
Section 151 of the Central Goods and Services Tax Act, 2017 deals with the power of the Commissioner or an authorised officer to call for information relating to matters connected with the CGST Act.
The provision gives the Commissioner, or an officer authorised by the Commissioner, the authority to issue an order directing any person to furnish specified information. The information must relate to a matter dealt with in connection with the CGST Act, and the order can specify the time, form and manner in which the information must be furnished.
Section 151 is a relatively short provision, but it has practical importance because GST administration depends heavily on information from taxpayers, businesses and other persons connected with taxable transactions.
The current Section 151 was substituted with effect from 1 January 2022. The earlier provision was connected with collection of statistics and information returns, whereas the substituted provision gives a more direct power to call for information relating to matters dealt with under the Act.
What Is Section 151 of the CGST Act?
Section 151 is titled “Power to call for information.”
The current statutory provision states:
“The Commissioner or an officer authorised by him may, by an order, direct any person to furnish information relating to any matter dealt with in connection with this Act, within such time, in such form, and in such manner, as may be specified therein.”
The provision therefore contains four important elements:
- Who can issue the direction?
The Commissioner or an officer authorised by the Commissioner. - Who can be directed?
Any person. - What can be requested?
Information relating to any matter dealt with in connection with the CGST Act. - How must the information be furnished?
Within the specified time and in the form and manner specified in the order.
Why Was Section 151 Introduced in Its Present Form?
Section 151 underwent an important change through the Finance Act, 2021.
The earlier Section 151 dealt with the power to collect statistics. It allowed the Commissioner to notify collection of statistics and require concerned persons to furnish information or returns in the prescribed manner.
That provision was substituted with effect from 1 January 2022. The current provision instead focuses directly on the power to call for information relating to matters dealt with in connection with the CGST Act.
This distinction is important when reading older GST articles or older versions of the CGST Act. Content describing Section 151 only as a general “power to collect statistics” reflects the earlier version and does not accurately describe the current statutory wording.
Who Can Exercise the Power Under Section 151?
The power can be exercised by:
- the Commissioner; or
- an officer authorised by the Commissioner.
Therefore, the provision does not give an unrestricted Section 151 power to every GST officer.
The order must come from the Commissioner or an officer who has been authorised by the Commissioner for this purpose.
Who Can Be Asked to Furnish Information?
Section 151 uses the expression “any person.”
This is broad.
Depending on the matter involved, a direction may potentially be issued to a person whose information is relevant to a matter connected with GST.
The provision is not restricted in its wording only to registered persons.
Therefore, depending on the circumstances, the person receiving the direction could be:
- a registered taxpayer;
- a business entity;
- a supplier;
- a recipient;
- a person connected with a transaction; or
- another person possessing relevant information.
The actual scope of a particular direction will depend on the information sought and its connection with the CGST Act.
What Information Can Be Called For?
The current Section 151 does not provide an exhaustive list of particular documents or categories of information.
Instead, it refers broadly to information relating to any matter dealt with in connection with the CGST Act.
Therefore, depending on the subject matter, information could relate to matters such as:
- taxable supplies;
- purchases;
- sales;
- invoices;
- business transactions;
- GST registration;
- tax payments;
- input tax credit;
- returns;
- accounts;
- supply arrangements;
- transaction records; or
- other information connected with administration of the CGST Act.
The precise information required should be identified in the order issued under Section 151.
Time, Form and Manner of Furnishing Information
One of the important features of Section 151 is that the order can specify:
- the time within which information must be furnished;
- the form in which it must be furnished; and
- the manner in which it must be furnished.
This gives flexibility to the GST administration.
For example, an order may require information to be furnished electronically, in a particular statement or in a specified format, depending on the nature of the information required.
A person receiving such an order should therefore carefully read the specific requirements instead of assuming that submitting the information in any format will satisfy the direction.
Section 151 Is an Information-Gathering Provision
The basic purpose of Section 151 is to enable the GST administration to obtain relevant information.
