If you receive a Section 153C notice in India, preserve the complete notice package, check its DIN, issuing authority, assessment years and stated deadline, and establish the date of the search or requisition it refers to. That date matters: the Income Tax Department’s current Section 153C text says the section does not apply to searches initiated or requisitions made on or after 1 April 2021. The 2026 repeal-and-savings rules also matter for older proceedings. Because the correct statutory framework and any objection depend on the record, have an Indian tax professional review the notice promptly.
What a Section 153C notice means
Section 153C of the Income-tax Act, 1961 is headed “Assessment of income of any other person.” In broad terms, it concerns seized or requisitioned money, bullion, jewellery, another valuable article or thing, books, documents or information that an Assessing Officer is satisfied relates to someone other than the person referred to in Section 153A. The material is handed to the Assessing Officer with jurisdiction over that other person, who may proceed under the linked assessment framework if the statutory conditions are met.
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The notice should therefore be read alongside the material it identifies and the search or requisition to which it connects you. Receiving a notice with this section number does not, by itself, establish that the assessment is valid or that the section applies to the case.
Why the search or requisition date matters
The current Income Tax Department text says Section 153C does not apply in relation to searches initiated under Section 132 or requisitions made under Section 132A on or after 1 April 2021. The search or requisition date is therefore a key fact; do not infer the governing regime from the section number printed on a notice alone.
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How to read the assessment years
The statutory text describes coverage by reference to the six assessment years immediately preceding the assessment year relevant to the previous year of the search or requisition, and relevant assessment year or years under Section 153A. It also provides for the search-year assessment year in specified circumstances. Check the years in your notice against the text applicable to the actual search date and case history rather than assuming a standard set of years applies.
What to do first
- Save the whole notice package. Keep the notice PDF, every attachment, the envelope or email metadata, portal messages, and earlier notices or orders. Record when and how you received it.
- Identify the notice and the deadline. Note the taxpayer name and PAN, issuing authority, DIN, statutory provision, assessment year or years, requested information, response instructions and due date. Use the date stated for your proceeding; the available official material does not establish a universal Section 153C response period.
- Map the stated connection to the search. Note the search or requisition date, what seized or requisitioned material the notice says relates to you, and whether the notice explains a handover to your jurisdictional Assessing Officer. Compare those details with the applicable statutory text.
- Check your e-Filing account. Review the proceeding’s status and available response options promptly. The Department says e-Proceedings response availability can depend on the proceeding status and limitation date.
- Build an evidence file around the questions asked. Gather records relevant to the specific items in the notice—for example, ledgers, bank statements, contracts, invoices, correspondence or ownership records—and prepare a concise explanation for each. This is practical preparation, not a universal statutory document list.
- Arrange an individualized review. A chartered accountant or Indian tax lawyer experienced in search assessments can assess the statutory version, search-material connection, jurisdiction, assessment years, service, deadlines and possible objections against the complete record.
How to submit a response
Use the route shown for your proceeding
The Income Tax Department’s e-Proceedings guidance says registered users and authorized representatives can view notices and submit responses with attachments through the e-Filing portal. Its stated route is Dashboard / Pending action / E-Proceeding. Follow the notice and the instructions visible in the live proceeding.
The Department says you can view an e-Proceedings response after submission, but cannot edit or withdraw it. Review the response and attachments before filing, then save the submitted version and portal acknowledgment.
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Do not assume “Comply to Notice” applies
“Comply to Notice” is a separate limited pre-login facility. The Department describes it for specified ITBA documents, including notices not linked to a PAN or TAN and certain Section 133(6) notices. It requires the complete DIN. Its FAQ says a submitted response cannot be edited, although another response may be submitted before the proceeding is blocked or closed. Check the notice and portal instructions rather than assuming this facility is the correct route for a Section 153C notice.
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Attachment limits differ by route
| Route | Attachment limits stated in Department guidance | What to check |
|---|---|---|
| e-Proceedings | Up to 5 MB for one attachment, up to 10 attachments and 50 MB total for the response. | Confirm the limits and available upload fields on the live proceeding screen. |
| Comply to Notice | Up to 5 MB per file and up to 10 files. | Use this only if the notice and service instructions direct you to this facility; confirm the live screen before submitting. |
Deadlines and common filing mistakes
The Department’s general notice time-limit page, which describes the Income-tax Act, 1961 as amended by the Finance Act 2026, does not state a Section 153C response deadline. The e-Proceedings FAQ describes portal cutoffs linked to the proceeding’s limitation date and status. Rely on the due date in your notice and the status shown for your proceeding; do not substitute the 15-day period described for a defective-return notice under Section 139(9), which is a different type of notice.
- If the stated deadline is close or the portal does not offer a response option, contact the authority through the official channel promptly and seek professional advice.
- Before submitting, check that every response addresses the question asked and that each attachment is legible, complete and associated with the right assessment year.
- Keep a copy of the response, all attachments, the acknowledgment and any later correspondence.
How the 2026 Act transition affects older cases
The Income-tax Act, 2025, as amended by the Finance Act 2026, repeals the Income-tax Act, 1961 and includes savings for proceedings connected with certain earlier searches and requisitions. It states that where a Section 132 search was initiated, or a Section 132A requisition was made, before commencement, provisions of the repealed Act continue to apply to proceedings connected with that search or requisition.
For a notice received on or after 1 April 2026, the receipt date alone does not determine which provisions govern. Establish when the search or requisition occurred and how the current proceeding relates to it, then have the documents considered under the transition clause and applicable law. The 1 April 2021 exclusion in the current Section 153C text makes careful chronology especially important.
Questions to raise in a professional review
The notice and full assessment record determine whether a legal objection is available. Ask your adviser to assess the specific issues raised by the documents, including:
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- Which statutory version applies given the search or requisition date and the 2026 savings rule?
- What seized or requisitioned material is said to relate to you, and how is that connection described?
- Do the assessment years and notice chronology match the applicable statutory framework?
- Which records answer each request, and what is the actual deadline and available filing route?
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