It bars disclosure of the "reason to believe" or "reason to suspect" recorded by an income-tax authority under section 247 or section 248 — the recorded satisfaction that grounds a search or a requisition. The bar is absolute in its terms: the reason is not to be disclosed to any person, to any authority, or to the Appellate Tribunal.
Why it is there
The recorded satisfaction that leads to a search or requisition is kept out of the hands of the person searched and out of the proceedings, so that the sources and intelligence behind it are not exposed by the very action taken on them.
Who it applies to
The income-tax authority who records the reason to believe or reason to suspect under section 247 or 248
The person searched or whose assets are requisitioned, who cannot obtain the reason
The Appellate Tribunal, which is named as an addressee of the bar
What this means in practice
Asking for the recorded reasons behind a search under section 247 or a requisition under section 248 will not get you them, and the Appellate Tribunal is expressly named among those to whom they are not to be disclosed. The section says nothing about the validity of the recording itself — only about disclosure.
An example
Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.
An income-tax authority records a reason to believe under section 247 and a search follows. The person searched asks for that recorded reason — first from the authority, then in the appeal against the resulting assessment, and finally by application to the Appellate Tribunal. He is refused at every stage: the section bars disclosure to any person, to any authority and to the Appellate Tribunal by name, so the satisfaction that grounded the search never enters the proceedings. What it does not do is excuse the recording — the section presupposes a reason recorded under section 247 or 248; it only keeps it from leaving the file.
Where you meet this section
You meet it as a refusal: when the person searched or whose assets were requisitioned seeks the recorded reasons — in objections, in an appeal, or before the Appellate Tribunal — this is the section cited against the request.
The words themselves
The reason to believe or reason to suspect, as referred to in section 247 or 248, recorded by the income-tax authority shall not be disclosed to any person or authority or the Appellate Tribunal.
Section 249, Income-tax Act, 2025.
What people get wrong
Reading it as excusing the authority from recording reasons. The section presupposes a reason recorded under section 247 or 248 and only forbids its disclosure.
Assuming the bar stops at the taxpayer. It extends to any person, any authority, and the Appellate Tribunal by name.
What this replaced
The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.
132 - Search and seizure
132A - Powers to requisition books of account, etc.
A circular binds the department, not you and not a court. Every one below was written under the 1961 Act; it reaches this section because the department’s own concordance carries the provision it names to this one.
Circular No. 4/2021 — Clarifications on provisions of the direct tax vivad se vishwas act 2020 2021-03-23
Circular No. 10/2012, dated 31-12-2012 — Section 132, read with section 132A of the income-tax Act, 1961 - search & seizure - Assessment of preceding years in search cases 2012-12-31
Circular No. 753 — Explanatory Notes on Provisions Relating to the Voluntary Disclosure of Income Scheme, 1997 1997-06-10
A notification is made under a power the Act gives and, within that power, is law. These too were made under the 1961 Act and are placed here by the department’s concordance.
Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 249. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.
CIT v Calcutta KnitwearsSupreme CourtHelps departmenttagged s.132 When must the satisfaction note be recorded before proceedings are taken against a third party?
CIT v S. Khader Khan SonSupreme CourtHelps taxpayertagged s.132(4) They recorded your statement in a survey. Can the addition rest on that alone?
CIT v Sinhgad Technical Education SocietySupreme CourtHelps taxpayertagged s.132 The seized documents say nothing about the years being assessed. Can s.153C still be used for them?
ITO v Seth BrothersSupreme CourtHelps departmenttagged s.132 The search party carted away all our books. Does the way a search was conducted make it illegal?
ITO v Vikram Sujitkumar BhatiaSupreme CourtHelps departmenttagged s.132 The search was before June 2015 but the notice came later. Which version of s.153C applies?
Manish Maheshwari v ACITSupreme CourtHelps taxpayertagged s.132 What has to happen before a search at someone else's premises can be used against you?
N.K. Proteins Ltd v DCITSupreme CourtHelps departmenttagged s.132 Can the whole of a bogus purchase be added, rather than a percentage?
P.R. Metrani v CITSupreme CourtHelps taxpayertagged s.132(4A) Can papers seized in a search be presumed true against me in the regular assessment?
PCIT v Abhisar Buildwell P LtdSupreme CourtCuts both waystagged s.132 Search assessment for a year already completed, but nothing incriminating was found. Can the officer still add?
PDIT (Investigation) v Laljibhai MandaliaSupreme CourtHelps departmenttagged s.132 Can I get a search warrant quashed by showing the department's material was too thin?
Pooran Mal v Director of InspectionSupreme CourtHelps departmenttagged s.132 The search on me was illegal. Can I stop the department using what it took?
Super Malls Pvt Ltd v PCITSupreme CourtHelps departmenttagged s.132 What if the same officer holds charge of both the searched person and you?
