Historical: Notification 70/2023 — Income-tax Nineteenth Amendment Rules (Search & Valuation)

CBDT Notification No. 70/2023 dated 28 August 2023 amended the Income-tax Rules, 1962 to create a formal procedure for specialised assistance and valuation during search proceedings under old Section 132 of the Income-tax Act, 1961. It inserted Rule 13 and Rule 13A and introduced Form No. 6C and Form No. 6CA.

What exactly did Notification 70/2023 do?

The notification was issued under Section 132(2), Section 132(9D) and Section 295 of the Income-tax Act, 1961. It inserted new procedural rules after Rule 12F of the Income-tax Rules, 1962. These rules were designed to structure how authorised officers could use outside specialists and valuers during a search.

This was more than a formatting amendment. Search proceedings can involve digital data, jewellery, immovable property, securities, machinery, artwork, mines, forests and other assets that require expertise beyond routine tax examination. Notification 70/2023 created a documented approval system for such assistance.

Rule 13: approval and requisition of specialised services

Rule 13 allowed the Principal Chief Commissioner, Chief Commissioner, Principal Director General or Director General, as applicable, to approve persons, entities or registered valuers whose services could be requisitioned for search-related purposes. Approval could arise from an application by the expert, from a reference by specified senior tax officers, or on the approving authority's own motion.

Once approved, an authorised officer could requisition the services of one or more approved persons for the purposes contemplated by old Section 132(2) or make a reference under old Section 132(9D).

Form 6C and the approval process

An applicant seeking approval under Rule 13 was required to apply in Form No. 6C. The form asked for identity details, PAN, contact information, nature of services, relevant qualifications, registrations and experience. The approving authority was required to dispose of the application within six months from the end of the month in which it was made.

Where approval was granted, the approved person/entity/registered valuer received a Designated Approval Number, an alphanumeric identifier contemplated by the rule.

Can an unapproved expert be used?

Yes, the 2023 rule contained a limited flexibility mechanism. Where the authorised officer considered it necessary or expedient, services could be requisitioned from, or a reference could be made to, a person/entity/registered valuer who was not already approved. The officer had to record reasons and obtain approval from the prescribed senior authority within 30 days of the requisition/reference.

This is an important historical detail because it shows that the rule did not make the pre-approved panel the only possible source of expertise. It instead required documented reasons and post-facto approval within the specified period for an exceptional case.

What kinds of specialists were contemplated?

The notes to Form 6C listed examples of services and qualifications. These included translators; persons/entities assisting with forensic analysis or data mining of digital data; certain bank managers/officers; jewellery valuers; immovable-property valuers; experts in forests; mining specialists; merchant bankers for valuation of securities/business assets; machinery and plant valuers; art specialists; actuaries; and other persons required because of local-area considerations.

For tax professionals, this list helps explain the breadth of technical issues that can arise during a search. It should not be treated as a general register of professionals for ordinary income-tax work.

Rule 13A: how valuation was structured

Rule 13A prescribed how fair market value should be determined for property referred under old Section 132(9D). The valuation method varied by asset class.

Form 6CA: valuation report

The person/entity/registered valuer receiving a valuation reference was required to submit Form No. 6CA to the authorised officer. The form captured the property being valued, valuation date, valuation method, major assumptions and fair market value. It also required verification by the valuer and certification regarding absence of direct/indirect interest in the property.

This form made the valuation exercise more traceable because the methodology and assumptions had to be disclosed instead of leaving the valuation as an informal expert estimate.

Why the notification mattered

About the spelling “Ninteenth”

The official Gazette notification itself uses the short title “Income-tax (Ninteenth Amendment) Rules, 2023”. Many summaries naturally render the word as “Nineteenth”. When citing the notification in formal research, it is useful to reproduce the official Gazette reference and notification number so there is no doubt about the document being discussed.

Does Notification 70/2023 directly govern a search in 2026?

Do not assume so. The notification was issued under the Income-tax Act, 1961 / Income-tax Rules, 1962 framework. From 1 April 2026, current matters must be examined under the Income-tax Act, 2025, current rules and the relevant repeal, transition and savings provisions. Historical rules may still matter for proceedings, records, litigation or events governed by the earlier law.

Accordingly, this URL should remain an archive/reference page rather than being repackaged as a current search-and-seizure procedure without a fresh statutory mapping.

How professionals should use this page today

• Use it when reviewing a 2023-era search record or valuation report.
• Check whether Form 6C approval and a Designated Approval Number were relevant to the expert involved.
• Review Form 6CA where a property valuation reference was made.
• Compare the valuation methodology with the relevant old Rule 13A asset category.
• For a live 2026 search matter, start with current law and use this article only as historical context.

Common mistakes

• Treating Notification 70/2023 as a general tax-compliance notification unrelated to search proceedings.
• Ignoring Rule 13A and focusing only on Rule 13.
• Missing Form 6C and Form 6CA when reviewing historical documentation.
• Assuming all experts had to be pre-approved despite the recorded-reasons exception.
• Applying the old rule automatically to a post-1 April 2026 proceeding.
• Citing a secondary article without checking the Gazette notification itself.

Frequently asked questions

Official reference

• CBDT / Gazette — Notification No. 70/2023 dated 28 August 2023

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