INCOME TAX AUTORITIES

Class of Income Tax Authorities (sec 116)

There shall be the following classes of Income-tax authorities, for the implementation of the Act.

Central Government

The Central Board of Direct Taxes (CBDT)

Principal Director General of Income Tax or Principal Chief Commissioner of Income Tax or
Directors-General of Income-tax(DGIT),ppp
Chief Commissioners of Income-tax (CCIT) or Principal
Directors of Income tax or Principal Commissioner of Income Tax or Directors of Income Tax or
Commissioners of Income-tax or Commissioners of Income-tax (Appeals)

Additional Directors of Income-tax or Additional Commissioners of Income-tax

Joint Directors of Income-tax or Joint Commissioners of Income-tax

Deputy Directors of Income-tax or Deputy Commissioners of Income-tax

Assistant Directors of Income-tax or Assistant Commissioner of Income-tax

Income-tax Officers

Tax Recovery Officers

Inspectors of Income-tax

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Definitions

1. Assessing Officer [Section 2(7A)] – Assessing Officer means an Income Tax officer or
Assistant Commissioner or Deputy Commissioner or Assistant Director or Deputy Director or
Additional Commissioner or Additional Director of Income Tax or the Joint Commissioner or Joint
Director of Income Tax who is vested with the relevant jurisdiction and assessment function under the
relevant provisions of the Act.

2. Commissioner [Section 2(16)] – Commissioner means a person appointed to be a Principal

Commissioner of Income Tax or Commissioner of Income Tax or a Principal Director of Income Tax
or a Director of Income tax u/s 117.

Jurisdiction of Income-tax Authorities – Sec.120

a) Income-tax authorities shall exercise all of the powers and perform all or any of the functions
conferred on them or assigned to them in accordance with the directions issued by the Board
or any other Income-tax authority authorized by the Board.
b) An income-tax Authority, who is higher in rank, may exercise the powers and perform the
functions of the Income-tax Authority lower in the rank, if so directed by the CBDT.
c) Any such directions or orders may be issued having regard to the following criteria:
a. Territorial Area – eg. Pin code, corporation division number.
b. Persons or classes of persons – eg. Companies, trusts.
c. Incomes or classes of income – eg. Salary income.
d. Cases or classes of cases – eg. Professionals, search cases, contractors.

d) The Board can authorize any Director General or Director of Income-tax to perform such
functions of any other Income-tax authority. The Board can also empower any Director
General or Chief Commissioner or Commissioner to issue order in writing to the effect that the
powers and functions conferred or assigned to an Assessing Officer shall be exercised by an
Additional Commissioner or an Additional Director or a Joint Director in any case.

e) Wherever necessary, the board may require, two or more Assessing Officers (same or different
class) to exercise and perform concurrently the powers, duties and functions in respect of any
area or classes of cases or incomes or persons. Any authority, lower in rank, may perform the
role of a higher authority.

Jurisdiction of Assessing Officers – Sec. 124

a. If an Assessing Officer is vested with jurisdiction over any area then he shall have
jurisdiction within the limit of such area: -
i. In the case of any person carrying on business or profession within that area or where
the business/profession is carried on by any person in more places than one, if the
principal place of business or profession is situated within that area.
ii. In the case of any other person, having place of residence within that area.

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 b. Any dispute relating to jurisdiction of an Assessing Officer to assess any person shall be
determined by the Principal Director General or Director General or Principal Chief
Commissioner or Chief Commissioner or Principal Commissioner or Commissioner of
Income-tax.
c. If the question of jurisdiction is relating to areas within the jurisdiction of different
Principal Directors or Director Generals or Principal Commissioners or Chief
Commissioners of Income-tax, then the concerned authorities themselves can determine the
issue.
d. If they are not in agreement then it shall be decided by the Board or by the Director
General of Income-tax or Chief Commissioner of Income-tax or Commissioner as the
Board may, by notification in the Official Gazette authorize in this behalf.
e. The assessee can dispute to the jurisdiction of Assessing Officer within the time limit
specified below:

Return of income filed No return of income filed Search Cases (Sec 132 or
132A)
Within one month from the Within the time allowed in notice Within one month from the
date of service of notice issuedu/s.142(1) or u/s.148 for filing thedate on which notice was
u/s.142(1)/143(2) Return of Income served u/s 153A / 153C
Or Or Or
Before completion of Time allowed to show cause as to Completion of the
assessment, whichever is why best judgment assessment assessment,
earlier u/s.144 should not be made, Whichever is earlier.
whichever is earlier.
f. Where the assessee calls on question the jurisdiction of an Assessing Officer and the
Assessing Officer is not satisfied with such claim, he shall refer this matter for
determination by Director General or Chief Commissioner or Commissioner of Income-tax
before completing the assessment.

