Income Tax Act 2025: Section 301 for Tax Year 2026-27

Interpretation

[Section-301 as per the Income Tax Act, 2025 (this Act) w.e.f. 1st April, 2026.]

In this Chapter––

• (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) “requisitioned items” means the books of account, or other documents or money or bullion or jewellery or other valuable article or thing requisitioned under section 248;
• (d) “search” means a search initiated under section 247;
• (e) “seized items” means the books of account, or other documents or money or bullion or jewellery or other valuable article or thing seized under section 247;
• (f) “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; and
• (g) “undisclosed income” includes––
  • (i) 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, in respect of the block period; or
  • (ii) any expense, exemption, deduction or allowance claimed under this Act which is found to be incorrect, in respect of the block period.

FAQs on Section 301 of Income Tax Act 2025

What does the term “block period” mean under Section 301?
“Block period” refers to the combined duration of six tax years preceding the year in which a search or requisition was initiated, plus the period from April 1 of the year of such search/requisition until the execution of the last authorisation related to it.

What is meant by “search” in this section?
“Search” refers to a search initiated under Section 247 of the Income Tax Act, 2025.

What is a “requisition” as per this section?
“Requisition” means a formal demand for books of account, other documents, or assets under Section 248.

What are “seized items” under this section?
“Seized items” include books of account, other documents, or assets like money, bullion, jewellery, or other valuable items taken during a search under Section 247.

What are “requisitioned items” according to Section 301?
“Requisitioned items” are books of account, documents, or assets that are formally called for under Section 248.

How is the “last of the authorisations” determined in the case of a search?
It is considered executed on the conclusion of the search, as documented in the final panchnama drawn, regardless of whether any seizure occurred.

How is the “last of the authorisations” determined in the case of a requisition?
It is considered executed when the authorised officer actually receives the requisitioned books, documents, or assets.

What is considered “undisclosed income” under this section?
“Undisclosed income” includes any income or property—such as money, bullion, jewellery, virtual digital assets, or expenditures—not disclosed or that would not have been disclosed under the Act for the block period.

Does incorrect claim of expenses or exemptions qualify as “undisclosed income”?
Yes, any incorrect claim of expense, exemption, deduction, or allowance under the Act for the block period is treated as undisclosed income.

Is a virtual digital asset considered while determining undisclosed income?
Yes, virtual digital assets are explicitly mentioned as part of items that may represent undisclosed income if not properly disclosed.