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Case lawIncome-tax Act 2025Chapter XVI › Section 294
Chapter XVIwas s.158BC

Section 294 of the Income-tax Act, 2025

Section 294 — Procedure for block assessment. Successor to s.158BC of the 1961 Act.

Where this section sits

Section 294 is in Chapter XVI — Procedure for Assessment, which runs from section 268 to section 301.

← Section 293  ·  Section 295 →

What this section does

Sub-section (1) governs what follows a search or requisition. Clause (a) requires the Assessing Officer to issue a notice calling for a return, in the prescribed form and verification, of undisclosed income for the block period, within a period specified in the notice not exceeding sixty days. Five consequences follow: the return is considered as if furnished under section 263 and a notice under section 270(8) is then issued; a return furnished beyond the period allowed is not deemed to be a return under section 263; no notice under section 280 is required for a proceeding under this part; the person cannot furnish a revised return; and the time may be extended by a further thirty days where, for the tax year immediately preceding the search or requisition, the return due date had not expired before it began, the assessee was liable for audit under section 63 for that year, those accounts had not been audited on the date of the notice, and the assessee requests the extension in writing to get them audited.

Clause (b) requires the Officer to determine the total undisclosed income of the block period in the manner laid down in section 293, with sections 268, 270(8), 270(10), 271, 276, 277 and 278 applying so far as may be. Clause (c) requires an order of assessment or reassessment determining the tax payable, and provides that section 275 shall not apply to it. Clause (d) applies section 250 to assets seized under section 247 or requisitioned under section 248.

Sub-section (2) disapplies section 270(1) to a return furnished under this section. Sub-section (3) requires the prior approval of the Additional Commissioner, Additional Director, Joint Commissioner or Joint Director before the notice under sub-section (1)(a) is issued.

Why it is there

After a search the Department has material for several years at once, and block assessment lets it be dealt with in a single proceeding rather than by reopening year by year. The section supplies the procedure for that route and says what ordinary machinery is switched off. The prior approval in sub-section (3) is the check on the notice being issued at all.

Who it applies to

The figures, and what each one turns on

Read the condition in the same row. A figure quoted without it is a wrong answer with a citation attached.
WhatFigureThe condition on itWhere
Maximum period the notice may allow for the block returnA period specified in the notice, not exceeding sixty daysSixty days is a ceiling on what the notice may allow; the notice may specify lessSub-section (1)(a)
Extension of the time to furnish the block returnA further period of thirty daysOnly where all four conditions in items (A) to (D) are met, including a written request by the assessee to get the unaudited accounts auditedSub-section (1)(a)(v)

What this means in practice

Sixty days is the outer limit of what the notice may allow, not an entitlement, and the consequence of missing the period is severe: a return filed beyond it is not deemed to be a return under section 263 at all. Nor can a block return be corrected — item (iv) removes the right to revise, so the first filing is the only one. The thirty-day extension is cumulative in its conditions and the last of them requires a written request from the assessee, so it is not granted on the Officer's own motion. Two ordinary safeguards are switched off: no section 280 notice is required, and section 275 does not apply to the block assessment order. The protection added is in sub-section (3), and it is a condition precedent — the approval must be taken before the notice issues.

An example

Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.

A search is initiated in the case of a firm. The Assessing Officer, after the Joint Commissioner's prior approval, issues a notice allowing forty-five days — within the sixty-day ceiling — for a block return of undisclosed income. The firm was liable for audit under section 63 for the immediately preceding tax year, whose return due date had not expired when the search began, and those accounts were unaudited on the date of the notice; it applies in writing for time to get them audited, and the period may be extended by thirty days. If it files after the period allowed, the return is not deemed to be one under section 263, and it cannot cure that by revising.

Where you meet this section

You meet this section as the notice following a search or requisition, calling for a return of undisclosed income for the block period within the period the notice specifies, and then as the block assessment or reassessment order passed under clause (c).

The words themselves

requiring him to furnish within a period specified in the notice, not exceeding sixty days, a return in the form and verified in the manner, as may be prescribed, setting forth his undisclosed income, for the block period
Section 294(1)(a), Income-tax Act, 2025.
any return furnished beyond the period allowed in the notice shall not be deemed to be a return under section 263
Section 294(1)(a)(ii), Income-tax Act, 2025.
a person who has furnished a return under this clause shall not be entitled to furnish a revised return
Section 294(1)(a)(iv), Income-tax Act, 2025.

What people get wrong

What this replaced

The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.

See the full 1961 to 2025 concordance.

Rules that serve this section

Rules of the Income-tax Rules, 2026 that work section 294. Where the rule’s own heading names the section we say so; the rest are marked on reading the rule, which is our derivation and not the department’s. A rule that serves the section silently and that we have missed will not appear here.

All of them are in the Rules 2026 index.

Case law carried across

Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 294. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.

Explainers

Read with

What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.