Search & Seizure – Sec. 132

Circumstances under which Powers of search and seizure can be exercised

The powers of search and seizure u/s.132 can be exercised where the Income-tax authority concerned
must have reason to believe in consequence of information in his possession that –

a) any person to whom summons u/s.131(1) or a notice u/s.142(1) has been issued to produce or cause
to be produced any books of account, or other documents has omitted or failed to produce or cause to
be produced, such books of account or other documents; or

b) any person to whom summons or notice as aforesaid has been or might be issued, will not produce
or cause to be produced any books of account or other document, which will be useful for or relevant
to any proceedings under the Act; or

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 c) any person is in possession of any money, bullion, jewellery or other valuable article or thing and
such money, bullion, jewellery or other valuable article or thing represents either wholly or partly
income or property which has not been or would not be disclosed for the purpose of the Act.

Authorizing & Authorized Officer

The Power to authorize a search is vested in higher authorities as indicated below:

Authorizing Officer Authorized Officer

1) Principal Director General or Director Additional Director, Additional Commissioner, Joint Director
General or Director or Principal Chief or Joint Commissioner or Assistant Director / Deputy Director
Commissioner or Chief Commissioner or or Assistant Commissioner / Deputy Commissioner or Income-
Principal Commissioner or tax Officer.
Commissioner.
2) Additional Director, Additional Assistant Director / Deputy Director or Assistant
Commissioner, Joint Director or Joint Commissioner / Deputy Commissioner or Income-tax Officer.
Commissioner empowered by the Board
in this behalf.

Note: The authorisation is done by issuing a search warrant in Form 45.

Powers of the Authorized Officer

a) Enter and search any building, place, vessel, vehicle or aircraft where he has reason to suspect
that such books of account, documents, money, bullion, jewellery or other valuable articles or
things are kept;

b) Break open the lock of any door, box, locker, safe, almirah, receptacle, where the keys are not
available;

c) Search any person who has got out of, or is about to get into, or is in the building, place, vessel,
vehicle or aircraft, which is being searched. The Authorized Officer may invoke this power in
case he has reason to suspect that such person has secreted about his person any books of
accounts, other documents, money, bullion, jewellery or other valuable article or thing;

d) Require any person who is found to be in possession or control of any books of account or
other documents maintained in the form of electronic record to afford the necessary facility to
inspect such books of account or other documents;

e) Seize any such books of account, documents or assets found as a result of such search. Bullion,
jewellery or other valuable article or things being stock-in-trade of the business, shall not be
seized. In such cases he shall make a note of inventory of such stock-in-trade;
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 f) Place marks of identification on any books of account or other documents or take extracts or
copies there form;

g) Make a note of any such money, bullion, jewellery or other valuable article or thing or take
inventory thereof;

h) Apart from the above, the Authorized Officer may, during the course of search or seizure
examines on oath any person who is found to be in possession or control of any books of
account, documents or assets. Any such statement made by such person during such
examination may thereafter be used in evidence in any proceeding under the Income-tax Act –
Sec.132(4); and

i) In a case where the building, place, vessel etc., is within the jurisdiction of the Chief
Commissioner or Commissioner but such authority does not have jurisdiction over the person,
it shall be competent for the authority to exercise powers under this section in case he has
reason to believe that any delay in getting authorization from the Chief Commissioner or
Commissioner having jurisdiction over such person may be prejudicial to the interests of the
revenue – Proviso to Sec 132(1).

j) In a case where chief commissioner or commissioner has reason to believe that books,
documents or any other article/thing are kept in any building, vessel, place, vehicle or aircraft
which was not specifically covered in the authorization, then they may authorize the authorized
officer to proceed to exercise the powers under search in respect of such building, place, vessel,
vehicle or aircraft also – Sec.132(1A)