GST authorities require information for several administrative and compliance functions.
For example, information may help the department understand:
- the nature of transactions;
- patterns of supplies;
- compliance with GST provisions;
- relationships between transactions;
- discrepancies in information;
- tax-related activities; or
- other matters connected with administration of the Act.
Section 151 therefore operates as an information-gathering tool.
Section 151 Does Not Itself Create a Tax Demand
An important distinction is that Section 151 itself is not a tax-demand provision.
The section provides the power to call for information.
It does not itself determine:
- tax liability;
- interest;
- penalty;
- confiscation;
- recovery; or
- arrest.
If information obtained under the GST law subsequently leads to another proceeding, the relevant statutory provision would have to be applied separately.
For example, a discrepancy discovered from information may potentially lead to scrutiny, audit, investigation or demand proceedings under the applicable provisions, but Section 151 itself is concerned with calling for information.
Section 151 and Section 150
Section 151 should be distinguished from Section 150, which deals with furnishing information returns.
Section 150 contains a separate statutory framework concerning information returns from specified persons maintaining specified records or information. The provision covers specified information relating to matters such as registration, accounts, returns, tax payments and certain transactions, subject to the statutory framework.
Section 151, in contrast, gives the Commissioner or authorised officer a power to issue an order directing any person to furnish information relating to a matter dealt with in connection with the Act.
In simple terms:
Section 150 → Information return framework
Section 151 → Specific power to call for information by order
Section 151 and Section 152
Section 152 is particularly important when studying Section 151.
Section 152 deals with the bar on disclosure of information.
Following the 2021 amendments, Section 152(1) provides that information relating to matters given for the purposes of Section 150 or Section 151 cannot, without previous written consent of the concerned person or authorised representative, be published in a manner that enables the particulars to be identified as referring to a particular person.
Section 152 also provides that such information cannot be used for proceedings under the Act without giving the concerned person an opportunity of being heard.
Therefore, Section 151 and Section 152 should be read together.
Section 151
Provides the power to call for information.
Section 152
Provides restrictions relating to disclosure and use of such information.
Section 151 and Confidentiality of Information
The relationship between Sections 151 and 152 is important for businesses.
A taxpayer or other person may be required to provide commercially sensitive information to the GST administration.
Section 152 provides statutory restrictions concerning publication and use of information covered by Sections 150 and 151.
The provision is therefore relevant to maintaining the confidentiality of identifiable information furnished under these sections.
Opportunity of Being Heard Under Section 152
The current Section 152 also provides an important procedural safeguard.
Information covered by Section 150 or Section 151 cannot be used for proceedings under the CGST Act without giving an opportunity of being heard to the person concerned.
This does not mean that Section 151 itself is a demand proceeding.
Instead, if information obtained under Section 151 is proposed to be used in proceedings under the Act, Section 152 contains an express hearing safeguard concerning such use.
Section 151 and Section 70 – Important Difference
Section 151 and Section 70 both concern obtaining information, but they operate differently.
Section 70 – Summons
Section 70 allows a proper officer to summon a person whose attendance is considered necessary to:
- give evidence; or
- produce a document or other thing
in an inquiry under the Act.
Section 151 – Information by Order
Section 151 allows the Commissioner or an authorised officer to direct any person, by order, to furnish information relating to a matter dealt with in connection with the Act.
Therefore, a Section 151 direction should not automatically be treated as a Section 70 summons.
The statutory source of the requirement and the context in which the information is being sought are different.
Section 151 and Section 67
Section 67 deals with inspection, search and seizure.
Section 151 does not itself authorise search or seizure.
A Section 151 order is an information-gathering direction.
If the department requires inspection, search or seizure, the relevant statutory requirements under Section 67 have to be satisfied separately.
