Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
>
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 TMI Notes - Adv. Search
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----
  • ---- All Laws----
  • Benami Property
  • Bill
  • Central Excise
  • Companies Law
  • Customs
  • DGFT
  • FEMA
  • GST
  • GST - States
  • IBC
  • Income Tax
  • Indian Laws
  • Money Laundering
  • SEBI
  • SEZ
  • Service Tax
  • VAT / Sales Tax
Types:
---- All Types ----
  • ---- All Types ----
  • Act Rules
  • Case Laws
  • Circulars
  • Manuals
  • News
  • Notifications
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
RelevanceDefaultDate
    Summons, Searches and Show Cause Notices - Parallel GST Adjudications: Defining 'Proceedings' u/s 6(...
    Consolidated SCNs, Cross-Examination and the Limits of Writ Relief in GST Adjudication
    Act RulesIncome Tax
    Comparison of SCHEDULE XVI "PERMITTED MODES OF INVESTMENT OR DEPOSITS" between the Income-Tax Act, 2...
    Act RulesIncome Tax
    Comparison of SCHEDULE-XV "DEDUCTION IN RESPECT OF LIFE INSURANCE PREMIA, CONTRIBUTION TO PROVIDENT ...
    Act RulesIncome Tax
    Comparison of SCHEDULE XIV "INSURANCE BUSINESS" between the Income-Tax Act, 2025 (as passed) and the...
    Act RulesIncome Tax
    Comparison of SCHEDULE XI "RECOGNISED PROVIDENT FUNDS" between the Income-Tax Act, 2025 (as passed) ...
    Act RulesIncome Tax
    Comparison of SCHEDULE X "DEDUCTION FOR SITE RESTORATION FUND FOR COMPUTING INCOME UNDER THE HEAD "P...
    Act RulesIncome Tax
    Comparison of SCHEDULE IX "DEDUCTION FOR TEA DEVELOPMENT ACCOUNT, COFFEE DEVELOPMENT ACCOUNT AND RUB...
    Act RulesIncome Tax
    Comparison of SCHEDULE VIII "INCOME NOT TO BE INCLUDED IN THE TOTAL INCOME OF POLITICAL PARTIES AND ...
    Act RulesIncome Tax
    Comparison of SCHEDULE VII "PERSONS EXEMPT FROM TAX" between the Income-Tax Act, 2025 (as passed) an...
    Act RulesIncome Tax
    Comparison of SCHEDULE VI "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF CERTAIN ELIGIBLE PERSONS IN ...
    Act RulesIncome Tax
    Comparison of SCHEDULE V "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF CERTAIN ELIGIBLE PERSONS INCL...
    Act RulesIncome Tax
    Comparison of SCHEDULE IV "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF ELIGIBLE NON-RESIDENTS, FORE...
    Act RulesIncome Tax
    Comparison of SCHEDULE III "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF ELIGIBLE PERSONS" between t...
    Act RulesIncome Tax
    Comparison of SCHEDULE II "INCOME NOT TO BE INCLUDED IN TOTAL INCOME" between the Income-Tax Act, 20...
    Act RulesIncome Tax
    Comparison of SCHEDULE I "CONDITIONS FOR CERTAIN ACTIVITIES NOT TO CONSTITUTE BUSINESS CONNECTION IN...
    Act RulesIncome Tax
    Comparison of section 536 "Repeal and savings." between the Income-Tax Act, 2025 (as passed) and the...
    Act RulesIncome Tax
    Comparison of section 524 "Presumption as to assets, books of account, etc." between the Income-Tax ...
    Act RulesIncome Tax
    Comparison of section 515 "Appearance by authorised representative." between the Income-Tax Act, 202...
    Act RulesIncome Tax
    Comparison of section 511 "Furnishing of report in respect of international group." between the Inco...
❯❯
MaximizeMaximizeMaximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

    +

    Are you sure you want to delete "My most important" ?