Constructive Seizure

1. Where it is not possible or practicable to take physical possession of any valuable articles
or things and remove it to a safe place due to its volume, weight, physical characteristics or
dangerous nature etc., the Authorized Officer may serve on the owner an order prohibiting
him from removing, parting with or otherwise dealing with it except with the previous
permission of the Authorized Officer and such action shall be deemed to be seizure of such
valuable article or thing. This is known as Constructive or Deemed Seizure – Second
Proviso to Sec.132 (1). This provision is not applicable in case of any valuable article or
thing are held as stock-in-trade of the business – Third Proviso to Sec.132 (1)

2. Restraint Order: Where it is not possible or practicable to seize and books of accounts,
other documents or money, bullion, jewellery, or other valuable article or thing, for the
reasons other than those mentioned in point 1 above, the authorized Officer may serve an
order on the owner or a person who is in the immediate possession or control thereof that
he shall not remove or part with or otherwise deal with it, except with the prior approval of
such officer. This is known as ‘Attachment Order’. The Attachment order shall not be
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 deemed to be seizure. However, such order is valid for a period of 60 days from the date of
the order – Sec.132 (8A).

3. The Authorized Officer may request for the service of any police officer or any officer of
the Central Government to assist him in the process of seizure – Sec.132 (2).

Powers to requisition of books of accounts etc – Section 132A

The powers granted under this section can be divided into two parts, as follows:

A. Power to requisition of books of accounts and other documents taken into custody under any
other law.

B. Situations under which power to requisition can be invoked.

A. Power to requisition of books of accounts and other documents taken into custody under
any other law:

1. In case any books of accounts or other documents and assets have been taken into custody by
any officer or authority like CBI, Enforcement Directorate, Customs, Money Laundering etc., then the
authorised officer may authorise their sub-ordinate to require such officer or authority to deliver to him
such books of accounts or other documents and assets.

2. Where such a requisition is made, the officer or the concerned authority shall be required to
deliver the books of accounts or other documents and assets to the requisitioning officer either at once
or when such officer or the authority is of the opinion that it is no longer necessary to retain the same
in his custody. – Section 132A (2).

3. Once any books of accounts or other documents or assets have been received by the Income
Tax Authority from any officer or authority under any other law, then all the provisions of section 132
(4A) [Presumptions of ownership] to section 132 (14) [Retention of books etc] and section 132B
[manner of utilisation of assets seized] shall apply, as if the such books of accounts or documents or
assets have been seized u/s 132(1).

B. Situations under which power to requisition can be invoked – Rule 112D

Where the Principal Director General or Director General or Principal Director or Director or Principal
Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner, in
consequence of information in his possession, has reason to believe that:

1. any person to whom summons u/s.131(1) or a notice u/s.142(1) has been issued to produce or
cause to be produced any books of account, or other documents has omitted or failed to produce or
cause to be produced, such books of account or other documents, as required by such summons or

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notice and the said books of accounts or other documents have been taken into custody by any officer
or authority under any other law for the time being in force. or

2. Any books of accounts or other documents will be useful for or relevant to any proceedings
under the Act and any person to whom a summon or notice as above-mentioned has been issued will
not or would not produce such books of accounts or other documents on the return of such books of
accounts or other documents by the officer or authority by whom the same have been taken into
custody under any other law for the time being in force. Or

3. Any assets represent either wholly of partly income or property which has not been or would
not be disclosed for the purpose of the Act, by any person from whose possession or control such
assets have been taken into custody by any officer or authority under any other law for the time being
in force – Section 132A (1).

Presumptions u/s. 132(4A)

Where any books of account, other documents, money, bullion, jewellery or other valuable article or
thing are found in the possession or control of any person in the course of a search, it may be presumed
that –

a) Such books of account, other documents, money, bullion, jewellery or other valuable thing
belong to such person;
b) The contents of such books of account and other documents are true; and
c) The signature and every other part of such books of account and other documents which
purport to be in the handwriting of any particular person or which may reasonably be
assumed to have been signed by or to be in the handwriting of any particular person are in
that person’s handwriting and in the case of a document stamped, executed or attested, that it
was duly stamped and executed or attested by the person by whom it purports to have been
so executed or attested.

