In plain words: since 2021, searches are assessed under the reassessment framework rather than the old block-assessment sections. Here is how the new route works.
The shift to reassessment
For searches on or after 1 April 2021, the old 153A/153C route was replaced. Search findings are now treated within the Section 147/148 reassessment machinery — with special treatment for search-linked cases.
Search as 'deemed information'
Material found in a search (or requisition) is deemed to be 'information' suggesting income has escaped assessment — the trigger for reassessment.
The extended look-back
For search cases, the law allows reopening for a longer period than ordinary cases — reaching back up to around ten years where large escaped income represented by assets is involved. (The exact outer limits have been revised by recent Finance Acts, so check the current position.)
The procedure
- Issue of a Section 148 notice (with the applicable pre-notice process).
- Sanction of the specified authority.
- An opportunity to file a return and respond.
- A reassessment order determining escaped income.
What defences survive
- Challenging the validity of the search and 'information'.
- Contesting time limits and sanction.
- Rebutting presumptions and additions on merits.
The takeaway
Search assessment is now part of reassessment — so the Section 148/148A defences (covered separately) become central.
Frequently asked questions
Are searches still assessed under 153A? Not for searches on/after 1 April 2021 — they fall under the Section 148 framework.
How far back can a search case reopen? Longer than ordinary cases — up to around ten years for large escaped income; check current limits.
What triggers it? Search material is deemed 'information' of escaped income.
How Vakil Help Desk helps
Vakil Help Desk advises on income-tax searches and surveys, Section 148/148A reassessment notices, search assessments, penalty and prosecution — and represents clients before the tax authorities, CIT(A), the ITAT and the High Courts. If you are facing a raid, a notice or a reassessment, we can help you respond correctly.
This article is for general legal awareness, not individual legal advice. Income-tax search, seizure and reassessment law, the time limits and the procedure are revised by the Finance Acts and clarified by the courts from time to time, and the right step depends on your facts and the current position. Please consult a professional before responding to a search, notice or reassessment.