VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — the block charge: sixty per cent under section 113, interest at one and a half per cent, and a flat fifty per cent penalty under section 158BFA(2)
CBDT Circulars & InstructionsCuts both wayss.113s.158BFAs.158BCs.158BAs.271AADs.271Ds.271DAs.271Es.132Bs.246As.253s.263

Statutory position — the block charge: sixty per cent under section 113, interest at one and a half per cent, and a flat fifty per cent penalty under section 158BFA(2)

What will a block assessment actually cost my client, and is there any way to keep the penalty off?

What will a block assessment actually cost my client, and is there any way to keep the penalty off?

Tax at sixty per cent of the total undisclosed income of the block period under section 113, plus surcharge under the proviso; interest under section 158BFA(1) at one and a half per cent per month where the block return is late or not filed; and a penalty under section 158BFA(2) of a sum 'equal to fifty per cent of tax so leviable' on the undisclosed income determined by the Assessing Officer. The first proviso to section 158BFA(2) gives complete immunity from that penalty, and from penalty under sections 271AAD(1), 271D, 271DA and 271E for the block period, if four conditions are met — the return was furnished under section 158BC(1)(a), the tax on it was paid or the seized money offered for adjustment, evidence of payment accompanied the return, and no appeal is filed against the assessment of the income shown in the return.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2024-09-01, reported as Income-tax Act 1961, s.113 as amended by the Finance (No. 2) Act 2024 (Act No. 15 of 2024) w.e.f. 1 September 2024 and by the Finance Act 2025 (Act No. 7 of 2025) w.r.e.f. 1 September 2024; s.158BFA substituted w.e.f. 1 September 2024 by s.49 of the Finance (No. 2) Act 2024. It bears on section 113, section 158BFA, section 158BC, section 158BA, section 271AAD, section 271D, section 271DA, section 271E, section 132B, section 246A, section 253, section 263 of the Income Tax Act 1961, in Search, Survey & Block Assessment, Penalty, Assessment & Scrutiny and How Tax Law Is Read matters.

Still good law. In force for a search initiated on or after 1 September 2024. Two of the corroborating URLs above are ARCHIVED versions (section 158BFA stamped Year 2019 (No. 1) and section 113 stamped Year 2015) and are cited only to show the superseded text; they must not be used to state the present law. Validity check could not be completed on an independent route: no decision applying the substituted section 158BFA or the amended section 113 was located, and no judgment reproducing either was found. CIT v Vatika Township, which is already in this library, is authority on the surcharge proviso to section 113 as it stood before the 2024 amendment, and the words it construed have since been omitted.

Why it matters

Three things have changed and each is worth money. First, the penalty is no longer a range. The 1995 section 158BFA(2) allowed a penalty of not less than the tax and not more than three times the tax; the substituted sub-section fixes a single figure — fifty per cent of the tax leviable on the undisclosed income determined. The Assessing Officer or the Commissioner (Appeals) 'may direct' the penalty, so the discretion is whether to levy at all, not how much. Second, the immunity in the first proviso is now expressly extended to sections 271AAD(1), 271D, 271DA and 271E for the block period, which is a real prize: the fake-invoice penalty and the cash loan, cash receipt and cash repayment penalties all fall away if the four conditions are met. But the price is that no appeal may be filed against the assessment of the income shown in the return, and the second proviso confines the immunity anyway to the income shown — anything the officer determines in excess of the returned figure is exposed to penalty on that excess. Third, section 113 has been trimmed: the words that tied the surcharge to the Central Act 'applicable in the assessment year relevant to the previous year in which the search is initiated' have been omitted with effect from 1 September 2024, so the surcharge limb no longer carries the year-linkage that CIT v Vatika Township was about. Interest has come down from two per cent to one and a half per cent a month, but the period has been lengthened: it now runs to the date the assessment is completed in every case, whereas the old provision stopped it at the date a late return was filed.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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Related

Other authorities on the same sections.