The Search & Seizure Manual, 2025, issued by CBDT – Issued: June 2025 – By Shri Ravi Agrawal, Chairman, CBDT
Purpose: Internal departmental use for consistent, lawful, & technology-driven investigation practices across India.
The Search & Seizure Manual, 2025, issued by the Central Board of Direct Taxes (CBDT), updates the earlier 2007 edition to align with major legislative, technological, & procedural developments in tax administration. It serves as a comprehensive operational guide for officers of the Directorate of Investigation & Central Charges dealing with search, seizure, & post-search processes under Sections 132, 132A & 132B of the Income-tax Act, 1961.
Foreword & Rationale
The manual reflects the Department’s shift toward data-driven, technology-enabled, & non-intrusive tax enforcement, while still relying on search & seizure in cases of serious evasion. With the growth of digital evidence, officers must now adhere to the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, & the Bharatiya Sakshya Adhiniyam, 2023 in handling seized data. Integration with FIU-IND, MCA-21, NATGRID, & CRS/FATCA frameworks strengthens intelligence capabilities.
Legal & Judicial Framework
Section 132 empowers authorised officers to search & seize assets based on “reason to believe” that income has been concealed. Judicial precedents like Pooranmal vs. Director of Inspection (SC) & Laljibhai Kanjibhai Mandalia (SC, 2022) uphold the constitutionality of search powers but emphasise reasonable belief & administrative accountability. “Reasons to believe” are confidential & not required to be disclosed to taxpayers.
Preparation for Search
Detailed guidelines are provided on identifying cases through:
– Internal sources (Insight, ITBA, AIS/SFT, TEPs, prior searches)
– External sources (FIU-IND reports, DRI/CEIB data, informants, public records, NATGRID, MCA’s CDM, DoT’s DIP, & Dark Web tools).
Each search must be backed by a Satisfaction Note, DGIT(Inv.) approval, & properly drafted warrants (Forms 45/45A) mentioning correct persons & premises.
Conduct of Search
The manual codifies modern procedures including:
– Showing warrant before commencement
– Maintaining control rooms & two-hourly reports
– Digital recording & videography
– Panchnama preparation
– Handling of digital assets, foreign currency, jewellery, FDRs, lockers & virtual digital assets
– Ensuring privacy, safety & data integrity.
It stresses that no tax should be collected during search & that seized materials must be inventorised, sealed, & transferred to the designated custodian.
Post-Search Procedures
Post-search actions include:
– Depositing seized cash in Personal Deposit (PD) Accounts
– Safe custody in strong rooms
– Valuation under Section 132(9D)
– Preparation of Appraisal Report & centralisation of cases
– Controlled inspection of seized material by the assessee
– Retention, provisional attachment, & inter-agency coordination under the BMA, PBPT & PMLA Acts.
Special Focus Areas
Separate chapters cover:
– Black Money Act, 2015 – investigation, prosecution & CRS/FATCA compliance
– Benami Transactions Act, 1988 – coordination with Benami Prohibition Units & e-court filings
– Air Intelligence Units (AIUs) – airport-level coordination
– Secret Service Fund (SSF) & reward schemes for informants & departmental staff.
Broader Perspective
The manual reinforces CBDT’s dual approach of “PRUDENT” enforcement & “NUDGE” compliance, ensuring that while voluntary compliance is encouraged, search actions remain a last resort against entrenched tax evasion. Officers are urged to keep the manual “living & evolving” through continuous feedback & updates.
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