Retention of books etc, seized during the course of search

a) The books or documents seized shall not be retained by the Authorized Officer for a period
exceeding 30 days from the date of order made u/s. 153A unless reasons are recorded in writing
and the approval of Principal Chief Commissioner, Chief Commissioner, Principal Commissioner,
Principal Director General or Director General or Principal Director or Director for such retention
is obtained. However, such authority shall not authorize such retention beyond 30 days after all the
proceedings under the Act in respect of the relevant years are completed – Sec. 132(8).
b) The person from whose custody any books of account or other documents are seized may make
copies thereof, or take extracts there from in the presence of the authorized officer or any other
person empowered by him in this behalf, at such places and time as fixed by the authorized officer
– Sec. 132(9).
c) If a person legally entitled to the books of account or other document seized during the course of
search objects for any reason to the approval given by the Principal Chief Commissioner, Chief
Commissioner, Principal Commissioner, Commissioner or Principal Director General or Director
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 for retention of such books or documents, the Board may, on receipt of an application from the
person, may pass an appropriate order after giving the opportunity of being heard – Sec.132 (10).
d) Where the Authorized Officer does not have jurisdiction over the person, the books of accounts or
other documents or any money, bullion, jewellery or other valuable articles or thing seized shall be
handed over by the Authorized Officer to the Assessing Officer having jurisdiction over such
person within a period of 60 days from the date on which the last authorization for search was
executed. Such Assessing Officer would then exercise the powers exercisable by the Authorized
Officer u/s 132(8) and Sec 132(9) – Sec 132(9A).
e) The provisions of the Code of Criminal procedure relating to searches and seizure shall apply to
searches and seizure u/s 132(1) and 132(1A) – Sec 132(13)
f) The board may make rules in relation to search and seizure for obtaining access into any building,
place, vessel, vehicle or aircraft where free access is not available and for ensuring the safe
custody of seized books of account or assets or any other documents – Sec. 132(14)

Manner of utilization of the assets seized – Sec. 132B

a) According to Sec. 132B, the assets seized u/s. 132 or requisitioned u/s. 132A may be adjusted
against the Government dues in the following manner:
The amount of any existing liability under the Income-tax Act or erstwhile Wealth-tax Act or the
amount of liability determined on completion of the assessment u/s. 153A or assessment of
the year relevant to the previous year in which search is initiated or requisition made,
including any penalty levied or interest payable in connection with such assessment or The
amount of liability arising on application made before Settlement Commission u/s 245C (1).
However, existing liability does not include Advance Tax payable for that previous year.
b) However, where the assessee –
i. explains nature and source of acquisition of any such asset to the satisfaction of the Assessing
Officer; and
ii. makes an application for release of such assets within 30 days from the end of the month, in
which the assets were seized,
the amount of any existing liability may be recovered out of such asset and the remaining
portion may be released with the prior approval of the Principal Chief Commissioner or Chief
Commissioner or Principal Commissioner or Commissioner to the person from whose custody
the assets were seized. The release shall be made within 120 days from the date of last of the
authorizations u/s. 132 or u/s. 132A was executed.
c) Any assets or proceeds which remain after the discharge of all liabilities shall be forthwith
made over or paid to the person from whose custody the assets were seized.
d) According to section 132B(4), the Government shall pay simple interest at the rate of 0.5%
for every month or part of the month on the excess of the money seized or the sale proceeds
arising on the sale of assets seized, after adjusting the liability. Such interest is payable from
the expiry of 120 days from the date of execution of search warrant u/s. 132 or requisition u/s.
132A to the date of completion of assessment u/s. 153A.

Power to call for information – Sec. 133

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Under this section, information can be gathered from a person, which is considered to be useful for or
relevant to any inquiry or in connection with any pending proceeding. The Assessing Officer or the
Joint Commissioner or the Commissioner (Appeals) may call for the information that as follows:

1) In the case of firm – Name and addresses of the partners of the firm and their respective shares;
2) In the case of HUF – Name and addresses of the manager and the members of the family.
3) Any person who is a trustee/ guardian/ agent – Names of the persons for or of whom he is
trustee, guardian or agent, and of their addresses;
4) Any assessee – Names and addresses of all persons to whom he has paid rent, interest,
commission, royalty or brokerage or any annuity in excess of Rs.1000 with particulars of all
such payments.
5) Any dealer, broker or agent or any person concerned in the management of the stock or
commodity exchange – Names and addresses of all persons to whom he or the exchange has
paid any sum in connection with the transfer of assets or any sum received with particulars of
all such payments and receipts.
6) Any person including a banking company or any officer thereof – Information in relation to
such points or matters or statements of accounts which in the opinion of the Assessing Officer
or higher authorities will be useful for or relevant to any enquiry or proceeding.

