Section 301 — Block Period Interpretation | ITA 2025

Section 301 — - INTERPRETATION (BLOCK ASSESSMENT)

Section 301 is the substantive equivalent of 1961 s. 158B -- the DEFINITIONAL ANCHOR for block-assessment provisions ss. 292-300 (1961 ss. 158BA-158BH). Defines critical terms: 'BLOCK PERIOD' (typically 6 / 10 years preceding search); 'UNDISCLOSED INCOME' (income not disclosed in original returns); 'PREVIOUS YEAR' (relevant tax years); various other operational terms. Critical for substantive application of search-led tax framework.

Statutory text — Income-tax Act, 2025

Marginal note -- Interpretation

For the purposes of this Part—

(a) “block period” means the aggregate of—

(i) the period comprising six tax years preceding the tax year in which the search was initiated or any requisition was made; and

(ii) the period starting from the 1st April of the tax year in which search was initiated or requisition was made and ending on the date of the execution of the last of the authorisations for such search or such requisition;

(b) “requisition” means requisition of books of account, other documents or any assets under section 248;

(c) “search” means a search initiated under section 247;

(d) “the last of the authorisations” shall be deemed to have been executed,—

(i) in the case of search, on the conclusion of search as recorded in the last panchnama drawn in relation to any person in whose case the warrant of authorisation has been issued, irrespective of whether or not any seizure is recorded in such panchnama;

(ii) in the case of requisition, on the actual receipt of the books of account or other documents or assets by the Authorised Officer;

(e) “undisclosed income” includes any money, bullion, jewellery, virtual digital asset or other valuable article or thing or any expenditure or any income based on any entry in the books of account or other documents or transactions, where such money, bullion, jewellery, virtual digital asset, valuable article, thing, entry in the books of account or other document or transaction represents wholly or partly income or property which has not been or would not have been disclosed for the purposes of this Act, or any expense, exemption, deduction or allowance claimed under this Act which is found to be incorrect, in respect of the block period. CHAPTER XVII SPECIAL PROVISIONS RELATING TO CERTAIN PERSONS A.—Association of persons, firm, Hindu undivided family, etc. 1.—Legal representatives Legal representative.

Corresponding provision — 1961 regime

INCOME-TAX ACT, 2025	INCOME-TAX ACT, 1961
INCOME-TAX ACT, 2025 -- s. 301	INCOME-TAX ACT, 1961 -- s. 158B
Block period definition	1961 s. 158B(a)
Undisclosed income definition	1961 s. 158B(b)
Previous year for block	1961 s. 158B(c)

KEY DEFINITIONS: (I) BLOCK PERIOD: (a) NORMAL CASES: 6 years preceding the year of search + portion of current year up to search date; (b) HIGH-VALUE CASES (escapement > INR 50 lakh): 10 years preceding (FA 2024 reduced from earlier 16 years); (II) UNDISCLOSED INCOME: income / assets not disclosed in original returns / under-disclosed; covers cash / bullion / jewellery / unaccounted business profits / unaccounted CG / etc.; (III) PREVIOUS YEAR: relevant tax year per Indian tax calendar. PRACTITIONER: review block period scope carefully; quantum determines window (50 lakh threshold critical).

CROSS-REFERENCES

Section 192 -- 60% block tax.
Section 247 -- Search.
Section 292-300 -- Block-assessment substantive framework.

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