Section 301 — Interpretation. Successor to s.158B of the 1961 Act.
Section 301 is in Chapter XVI — Procedure for Assessment, which runs from section 268 to section 301.
The section defines five expressions for the Part dealing with search and requisition assessments. Clause (a) defines "block period" as the aggregate of the six tax years preceding the tax year in which the search was initiated or the requisition made, plus the period from 1 April of that tax year to the date of execution of the last of the authorisations. Clauses (b) and (c) tie "requisition" to section 248 and "search" to section 247. Clause (d) fixes when the last of the authorisations is deemed executed — for a search, on conclusion of the search as recorded in the last panchnama drawn in relation to any person in whose case the warrant was issued, whether or not any seizure is recorded in it; for a requisition, on actual receipt of the books, documents or assets by the Authorised Officer. Clause (e) defines "undisclosed income" to include money, bullion, jewellery, virtual digital asset or other valuable article or thing, and any expenditure or income based on an entry in the books or other documents or transactions, representing wholly or partly income or property not disclosed or that would not have been disclosed, and any expense, exemption, deduction or allowance claimed which is found to be incorrect, in respect of the block period.
Search assessments operate over a composite period rather than a single year, and the whole Part depends on knowing exactly how long that period is and what falls into it; this section fixes both, and pins the closing date to an identifiable event on the record.
| What | Figure | The condition on it | Where |
|---|---|---|---|
| Years included in the block period before the year of search or requisition | 6 tax years | The six tax years preceding the tax year in which the search was initiated or the requisition made | Clause (a)(i) |
| Start of the part-year included in the block period | 1 April of the tax year of search or requisition | Running to the date of execution of the last of the authorisations for the search or requisition | Clause (a)(ii) |
The block period is not a round number of years: it is six full tax years plus a broken period beginning on 1 April of the year of the search and ending on the date the last authorisation is executed, so the end date depends on the last panchnama rather than on any assessment step. That date is decided by clause (d): for a search, the conclusion recorded in the last panchnama drawn in relation to any person covered by the warrant, whether or not it records a seizure — so a nil panchnama still closes the period. "Undisclosed income" here is wider than concealed receipts; it expressly takes in an expense, exemption, deduction or allowance claimed and found to be incorrect.
A search is initiated on a company in a tax year and the last panchnama is drawn on 20 August of that year. The block period is then the six tax years preceding that year plus the stretch from 1 April of the year of search to 20 August — not seven whole tax years. The panchnama fixes that end date even where it records no seizure at all, clause (d)(i) making conclusion of the search as recorded in the last panchnama the decisive event. What has to be accounted for over that period is not only unrecorded cash, jewellery or a virtual digital asset but any deduction, exemption or allowance claimed in those years that turns out to be incorrect.
A reader does not meet section 301 directly; it supplies the vocabulary of the block assessment. Its definitions decide the span covered by the notice under section 294(1)(a), the date the panchnama fixes, and what the block period assessment order can treat as undisclosed income.
the period comprising six tax years preceding the tax year in which the search was initiated or any requisition was made
See the full 1961 to 2025 concordance.