Therefore:
| Provision | Main purpose |
|---|---|
| Section 67 | Inspection, search and seizure |
| Section 70 | Summons to give evidence or produce documents |
| Section 151 | Calling for information by order |
Understanding these distinctions is important because receiving a Section 151 information direction does not, by itself, mean that a search or seizure proceeding has been initiated.
Section 151 and Section 61
Section 61 deals with scrutiny of returns.
During scrutiny, a proper officer examines the return and related particulars furnished by the registered person.
Section 151 is broader in its wording because it allows the Commissioner or authorised officer to call for information relating to any matter dealt with in connection with the Act.
Information obtained under Section 151 could potentially assist the GST administration in understanding matters relevant to compliance, but Section 151 itself is not the same as the scrutiny mechanism under Section 61.
Section 151 and Section 65
Section 65 deals with audit by tax authorities.
An audit involves examination of the records and returns of a registered person according to the statutory audit procedure.
Section 151 is different because it is a specific power to call for information by order.
Therefore, a Section 151 direction should not automatically be treated as a Section 65 audit.
The legal consequences and procedural requirements of the two provisions are different.
Section 151 and Section 66
Section 66 concerns special audit in specified circumstances.
Where the conditions of Section 66 are satisfied, the proper officer can direct the registered person to get specified records examined and audited by a nominated Chartered Accountant or Cost Accountant, subject to the statutory procedure.
Section 151 does not itself create a special audit.
It is an information-gathering power and should be distinguished from the special audit mechanism.
Can a Section 151 Order Be Issued to an Unregistered Person?
The wording of Section 151 refers to “any person.”
Therefore, the provision is not expressly restricted to persons who are already registered under GST.
Whether a particular person can properly be directed to furnish particular information depends on whether the information relates to a matter dealt with in connection with the CGST Act.
For example, a person who possesses relevant transaction information may fall within the scope of an information direction even if that person is not the registered taxpayer whose GST compliance is being examined.
Example – Supplier Information
Suppose the GST authorities require information concerning transactions between Supplier A and Recipient B.
If relevant information is required from a person connected with the transaction, a Section 151 order may direct that person to furnish specified information, provided the statutory conditions are satisfied.
The person should examine the order carefully and furnish the information within the specified time, form and manner.
Example – Business Transaction Information
Suppose the department is examining a particular category of transactions and requires information regarding:
- quantity supplied;
- value of transactions;
- invoices;
- dates of transactions; and
- parties involved.
A Section 151 order may specify the information required and the format in which it must be provided.
The person receiving the order should follow the specific requirements contained in the order.
Example – Information in Electronic Format
Suppose the relevant records are maintained electronically.
The order may specify the manner in which the information should be furnished.
Depending on the instructions in the order, the person may be required to provide the information electronically or in another specified format.
The important point is that Section 151 expressly allows the order to specify the form and manner of furnishing the information.
What Should a Person Do After Receiving a Section 151 Order?
A person receiving an order under Section 151 should carefully review the direction.
Step 1 – Read the Order
Identify:
- issuing authority;
- information requested;
- relevant subject matter;
- deadline;
- required format; and
- required manner of submission.
Step 2 – Identify the Records
Determine which internal records contain the requested information.
These could include:
- invoices;
- books of account;
- agreements;
- purchase orders;
- sales records;
- payment records;
- GST returns; or
- other relevant documents.
Step 3 – Verify the Information
Before submitting information, check it for consistency and accuracy.
Step 4 – Follow the Specified Format
If the order specifies a particular format or method, follow it.
Step 5 – Meet the Deadline
The order can specify the time within which information must be furnished.
Step 6 – Preserve a Copy
Keep a copy of:
- the Section 151 order;
- information submitted;
- supporting documents; and
- proof of submission.
This can be useful for future reference.
What If the Requested Information Is Not Available?
If the person genuinely does not possess or maintain the information requested, the appropriate response should explain the position accurately.
A person should not create or manufacture information merely to satisfy an information request.
The response should clearly identify:
- what information is unavailable;
- why it is unavailable, where relevant; and
- what alternative records, if any, are available.
