Rule 225 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 225 is the long procedure for recovering tax once a Tax Recovery Officer has drawn up a certificate. Sub-rules (75) to (83), which carried the headings on arrest and detention of a defaulter, are no longer part of it: Notification 120/2026 omitted them with effect from 1 April 2026. This article explains exactly what that notification did and what rule 225 still provides.
This article is written as per the Income-tax Rules, 2026 (G.S.R. 198(E), notified on 20 March 2026), read with the amending notifications issued up to 22 September 2026. Later notifications should be checked before you act.
Rule 225 is headed "Procedure for recovery of tax for the purposes of sections 413 and 475". Sub-rules (75), (76), (77), (78), (79), (80), (81), (82), (83) and (91) were omitted by the Income-tax (Fourth Amendment) Rules, 2026 (G.S.R. 822(E), 17 September 2026), and rules 2 to 4 of that notification are deemed to have come into force on 1 April 2026. The same notification also omitted clause (c) of sub-rule (4) and made three smaller changes in sub-rules (19), (56) and (87). The rest of rule 225 on notice, attachment, sale, receivers, appeals and review continues.
What notification 120/2026 does to rule 225
The notification is made under section 533 of the Income-tax Act, 2025, read with sections 262, 273, 413, 514 and 515. Rule 4 of the notification deals with rule 225 and makes five changes:
- In sub-rule (4), clause (c) is omitted.
- In sub-rule (19), the words "or to arrest" are replaced by the word "of".
- In sub-rule (56), the reference "sub-rule 53(iv).S" is replaced by "sub-rule 53(d)".
- Sub-rules (75), (76), (77), (78), (79), (80), (81), (82), (83) and (91) are omitted.
- In sub-rule (87), the brackets and words "(except arrest and detention)" are omitted.
Rule 1 of the notification fixes the dates: rules 2 to 4 of the notification are deemed to have come into force on the 1st day of April, 2026, while rules 5 to 8 (which deal with rules 246 and 256 and Forms 169 and 171) come into force on publication in the Official Gazette. Because the rule 225 changes are in rule 4, they are the deemed 1 April 2026 group.
If a recovery certificate is already running against you, our legal dispute resolution support can help you read it against the text as it now stands. Our guide to the Tax Recovery Officer's powers in rule 226 shows how the next rule connects with this one.
The omitted sub-rules, by heading
The Rules as notified in March 2026 printed these sub-rules under the following headings. After the notification they are omitted, and this article says nothing more about how they worked.
| Sub-rule | Heading as notified | Position now |
|---|---|---|
| (75) | Notice to show cause | Omitted |
| (76) | Hearing | Omitted |
| (77) | Custody pending hearing | Omitted |
| (78) | Order of detention | Omitted |
| (79) | Detention in and release from prison | Omitted |
| (80) | Release | Omitted |
| (81) | Release on ground of illness | Omitted |
| (82) | Entry into dwelling house | Omitted |
| (83) | Prohibition against arrest of women or minors, etc. | Omitted |
| (91) | Subsistence allowance | Omitted |
The notification omits these sub-rules; it does not renumber the ones around them. The text consulted therefore leaves sub-rules (74) and (84) side by side, and the later numbers (84) onwards stay as they were.
What changed elsewhere in rule 225
| Provision | As notified in March 2026 | After 120/2026 |
|---|---|---|
| Sub-rule (4), clause (c) | One of the modes of recovery was "by arrest of the defaulter and his detention in prison" | Clause (c) omitted. The modes that remain are (a) attachment and sale of movable property, (b) attachment and sale of immovable property and (d) appointing a receiver; clause (d) keeps its letter |
| Sub-rule (19) | Officer authorised to attach or sell any property "or to arrest" the defaulter | The words "or to arrest" are replaced by "of", so the sub-rule speaks of attaching or selling property of the defaulter |
| Sub-rule (56) | Reserve price "specified under sub-rule (53)(iv).S" | Reference now reads "sub-rule 53(d)" |
| Sub-rule (87) | Proceedings against the legal representative "(except arrest and detention)" | Bracketed words omitted; the proceedings in the rule may be continued against the legal representative of a defaulter who dies |
| Sub-rules (75) to (83) and (91) | Printed in the rule | Omitted |
What rule 225 still provides, in outline
For the detail, read our separate posts on each part. In outline, the rule as it stands has these blocks:
- Definitions and notice (sub-rules (1) and (2)). "Certificate", "defaulter", "execution", "movable property", "officer" and "share in a corporation" are defined. The Tax Recovery Officer serves a notice requiring payment of the amount in the certificate within fifteen days from service.
