Section 133(6) Notice – Information Call by Income Tax Authorities

A Section 133(6) notice under the Income-tax Act, 1961 is a formal statutory communication through which an Income Tax Authority calls upon any person — whether the assessee, a third party, a bank, a registrar, a broker, a tenant, a buyer, a seller, a contractor, a business associate, or any entity otherwise connected with a transaction — to furnish specified information or documents useful or relevant for the purposes of the Act. Unlike Section 143(2) scrutiny, which is addressed only to the taxpayer whose return is under examination, a Section 133(6) notice is a wide-ranging evidence-gathering tool — it can go to anyone the department believes holds facts material to a case, and it is increasingly the backbone of the Risk Management Strategy, the e-Verification Scheme, 2021, and the pre-notice data-building exercises that precede Section 148A(b) reassessment show-causes and Section 143(2) scrutiny selections. For a recipient, therefore, a Section 133(6) notice is far more than a routine document call — it is often the first visible signal that the department is building a case, and every word of the response gets recorded, analysed, and used.

The statutory power flows from Section 133 read with Section 133(6). Section 133(6) specifically authorises the Assessing Officer, Deputy Commissioner (Appeals), Joint Commissioner, Commissioner (Appeals), Commissioner, Principal Commissioner, Chief Commissioner, Principal Chief Commissioner, or any designated Prescribed Income-tax Authority / Director-General / Director under Rule 112D, to require any person — including banking companies, officers of the State / Central Government, insurance companies, mutual funds, co-operative societies, educational institutions, hospitals, and every other entity — to furnish specified information in such form as the authority may specify. The notice can be issued even in situations where no proceeding is pending against the addressee, provided the information is useful for or relevant to any inquiry or proceeding under the Act. Information commonly sought includes — copies of agreements, bank statements, purchase / sale deeds, rental income data, shareholding details, transaction particulars, confirmation of balances, details of third-party transactions, and records under Statement of Financial Transactions (SFT) obligations under Section 285BA.

Our Section 133(6) Notice Response Services cover the full response lifecycle — reviewing the notice to identify the authority, the nature of information sought, the underlying relevance, and the deadline; assessing whether the addressee is being asked about their own affairs (recipient as taxpayer) or as a third party (recipient as witness / custodian); building a complete, accurate, and carefully-worded response with supporting documentary evidence; verifying that the information we provide aligns with AIS / 26AS / our own ITR / books where applicable (to prevent creating unintended mismatches for ourselves or the counter-party); responding through the e-filing portal's Compliance / e-Verification module (where applicable) or by email / hard copy as directed; drafting adjournment requests where time is genuinely short; defending against Section 272A(2)(c) penalty (Rs. 500 per day) for failure to comply; managing follow-up queries, cross-verifications, and onward Section 143(2) / 148A(b) / 147 consequences; and — where the notice is jurisdictionally flawed, over-broad, or issued without specifying any connection to a proceeding — advising on limited compliance, privilege claims, and, in extreme cases, writ challenge before the High Court.

Section 133(6)
Information-call power
Taxpayer + Third Party
Wide addressability
e-Verification
Portal-driven today
Rs. 500 / Day
Sec 272A(2)(c) penalty
Provisions We Work Under
Sec 133 – General Power
Sec 133(6) – Info Call
Sec 133C – Verification
Sec 285BA – SFT
e-Verification Scheme, 2021
Rule 112D – Authority
Sec 272A(2)(c) – Penalty
Sec 148A(b) – Downstream SCN

Main Categories of Section 133(6) Notices

Taxpayer-Own

Notice on Own Transactions

Notice addressed to the taxpayer seeking information about their own transactions / income / assets.

  • Specific transaction details
  • Bank / DMAT data
  • Rental / sale data
  • Loan / gift inquiries
  • Own AIS / 26AS scrutiny
  • Pre-scrutiny build-up
Third-Party

Notice as Witness / Custodian

Notice calling the recipient to furnish information about another person's transactions with them.

  • Counter-party confirmation
  • Invoice / payment data
  • Commission / brokerage info
  • Rent / tenant confirmation
  • Transaction ledger
  • Neutral evidence supply
Institutional

Banks / MFs / Brokers / Registrars

Institutional Section 133(6) — bank statements, DMAT holdings, MF folios, property registrations.

  • Bank statement calls
  • DMAT / BO holdings
  • Mutual fund folios
  • Sub-registrar data
  • Credit card statements
  • Locker records
e-Verification

e-Verification Scheme 2021

133(6) notices under the e-Verification Scheme, 2021 for AIS / SFT / 26AS mismatch follow-up.

