Section 301 of Income Tax Act 2025: What Is Block Period and Undisclosed Income?
Section 301 defines the essential expressions used for search-related block assessments, including the block period, search, requisition, the last authorisation and undisclosed income.
What does Section 301 cover?
Section 301 is an interpretation provision for the block-assessment Part of Chapter XVI. It explains how the relevant time period is determined, what constitutes a search or requisition, when the final authorisation is treated as executed, and what may fall within undisclosed income. It must be read with the operative block-assessment provisions, particularly Sections 292 to 300.
Definitions under Section 301
1. Block period - Section 301(a)
The block period is the aggregate of (i) the six tax years preceding the tax year in which a search is initiated or a requisition is made and (ii) the period beginning on 1 April of the tax year of the search or requisition and ending on the date of execution of the last authorisation.
Thus, it includes six preceding tax years and the relevant portion of the current tax year, rather than automatically seven complete tax years.
2. Requisition - Section 301(b)
A requisition means the requisition of books of account, other documents or assets under Section 248. It is distinct from the physical conduct of a search.
3. Search - Section 301(c)
A search means a search initiated under Section 247. The statutory definition ties the block-assessment framework to the search power provided by that section.
4. Last of the authorisations - Section 301(d)
For a search, the last authorisation is deemed executed when the search concludes as recorded in the last panchnama drawn for a person covered by the warrant, whether or not any seizure is recorded. For a requisition, it is deemed executed on actual receipt of the books, documents or assets by the Authorised Officer.
This date matters because it fixes the endpoint of the current-year component of the block period.
5. Undisclosed income - Section 301(e)
The inclusive definition covers money, bullion, jewellery, virtual digital assets, other valuable articles or things, expenditure and income reflected in books, documents or transactions where they represent, wholly or partly, income or property not disclosed or that would not have been disclosed for income-tax purposes. It also includes an expense, exemption, deduction or allowance claimed under the Act that is found to be incorrect in respect of the block period.
The actual determination and computation of undisclosed income must follow the applicable block-assessment provisions and the evidence in the case.
Example: how is the block period calculated?
Illustration: Assume a search is initiated during tax year 2026-27 and the last search authorisation is executed on 15 September 2026. The block period ordinarily comprises the six preceding tax years, 2020-21 through 2025-26, together with 1 April 2026 to 15 September 2026.
This example assumes a straightforward search and is for explanation only; the actual dates and statutory facts control.
Why are these definitions important?
- Period of examination: The definition of block period sets the temporal boundaries of the special assessment.
- Evidence and records: The last panchnama or actual receipt record can be material to determining the terminal date.
- Digital assets: Virtual digital assets are expressly included in the inclusive definition of undisclosed income.
- Incorrect claims: Incorrect expenses, exemptions, deductions or allowances may fall within the definition, subject to the governing assessment provisions.
- Related sections: Section 292 addresses assessment of total undisclosed income, Section 293 its computation, and Section 294 the procedure.
Frequently asked questions
Does the block period always mean seven complete years?
No. It consists of six preceding tax years plus the specified part of the tax year in which the search or requisition occurs.
Does Section 301 itself impose a tax or penalty?
No. It provides definitions. The applicable assessment, tax, interest and penalty provisions must be considered separately.
Can undisclosed income include virtual digital assets?
Yes. Virtual digital assets are expressly mentioned in Section 301(e), subject to the conditions in the definition and the applicable provisions.
Does a panchnama need to record a seizure to count?
No. For the statutory last-authorisation rule, Section 301(d) expressly states that the last panchnama can be relevant irrespective of whether a seizure is recorded.
Official statutory sources
Read the consolidated Income-tax Act, 2025, as amended by Finance Act, 2026 and the Income Tax Department's Act and Rules resource page. Consult the official text for any subsequent amendments and case-specific application.
Last reviewed: 11 November 2026. This article provides general legal information and is not a substitute for professional advice.