Section 133C - Power to Call for Information by Prescribed Income-tax Authority
Case Laws & Commentary - Income-tax Act, 1961 (as amended by the Finance Act, 2026) - bharattax.co Treatise
Provision: Section 133C - the prescribed income-tax authority may, for the purpose of verifying information in its possession, issue notice to any person requiring furnishing of information/documents in the prescribed manner; sub-section (2) permits processing/utilisation of the response and uploading of the outcome (FA 2016).
Chapter / Part: Chapter XIII, Part C - Powers.
Inserted: By the Finance (No. 2) Act, 2014, with effect from 1 October 2014; sub-section (2) inserted by the Finance Act, 2016.
FA 2026 status: Not amended by the Finance Act, 2026.
Nature: Recent, technology-driven verification power supporting centralised/automated data-matching. No direct case law (candour rule).
A. SECTION COMMENTARY
A verification and data-matching power
Section 133C, introduced in 2014 and augmented in 2016, equips the prescribed income-tax authority with a power to issue notices, for the limited purpose of verifying information already in the Department's possession, requiring a person to furnish information or documents in the prescribed manner. Sub-section (2) authorises the prescribed authority to process the information so obtained - including by way of automated data-matching against returns and third-party reports - and to make the outcome available to the Assessing Officer. The provision is part of the Department's move towards centralised, technology-enabled compliance verification (the Centralised Communication Scheme), under which notices may be issued and responses processed without the personal interface of a jurisdictional officer.
Character and safeguards
Section 133C is a verification power, not an assessment or adjudication power: it enables the Department to confront a discrepancy in the data it holds and to seek the person's explanation, but the consequences of the verification (assessment, reassessment, penalty) flow through the substantive provisions, with their own safeguards. There is, as yet, no reported decision construing section 133C; this is stated candidly. The natural-justice standards that the courts have insisted on for the cognate faceless/centralised machinery (an effective opportunity to respond, a reasoned consideration of the response) supply the nearest governing principles.
B. STATUTORY POSITION (verbatim text)
Reproduced below is section 133C as it stands in the bare Act.
133C. (1) The prescribed income-tax authority may, for the purposes of verification of information in its possession relating to any person, issue a notice to such person requiring him, on or before a date to be specified therein, to furnish information or documents verified in the manner specified therein, which may be useful for, or relevant to, any inquiry or proceeding under this Act.
(2) Where any information or document has been received in response to a notice issued under sub-section
(1), the prescribed income-tax authority may process and utilise such information and document in accordance with the scheme notified under sub-section (3) or the provisions of section 135A.
(3) The Board may make a scheme for centralised issuance of notice and for processing of information or documents and making available the outcome of the processing to the Assessing Officer.
(4) The scheme made under sub-section (3) shall cease to have effect from the date on which the scheme notified under section 135A in respect of this section comes into effect.
Explanation.—In this section, the term "proceeding" shall have the meaning assigned to it in clause (b) of the Explanation to section 133A.
Note: Section 133C has not been directly construed in any reported decision. The cognate authorities are those on the fairness standards governing centralised/faceless communication and verification.
C. AUTHORITIES
Cluster 1 - Verification machinery must afford an effective opportunity (cognate)
There being no direct authority, the controlling fairness standards are drawn from the faceless/centralised-procedure jurisprudence.
Sanjay Aggarwal v. National Faceless Assessment Centre (2021) 436 ITR 180 (Del)
Forum / Citation: Delhi High Court, 2 June 2021. Reported: (2021) 436 ITR 180 (Del); (2021) 203 DTR 73; (2021) 321 CTR 145; (2021) 281 Taxman 282.
Held: A centralised/faceless process that affects the assessee must afford an effective opportunity to respond and to be heard; denial of that opportunity vitiates the resulting action.
Principle: Verification and data-matching processes feeding into assessment must observe natural justice.
Relevance: Supplies the fairness benchmark for the section 133C verification process.
Compiled for the bharattax.co Treatise on the Income-tax Act, 1961 (as amended by the Finance Act, 2026). Statutory text reproduced verbatim from the bare Act (Chapter XIII, ss. 116-138). Each authority is cited with its full parallel reporter citations as reported; Supreme Court, High Court and Income Tax Appellate Tribunal (ITAT) rulings are identified as such. Where a section has not been directly construed, that is stated candidly and the nearest governing authority is given. For professional reference; not legal advice.
