TaxTMI 
TaxTMI 
Comparison of section 294 "Procedure for block assessment." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)
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....on and the Income-tax Department. Effective date or decision date: Not stated in the document. Background & Scope Statutory hooks: Clause 294, Income Tax Bill, 2025 (Old Version). Context: procedure to be followed where a search has been initiated or requisition made. Coverage: issuance of notice requiring a return for the block period, treatment of such return, procedural cross-references for assessment and penalties, treatment of seized/requisitioned assets, and prior approval before issuing notice. Definitions or further explanations: Not stated in the document. Statutory Provision Mode Text & Scope * Clause 294 addresses situations where a search is initiated or requisition made. The Assessing Officer (AO) must issue a notice requ....
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....earches/requisitions, by compelling a targeted return within a strict timeframe, limiting revision rights, and specifying which procedural and penal provisions apply. The treatment of such returns "as if" u/s 263 suggests an intent to subject such returns to a particular return regime while ensuring downstream procedure u/s 270(8). The prohibition on revision and on section 270(1) suggests an intent to fix the record and limit post-disclosure tinkering. The requirement for prior supervisory approval indicates a policy of internal checks before initiating the block return procedure. Exceptions/Provisos Carve-outs and conditions in the Clause: (i) Section 275 does not apply to orders passed under this Clause; (ii) where assessment/reassessm....
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....requires issuance of notice u/s 270(8), and prescribes that several other specified sections "shall, so far as may be, apply" (268, 270(8), 270(10), 271, 276, 287, 288). The Clause excludes application of section 275 to resulting orders and excludes section 270(1) from application to the special return. The Clause further references sections 247, 248 and 250 for treatment of seized/requisitioned assets and section 295 for block-period alignment. Any rules, notifications or circulars beyond these sections: Not stated in the document. Differences between the two provisions and practical impact of each change * Content of the return required: The Bill (Clause 294 - Old Version) requires the assessee to furnish "a return ... setting forth hi....
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....s the provisions to be applied "so far as may be" as sections 268, 270(8), 270(10), 271, 276, 287 and 288. The Act lists sections 268, 270(8), 270(10), 271, 276, 277 and 278. * Practical impact: Different cross-references change which penalty, prosecution or procedural provisions are available. The Bill's inclusion of sections 287 and 288 (and omission of 277/278) would have applied different penal/process provisions than the Act's choice of 277 and 278. This affects potential penalties, prosecution exposure, and consequential procedural steps; taxpayers and authorities will need to re-evaluate the risk/relief profile as per the final list. * Returns filed beyond the time allowed - cross-reference discrepancy: The Bill states th....
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....under this Chapter"; the Act uses "as may be prescribed" and "under this part." * Practical impact: Largely stylistic; however, "as may be prescribed" can be read as preserved legislative discretion. The chapter/part wording difference is terminological and unlikely to have substantive legal effect but should be noted for drafting clarity. * Common features preserved: Both versions require prior approval of an Additional Commissioner/Additional Director/Joint Commissioner/Joint Director before issuance of the notice; both disallow revision of a return filed under the provision; both state no notice u/s 280 is required for proceeding. * Practical impact: These consistent elements preserve administrative checks and constrain assessee....