- When the certificate can be executed (sub-rule (3)) and the modes of recovery (sub-rule (4)). No step in execution is taken until fifteen days have passed from service, subject to the exceptions in the sub-rule. After that, recovery is by the modes listed in sub-rule (4) as now amended.
- Interest, costs, title and bars (sub-rules (5) to (12)). These cover interest and charges, the purchaser's title, the bar on suits, disposal of proceeds, the bar on civil courts except for fraud, exempt property, claims and objections, and removal of attachment.
- Attachment and sale of movable property (sub-rules (13) to (47)). Our posts on attachment of movable property and sale of attached movable property take these sub-rules in turn.
- Immovable property (sub-rules (48) to (70)). Attachment, proclamation, auction, confirmation, sale certificate and the time limit for sale are explained in our posts on auction of immovable property and on limitation and setting aside a sale.
- Receivers (sub-rules (71) to (74)). Appointment of a receiver for a business or for immovable property, the receiver's powers and withdrawal of management.
- General provisions (sub-rules (84) to (90) and (92) to (95)). Officers deemed to act judicially, powers to take evidence, continuance of the certificate on the defaulter's death, appeals (to be presented within thirty days from the date of the order appealed against), review, recovery from a surety, forms, guidelines, saving of the tax's first charge and removal of difficulties.
Our overview of notice, modes and safeguards under rule 225 is a good place to start for the sequence as a whole.
Which sections of the Act the rule serves
Rule 225 names sections 413 and 475 of the Income-tax Act, 2025 in its heading. Our article on sections 412 to 415, penalty when tax is in default and the tax recovery certificate explains the certificate that sets rule 225 in motion, and our article on sections 473, 474, 475 and 477 covers section 475. Other modes of recovery are in the article on section 416.
An example
Meridian Fabrics Private Limited has a certificate drawn up against it. The Tax Recovery Officer serves the notice under sub-rule (2), requiring payment within fifteen days from service. The company does not pay within that period or any further time the Officer grants. Under sub-rule (4) as it now reads, the Officer may proceed by attaching and selling its movable property, by attaching and selling its immovable property, by appointing a receiver, or by more than one of these. Arrest and detention is no longer one of the listed modes, and the sub-rules that carried the steps connected with it are omitted. If the company disputes an order of the Officer that is not conclusive, an appeal lies under sub-rule (88) to the Chief Commissioner or Commissioner of Income-tax, and it must be presented within thirty days from the date of the order.
Need help with a recovery notice?
If a certificate or a demand has been raised against you or your company, a written reply and a correct reading of the current text matter more than speed. Our team prepares responses and appeals through legal dispute resolution support, and you can talk through a specific notice on our legal consultation page.
Key takeaways
- Sub-rules (75) to (83) and (91) of rule 225 are omitted by G.S.R. 822(E) of 17 September 2026, deemed in force from 1 April 2026.
- Clause (c) of sub-rule (4), the mode of recovery by arrest and detention, is also omitted.
- Sub-rules (19), (56) and (87) carry small consequential changes, printed in the table above.
- Notice, attachment, sale, receivers, appeals and review continue to apply.
- The notification omits sub-rules without renumbering the rest.
Read next
- Rule 225: notice, modes and safeguards
- Rule 225: attachment of movable property
- Rule 225: auction of immovable property
- Rule 225: limitation and setting aside a sale
- Rule 226: Tax Recovery Officer's rectification powers
Disclaimer: Based on the Income-tax Rules, 2026 (G.S.R. 198(E), notified on 20 March 2026), read with the amending notifications issued up to 22 September 2026, as consulted on 2 October 2026. It explains the words of the rules and forms only; later notifications, the forms and utilities on the e-filing portal, circulars and the way the tax authorities apply these provisions should be checked. This article is general information, not legal advice; check the official text before acting.