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If you receive a Section 153C notice, preserve the complete notice package, identify its deadline and assessment years, and check the search or requisition date and the material said to relate to you. The Income Tax Department’s current Section 153C text excludes searches initiated or requisitions made on or after 1 April 2021, while the Income-tax Act, 2025 contains savings for proceedings connected with searches or requisitions made before its commencement. The dates and documents determine which rules may apply, so arrange a prompt review by an Indian tax professional rather than assuming the section number settles the issue.
What a Section 153C notice concerns
Section 153C of the Income-tax Act, 1961 is headed “Assessment of income of any other person.” In the circumstances described by the Income Tax Department, it concerns money, bullion, jewellery, another valuable article or thing, books, documents, or information seized or requisitioned in connection with another person, where the Assessing Officer is satisfied that the material 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 applicable assessment framework if its statutory conditions are met.
The current Department text says Section 153C does not apply to searches initiated under Section 132 or requisitions made under Section 132A on or after 1 April 2021. A notice bearing this section number therefore needs to be assessed against the date of the underlying search or requisition and the law applicable to the proceeding—not just its heading.
The section describes assessment-year 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 the notice against the version of the law applicable to the actual search date and procedural history.
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What to check first in the notice
Make a working copy of the notice and attachments, then record the following before preparing a substantive response:
- Identity and authority: the taxpayer name and PAN, issuing Assessing Officer or other authority, and Document Identification Number (DIN).
- Scope: the statutory provision cited, each assessment year, each question or document requested, and any material the notice says connects you to the search or requisition.
- Chronology: the notice date, date and method of receipt, response due date, search or requisition date, and relevant earlier notices or orders.
- Instructions: the specified response channel, file requirements, and any portal status or limitation date shown for the proceeding.
Save the original PDF, attachments, envelope or email metadata, portal messages, and earlier related correspondence. These help establish what was served and when.
How to prepare a careful response
- Preserve the record. Keep an untouched copy of the notice package and make a separate working folder for the response and supporting documents.
- Map each request to evidence. For every question, identify the records that address it, such as relevant ledgers, bank statements, contracts, invoices, correspondence, or ownership records. Organize files by question and prepare a concise explanation of what each document shows. This is a practical way to prepare, not a universal statutory checklist.
- Check the search connection and years. Establish the search or requisition date and identify what material is alleged to relate to you. Compare the years and procedural chronology in the notice with the applicable statutory text.
- Get individualized advice promptly. A chartered accountant or Indian tax lawyer experienced in search assessments can review the statutory version, material connection, jurisdiction, service, assessment years, deadline, and any potential objections. The notice and complete record are needed to assess a particular case.
- Review before filing. Confirm that the response addresses each request, that attachments are legible and correctly identified, and that no unrelated or unsupported material has been included.
Where to submit a reply
Use the route specified in the notice and displayed for the proceeding. The Income Tax Department’s e-Proceedings FAQ says registered users or authorized representatives can view notices and submit responses with attachments through the e-Filing portal. Its listed navigation is Dashboard / Pending action / E-Proceeding. The FAQ says a response can be viewed after submission but cannot be edited or withdrawn, so retain the submitted response and acknowledgment.
The separate Comply to Notice service is a limited pre-login facility. The Department’s FAQ describes it for specified ITBA documents, including notices not linked to a PAN/TAN and certain Section 133(6) notices. It requires the complete DIN. The FAQ says a submitted response cannot be edited, although another response may be made before the proceeding is blocked or closed. Do not assume this facility is appropriate for every Section 153C notice; follow the instructions for your specific notice and portal proceeding.
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| Route | What the Department describes | Practical check |
|---|---|---|
| e-Proceedings | Registered users or authorized representatives can view notices and submit responses with attachments through the e-Filing portal; the FAQ gives the path Dashboard / Pending action / E-Proceeding. | Use the proceeding’s displayed instructions and status. The FAQ says a submitted response cannot be edited or withdrawn. |
| Comply to Notice | A limited pre-login facility for specified ITBA documents, including notices not linked to a PAN/TAN and certain Section 133(6) notices; it requires the complete DIN. | Check that the facility and notice instructions apply to your case. The FAQ says a submitted response cannot be edited. |
How to handle the deadline and attachments
Use the due date in your notice and check the live status of the proceeding. The Department’s general notice time-limit overview, which describes the Income-tax Act, 1961 as amended by Finance Act 2026, does not specify a universal response period for Section 153C. The e-Proceedings FAQ says response availability can depend on proceeding status and the limitation date. Do not substitute the 15-day period mentioned for a defective-return notice under Section 139(9); that is a different type of notice.
If the due date is near, or the portal does not offer a response option, promptly contact the authority through the official channel shown for the proceeding and seek professional advice. Keep a record of the contact and any response.
The current e-Proceedings FAQ lists up to 10 attachments, a maximum of 5 MB per attachment, and 50 MB total for a response. The separate Comply to Notice FAQ lists a 5 MB per-file limit and up to 10 files. Because portal limits can change, confirm the live screen before filing. Save a copy of the final response, attachments, and portal acknowledgment or other proof of submission.
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The official Income-tax Act, 2025 text, as amended by Finance Act 2026, repeals the 1961 Act and includes savings. It says 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.
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For a notice received on or after 1 April 2026, the section number alone does not establish which provisions govern. The key chronology includes the search or requisition date, the relationship of the current proceeding to it, and the transition rule. Have those records reviewed against the applicable legislation and relevant current case law.
Questions to take to a tax professional
Bring the complete notice package, related portal messages, earlier notices or orders, and records relevant to the request. To make the review focused, ask about:
Quick Recap
- Which statutory version and transition provisions apply given the search or requisition date?
- What seized or requisitioned material is said to relate to you, and what does the record show about the statutory connection and handover to your Assessing Officer?
- Do the assessment years and notice chronology match the applicable provisions and case history?
- What evidence answers each request, and what should the response explain?
- What deadline and submission route apply in the notice and the live portal proceeding?
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