Chapter XVI - Procedure for Assessment
Section 301
Section 301: meaning of block period, search, requisition and undisclosed income
Section 301 is a definitions section. It sets out what certain terms mean wherever they are used in the Act's provisions dealing with assessment following an income-tax search or requisition of books, documents or assets - most importantly, what counts as the 'block period' and what counts as 'undisclosed income' for that block period.
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Need advice on Section 301?
This article is for general information. Refer to the Income-tax Act, 2025 as amended by the Finance Act, 2026 and the Taxation and Other Laws (Amendment) Act, 2026 for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
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.
Introduction
Section 301 defines the block period, search, requisition and undisclosed income terms used by the special assessment provisions.
These definitions control the year range and evidence base for a block assessment.
Key takeaways
Block-period definition
The defined period covers the six preceding tax years plus the relevant part of the tax year of search or requisition.
Search and requisition are specified
The terms connect to searches under section 247 and requisitions under section 248.
Undisclosed income includes records and assets
The definition addresses unreported assets, expenditure and entries or transactions found through the statutory process.
Block period
"Block period" means the aggregate of two stretches of time: (i) the six tax years preceding the tax year in which the search was initiated or the requisition was made; and (ii) the period starting from 1st April of the tax year in which the search was initiated or requisition was made, and ending on the date the last of the authorisations for that search or requisition was executed.
Search, requisition and "the last of the authorisations"
"Search" means a search initiated under section 247, and "requisition" means requisition of books of account, other documents or any assets under section 248.
"The last of the authorisations" is deemed to have been executed:
- In the case of a search - on conclusion of the search, as recorded in the last panchnama drawn in relation to any person in whose case the warrant of authorisation was issued, whether or not any seizure is recorded in that panchnama.
- In the case of a requisition - on the actual receipt of the books of account, other documents or assets by the Authorised Officer.
Undisclosed income
"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 that money, bullion, jewellery, virtual digital asset, valuable article, thing, entry or transaction represents wholly or partly income or property that has not been, or would not have been, disclosed for the purposes of the Act, or any expense, exemption, deduction or allowance claimed under the Act that is found to be incorrect - in each case in respect of the block period.
Step-by-step flow for applying the definitions in Section 301
- 1
Was there a search or a requisition as defined?
"Search" means a search initiated under Section 247; "requisition" means a requisition of books, documents or assets under Section 248 (Section 301(b) and (c)).
- No: The block-period definitions in Section 301 are not triggered.
- Yes: Go to the next step.
- 2
Find the tax year in which the search was initiated or requisition made
This is the anchor year for the block period.
- 3
Take the six preceding tax years
Section 301(a)(i) includes the six tax years before the anchor year.
- 4
Add the current-year period
Section 301(a)(ii) adds the period from 1 April of the anchor year to the date the last of the authorisations is executed. Under Section 301(d), that is the conclusion of the search recorded in the last panchnama (seizure or not), or, for a requisition, actual receipt of the books, documents or assets by the Authorised Officer.
- 5
Test each item against "undisclosed income"
Section 301(e) covers money, bullion, jewellery, virtual digital assets, other valuables, expenditure, or income based on entries or transactions that represent undisclosed income or property, and any expense, exemption, deduction or allowance found incorrect, for the block period.
Practical checklist
Do
- Use the statutory definition when setting the first and last years of the block period.
- Keep the search or requisition authorisation record for the relevant date calculation.
Avoid
- Substitute an informal search date or generic meaning of undisclosed income for the defined terms.
Illustrative example
Worked example: working out a block period
Hypothetical facts (illustration only, not a real taxpayer): A search under Section 247 is initiated at a jeweller's premises on 12 November 2026. The last panchnama, recording the conclusion of the search, is drawn on 18 November 2026. Unrecorded cash is found, and a deduction claimed in an earlier return is found to be incorrect.
Anchor year
The search falls in the tax year beginning on 1 April 2026.
Six preceding years
Under Section 301(a)(i), the six tax years before it are those beginning on 1 April 2020, 2021, 2022, 2023, 2024 and 2025.
Current-year period
Under Section 301(a)(ii) and (d)(i), the period runs from 1 April 2026 to 18 November 2026, the date of the last panchnama.
Items
The cash and the incorrect deduction both fall within the Section 301(e) meaning of undisclosed income, as they relate to the block period.
Outcome
- The block period is the six tax years beginning 1 April 2020 to 1 April 2025, plus 1 April 2026 to 18 November 2026.
- Section 295(2) has its own block-period rules where the income belongs to another person.
Frequently asked questions
What is the "block period" under Section 301?
It is the six tax years preceding the year of the search or requisition, plus the part of the year of search/requisition itself running from 1st April up to the date the last authorisation for the search or requisition was executed.
Does a virtual digital asset count as undisclosed income?
Yes - Section 301's definition of "undisclosed income" expressly includes a virtual digital asset, alongside money, bullion, jewellery and other valuable articles or things, where it represents income or property not disclosed for the purposes of the Act.
When is "the last of the authorisations" treated as executed?
For a search, on conclusion of the search as recorded in the last panchnama for the person named in the warrant. For a requisition, on the actual receipt of the books of account, documents or assets by the Authorised Officer.
Can an incorrect deduction claim be undisclosed income under Section 301?
Yes. Section 301(e) includes any expense, exemption, deduction or allowance claimed under the Act which is found to be incorrect, in respect of the block period.
Need help applying this provision to your situation?
Get help responding to a search or requisition assessmentLast updated 9 October 2026