    NOTE:

    Notes
    Showing Results for :
    Reset Filters
    Results Found:
    Show All SummariesHide All Summaries
    Case LawsGST
    Show AI Summary
    GST enforcement: summons/searches are investigative; show cause notices mark formal proceedings and define subject matter.
    Issuance of summons, searches and seizures are investigative steps and do not constitute initiation of proceedings; formal adjudicatory commencement is principally the issuance of a show cause notice which defines the subject matter. The subject matter is determined from the show cause notice, and a twofold test-identity of liability on the same facts and identity or overlap of relief sought-governs whether two proceedings are the same. Cross-empowerment permits intelligence-based action by either authority, but parallel adjudications on identical subject matter are barred; authorities must coordinate and share information.
    Case LawsGST
    Show AI Summary
    GST: consolidated SCNs valid for connected-period fraud, cross-examination limited unless prejudice shown.
    The adjudicating authority must consider representations and hearings under section 74(9), but the right to cross-examination in SCN proceedings is not absolute and requires demonstrable prejudice to vitiate adjudication. Sections 73 and 74 allow consolidated SCNs across periods when connected fraudulent invoice chains exist. Orders must remain within the grounds and amounts specified in the SCN, and writ jurisdiction should be declined where an efficacious statutory appeal under section 107 is available absent exceptional circumstances.
    Act RulesIncome Tax
    Show AI Summary
    Permitted Modes of Investment: clarifies eligible instruments for registered non profit funds under section 350 compliance.
    The schedule lists closed, enumerated permitted modes of investment for monies under section 350, privileging government backed and regulated instruments, specified sectoral debt and equity, deposits with public authorities, and notified schemes; it defines key terms (e.g., long term finance as five year minimum) and preserves transitional and historical exceptions including a one year short term holding rule for non specified assets and preservation of corpus assets held on specified historical dates.
    Act RulesIncome Tax
    Show AI Summary
    Deduction for specified payments: qualifying contributions allowed, but breach or early disposal triggers recapture of previously allowed deductions.
    Schedule XV lists payments that qualify for deduction under section 123-notably life insurance premia subject to quantitative ceilings by policy issue date and disability status, specified provident/pension/superannuation contributions, notified securities and mutual fund units, certain term deposits and housing finance repayments-and sets withdrawal and recapture rules whereby surrender, premature transfer, early withdrawal or sale within holding periods causes previously allowed deductions to be treated as income; definitions and eligibility depend on cross-references and delegated notifications.
    Act RulesIncome Tax
    Show AI Summary
    Life insurance taxable profit computed by annual average of actuarial surplus, separate from other business for tax purposes.
    Life insurance taxable profit must be computed separately as the annual average of actuarial surplus from statutory valuations excluding earlier inter-valuation surplus/deficits, with specified add-backs; non-life taxable income is the profit before tax and appropriations per statutory accounts subject to enumerated tax adjustments, and non-resident branch profits may be allocated by India-premium proportion absent suitably reliable alternative data.
    Act RulesIncome Tax
    Show AI Summary
    Recognition conditions for provident funds determine tax treatment and trustee obligations, with investment limits tied to securities definitions.
    Schedule XI conditions tax-favourable treatment of recognised provident, superannuation and gratuity funds on structural and operational criteria (trust form, vesting, non-revocability, employee coverage, permitted assets and payment rules); recognition/approval is discretionary and revocable; failures attract inclusion of accumulated balances or contributions in employee income and procedural obligations such as TDS; trustees face record-keeping, reporting and potential liability, while the Board may make rules subject to statutory limits and section 534 oversight.
    Act RulesIncome Tax
    Show AI Summary
    Deduction for site restoration funds: designated SBI deposits allow capped tax relief but trigger deeming on improper use.
    A deduction permits upstream petroleum and natural gas taxpayers to deduct amounts deposited in designated site restoration accounts held with the State Bank of India, limited to the lesser of actual deposits or 20% of business profits before the deduction; deposits and interest are treated as account balance, withdrawals are restricted to scheme permitted uses, and improper utilisation or account closure triggers deeming provisions or disallowance, with an eight year clawback on asset sales subject to narrow exceptions.
    Act RulesIncome Tax
