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Notices & Litigation

You bought property in India and now must explain where the money came from (148A(b))

A notice asks you to show the source of the funds you used to buy a flat in India, and you're worried it turns into a full reopening of your old years.

You are an NRI who bought property in India — say an ₹80 lakh flat — and the department has sent a show-cause notice under Section 148A(b) asking you to explain the source of that investment before it decides whether to reopen the year. The notice flags the purchase, often picked up from the registrar's reporting, and gives you a window to reply. A clear, documented reply at this stage can close the matter; a weak or missed one lets the department move to a full Section 148 reassessment.
Last reviewed: 10 June 20269 min readReviewed by Preetesh Maloo, CA

The short answer

Section 148A(b) is a show-cause stage that comes before any reassessment. The department has information suggesting income may have escaped assessment — here, a high-value property purchase — and it must give you a chance to explain before it can issue a Section 148 notice and reopen the year. You reply within the window stated on the notice, setting out where the funds came from: inward remittance from abroad, your NRE or NRO account, sale proceeds, a loan. If your reply shows the source is explained and taxed (or not taxable), the officer can drop the matter at the 148A(d) stage without opening a full reassessment.

References on this page

  • Section 148A(b) (show-cause before reassessment — your chance to explain)
  • Section 148A(d) (the officer's order on whether to reopen, after your reply)
  • Section 148 (the reassessment notice itself, issued only if the matter proceeds)
  • Section 69 / Section 69A (unexplained investment — what an unanswered source risks)

What this show-cause is — and what it is not (Section 148A(b))

Section 148A(b) is a show-cause. It is the step the department must take before it can reopen a past year for reassessment. The notice tells you it holds information suggesting income chargeable to tax may have escaped assessment — in a property case, that information is usually the registrar's report of a high-value purchase — and it asks you to explain why the year should not be reopened.

The key point is the sequence. A 148A(b) notice is not yet a reassessment. It is the opportunity to head one off. After your reply, the officer passes an order under Section 148A(d) deciding whether there is a fit case to reopen. Only if that order goes against you does a Section 148 notice follow and the year actually reopens.

That is why this stage matters so much. A high-value purchase looks suspicious only until the source is shown. For most NRIs the money came from abroad through perfectly clean channels, and the entire concern dissolves once that is documented properly. The reassessment process we cover at our Section 148 response page is the heavier road this notice is meant to avoid.

Why the property purchase triggered it

The department receives reporting on high-value transactions, and registered property purchases above a threshold flow into the system against your PAN. When a return for that year shows modest or no Indian income, the purchase stands out and a 148A(b) notice is generated, often without anyone first checking that the buyer is an NRI funding it from overseas earnings.

For a non-resident, the explanation is usually straightforward — the issue is documenting it cleanly, not the substance.

Source of the fundsWhat proves it
Salary / earnings abroad, remitted inInward remittance advice; NRE account credits
Indian income already taxedNRO account history; the relevant return
Sale of another assetThe sale deed and the gain already reported

The distinction between an NRE and an NRO account often does a lot of the work. Money in an NRE account is, by definition, foreign earnings brought into India and is not Indian-source income, so a purchase funded from NRE balances is explained largely by the account's own history. NRO funds need a little more — showing that the income behind them was reported. Either way, the reply turns an unexplained number into a traceable one.

The reply window, and treating it as the real defence

The notice gives you a period to respond — read the exact date and the number of days off your own notice, because the window stated on it governs and it can be short. An extension can sometimes be requested through the portal, but the safe assumption is that the stated window is what you have.

This reply is not a formality. It is the stage where the case is most easily won, because the officer has not yet committed to a position. A complete reply — a covering explanation, the bank and remittance records, the sale or loan papers, tied to the specific purchase the notice names — gives the officer a clean basis to drop the matter under Section 148A(d).

A reply that is late, partial, or argues without documents pushes the case the other way. If the source isn't shown, the investment can be treated as unexplained (Section 69 / 69A) and the year reopened. The work, then, is to make the reply so complete that reopening has no foundation. Where the matter is already at or past the reassessment stage, or an officer is involved and you need formal representation, that is handled through our tax representation service rather than this page.

A worked example — Faisal's ₹80 lakh flat

Faisal, an NRI working in Dubai, bought an ₹80 lakh flat in Pune. Two years later a 148A(b) notice arrived asking him to explain the source of the investment, since his Indian return for that year showed only a little NRO interest. On paper, an ₹80 lakh purchase against near-nil reported income looks exactly like escaped income.

In fact the funding was clean. About ₹60 lakh came from his Dubai salary, remitted into his NRE account over the prior two years; ₹15 lakh came from an NRE fixed deposit he broke; and ₹5 lakh came from his father as a gift, by bank transfer. None of it was untaxed Indian income.

The reply set this out transaction by transaction — NRE account statements showing the inward remittances, the FD closure, and the gift transfer with a short gift declaration — mapped against the dates and amounts in the sale deed. With the source fully traced, the officer passed an order under Section 148A(d) holding it was not a fit case to reopen, and no Section 148 notice followed. The figures are illustrative; the lesson is that the source was documented before the department formed a view, not after.

What's involved

What the CA actually does

  1. 1

    We map the purchase to its funding, transaction by transaction

    We take the sale deed and trace every rupee of the consideration back to its source — inward remittance, NRE or NRO balances, a sale, a loan, a gift — so the reply accounts for the whole purchase, not just part of it.

  2. 2

    We assemble the source-of-funds proof an officer will accept

    We pull the bank statements, remittance advices, FD closures and any gift or loan papers, and present them as a clean trail tied to the dates and amounts the notice flags — the difference between an explanation that is asserted and one that is evidenced.

  3. 3

    We draft and file the 148A(b) reply within the window

    We prepare the reasoned reply and file it on the portal against your notice inside the stated period, framing the source so the officer has a clean basis to drop the matter at the 148A(d) stage.

  4. 4

    We stay on it if it proceeds toward reassessment

    If the matter moves past 148A and an officer engages, we carry it onto formal representation — replying to the reassessment and putting the same documented source on record — so you are not left to face a 148 alone.

What to have ready

Documents you'll typically need

  • The 148A(b) show-cause notice (PDF and the email it arrived with)
  • The registered sale deed / agreement for the property
  • NRE and NRO account statements covering the funding period
  • Inward remittance advices (FIRC / bank remittance confirmations)
  • Fixed deposit closure statements, where an FD was used
  • Gift or loan documents, where part of the funds came from family
  • The income tax return for the year the notice relates to

Your destination country can change the details

Requirements differ from one consulate, university and visa route to the next — how recent the figures must be, how long funds must have been held, and which certificates are mandatory. We assemble the documents around the exact checklist you're applying under. To see how India's tax treaty with your country of residence affects related filings, set your country below or compare all 31 countries.

Frequently asked questions

Common questions

Got a 148A(b) notice on an Indian property purchase?

Send us the notice and your sale deed. A practising CA will map the source of funds and tell you on a free call how to reply within the window — no obligation.

No card, no obligation. All certification and filing work is handled by ICAI-registered practising Chartered Accountants.