Chapter XXIII - Miscellaneous
Section 525
Section 525: authorisation and assessment in case of search or requisition
Section 525 clears up a procedural point about search and requisition proceedings under the Income-tax Act, 2025: naming more than one person on a single authorisation or requisition doesn't turn them into an association of persons or body of individuals, and the resulting assessment or reassessment must still be made separately for each person named.
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This article is for general information. Refer to the Income-tax Act, 2025 as amended by the Finance Act, 2026 and the Taxation and Other Laws (Amendment) Act, 2026 for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
(1) Irrespective of anything contained in this Act,— (a) it shall not be necessary to issue an authorisation under section 247 or make a requisition under section 248 separately in the name of each person; (b) where an authorisation under section 247 has been issued or requisition under section 248 has been made mentioning therein the name of more than one person, the mention of such names of more than one person on such authorisation or requisition shall not be deemed to construe that it was issued in the name of an association of persons or body of individuals consisting of such persons.
(2) Irrespective of an authorisation issued under section 247 or a requisition made under section 248 mentioning therein the name of more than one person, the assessment or reassessment shall be made separately in the name of each of the persons mentioned in such authorisation or requisition.
Introduction
One search authorisation or requisition may mention more than one person. Section 525 states that this fact alone does not turn those persons into an association of persons or body of individuals.
Despite a shared authorisation or requisition, assessment or reassessment must be made separately in each named person’s name.
Key takeaways
Joint naming permitted
The Act does not require separate authorisations or requisitions merely because more than one person is named.
No deemed collective person
Naming several people does not by itself create an association of persons or body of individuals.
Separate assessments
An assessment or reassessment is still made separately in the name of each named person.
One authorisation or requisition can name more than one person
Irrespective of anything else in the Act:
- It is not necessary to issue a separate authorisation under section 247, or make a separate requisition under section 248, in the name of each person
- Where an authorisation under section 247 or a requisition under section 248 names more than one person, that alone does not mean it was issued in the name of an association of persons or body of individuals consisting of those persons
But assessment is still made separately for each person
Irrespective of an authorisation under section 247, or a requisition under section 248, naming more than one person, the assessment or reassessment shall be made separately in the name of each of the persons mentioned in that authorisation or requisition.
Applying Section 525 in practice
Two effects. A search authorisation or requisition need not name each person in a separate instrument. Naming several persons does not, by itself, constitute them an AOP or BOI. Yet each named person's assessment or reassessment must be made separately, despite the joint authorisation.
Step-by-step flow for applying Section 525
- 1
Was an authorisation under section 247 issued, or a requisition under section 248 made?
- No: Section 525 does not apply.
- Yes: Go to the next step.
- 2
Was a separate authorisation or requisition needed for each person?
No. Under Section 525(1)(a), it is not necessary to issue it separately in the name of each person.
- 3
Does it mention more than one person?
- No: The assessment or reassessment is made in the name of the person mentioned.
- Yes: Go to the next step.
- 4
Does naming several persons create an AOP or BOI?
No. Under Section 525(1)(b), naming more than one person is not to be construed as issuing it in the name of an association of persons or body of individuals.
- 5
Make the assessment
Under Section 525(2), the assessment or reassessment is made separately in the name of each person mentioned.
Practical checklist
Do
- Identify every person named on the search authorisation or requisition and keep the relevant documents for each person.
- Where names are combined on one authorisation or requisition, maintain separate income and evidence records for each named person.
- Check that any assessment or reassessment is made separately in each named person’s name as sub-section (2) states.
- review the actual names on the instrument, each person's seized material and separate assessment record.
Avoid
- Do not infer an association of persons or body of individuals solely from multiple names on the same authorisation or requisition.
- Do not assume a separate authorisation must always be issued for each person.
Illustrative example
Worked example: one authorisation naming three brothers
Hypothetical facts (illustration only, not a real taxpayer): Three brothers run separate proprietorship businesses from one building. A single authorisation under section 247 names all three of them, and a search is carried out at the building.
Single authorisation
Under Section 525(1)(a), one authorisation naming all three is valid; a separate authorisation for each brother is not necessary.
Status
Under Section 525(1)(b), naming all three does not mean the authorisation was issued in the name of an AOP or BOI made up of the brothers.
Assessment
Under Section 525(2), each brother is assessed separately in his own name on his own income.
Outcome
- Three separate assessments follow, one for each brother.
- The brothers are not assessed together as an AOP or BOI merely because they were named in one authorisation.
Glossary
- Authorisation
- The instrument for a search under section 247 that may name more than one person under section 525.
- Separate assessment
- The section 525(2) requirement to assess or reassess each named person in that person’s own name.
Frequently asked questions
If a search authorisation names three people, are they treated as one association of persons?
No - Section 525(1)(b) specifically says naming more than one person on an authorisation or requisition does not mean it was issued in the name of an association of persons or body of individuals.
Does each person named in the authorisation get a separate assessment?
Yes - Section 525(2) requires the assessment or reassessment to be made separately in the name of each person mentioned in the authorisation or requisition.
Need help applying this provision to your situation?
Talk to our tax team about this sectionLast updated 10 October 2026