New Delhi, May 7 -- The reintroduction of block assessment regime in Finance Act (No 2) 2024 marked a significant evolution in tax enforcement framework. The regime, applicable to search and requisition proceedings initiated on or after 1 September, 2024, was aimed at reinforcing the government's efforts to curb tax evasion and bring greater focus to taxation of undisclosed income.

The initial structure of tax provisions raised concerns among taxpayers, particularly due to interpretational ambiguities and risk of additional taxation on already disclosed income. These concerns necessitated a timely recalibration of tax law and corresponding compliance filings.

Under Section 158BC(1) of the Income-tax Act, taxpayers subjected to search pr...