    Show AI Summary
    Deduction for development account deposits: allowable up to 40% of profits, subject to strict deposit, audit and claw back rules.
    The Schedule allows growers and manufacturers of tea, coffee and rubber to deduct deposits into prescribed development accounts up to the lesser of actual deposits or 40% of business profits, subject to carrying on the specified business in India, depositing funds in specified special or deposit accounts under board or National Bank schemes, and furnishing a prescribed audited report by the specified date; unauthorised withdrawals or use for specified articles are deemed taxable and assets acquired from such funds are subject to claw back if sold or transferred within eight years.
    Act RulesIncome Tax
    Show AI Summary
    Income exclusion for political funding conditioned on transparency, recordkeeping, prescribed receipt modes and distribution obligations.
    The Schedule excludes specified receipts from total income of eligible political parties and electoral trusts-covering property income, other sources, capital gains and voluntary contributions for registered parties, and voluntary contributions for electoral trusts-conditional on maintenance of books, audited accounts, prescribed filing of returns, donor identification for significant contributions, prescribed modes of receipt for larger donations, distribution obligations for electoral trusts, and cross-referenced compliance with electoral and banking statutory provisions.
    Act RulesIncome Tax
    Show AI Summary
    Persons exempt from tax: categories qualify for total income exclusion subject to approvals, notifications and prescribed conditions.
    Schedule VII lists 48 categories of persons whose total income is exempt from income tax subject to specified conditions: approvals by tax/regulatory authorities, Central Government notifications, prescribed financing thresholds to qualify as wholly or substantially government financed, and defined time limited exemptions for certain financing institutions. The Schedule relies on six Notes for statutory definitions and cross references other income tax provisions (including treatment of anonymous donations) to determine exclusion from total income.
    Act RulesIncome Tax
    Show AI Summary
    IFSC tax exclusion for specified financial incomes conditions relief on non-resident unit-holding, convertible receipts and prescribed rules.
    Schedule VI excludes specified IFSC-related income from "total income" for defined eligible persons, listing discrete income heads (capital gains on IFSC exchange transfers, securities transfers, securitisation trust receipts, derivative and portfolio receipts, royalty/interest on aircraft/ship leases, specified fund returns, dividends of IFSC leasing units, and interest payable by IFSC units) together with conditional eligibility tied to convertible foreign exchange receipt, non-resident unit-holdings, commencement-of-operations windows, regulatory registration, and delegated computational prescriptions.
    Act RulesIncome Tax
    Show AI Summary
    Tax exclusion for institutional investment vehicles: conditional non inclusion of specified income subject to regulatory compliance and clawback.
    Schedule V excludes specified income from total income for defined eligible persons-investment funds, business trusts (including REITs/InvITs), venture capital vehicles and certain foreign public investors-operating as a negative list subject to conditions and Notes. Exclusions include non business dividend and interest for investment funds, SPV interest/dividend exemptions for business trusts, REIT rental income exclusions for directly owned assets, and a layered specified person exemption with holding period, investment type, proportional computation, carve outs and clawback rules; implementation relies on cross references to SEBI/RBI/IFSC rules and Board guidelines.
    Act RulesIncome Tax
    Show AI Summary
    Non resident exemptions conditioned on residency, limited presence and Central Government notification restrict exclusions from taxable income.
    Schedule IV excludes specified receipts from total income of defined non residents and foreign companies where each listed entry identifies the income class, eligible person and conditions for exclusion. Exclusions depend on factual predicates-residency under foreign exchange rules, limited period of presence, absence of employer taxable presence in India, RBI permissions for NR(E) accounts-and on Central Government notification or approved agreements. Key categories include NR(E) account interest, diplomatic remuneration, short term foreign employee remuneration, specified royalties/fees, Offshore Banking Unit deposits, intra group cruise lease rentals, regional community investments and notified crude oil arrangements.
    Act RulesIncome Tax
    Show AI Summary
    Income exclusions from total income: targeted, conditional exemptions rely on prescribed procedures and cross referenced regulations.
