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.
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.
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.
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Get help responding to a search or requisition assessmentLast updated 9 September 2026