The section names the specified authority for the purposes of sections 280 and 281 as the Additional Commissioner, the Additional Director, the Joint Commissioner or the Joint Director. It is a single sentence doing nothing else: it fixes the rank whose sanction those two sections require, and creates no procedure, condition or time limit of its own.
Why it is there
Sections 280 and 281 make the issue of a notice conditional on the approval of a "specified authority"; this section supplies the identity of that authority so the requirement is workable.
Who it applies to
The Additional Commissioner
The Additional Director
The Joint Commissioner
The Joint Director
An assessee served with a notice under section 280 or 281
What this means in practice
For a taxpayer the value of the section is as a check: a notice under section 280 or 281 must carry the sanction of one of the four named ranks, and sanction by anyone else does not satisfy those sections. The section says nothing about when or how the sanction is to be recorded — those conditions are in sections 280 and 281 themselves.
An example
Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.
A notice under section 281 is issued after the approval of a Joint Commissioner has been obtained: the sanction is by one of the four ranks this section names, so the specified-authority requirement in section 281 is answered. Approval taken from a Deputy Commissioner, or from the Income-tax Officer handling the case, would not do, because section 284 names the Additional Commissioner, Additional Director, Joint Commissioner and Joint Director in the alternative and no one else. When or how that approval must be recorded is not decided here — those conditions sit in sections 280 and 281.
Where you meet this section
On the face of a notice under section 280 or 281, and in the record produced with it: the sanction of the specified authority. Checking which rank gave that approval is the practical use the section has for a taxpayer; it creates no proceeding of its own.
The words themselves
The specified authority for the purposes of sections 280 and 281 shall be the Additional Commissioner or the Additional Director or the Joint Commissioner or the Joint Director.
Section section 284, Income-tax Act, 2025.
What people get wrong
Expecting the sanction requirement itself to be in this section. Section 284 only identifies the authority; the requirement, and any conditions attached, are in sections 280 and 281.
Reading the four ranks as a hierarchy. The section names them in the alternative, so any one of them is the specified authority.
Applying the definition beyond sections 280 and 281 — the section is expressly limited to those purposes.
What this replaced
The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.
148A - Procedure before issuance of notice under section 148
Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 284. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.
CIT v S. Goyanka Lime & Chemical LtdSupreme CourtHelps taxpayertagged s.151 Is 'Yes, I am satisfied' enough for the sanctioning authority to write?
Chhugamal Rajpal v S.P. ChalihaSupreme CourtHelps taxpayertagged s.151 The sanctioning authority just wrote 'yes' and signed. Is that a sanction?
ITO v Lakhmani Mewal DasSupreme CourtHelps taxpayertagged s.151 How strong does the officer's material have to be before he can reopen?
ITO v Tej Partap SinghSupreme CourtCuts both waystagged s.148A The High Court quashed my s.148 notice because the ward officer issued it instead of the faceless unit. Does that judgment still stand?
Union of India v Ashish AgarwalSupreme CourtHelps departmenttagged s.148A What happened to the thousands of s.148 notices issued under the old rules after the law changed in 2021?
Union of India v Rajeev BansalSupreme CourtCuts both waystagged s.148A Your notice was issued in the 1 April to 30 June 2021 window. Was it saved by tola, or is it dead?
Ankit Agarwal v PCCITHigh CourtHelps taxpayertagged s.148A My 148A notice says I never filed a return, but I did. Is that enough to get it quashed?
Biswajit Deb v Union of IndiaHigh CourtHelps taxpayertagged s.151 The recorded reasons admit the AO had no time to verify my transactions. Is the reopening valid?
Champa Impex P Ltd v Union of IndiaHigh CourtHelps departmenttagged s.148A The AO made no enquiry before issuing my 148A(b) notice. Does that kill the reopening?
Charu Chains & Jewels (P) Ltd v ACITHigh CourtCuts both waystagged s.148A The s.148A(b) notice refers to information the officer never showed you. Can you insist on seeing it?
Chotanagpur Diocesan Trust v Union of IndiaHigh CourtHelps taxpayertagged s.148A My 148A(b) notice describes an enquiry but nothing was attached. Can I insist on the material?
Dr Mathew Cherian v ACITHigh CourtHelps taxpayertagged s.148A I'm a consultant doctor at a hospital. Can the AO reopen and tax my fees as salary?
Hexaware Technologies Ltd v ACITHigh CourtHelps taxpayertagged s.148A Your s.148 notice came from your own local officer, not from the faceless unit. Does that matter?
Meet Lalwani v ITOHigh CourtHelps taxpayertagged s.148A I filed the death certificate and they still issued the 148 notice in my mother's name. Is it valid?
PCIT v Meenakshi Overseas Pvt LtdHigh CourtHelps taxpayertagged s.151(1) The reasons recorded just repeat what the Investigation Wing said. Is that enough to reopen?
Parmesh Chand Yadav v ITOHigh CourtHelps departmenttagged s.148A The AO has issued a s.148A notice on crypto exchange data showing Rs 4.65 crore of transactions. I have given my bank statements and my return — is…
Rahul Sachan v ITOHigh CourtHelps departmenttagged s.148A The s.148A(d) order does not answer my objections at all. Is that enough on its own to get the reassessment notice quashed?
Sanjay Kumar Bijay Kumar v PCITHigh CourtHelps taxpayertagged s.148A The same cash deposits were already reassessed and accepted at nil. Can they reopen them again?
Sapphire Foods India Ltd v ACITHigh CourtHelps taxpayertagged s.148A(b) The officer has reopened my scrutiny assessment because the audit party disagreed with what he allowed. Is that a fresh look or a change of opinion?
Sevensea Vincom P Ltd v PCITHigh CourtHelps taxpayertagged s.148A They reopened AY 2016-17 in 2022 for under Rs 50 lakh. Is the notice time-barred?
Siemens Financial Services Pvt Ltd v DCITHigh CourtHelps taxpayertagged s.148A Beyond three years, who has to approve the reopening — and what if the wrong officer signed?
Sonansh Creations P Ltd v ACITHigh CourtHelps taxpayertagged s.148A The officer says I took accommodation entries and I say I received nothing. Must he have material that the entries exist before he reopens?
Susai Amalanathan Antoni Vincent v ITOHigh CourtHelps departmenttagged s.148A Can I get a s.148A order set aside on the ground that the 'information' did not come through the Risk Management Strategy?
T.K.S. Builders P Ltd v ITOHigh CourtHelps departmenttagged s.148A Can the jurisdictional AO issue my s.148 notice, or must reassessment go through the faceless route?
Diach Chemicals and Pigments P Ltd v DCITITATHelps taxpayertagged s.148A The department says my purchases are bogus. Do the suppliers' returns and the input credit allowed on those invoices count for anything in the…
e-Verification Instruction 2(i) of 2024CBDTCuts both waystagged s.148A A compliance campaign message arrived and nothing was done about it. What does the department do next, and does an updated return filed late in the…
Change of opiniontagged s.148A The same papers were before the officer last time — can he reopen and take a different view now?
How crypto is taxed in Indiatagged s.148A How is crypto taxed in India — what rate, what TDS, what do I report, and what happens when the department writes to me?
What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.