    Schedule III excludes specified categories of receipts from total income for designated eligible persons, linking each excluded income to eligible person categories and conditional provisos. It covers personal reliefs (pensions, allowances, capped partial NPS withdrawals), partnership and family allocations, disaster compensation, conditional sectoral subsidies and institutional exemptions (research, khadi, securitisation, investor protection and settlement funds), and relies on prescribed procedures, certificates and cross references to subordinate legislation for operability.
    Act RulesIncome Tax
    Show AI Summary
    Life insurance exemption tightened by period, premium ratio and aggregate premium tests, altering tax treatment of policy and IFSC receipts.
    Schedule II excludes specified classes of income from total income while imposing conditional tests on life insurance and retirement/savings receipts. Life insurance exclusions depend on policy issue periods, premium to sum assured ratios, aggregate premium ceilings and express ineligibility for certain receipts. Provident fund interest attributable to large post cut off contributions is excluded from exemption with the non excluded portion to be computed as prescribed. The Schedule adds an equalisation levy exclusion interacting with treaty notifications and treats IFSC issued policies differently under a targeted aggregate premium carve out.
    Act RulesIncome Tax
    Show AI Summary
    Business connection safe harbour for non-resident funds: compliance thresholds determine Indian tax nexus exclusion.
    The Schedule establishes a safe harbour whereby certain non-resident investment funds and eligible fund managers will not constitute a business connection in India if they satisfy exhaustive investor-composition, concentration, corpus, independence, non-control, prohibited-associate-investment and arm's-length remuneration conditions, with specified carve-outs, transitional reliefs, registration requirements under prescribed securities-regulator frameworks, and filing and record keeping obligations to substantiate compliance.
    Act RulesIncome Tax
    Show AI Summary
    Savings on repeal preserve procedural and substantive continuity for matters tied to earlier tax years under the repealed regime.
    The repeal provision preserves continuation of rights, obligations and proceedings relating to tax years beginning before the statutory cut-off by deeming prior actions, elections, penalties, refunds, recovery, carry-forwards of losses, credits and depreciation to remain effective and by allowing pending and certain later-initiated proceedings to be conducted under the repealed procedural rules; it invokes the General Clauses Act for repeal effect and specifies fallback mechanics for schemes where no corresponding provision exists in the new Act.
    Act RulesIncome Tax
    Show AI Summary
    Presumption of ownership and authenticity expands to electronic records, increasing evidentiary weight in tax proceedings.
    The provision establishes rebuttable presumptions in proceedings under the Income tax enactment that items found in a search or survey-or delivered to a requisitioning officer-belong to the person in whose possession or control they are found and that books, documents, signatures and executions are true/authentic; the enacted text expressly extends those presumptions to electronic information and computer systems and adds a specific presumption that recorded electronic exchanges are exchanged between the purported parties.
    Act RulesIncome Tax
    Show AI Summary
    Authorised representative rules limit who may represent taxpayers, set disqualification grounds, and preserve appeal rights.
    The provision permits an assessee to attend proceedings before income tax authorities and the Appellate Tribunal through an authorised representative drawn from an enumerated list, subject to written authorisation and exclusions; personal attendance is required where examination on oath or affirmation is mandated. The definition of authorised representative and of "accountant" contains specific exceptions to prevent conflicts of interest, while disqualification rules-based on dismissal from service, insolvency, specified convictions or prior penalties-apply with procedural safeguards including opportunity to be heard and a one month appeal to the Board. Several qualifications and categories are to be determined by subordinate prescription, and transitional cross references to prior statutes determine legacy practitioner recognition.
    Act RulesIncome Tax
    Show AI Summary
    Country-by-country reporting requires Indian resident entities to notify authorities and file consolidated international group reports.
    Section 511 establishes a country by country reporting regime requiring Indian resident constituent entities with non resident parents to notify the prescribed income tax authority regarding designation as an alternate reporting entity and to provide parent/alternate details, while Indian resident parent or alternate reporting entities must furnish consolidated reports in the prescribed form and manner; fallback filing applies where foreign jurisdictions do not file or exchange reports or where a systemic failure is intimated, and exemptions apply if consolidated group revenue falls below a prescribed threshold.