CHAPTER XIII - INCOME-TAX AUTHORITIES
Section 133C - Power to Call for Information by Prescribed Income-tax Authority
Case Laws & Commentary - Income-tax Act, 1961 (as amended by the Finance Act, 2026) - bharattax.co Treatise
Provision: Section 133C - the prescribed income-tax authority may, for the purpose of verifying information in its possession, issue notice to any person requiring furnishing of information/documents in the prescribed manner; sub-section (2) permits processing/utilisation of the response and uploading of the outcome (FA 2016).
Chapter / Part: Chapter XIII, Part C - Powers.
Inserted: By the Finance (No. 2) Act, 2014, with effect from 1 October 2014; sub-section (2) inserted by the Finance Act, 2016.
FA 2026 status: Not amended by the Finance Act, 2026.
Nature: Recent, technology-driven verification power supporting centralised/automated data-matching. No direct case law (candour rule).
A. SECTION COMMENTARY
A verification and data-matching power
Section 133C, introduced in 2014 and augmented in 2016, equips the prescribed income-tax authority with a power to issue notices, for the limited purpose of verifying information already in the Department's possession, requiring a person to furnish information or documents in the prescribed manner. Sub-section (2) authorises the prescribed authority to process the information so obtained - including by way of automated data-matching against returns and third-party reports - and to make the outcome available to the Assessing Officer. The provision is part of the Department's move towards centralised, technology-enabled compliance verification (the Centralised Communication Scheme), under which notices may be issued and responses processed without the personal interface of a jurisdictional officer.
Character and safeguards
Section 133C is a verification power, not an assessment or adjudication power: it enables the Department to confront a discrepancy in the data it holds and to seek the person's explanation, but the consequences of the verification (assessment, reassessment, penalty) flow through the substantive provisions, with their own safeguards. There is, as yet, no reported decision construing section 133C; this is stated candidly. The natural-justice standards that the courts have insisted on for the cognate faceless/centralised machinery (an effective opportunity to respond, a reasoned consideration of the response) supply the nearest governing principles.
B. STATUTORY POSITION (verbatim text)
Reproduced below is section 133C as it stands in the bare Act.
133C. (1) The prescribed income-tax authority may, for the purposes of verification of information in its possession relating to any person, issue a notice to such person requiring him, on or before a date to be specified therein, to furnish information or documents verified in the manner specified therein, which may be useful for, or relevant to, any inquiry or proceeding under this Act.
(2) Where any information or document has been received in response to a notice issued under sub-section
(1), the prescribed income-tax authority may process and utilise such information and document in accordance with the scheme notified under sub-section (3) or the provisions of section 135A.
(3) The Board may make a scheme for centralised issuance of notice and for processing of information or documents and making available the outcome of the processing to the Assessing Officer.
(4) The scheme made under sub-section (3) shall cease to have effect from the date on which the scheme notified under section 135A in respect of this section comes into effect.
Explanation.—In this section, the term "proceeding" shall have the meaning assigned to it in clause (b) of the Explanation to section 133A.
Note: Section 133C has not been directly construed in any reported decision. The cognate authorities are those on the fairness standards governing centralised/faceless communication and verification.
C. AUTHORITIES
Cluster 1 - Verification machinery must afford an effective opportunity (cognate)
There being no direct authority, the controlling fairness standards are drawn from the faceless/centralised-procedure jurisprudence.
Sanjay Aggarwal v. National Faceless Assessment Centre (2021) 436 ITR 180 (Del)
Forum / Citation: Delhi High Court, 2 June 2021. Reported: (2021) 436 ITR 180 (Del); (2021) 203 DTR 73; (2021) 321 CTR 145; (2021) 281 Taxman 282.
Held: A centralised/faceless process that affects the assessee must afford an effective opportunity to respond and to be heard; denial of that opportunity vitiates the resulting action.
Principle: Verification and data-matching processes feeding into assessment must observe natural justice.
Relevance: Supplies the fairness benchmark for the section 133C verification process.
Compiled for the bharattax.co Treatise on the Income-tax Act, 1961 (as amended by the Finance Act, 2026). Statutory text reproduced verbatim from the bare Act (Chapter XIII, ss. 116-138). Each authority is cited with its full parallel reporter citations as reported; Supreme Court, High Court and Income Tax Appellate Tribunal (ITAT) rulings are identified as such. Where a section has not been directly construed, that is stated candidly and the nearest governing authority is given. For professional reference; not legal advice.