In respect of cases covered u/s. 131(2), wherein the noticed income-tax authority may
inquire/collect information for the purpose of agreement under sections 90 & 90A, the powers
granted u/s. 133 may be invoked by such notified income-tax authority even where there is no
proceedings pending – Proviso to Sec. 133.

Faceless Collection of Information [Section 135A]

1. This section empowers the Central Government to make a scheme, by notification in the
Official Gazatte, for the purposes of:
a. Calling for information u/s 133;
b. Collecting information u/s 133B;
c. Calling for information by prescribed income tax authority u/s 133C;
d. Exercise of power to inspect register of companies u/s 134;
e. Exercise of power of Assessing Officer u/s 135.
2. The objective of the scheme aims to impart greater efficiency, transparency and accountability
by:
a. Eliminating the interface between the income tax authority and the assesee or any other
person to the extent technologically feasible;
b. Optimisinig utilisation of the resources through economics of scale and functional
specialisation;
c. Introducing a team based exercise of powers, including to call for, or collect, or
process, or utilise the information, with dynamic jurisdiction.

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 3. As per this scheme, the Central Government may direct, by notification in the gazette, that any
of the provisions of the Act, would not apply or would apply with specified exceptions,
modifications and adaptions. However, no such directions can be issued after 31-03-2022.
4. Every notification issued u/s 135A is to be laid before each house of parliament as soon as may
be after notification is issued.

Survey – Sec 133A

The objective of conducting Survey u/s 133A is a routine exercise on the part of CBDT to enlarge the
tax base, verify the correctness in maintenance of books, stock records by the assessee. The Survey
operations may be broadly classified into:

A. Survey specific to premises of business or profession or any place where charitable activities are
carried out [Section 133A(1)].

B. Survey for Verifying the compliance of TDS / TCS [Section 133A(2A)].

C. Survey in connection with functions, ceremony, events etc [ Section 133A(5)].

Income Tax Authority authorised to conduct Survey

1. A Principal Commissioner or Commissioner, a Principal Director or Director, a Joint

Commissioner or Joint Director, an Assistant Director or a Deputy Director or an Assessing
Officer or Tax Recovery officer and an Inspector of Income Tax.
2. For the purposes of survey, the powers of an Inspector of Income Tax is restricted to enter
specific place to afford him the facility to inspect books or documents or specific place to mark
identification on the books or documents and specific place where function, ceremony or event
is organised. Except these specific situations, an Inspector cannot enter any place u/s 133A.
3. Exercise of survey powers for the period from 01-04-2020 to 31-10-2020 are as follows:

Types of cases Approval from Authority empowered to conduct survey

Where information Joint Director / Joint Deputy Director, Assistant Director, Assessing
received from Commissioner Officer, Tax Recovery Officer or Inspector of
prescribed authority Income tax
In other cases Director / Commissioner Joint Director, Joint Commissioner, Deputy
Director, Assistant Director, Assessing officer, Tax
Recovery officer or Inspector of Income Tax

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 4. With effect from 01-11-2020 – No action under this section (ie., initiating survey) shall be
taken by an Income tax authority without prior approval of Principal Director General or
Director General or the Principal Chief Commissioner or the Chief Commissioner.

A. Survey specific to premises of business or profession or any place where charitable

activities are carried out.

1. Principal Commissioner or Commissioner, a Joint Commissioner, a Principal Director or

Director, a Joint Director, an Assistant Director or a Deputy Director or an Assessing Officer or a Tax
Recovery Officer and Inspector of Income Tax are authorised for Survey.

2. An Income-tax authority conducting survey may enter –

i) any place within the limits of the area assigned to him; or

ii) any place occupied by any person in respect of whom he exercises jurisdiction; or
iii) any place in respect of which he is authorized to conduct survey by any other Income-tax
authority who is assigned the area within which such place is situated or who exercises jurisdiction
in respect of any person occupying such place.

at which a business or profession or charitable activity is carried on, whether or not it is a principal
place of carrying on such activity.

