Rule 232 — Service of notice, summons, requisition, order and other communication under section 501. Made under s.501 of the Income-tax Act, 2025.
Rule 232 gives effect to Section 501 of the Income-tax Act, 2025. A rule cannot go beyond the section it serves: where the two seem to differ, the section governs.
Sub-rule (1) sets the scope: for the purposes of section 501(1), the addresses, including the address for electronic mail or electronic mail message, to which a notice, summons, requisition, order or any other communication under the Act may be delivered or transmitted are those in sub-rule (2).
Sub-rule (2)(a) lists the addresses for a communication delivered or transmitted in the manner provided under section 501(1)(a) or (b): the address available in the PAN database of the addressee; the address given in the income-tax return to which the communication relates; the address available in the last income-tax return furnished by the addressee; the address of the assessee as furnished in Form No. 98 under rule 160 or Form 165 under rule 237; in the case of a company, the address of the registered office as given on the website of the Ministry of Corporate Affairs; the address available in the records of the Unique Identification Authority of India or any authority or Department of Central Government, State Government or Local Self Government; the address available in the records of any public service utility provider; and the address furnished in any correspondence with any of those authorities or entities. That list is subject to an override in the closing words: the communication shall not be delivered or transmitted to any of those addresses where the addressee furnishes in writing any other address for the purposes of communication to the income-tax authority or any person authorised by such authority issuing the communication.
Sub-rule (2)(b) lists the addresses for a communication delivered or transmitted electronically: the e-mail address available in the income-tax return to which the communication relates; the e-mail address in the last income-tax return furnished; the registered mail address available in the e-filing portal of the assessee; the e-mail address given while making application for PAN; in the case of a company, the e-mail address available on the website of the Ministry of Corporate Affairs; any e-mail address given by the addressee to the income-tax authority or any person authorised by that authority; and the e-mail address available in the records.
Sub-rule (3) makes the Principal Director General of Income-tax (Systems) or the Director General of Income-tax (Systems) responsible for specifying the procedure, formats and standards for secure transmission of electronic communication, and for formulating and implementing appropriate security, archival and retrieval policies in relation to it.
Section 501 governs how a communication under the Act is served but does not say where it may be sent, and a taxpayer who has moved, or who has different addresses in different records, could otherwise dispute every service. Rule 232 lists the sources of address the Department may draw on, physical and electronic, and puts them beyond argument. The closing words of sub-rule (2)(a) then give the addressee a way to take control: an address furnished in writing displaces the listed ones.
The list is a list of permitted sources, not a sequence, so service at any one of them answers the rule and a taxpayer cannot complain that a more current address existed elsewhere. The one way to displace the list is to furnish another address in writing to the income-tax authority, or the person authorised by it, issuing the communication; the closing words of sub-rule (2)(a) then bar delivery to the listed addresses. That override sits in clause (a), which deals with communications under section 501(1)(a) or (b), while clause (b) governs electronic addresses. The reach of clause (a) is wide — the records of the Unique Identification Authority of India, of any authority or Department of Central, State or Local Self Government, of any public service utility provider, and any correspondence with them — so an address given to an unrelated public body can become the address at which a tax notice is validly served. Note that sub-rule (3) leaves the security and retention of electronic communications to be specified by the systems authority, and prescribes nothing itself.
A company changes its office and updates the address on the Ministry of Corporate Affairs website but not in the PAN database. A notice sent to the PAN database address is at one of the addresses rule 232(2)(a) permits, so the address in the PAN database being out of date does not by itself vitiate delivery. Had the company written to the income-tax authority issuing the communication furnishing its new address for the purposes of communication, the closing words of rule 232(2)(a) would have barred delivery to the PAN database address.
You meet it whenever service is disputed — when a notice is said not to have reached the assessee — and in the intimation an assessee sends to change the address at which he is to be communicated with.
but such communication shall not be delivered or transmitted to the address mentioned in items (i) to (viii), where the addressee furnishes in writing any other address for the purposes of communication to the income-tax authority or any person authorised by such authority issuing the communication
the registered mail address available in the e-filing portal of the assessee