    TMI Notes

    Back

    All TMI Notes

    Showing Results for :
    Reset Filters
      No Records Found

      TMI Notes

      Back

      All TMI Notes

      whatsappJoin Channel
      Showing Results for : Reset Filters

      Comparison of section 301 "Interpretation." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

      10 September, 2025

      Contents
      Acts
      Rules & Regulations
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      Section 301 Interpretation

      Income-tax Act, 2025

      At a Glance

      The document is Clause 301 of the Income Tax Bill, 2025 (Old Version) titled "Interpretation" within the Chapter on special procedure for assessment of search cases. It supplies definitions and scope for terms such as "block period", "requisition", "requisitioned items", "search", "seized items", "the last of the authorisations" and "undisclosed income". It matters because these definitions frame assessment, seizure and requisition proceedings u/ss 247-248 and related provisions; affected parties include taxpayers subject to search/requisition, authorised officers and the tax department.

      Background & Scope

      Statutory hooks: Clause 301 is situated in the Income Tax Bill, 2025, under the Chapter dealing with "Special procedure for assessment of search cases". It supplies interpretive definitions to be used "in this Chapter". The clause explicitly references sections 247 and 248 (search and requisition) for the operative processes it supports. The Clause provides definitions that govern temporal scope ("block period"), material objects subject to requisition/seizure ("requisitioned items", "seized items"), process milestones ("the last of the authorisations") and the core fiscal concept used in such proceedings ("undisclosed income").

      Statutory Provision Mode

      Text & Scope

      Clause 301 provides definitional scope for terms used in the Chapter:

      • "block period": Aggregate of two components-(i) six tax years preceding the tax year in which the search was initiated or any requisition was made; and (ii) the period from 1 April of the tax year in which the search/requisition was made up to the date of execution of the last authorisation for such search/requisition.
      • "requisition": Requisition of books of account, other documents or any assets u/s 248.
      • "requisitioned items": Books of account, other documents or money, bullion, jewellery or other valuable article or thing requisitioned u/s 248.
      • "search": A search initiated u/s 247.
      • "seized items": Books of account, other documents or money, bullion, jewellery or other valuable article or thing seized u/s 247.
      • "the last of the authorisations": Deemed executed-(i) for search: on 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 any seizure is recorded; (ii) for requisition: on actual receipt of the books of account, documents or assets by the Authorised Officer.
      • "undisclosed income": Two limbs-(i) money, bullion, jewellery, virtual digital asset or other valuable article or thing or any expenditure or any income based on entries in books/documents/transactions representing wholly or partly income or property not disclosed for purposes of the Act in respect of the block period; or (ii) any expense, exemption, deduction or allowance claimed under the Act which is found to be incorrect, in respect of the block period.

      Interpretation

      The Clause employs temporal and material markers to delineate the ambit of "undisclosed income" and the period for which such income will be examined ("block period"). The first limb of "undisclosed income" focuses on tangible and intangible assets (including "virtual digital asset") and entries/transactions that reflect nondisclosure. The second limb separately addresses incorrect fiscal claims-expenses, exemptions, deductions or allowances-claimed under the Act. The inclusion of both tangible assets and accounting entries suggests a dual focus on physical seizure and documentary/book-entry analysis within the block period. The text signals that the last panchnama in relation to any person is determinative for the conclusion of a search, thus providing a concrete procedural milestone for the operation of time-bound rules linked to the block period.

      Exceptions/Provisos

      No express exceptions or provisos beyond the two-part structure of the "block period" and the two-limbed definition of "undisclosed income" are included within Clause 301. Specific carve-outs, thresholds or exclusions are Not stated in the document.

      Illustrations

      • Example 1: A search initiated on 15 December of tax year Y (warrants executed for multiple persons) will have block period component (i) the six tax years preceding Y, and (ii) from 1 April of Y to the date recorded as conclusion in the last panchnama-this determines the period within which alleged undisclosed income is assessed.
      • Example 2: Books of account seized u/s 247 containing entries asserting certain expenses claimed as deductions for the block period could be treated as evidence of "undisclosed income" under limb (g)(i) or as an incorrect deduction under limb (g)(ii), depending on factual findings made during assessment.

      Interplay

      Clause 301 repeatedly cross-references sections 247 and 248 for the operative acts of search and requisition. The Clause also depends on "panchnama" as a procedural record to mark the conclusion of search operations. No other Rules, Notifications or Circulars are mentioned in Clause 301. Any application of this Clause in relation to other provisions of the Bill or the Act is Not stated in the document.