2. On entering such place he can require the proprietor, trustee, employee or any other person to
do the following:

i) To afford him necessary facility to inspect such books of account and documents.
ii) To afford him necessary facility to check or verify cash, stock or other valuable articles or
things found.
iii) To furnish such information which may be useful for or relevant to any proceeding.

Note: If the person carrying on business or profession states that any of his books of account or other
documents or assets relating to his business or profession are kept at some other place, then such other
place shall also be covered.

3. An Income-tax authority can enter any place of business or profession or activity for charitable
purpose is carried on, only during hours at which such place is open for such conduct of business or
profession or charitable activity and in respect of any other place only after sunrise and before sunset.
– Section 133A (2).

4. An Income-tax authority may do the following during the course of survey:

i) Place marks of identification on the books and documents or take extracts or copies there from. –
Section 133A (3) (i)
ii) Make an inventory of any cash, stock or other valuable article. - Section 133A (3) (ii)
iii) Record the statement of any person, which may be useful for or relevant to, any proceedings
under this Act - Section 133A (3) (iii)

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5. An Income-tax authority cannot remove any assets during survey operations.

6. However, an Income-tax authority is empowered to impound and retain in his custody any
books of account or other document inspected by him. Such power can be exercised only after
recording reasons. The books and documents so impounded can be retained beyond 15 days (excluding
holidays) only after obtaining the approval of the Principal Chief Commissioner or Chief
Commissioner or Principal Director General or Director General or Principal Commissioner or
Commissioner or Principal Director or Director.

Note: Considering the seriousness of the case, a survey operation may be converted to a search
operation u/s. 132, subject approval from appropriate authorities.

B. TDS / TCS Survey [Section 133A(2A)]

1. This section empowers an income tax authority to conduct survey for the purpose of verifying
the compliance of provisions of TDS and TCS at any office or other place where business or
profession is carried on.

2. For the purpose of this section, institution carrying on charitable activities are not covered.

3. The income tax authority carrying survey under this section shall not impound and retain books
of account or other documents inspected by him and shall not make an inventory of any cash, stock or
other valuable article of thing checked or verified by him – Proviso to section 133A(3).

C. Survey in connection with functions, ceremony, events etc

1. While considering the nature and scale of expenses incurred by an assessee in connection with
any function, ceremony or event, if the Income-tax authority deems it necessary, he can record a
statement after conclusion of such function, ceremony or event from the person who incurred such
expenses or any other person who is likely to possess information as regards such expenditure – Sec.
133A(5).

2. It may be mentioned here that if the person who has incurred the expenditure is unable to
explain the source or if the explanation offered is not satisfactory, then the amount of such expenditure
shall be assessed as income in accordance with section 69C.

Note 1: If a person refuses or evades to provide facility as required under this provision the Income-
tax authority shall have all powers u/s. 131 (1) for enforcing compliance thereof.

Note 2: The survey operations cannot be carried out by an Assistant Director or a Deputy Director or
an Assessing Officer or a Tax Recovery Officer or an Inspector of Income-tax unless they obtain
approval of the Joint Director or Joint Commissioner.

Power to Collect Certain Information – Sec 133B

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1. An income tax authority may, for the purpose of collecting any information useful or relevant
for the purposes of the Act, enter any building or place within the limits of the area assigned to such
authority or he exercises jurisdiction, at which a business or profession is carried on and require to
furnish such information in Form 45D – Sec 133B(1).

2. An income tax authority can enter any such place only during the hours at which it is open for
the conduct of business or profession – Sec 133B (2).

3. An income tax authority cannot remove any books, documents, cash, stock, valuables or any
assets – Sec 133B (3).

Power to call for information by Prescribed authority – Sec 133C

1. The prescribed Income tax authority may, for the purpose of verifying any 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 in the manner specified therein, which may be
useful for any enquiry or proceeding under this act (sec 133C(1)).

2. On receipt of information or documents in response to the notice, the prescribed income tax
authority may process such information or document and make available the outcome of such
processing to the Assessing Officer. (sec 133C(2)).

3. The CBDT may make centralised scheme for issuance of notice or processing of information or
documents and make available the outcome of such processing to the Assessing Officer – Section
133C (3).

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