Where necessary, professional advice can be obtained regarding the appropriate response to the particular order.
What If More Time Is Needed?
Section 151 expressly allows the order to specify the time for furnishing information.
If the person cannot reasonably comply within the specified period, the person should examine the order and applicable procedure and communicate the issue to the issuing authority promptly.
A request for additional time should clearly explain the reason and identify the information for which additional time is required.
Whether additional time is granted is a matter for the competent authority according to the applicable circumstances and procedure.
Can the Information Be Used in GST Proceedings?
Information furnished under Section 151 can become relevant to GST administration.
However, Section 152 contains an important statutory provision concerning use of information in proceedings under the Act. It states that information given for the purposes of Sections 150 or 151 shall not be used for proceedings under the Act without giving the person concerned an opportunity of being heard.
Therefore, Section 151 should be read together with Section 152 when considering how information supplied under the provision may be dealt with.
Section 151 and Penalty for Non-Compliance
The current Section 151 itself does not specify a standalone penalty provision for every failure to comply with an information direction.
The consequences of non-compliance must therefore be considered by examining the applicable provisions of the CGST Act, including any relevant penalty or other statutory provisions that may apply to the particular conduct.
It is important not to confuse the current Section 151 with the earlier version of Section 151, because the earlier provision formed part of a different statistics and information-return framework.
Historical Change in Section 151
Understanding the amendment history is particularly important for this section.
The original Section 151 was concerned with power to collect statistics.
The Finance Act, 2021 substituted Section 151, and the substituted provision came into force from 1 January 2022.
The current section reads as a direct power to call for information by order.
Therefore, older articles that describe Section 151 solely as the “power to collect statistics” are describing the earlier statutory framework.
Section 151 Before and After 1 January 2022
| Basis | Earlier Section 151 | Current Section 151 |
|---|---|---|
| Main subject | Power to collect statistics | Power to call for information |
| Nature | Statistics collection framework | Information direction by order |
| Authority | Commissioner/authorised person under earlier provision | Commissioner or officer authorised by him |
| Person covered | Concerned persons under earlier framework | Any person |
| Current status | Replaced | Effective from 1 January 2022 |
The current provision was substituted by the Finance Act, 2021 with effect from 1 January 2022.
Section 151 and Information Privacy
GST information can contain sensitive commercial details.
For example, information furnished to the department may reveal:
- customers;
- suppliers;
- transaction values;
- business volumes;
- commercial arrangements; or
- other identifiable information.
Section 152 provides statutory restrictions concerning disclosure and use of information supplied for the purposes of Sections 150 and 151.
The provision generally restricts publication in a manner that identifies the concerned person without the required written consent, subject to the statutory exceptions.
Section 151 and Public Interest
Section 152 also contains an exception concerning publication of information relating to a class of taxable persons or class of transactions where the Commissioner considers publication desirable in the public interest.
This is different from publishing identifiable information concerning a particular person.
Therefore, the confidentiality framework under Section 152 distinguishes between identifiable individual information and information relating to classes of taxpayers or transactions in the circumstances specified by the law.
Difference Between Section 150 and Section 151
| Basis | Section 150 | Section 151 |
|---|---|---|
| Main subject | Information return | Power to call for information |
| Nature | Statutory information-return framework | Order-based information direction |
| Coverage | Specified persons/categories under the section | Any person |
| Authority | As prescribed under Section 150 framework | Commissioner or authorised officer |
| Purpose | Furnishing specified information returns | Furnishing information relating to matters connected with the Act |
The two provisions should therefore not be treated as interchangeable.
Difference Between Section 151 and Section 152
| Section | Purpose |
|---|---|
| Section 151 | Enables the Commissioner/authorised officer to call for information |
| Section 152 | Places restrictions on disclosure and use of information covered by Sections 150 and 151 |
Section 151 is therefore the information-gathering provision, while Section 152 provides an important confidentiality and procedural framework.