      Differences between Clause 301 (Old Version) and Section 301 (Income-tax Act, 2025) and Practical Impact

      • Scope marker/heading: The Bill (Clause 301) uses "In this Chapter"; the Act (Section 301) uses "For the purposes of this Part".
        • Practical impact: Terminology shift (Chapter vs Part) is largely stylistic but may reflect reorganisation of the statute; no substantive legal change is indicated in the texts provided.
      • Definitions added/omitted: The Bill contains explicit definitions of "requisitioned items" and "seized items" (books, documents, money, bullion, jewellery or other valuable articles seized/requisitioned u/ss 247/248). The Act text omits these two separate definitions.
        • Practical impact: Omitting explicit labels for "seized items" and "requisitioned items" in the Act reduces immediate textual clarity about what the statute contemplates when referencing seized or requisitioned property. Procedure and evidential handling that depend on named categories may require reliance on the general description in other clauses or on rules/guidance; this increases potential interpretive work for assessors and advisers.
      • Placement and labelling of "the last of the authorisations": Both texts contain a provision deeming when "the last of the authorisations" is executed, with identical operative sub-clauses for search (conclusion as recorded in last panchnama) and requisition (actual receipt). The Bill lists this at (f) while the Act lists similar text at (d).
        • Practical impact: No substantive change; re-lettering only affects cross-references in other sections and transitional drafting adjustments.
      • "Undisclosed income" formulation: The Bill sets out "undisclosed income" in a two-part structure (g)(i) and (g)(ii): (i) items/entries/transactions representing undisclosed income; or (ii) any expense/exemption/deduction/allowance claimed under the Act which is found to be incorrect. The Act consolidates the concept under (e), merging the two ideas into one continuous sentence and, per the appended note, corrects a typographical error ("or or any" corrected to "or any").
        • Practical impact: Substantively the Act appears to preserve both limbs of the Bill's definition, but the Act's merged wording could affect syntactic clarity and the parsing of whether the second limb is an alternative or a continuation. The corrigenda indicates only a textual correction, not a policy change.
      • Terminology for virtual assets: Both texts expressly include "virtual digital asset" in the list of items capable of constituting undisclosed income.
        • Practical impact: Confirms legislative intent to treat virtual assets on par with traditional valuables in search/requisition contexts.
      • Minor editorial differences: The Bill uses semicolons and clause divisions (a)-(g); the Act uses (a)-(e) with subclauses.
        • Practical impact: Largely drafting-style; may require attention in drafting cross-references and rules.

      Practical Implications

      • Compliance and risk areas: The Clause identifies a multi-year window ("block period") for investigation of undisclosed income, incorporating both the six preceding tax years and the year-of-search period up to the last authorisation. Taxpayers subject to search/requisition must be cognisant that both physical assets (including VDA) and documentary entries for that combined period are within scope.
      • Record-keeping/evidence points: Because "requisitioned items" and "seized items" explicitly include books of account and various forms of valuables, maintaining contemporaneous documentation, clear provenance and substantiation of claimed expenses/exemptions for the block period will be essential. The Clause makes the panchnama the operative record for concluding a search; therefore preservation and contestation of panchnama contents may be critical in subsequent proceedings.

      Key Takeaways

      • Clause 301 defines "block period" as six tax years preceding the tax year of search/requisition plus the part of that tax year up to the last authorisation.
      • Both physical assets (including money, bullion, jewellery and virtual digital assets) and documentary/book entries are captured within "undisclosed income".
      • The Clause separately recognises incorrect claims of expense, exemption, deduction or allowance as constitutive of "undisclosed income".
      • Procedural milestone: the last panchnama (for searches) and actual receipt by Authorised Officer (for requisition) determine the completion of authorisation for temporal calculations.
      • "Requisitioned items" and "seized items" are separately defined to include books of account and valuables, thus clarifying the kinds of materials that can be requisitioned or seized u/ss 247-248.
      • The Clause does not set out exceptions, thresholds, rights of persons from whom items are seized/requisitioned, or detailed procedural safeguards-those are Not stated in the document.
      • References to other legislative instruments, dates of effect, appeals or procedures post-seizure/requisition are Not stated in the document.

      Full Text:

      Section 301 Interpretation

      Topics

      ActsIncome Tax