  • AIS feedback trail
  • SFT mismatch
  • Portal-only communication
  • Compliance module
  • Pre-148A build-up
  • Risk-management driven
Foreign-Asset

Foreign Asset / Income

Section 133(6) to gather data on foreign assets / income — Schedule FA validation, Black Money Act build-up.

  • Foreign bank data
  • ESOP / RSU vests
  • Overseas property
  • Schedule FA validation
  • BM Act, 2015 exposure
  • Sec 10(38) / 10A / 80HHC
Pre-Reassessment

Pre-Sec 148A Enquiry

133(6) as part of Section 148A(a) preliminary enquiry before reassessment — quiet data-building.

  • 148A(a) enquiry link
  • Risk analysis
  • Information gathering
  • Not yet SCN stage
  • Pre-148 signal
  • Escaped income build-up

Key Section 133(6) Concepts at a Glance

Power

Who Can Issue

AO, JCIT, CIT, PCIT, CCIT, PCCIT, and Prescribed Income-tax Authority under Rule 112D.

AO PCIT / CCIT
Addressee

Wide Addressability

Can be issued to any person — taxpayer, third party, bank, corporate, officer, or institution.

Anyone Connected
Relevance Test

"Useful / Relevant"

Information must be "useful for or relevant to" any proceeding / inquiry under the Act.

Useful Relevant
No Proceeding

Independent of Pending Case

Notice can issue even without any proceeding pending against the addressee (prescribed authority).

Pre-Case Gathering
Timeline

Response Period

Deadline stipulated in the notice — typically 7 to 30 days; adjournments generally granted on request.

7 – 30 Days Adjourn
Penalty

Sec 272A(2)(c)

Rs. 500 per day of failure to furnish information, leviable after Section 274 hearing.

Rs. 500 / Day Sec 274
Downstream

148A(b) / 143(2) Trigger

Response is evidence in any downstream Section 148A(b) SCN, Sec 143(2) scrutiny, or Sec 147 order.

Record Used Later
Writ

Article 226 Challenge

Egregiously over-broad / jurisdictionally flawed notices can be challenged by writ petition.

Art. 226 Exceptional

What Our Section 133(6) Response Engagement Covers

Diagnosis

Notice Review & Context

Decoding the notice, identifying the authority, assessing the underlying proceeding and downstream risk.

  • Authority check
  • Relevance test
  • Deadline & mode
  • Own vs third-party
  • AIS / 26AS mapping
  • Downstream risk view
Response

Information Preparation

Assembling accurate information from books / records, with supporting documentary evidence.

  • Data extraction
  • Ledger reconciliation
  • Bank / DMAT match
  • Document bundling
  • Consistency with ITR
  • Supporting annexures
Submission & Follow-up

Submission & Downstream

Portal / email / hard-copy submission and management of follow-up queries and downstream notices.

  • e-Filing portal upload
  • Compliance module
  • Email / hard copy
  • Acknowledgement retention
  • Follow-up query reply
  • Downstream preparation

Our Section 133(6) Notice Response Services

01

Own-Transaction Notice

Defence for notices seeking information on your own transactions — ITR / AIS / 26AS tie-out.

02

Third-Party Notice

Response as witness / custodian — accurate, neutral, non-incriminating information supply.

03

e-Verification Response

e-Verification Scheme, 2021 response via Compliance module on the e-filing portal with AIS feedback.

04

Institutional 133(6)

Banks / MFs / brokers / corporates — institutional-scale 133(6) responses with standardised data.

05

Foreign-Asset 133(6)

Response where foreign assets / ESOPs / RSUs / overseas accounts are queried — Schedule FA defence.

06

Pre-148A Enquiry Response

Strategic response where 133(6) appears to be pre-148A enquiry — prevention of reassessment opening.

07

Sec 272A(2)(c) Penalty Defence

Defence against Rs. 500/day non-compliance penalty — Sec 273B reasonable-cause pleas.

08

Writ Challenge (Art. 226)

High Court writ against egregiously over-broad / jurisdictionally flawed 133(6) notices.

When You Need Expert Section 133(6) Support

133(6) on Your Transactions

AO has sought information on your own bank / property / equity transactions — data tie-out needed.

As Third-Party Witness

Notice asks you to confirm transactions with another assessee — neutral reply critical.

e-Verification Notice

Portal Compliance module shows e-Verification Scheme notice — AIS feedback needs careful drafting.

Pre-148A Signals

Notice appears to be pre-reassessment enquiry — response may shape 148A(b) outcome.

Foreign-Asset Query

Foreign bank / brokerage / ESOP / RSU flagged — Schedule FA and BM Act exposure in play.

Institutional Notice

Bank / MF / broker / corporate receives 133(6) — high-volume data request requiring careful drafting.

