies to each point in the order the notice raises them.
A. The notice is beyond the time allowed
2. Under section 149(1)(a), no notice under section 148 can issue for AY 2021-22 after three years and three months from the end of the assessment year, that is, after 30/06/2025. The longer period applies only where the income alleged to have escaped is ₹50 lakh or more. The amount alleged here is ₹18,40,000.
3. The show cause notice is dated 12/09/2025. No valid notice under section 148 can follow (see Union of India v. Rajeev Bansal, Supreme Court, 03/10/2024, on the time limits in section 149). The proceedings may be dropped on this ground alone.
B. Cash deposits of ₹12,60,000
4. Without prejudice to ground A, the deposits are the day's cash sales of Mehra Traders. They are recorded in the cash book and included in the turnover returned for the year. Copies of the cash book are enclosed.
C. Interest of ₹5,80,000
5. The return offers interest of ₹4,12,500, which agrees with Form 26AS and the TDS of ₹41,250. The balance of ₹1,67,500 is interest on a fixed deposit held jointly, [CA to confirm: name of the joint holder and the return in which it is offered].
D. Documents enclosed
6. Cash book for FY 2020-21; savings bank statement for FY 2020-21; computation of income for AY 2021-22.
Prayer
7. The assessee requests that the proceedings be dropped as barred by limitation under section 149(1)(a); without prejudice, that the explanation on merits be accepted; and that a personal hearing be granted before any order is passed under section 148A.
Yours faithfully,
For Rajan Mehra
[CA name, membership number, UDIN]