Section 153A: Assessment in Case of Search or Requisition
Section 153A prescribed a special assessment procedure where a search was initiated under Section 132 or assets, books or documents were requisitioned under Section 132A. It remains important for legacy proceedings, but does not govern searches initiated after 31 March 2021.
What does Section 153A mean?
Section 153A provided an overriding mechanism for assessing or reassessing income following a search or requisition. For qualifying searches, it operated notwithstanding Sections 139, 147, 148, 149, 151 and 153. Its operation must be read together with Sections 153B (time limits), 153C (income or assets relating to another person) and 153D (approval).
Section 153A(1): Notice and assessment procedure
The Assessing Officer was required to issue a notice calling for returns for each of the six assessment years immediately preceding the assessment year relevant to the previous year of search or requisition, and for additional relevant assessment years where the statutory conditions were met. The return was to be furnished in the prescribed form and manner and treated, so far as applicable, like a return under Section 139.
The Assessing Officer was then to assess or reassess total income separately for each applicable assessment year. The special procedure was not an automatic authorisation to extend every search to ten years; the additional-year conditions were separate.
When could the search assessment extend beyond six years?
For qualifying searches or requisitions initiated on or after 1 April 2017, the law permitted coverage of additional relevant assessment years beyond six and up to ten years, where the Assessing Officer possessed books, documents or evidence showing escaped income represented in the form of an asset of at least Rs. 50 lakh in the relevant year or in aggregate across the relevant years, and the other statutory conditions were satisfied.
For this purpose, the statutory explanation included immovable property, shares and securities, loans and advances, and bank deposits within the meaning of asset.
| Situation | Broad legal treatment |
|---|---|
| Search between 1 June 2003 and 31 March 2021 | Section 153A legacy search assessment, subject to applicable amendments and limitation rules. |
| Additional years beyond six | Up to ten years only when the specific asset-linked Rs. 50 lakh conditions and date requirements are met. |
| Search from 1 April 2021 to 31 August 2024 | Reassessment provisions under Sections 147 to 151, as preserved by Section 152(3). |
| Search from 1 September 2024 | Special block assessment under Chapter XIV-B of the 1961 Act, subject to the subsequent 2025 Act transition. |
Pending assessments: Abatement and revival
Abatement under the second proviso
Assessments or reassessments pending for covered assessment years on the date of search or requisition generally abated, allowing those years to be considered in the search assessment process. An assessment already completed is different from a pending assessment; judicial decisions may limit additions for completed or unabated years in the absence of incriminating material.
Section 153A(2): Revival after annulment
If proceedings initiated or orders made under Section 153A(1) were annulled in appeal or other legal proceedings, an assessment or reassessment that had abated could revive from receipt of the annulment order by the Principal Commissioner or Commissioner. Revival ceased if the annulment order was subsequently set aside.
Explanations to Section 153A
Except where the special provisions of Sections 153A, 153B and 153C provided otherwise, other provisions of the Income-tax Act continued to apply. Tax for an assessment year was chargeable at the rates applicable to that year.
What changed after 2021 and September 2024?
The Finance Act, 2021 ended the use of Section 153A for searches or requisitions initiated from 1 April 2021. The Finance (No. 2) Act, 2024 then introduced a new Chapter XIV-B regime for searches or requisitions initiated on or after 1 September 2024. Section 158BA governs assessment of undisclosed income for the block period, while Section 158BC addresses procedure and Section 158BE deals with time limits.
Under the Income-tax Act, 2025, which took effect on 1 April 2026, search assessments are addressed in the corresponding block assessment provisions, including Sections 294 to 296. The applicable law in a particular case depends on the search date, tax year, amendments, and savings or transitional rules; the section numbers are not interchangeable.
Practical points for taxpayers
- Identify the date on which the search was initiated or requisition made before choosing the governing assessment regime.
- Check the assessment years covered by the notice and whether any additional years satisfy the statutory threshold.
- Determine whether the original proceedings were pending or already concluded on the search date.
- Verify limitation periods, required approvals and any exclusions before assessing validity of a notice or order.
- Keep copies of the search authorisation, panchnama, notices, returns, evidence and assessment orders.
Official legislation and guidance
Read the official Section 153A text, the transitional rules under Section 152, the block assessment provisions in Section 158BA, the Section 158BC procedure, and the Income-tax Act, 2025 (official PDF).
Legislative history: Section 153A was inserted by the Finance Act, 2003, subsequently amended by the Finance Acts of 2008, 2012 and 2017, and restricted to searches up to 31 March 2021 by the Finance Act, 2021. This article explains the framework rather than reproducing every historical amendment verbatim. Updated: 26 October 2026.