Vijay Krishnaswami v DDIT (Investigation)Supreme CourtHelps taxpayertagged s.132 The Settlement Commission accepted my disclosure. Can the department still prosecute me for evasion?
ACIT v Satish Kumar KeshriHigh CourtHelps taxpayertagged s.132(1) The search on me turned up nothing but the AO still made additions for an old year. Can he?
Alishan Complex P Ltd v Initiating OfficerHigh CourtHelps taxpayertagged s.132(4) The benami attachment rests on a retracted statement and they refused cross-examination. Is that evidence?
Anurag Bagaria v Income Tax DepartmentHigh CourtHelps taxpayertagged s.132 After a search I filed revised returns giving up a capital gains claim and paid the tax. Can I still be prosecuted under s.276C(1) for wilful evasion?
CIT v Dhingra Metal WorksHigh CourtHelps taxpayertagged s.132(4) A partner surrendered income during a survey and we have since reconciled the stock. Can we withdraw it?
CIT v Girish ChaudharyHigh CourtHelps taxpayertagged s.132(4A) A seized loose sheet has the bare figure '48' on it and the officer has assessed Rs 48 lakhs. Can he read the scale into the entry like that?
CIT v Ratanlal Vyaparilal JainHigh CourtHelps taxpayertagged s.132 Does the jewellery instruction explain the source of the gold, or only stop the department seizing it?
CIT v S.K. KatyalHigh CourtHelps taxpayertagged s.132 The last panchnama only records the seals being broken and my keys being handed back. Does that date start the limitation clock?
CIT v Satya Narain PatniHigh CourtHelps taxpayertagged s.132 The search party left our jewellery alone but the AO has still added part of it. Can he do both?
Dipen Laljibhai Mandalia v DGITHigh CourtHelps taxpayertagged s.132 The department is justifying my search warrant with discrepancies it discovered after the satisfaction note was recorded. Can material found later…
FCS Manufacturing (India) Pvt Ltd v DDITHigh CourtCuts both waystagged s.132(9B) Your bank accounts are provisionally attached and the business cannot operate. Is there a way out short of paying?
Kailashben Manharlal Chokshi v CITHigh CourtHelps taxpayertagged s.132(4) I disclosed a large sum in the search statement and retracted two months later. Will the retraction hold?
PCIT v Anand Kumar Jain (HUF)High CourtHelps taxpayertagged s.132(4) The addition rests only on an entry operator's search statement. Is that enough to assess me?
PCIT v Best Infrastructure (India) P LtdHigh CourtHelps taxpayertagged s.132 The share capital addition rests on a statement I was never allowed to cross-examine. Does it stand?
Paul Mathews and Sons v CITHigh CourtHelps taxpayertagged s.132(4) Can the officer treat what I said during a survey as sworn evidence against me?
Pawan Kumar Goel v Union of IndiaHigh CourtHelps taxpayertagged s.132 The officers came for a survey, converted it into a search the same day and took away the cash. Can I get that quashed?
Pramod Swarup Agarwal v PDIT (Inv)High CourtHelps taxpayertagged s.132 The authorised officer who searched us has now summoned us under s.131(1A). Can he?
Rajesh Gupta v ACITHigh CourtHelps departmenttagged s.132 It is well past 120 days since the search and they still hold my jewellery. Must they release it?
Sundaram Finance Ltd v ACITHigh CourtHelps departmenttagged s.132 The notice did not specify the default, but you clearly understood it. Does the defect still help you?
DCIT v ACE Infracity Developers P LtdITATHelps taxpayertagged s.132 My lenders are NBFCs that make hundreds of loans. How much of their own affairs do I have to prove?
Diach Chemicals and Pigments P Ltd v DCITITATHelps taxpayertagged s.132 The department says my purchases are bogus. Do the suppliers' returns and the input credit allowed on those invoices count for anything in the…
Garware Technical Fibres Ltd v DCITITATCuts both waystagged s.132 The addition rests on a pen drive seized in the search and no s.65B certificate was drawn at the time. Does that kill it?
Rameshchandra Balachand v JCIT (OSD)ITATHelps taxpayertagged s.132(4) The officer says my partner is a sleeping partner because she is not in the office every day. Can he disallow her remuneration?
Rashmi Jalan v ACITITATHelps taxpayertagged s.132(4) The 271AAB notice does not say which clause or what rate. Can the penalty survive?
Seo Lehenga House v DCITITATHelps taxpayertagged s.132(1) I have already offered the profit on the disputed transactions. Can the officer add the broker's commission on top under s.69C?
T.S. Kumarasamy v ACITITATCuts both waystagged s.132(4) In my block assessment the officer has treated loans recorded in my seized books as undisclosed income while calling those very books unreliable, and…
What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.