Short Deadline

Response window is too short for accurate data gathering — adjournment petition needed.

Over-Broad Notice

Notice is omnibus / jurisdictionally vague — limited-compliance or writ strategy evaluation.

Information & Documents Needed

Notice & Authority

  • Copy of 133(6) notice
  • DIN & issue / service dates
  • Issuing authority & ward
  • Reference to proceeding
  • Related AIS / 26AS flag
  • Compliance module screenshot
  • Deadline & mode

Books & Transaction Data

  • Relevant ledgers
  • Bank statements
  • DMAT / BO statements
  • MF folio summary
  • Invoices / contracts
  • Property deeds
  • Loan / gift docs

Matching Data

  • Filed ITR & schedules
  • Form 26AS / AIS / TIS
  • Form 16 / 16A
  • Tax audit report (3CD)
  • Prior 133(6) responses
  • DSC / e-filing credentials
  • Authorisation / POA

Our End-to-End Sec 133(6) Response Approach

1

Notice Diagnosis

Decode the notice, check authority / relevance / deadline, and classify own vs third-party.

2

Data Extraction

Pull relevant transaction data from books, bank, DMAT, MF, and counter-party records.

3

Consistency Check

Ensure alignment with filed ITR / AIS / 26AS to prevent creating mismatches for self / counter-party.

4

Drafting & Submission

Draft a clear reply with annexures and submit through portal / email / hard copy with acknowledgement.

5

Follow-Up

Manage follow-up queries, downstream 148A(b) / 143(2) preparation, and penalty defence if needed.

Why Choose Us for Section 133(6) Response

Senior CA-led response
Advocate-backed strategy
e-Verification module expertise
Downstream-risk foresight
AIS / 26AS tie-out discipline
Foreign-asset expertise
Confidential engagement
Writ capability (Art. 226)

