Section 153A concerns the person searched; Section 153C concerns another person linked to material seized in that search. The distinction matters, but so does the search or requisition date: the Income-tax Act, 1961’s Sections 153A and 153C are part of a historical assessment framework, not the route for every later search case.
What is the difference between Sections 153A and 153C?
| Point of comparison | Section 153A | Section 153C |
|---|---|---|
| Person assessed | The person searched under Section 132, or whose books, documents or assets were requisitioned under Section 132A. | A person other than the person covered by Section 153A, if the statutory connection between that person and seized material is established. |
| What triggers the proceeding | A search or requisition involving that person. | Seized material connected to another person is identified and handed to the Assessing Officer with jurisdiction over that person; the statutory conditions must also be met. |
| Assessment procedure | Provides the search-case procedure for issuing notice and making an assessment. | Directs the officer, when its conditions are satisfied, to assess the other person in the manner provided in Section 153A. |
| Assessment-year scope | Sets out the years covered by the historical search-assessment scheme, subject to the section’s wording and qualifications. | Links the years under consideration to the Section 153A framework, subject to the applicable statutory conditions and exceptions. |
| Search-date scope | Applies to searches or requisitions within the historical period specified in the section: after 31 May 2003 and on or before 31 March 2021. | Section 153C(3) excludes searches initiated, and requisitions made, on or after 1 April 2021. |
In short, Section 153A is the searched-person route in this framework. Section 153C extends a related assessment process to a different person only where the seized material meets the statutory connection test.
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When can seized material connect another person to a Section 153C assessment?
Section 153C identifies two broad forms of connection: seized money, bullion, jewellery or another valuable article or thing “belongs to” the other person; or seized books or documents pertain to that person, or information contained in them relates to that person. The material must also bear on determining that person’s total income.
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The provision therefore does not make a third party assessable merely because their name appears in seized material. The nature of the material, its connection to the person, and its relevance to determining that person’s income matter. Section 153C also provides for the material to be handed over to the Assessing Officer who has jurisdiction over the other person.
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How do assessment years and procedure work?
Section 153C adopts the manner of assessment provided in Section 153A; it is not a wholly separate assessment procedure. Its assessment-year span is tied to the Section 153A scheme. The statutory formulation refers to six assessment years immediately preceding the relevant assessment year, along with relevant assessment year or years, subject to the Act’s qualifications and exceptions.
That span is not a guarantee that every year in it will automatically be assessed or reopened. The applicable statutory version, the relevant dates and the conditions for proceeding determine what years are in issue in a particular case.
What changed for searches after the historical 153A/153C framework?
For later searches, the other-person undisclosed-income route identified in official materials is Section 158BD, which proceeds under Section 158BC. The Finance Act, 2025 substituted Section 158BD with effect from 1 September 2024. The Income Tax Department also provides materials on the Income-tax Act, 2025 and transition rules, so the governing Act and transitional provisions should be checked for the facts and dates involved.
Do not assume that Sections 153A and 153C govern every search case simply because the question concerns a searched person and another person. The applicable route depends first on the search or requisition date and the law governing that case.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Why is there no single limitation deadline for every Section 153C case?
Historical completion periods under Section 153B vary with the financial year in which the last search authorization was executed. Section 153B does not apply to searches or requisitions within the later regime described above, and its treatment of an “other person” includes specific timing rules. A reliable deadline calculation therefore requires the search and handover dates, the applicable statutory version, and any relevant exclusions, extensions or transition provisions.
This comparison explains the statutory framework, not whether a particular notice or assessment is valid. That conclusion depends on the notice, seized material, procedural history and governing law.
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