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CA Final · Direct Tax Laws & International Taxation · Taxation of Digital Transactions

A search under the Income-tax Act, 2025 was initiated in tax year 2026-27 on Dhruv Crypto Ltd. Warrants were executed at different premises, and the last panchnama in relation to any person under the warrant was recorded on 5 February 2027, with no seizure noted in it. When is the last of the authorisations deemed executed?

The last authorisation is deemed executed on 5 February 2027, the conclusion of search recorded in the last panchnama. Whether anything was seized in that panchnama is irrelevant under the definition, so the block period's closing date is that day.

  1. AOn 5 February 2027, as the conclusion of search recorded in the last panchnama, even though nothing was seizedCorrect
  2. BOnly on the date of the first panchnama
  3. CNot executed, because no seizure was recorded in the last panchnama
  4. DOn 31 March 2027, the end of the tax year

Explanation

Section 301(d)(i) deems the last authorisation executed on the conclusion of search as recorded in the last panchnama, irrespective of whether any seizure is recorded. So the date is 5 February 2027. The option requiring seizure contradicts the express wording.

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