FAQs on Section 133(6) Notices

What is a Section 133(6) notice under the Income Tax Act?
A Section 133(6) notice is a formal communication issued by a specified Income Tax Authority under Section 133 of the Income-tax Act, 1961, calling upon a person to furnish information or documents that are "useful for or relevant to any inquiry or proceeding" under the Act. The power is wide — it can be exercised by the Assessing Officer, Joint Commissioner, Commissioner, Principal Commissioner, Chief Commissioner, Principal Chief Commissioner, as well as prescribed Income-tax Authorities designated under Rule 112D. The notice can be issued to any person — the taxpayer themselves, a third party, a bank, a registrar, a mutual fund, a broker, a corporate, a government officer, or any institution — and can seek a wide range of information including bank statements, transaction confirmations, agreements, property records, shareholding data, and similar material. Today, it is the backbone of the Risk Management Strategy and the e-Verification Scheme, 2021, and frequently precedes Section 148A(b) reassessment show-causes and Section 143(2) scrutiny selections.
Can a Section 133(6) notice be issued to a third party (not the taxpayer)?
Yes — this is one of the distinctive features of Section 133(6). Unlike a Section 143(2) scrutiny notice (which can only be issued to the assessee whose return is under examination), a Section 133(6) notice can be issued to any person — whether the taxpayer, a third party with counter-party transactions, or an institution / intermediary that holds records. The typical third-party recipients include banks (for bank statements of a taxpayer under examination), brokers and depositories (for DMAT / trading data), mutual funds (for folio records), sub-registrars and registrar authorities (for property-purchase data), companies (for shareholding, dividend, or ESOP records), tenants (for rent-paid confirmation), buyers / sellers (for transaction confirmation), and employers (for payroll / perquisite data). As a third-party recipient, the response needs to be accurate and neutral — supplying the factual information sought without volunteering extraneous material or creating inconsistencies with the recipient's own ITR / books.
Is Section 133(6) the same as the e-Verification Scheme, 2021?
Not quite the same, but closely related. Section 133(6) is the underlying statutory power to call for information. The e-Verification Scheme, 2021, notified by CBDT, is an operational framework that uses Section 133(6) (and the parallel Section 133C power relating to verification of information already in the department's possession) to process the large volume of AIS / SFT / Form 26AS flags and verify them directly with the taxpayer through the Compliance module on the e-filing portal. In practice, many 133(6) notices today arrive as automated e-Verification notices — the taxpayer is asked to confirm, dispute, or explain a specific transaction reflected in AIS (for example, an interest credit, a dividend receipt, or a property transaction) without a formal proceeding being opened. A carefully-worded response at the e-Verification stage can close the matter at source; a careless or contradictory response often leads to downstream Section 148A(b) reassessment or Section 143(2) scrutiny.
What is the time limit for responding to a Section 133(6) notice?
Section 133(6) itself does not prescribe a fixed statutory timeline — the response window is stipulated in the notice itself by the issuing authority, and is typically between 7 and 30 days. The exact period depends on the nature of information sought, the complexity, and the issuing authority's working timeline. Adjournment or extension requests, filed in writing with a reasoned basis (volume of data, travel / leave, dependence on third-party records, etc.), are generally granted by authorities on genuine requests — particularly where the taxpayer is not obstructing the enquiry. Failure to respond within the specified time, without a reasonable cause, exposes the recipient to penalty under Section 272A(2)(c) of the Income-tax Act, at Rs. 500 per day of default. The penalty, however, is leviable only after a Section 274 hearing, and Section 273B provides a "reasonable cause" defence that is frequently accepted in genuine cases.
What penalty can be levied for non-compliance with a Section 133(6) notice?
Under Section 272A(2)(c) of the Income-tax Act, failure to furnish information in response to a notice under Section 133 (including Section 133(6)) attracts a penalty of Rs. 500 for every day during which the failure continues. The penalty is levied only after a show-cause notice under Section 274 is issued and the recipient is given an opportunity of being heard. Under Section 273B, no penalty is imposable if the recipient shows "reasonable cause" for the failure — typical acceptable grounds include genuine non-receipt of notice, travel / medical / personal emergency, dependence on third-party records not in the recipient's direct possession, or excessive / unreasonably short notice period. In practice, where a bona-fide response is filed even after a delay, supported by an apology and a reasonable-cause explanation, the penalty is often dropped or drastically reduced. The bigger risk, however, is that non-response gets recorded and used in the downstream proceeding against the principal taxpayer — which is frequently a higher cost than the penalty itself.
Do I need to provide books of accounts in response to a Section 133(6) notice?
The scope of the information requirement is governed strictly by the wording of the specific Section 133(6) notice received. The recipient is obliged to furnish only the specific information / documents called for — not to make a general disclosure of their books of accounts or financial affairs. If the notice calls for "copies of ledger of XYZ for FY 2023-24" — that is the specific document to supply. If it calls for "bank statement of Account No. 12345 for FY 2022-23" — that alone is the scope. A recipient is not obliged (nor advised) to volunteer broader information beyond what is asked. That said, the supplied information should be complete, accurate, and consistent with the recipient's own ITR and AIS position — since any inconsistency between the Section 133(6) response and other records creates a red flag for the recipient's own future proceedings. Drafting the response is therefore a precision exercise — fully compliant with the call, but not over-compliant.
Can a Section 133(6) notice be challenged in a writ petition?
Yes, but only in exceptional circumstances. Courts have consistently held that Section 133(6) is a wide-ranging investigative power exercisable even without a pending proceeding, and generally should not be interfered with at the threshold. However, writ jurisdiction under Article 226 of the Constitution has been invoked successfully in cases where — (i) the notice is issued by an authority not empowered under Section 133 read with Rule 112D; (ii) the notice is wholly without any nexus to any "inquiry or proceeding" under the Act — i.e., a fishing or roving expedition; (iii) the notice is vague, omnibus, or calls for information clearly beyond the purview of the Act; (iv) the notice violates statutory protections (for example, calling for privileged communication without due process); (v) the notice suffers from patent mala fides. Writ is a discretionary remedy — courts would usually expect the recipient to first engage with limited compliance or seek a structured clarification from the authority before approaching the Court.
What are common mistakes people make while responding to Section 133(6) notices?
The most recurring mistakes we see are — (i) ignoring the notice as "it is not scrutiny" — failing to realise that the response goes on record and shapes downstream Section 148A(b) / 143(2) proceedings; (ii) over-disclosing — volunteering information well beyond the scope of the specific call and inadvertently opening up further queries; (iii) inconsistency — filing responses that do not align with the recipient's own ITR / AIS / books, creating future mismatches; (iv) missing the deadline without filing an adjournment, attracting Section 272A(2)(c) exposure; (v) responding without reviewing the relevance / authority of the notice — in some cases, the notice is issued without jurisdiction and a limited-compliance strategy may be available; (vi) as a third-party recipient, creating exposure for a counter-party by careless wording; (vii) not retaining the acknowledgement of submission — making it difficult to rebut allegations of non-response later; and (viii) attempting to handle complex 133(6) notices (foreign asset, pre-148A, high-value SFT flags) without professional advice. Each of these can be prevented with disciplined, advised response management.

Every 133(6) Is a Signal. Respond With Precision.

Partner with our CAs and advocates for end-to-end Section 133(6) Notice Response Services — own and third-party responses, e-Verification, pre-148A strategy, and penalty defence — all under one roof.

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