Rule 151 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Rule 151 of the Income-tax Rules, 2026 puts a section 248 requisition into Form No. 86, requires a written requisition with copies to the person concerned, and imports the rule 148 packaging and custody machinery.
The authorisation under rule 151
Sub-rule (1): the authorisation under section 248(1) by the Director General or Director or the Chief Commissioner or Commissioner shall be made in Form No. 86, shall be in writing under the signature of the officer issuing it, and shall bear his seal. The 1962 parallel is rule 112D.
The formal requirements are identical to those in rule 148(3) for a search authorisation — writing, signature and seal — which is what makes the two instruments equivalent in the eyes of the machinery that follows.
The requisition itself
Sub-rule (2): the officer authorised to make a requisition — the requisitioning officer — makes it in writing to the officer or authority referred to in section 248(1)(a), (b) or (c) — the delivering officer or authority — calling upon him to deliver:
- the books of account or other documents;
- assets; or
- the computer system containing information,
as specified in the requisition. It shall be accompanied by a copy of the Form No. 86 authorisation, and a copy of the requisition, along with a copy of the authorisation, shall be forwarded to the person referred to in section 248(1)(a), (b) or (c).
Rule 151 runs between the requisitioning officer and the delivering officer or authority — typically another agency already holding the material. But the sub-rule expressly requires copies of both the requisition and the authorisation to go to the person whose books, assets or computer system are being requisitioned. He is not a bystander to the process, and he receives the same documents the delivering authority does.
What rule 151 requires of the delivering officer
| Clause | Step |
|---|---|
| (a) | Prepare a list of the books of account or other documents, assets or computer system containing information delivered |
| (b) | Before effecting delivery, place everything except money and the books of account and documents in physical form in listed packages |
| (c) | Every package bears an identification mark and seal of the requisitioning officer or of any other income-tax authority not below the rank of Income-tax Officer on his behalf, and also of the delivering officer or authority |
| (d) | The person concerned, or any other person on his behalf, shall also be permitted to place his seal or signature on the packages |
| (e) | A copy of the list is delivered to that person, and a copy is also forwarded by the delivering officer to the approving authority |
Where rule 148 requires the authorised officer's seal and permits the occupant's, clause (c) of rule 151 requires the seal of the requisitioning officer (or an officer not below Income-tax Officer rank acting for him) and that of the delivering officer or authority — with the person's own seal or signature permitted on top. The extra seal exists because the material passes between two authorities, and the chain of custody has to be attested at the handover.
Note that the exclusion in clause (b) is the same as rule 148(17): money, and books of account and documents in physical form, stay outside the sealed-package regime.
The machinery rule 151 imports
Sub-rule (4): the provisions of sub-rules (19) to (22) of rule 148 and rule 152 shall, so far as may be, apply — as if the things delivered to the requisitioning officer under section 248 had been seized under section 247(1) by the requisitioning officer from the custody of the person referred to in section 248(1)(a), (b) or (c) — and those provisions are read as if for the words "the authorised officer" the words "the requisitioning officer" were substituted.
| Imported provision | Effect on a requisition |
|---|---|
| Rule 148(19) | Material and money may be conveyed to a Custodian not below Income-tax Officer rank |
| Rule 148(20) | Safe custody, strong room or hired bank lockers operated jointly by two nominated officers, money to a Personal Deposit Account |
| Rule 148(21) | A sealed package is reopened on notice, before two respectable witnesses, and resealed or delivered |
| Rule 148(22) | The Assessing Officer to whom material is handed over gets the same powers |
| Rule 152 | Surplus assets are released forthwith to the person from whose custody they came, before two respectable witnesses |
The deeming in sub-rule (4) does more than save drafting. Because the requisitioned material is treated as seized from the person's own custody, that person acquires the full set of downstream protections — notice before a package is reopened, the right to be present, the right to see it resealed, and the right to have surplus assets released forthwith before witnesses. Without the deeming, none of those would attach to material that was delivered by a third agency rather than taken from him.
Worked example
| Facts | Position under rule 151 |
|---|---|
| Commissioner authorises a requisition | Form No. 86, signed and sealed |
| Requisition sent to the holding authority | In writing, with a copy of the authorisation |
| Copies to the taxpayer | Both the requisition and the authorisation |
| Server containing accounting data requisitioned | A computer system containing information is expressly covered |
| Physical ledgers delivered | Not packaged — same exclusion as rule 148(17) |
| Gold bars delivered | Packaged, sealed by both officers; the person may add his seal |
| Package later reopened | Notice to the person, two witnesses, resealing — rule 148(21) as applied |
| Assets remaining after liabilities are met | Released forthwith under rule 152 as applied |
Compliance checklist
- Check the authorisation is in Form No. 86, signed and sealed by a competent authority.
- Confirm the requisition was made in writing with the authorisation attached.
- As the person concerned, check you received both copies.
- Obtain the list of what was delivered.
- Check the packages carry both official seals, and add your own seal or signature.
- Verify a copy of the list went to the approving authority.
- Expect notice before any package is reopened, and attend.
- Claim release of surplus assets under rule 152 as applied.
Common mistakes
- Overlooking the copy that must reach the person concerned.
- Accepting a single seal on the packages.
- Not exercising the right to add a seal or signature.
- Assuming the rule 148 safeguards do not apply to a requisition.
- Treating a computer system as outside the requisition power.