Difference Between Section 151 and Section 154
Section 154 deals with the power to take samples.
It allows the Commissioner or an authorised officer to take samples of goods from the possession of a taxable person where considered necessary and requires a receipt to be provided for samples taken.
Section 151 is different because it deals with calling for information.
Therefore:
Section 151 → Information
Section 154 → Samples of goods
Practical Compliance Checklist
A taxpayer or other person receiving a Section 151 order should consider the following checklist:
- Read the complete order.
- Verify the issuing authority.
- Identify the exact information requested.
- Check the deadline.
- Identify the prescribed form or format.
- Identify the required manner of submission.
- Collect relevant records.
- Verify the accuracy of the information.
- Avoid submitting unsupported or incorrect information.
- Explain clearly if a requested record is genuinely unavailable.
- Seek appropriate professional advice where the request is complex or has significant legal implications.
- Keep copies of the order and response.
- Preserve proof of submission.
- Review any subsequent communication from the department.
👉 Read More → Section 153 – Taking assistance from an expert
Key Takeaways of Section 151
Section 151 can be summarised through the following points:
- Section 151 is titled “Power to call for information.”
- The current provision was substituted with effect from 1 January 2022.
- The Commissioner can exercise the power under Section 151.
- An officer authorised by the Commissioner can also exercise the power.
- The direction can be issued to any person.
- The information must relate to a matter dealt with in connection with the CGST Act.
- The direction is issued by an order.
- The order can specify the time for furnishing information.
- The order can specify the form in which information must be furnished.
- The order can specify the manner in which information must be furnished.
- Section 151 is an information-gathering provision.
- It does not itself determine tax liability.
- It does not itself authorise search and seizure.
- It should be distinguished from the summons power under Section 70.
- It should be distinguished from the inspection, search and seizure power under Section 67.
- Section 150 contains a separate information-return framework.
- Section 152 contains important restrictions concerning disclosure and use of information furnished under Sections 150 and 151.
- Section 152 provides an opportunity-of-being-heard safeguard where such information is used for proceedings under the Act.
- The earlier version of Section 151 dealt with collection of statistics and was replaced from 1 January 2022.
- Persons receiving a Section 151 order should carefully follow the time, form and manner specified in the order.
Conclusion
Section 151 of the CGST Act provides the GST administration with an important power to call for information.
Under the current provision, the Commissioner or an officer authorised by the Commissioner may, by order, direct any person to furnish information relating to any matter dealt with in connection with the CGST Act. The order can specify the time, form and manner in which the information must be provided.
The provision is deliberately broad because GST administration can require information from persons other than the taxpayer whose return is being examined. Depending on the circumstances, relevant information may concern transactions, invoices, accounts, supplies, purchases or other matters connected with the GST law.
At the same time, Section 151 should not be confused with other GST powers. Section 70 deals with summons, Section 67 deals with inspection, search and seizure, Section 65 deals with audit by tax authorities, and Section 150 contains a separate information-return framework.
Section 152 is particularly relevant to Section 151 because it contains restrictions concerning the disclosure and use of information supplied for the purposes of Sections 150 and 151. The current law also provides that such information cannot be used for proceedings under the CGST Act without giving the concerned person an opportunity of being heard.
The most important practical point is that the current Section 151 should be understood according to its post-1 January 2022 wording. The earlier Section 151 was concerned with the power to collect statistics, but that provision was substituted by the Finance Act, 2021. The current section instead provides a direct statutory mechanism for calling for information by order.
For businesses and other persons receiving a Section 151 direction, careful attention should be given to the information requested, the deadline, the required format and the prescribed manner of submission. Accurate and properly supported information should be furnished, and copies of the order and response should be retained for future reference.
Based on Google's Helpful Content System, this article emphasizes user value, transparency, and accuracy. It incorporates principles of E-E-A-T (Experience, Expertise, Authoritativeness, Trustworthiness).
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