Home / Glossary
The vocabulary, defined.
Terms that appear constantly in assessment orders and appellate submissions, defined plainly and linked to the provision they arise under. Statutory references are to the Income-tax Act, 1961 unless stated otherwise.
A
Abatement
The automatic termination of a pending assessment or reassessment for a year falling within a search block, so that the proceeding merges into the search assessment. Under the earlier scheme this applied to years covered by section 153A; under block assessment, pending assessments for years in the block period abate into the single block order.
Additional ground
A ground of appeal not included in the memorandum of appeal, which the appellate authority may permit to be argued if satisfied the omission was not wilful or unreasonable. Most commonly used for jurisdictional points discovered after Form 35 was filed.
Assessed total income
Total income as computed by the Assessing Officer, as distinct from income as returned. It is the figure on which appeal fees are calculated under sections 249(1) and 253(6).
Authorised officer
The officer named in a search warrant under section 132 and empowered to enter, search, seize and examine on oath. Distinct from the Assessing Officer who later makes the assessment.
B
Best judgment assessment
An assessment made under section 144 on the Assessing Officer's own estimate, where the assessee has failed to comply or where the books have been rejected. It must rest on some material and cannot be arbitrary — an estimate is not the same as a guess.
Block period
The span of years covered by a single block assessment following a search. Undisclosed income is determined for the block as a whole rather than year by year.
Books of account
The regular records of a business. Their rejection under section 145(3) requires an identified defect going to reliability, not dissatisfaction with the profit they disclose.
C
Condonation of delay
Admission of an appeal or application filed after the limitation period, where the authority is satisfied there was sufficient cause. Available under sections 249(3), 253(5) and 260A(2A). Not available for rectification under section 154, which contains no condonation power; no amendment can be made after the four years in section 154(7).
Cross-examination
The opportunity to question a person whose statement is relied on against the assessee. Where an addition rests on a third party's statement, principles of natural justice ordinarily require it. The request must be made on the record during the assessment for its refusal to be argued with a foundation later.
Cross-objection
A respondent's challenge to part of an order, filed after the other side has appealed to the Tribunal. Filed on Form 36A within 30 days of receipt of notice of the appeal, with no fee. The 30-day period was not converted to the month-end formula in 2024.
s.253(4)
D
Dumb document
A seized paper bearing figures or notations that does not, on its own terms, identify the transaction, the parties, the period or the nature of the entry. Whether such material can sustain an addition without corroboration is one of the most frequently argued questions in post-search litigation.
Demand notice
The notice of demand under section 156 accompanying an assessment or penalty order. Its date of service — not the date of the order — starts the 30 days for an appeal to the CIT(A). The two dates are frequently different.
F
Faceless assessment and appeal
Assessment and first appeal conducted without personal interface, through the electronic portal. Because there may be no second chance to explain, submissions must be complete on the file and drafted to be read without oral gloss.
Form 35 / Form 36 / Form 36A
The memorandum of appeal to the CIT(A), the memorandum of appeal to the Tribunal, and the memorandum of cross-objections respectively, under the Income-tax Rules, 1962. The Income-tax Rules, 2026 prescribe Forms 99, 115 and 116 in their place for matters governed by the 2025 Act.
I
Incriminating material
Material found in the course of a search having a bearing on the determination of total income for a particular year. Under section 153A, for a year whose assessment had attained finality with nothing pending on the date of search, an addition had to be founded on such material — a point going to jurisdiction rather than merely merits.
O
On-money
Consideration received over and above the amount recorded in the sale documents, most commonly alleged in real estate. Additions are typically derived from a seized sheet or a purchaser's statement and then extrapolated across a project, which puts the sample, the extrapolation and the resulting double counting in issue.
Order giving effect
The order passed by the Assessing Officer implementing an appellate direction, recomputing income and demand. Delay in passing it is a common subject of grievance, since relief allowed on appeal has no practical effect until it is given.
P
Panchnama
The record drawn up at the conclusion of search proceedings in the presence of witnesses, listing what was found and seized. It defines the material an assessment may be built on, and the date it bears drives later limitation.
Paper book
The indexed compilation of documents relied on before an appellate authority. Its value lies in the indexing: a document the bench cannot reach while the point is live has not really been filed.
Protective assessment
An assessment made on one person to protect the revenue where it is uncertain which of two persons the income belongs to, the substantive assessment being made on the other. Only one can ultimately be sustained.
R
Reason to believe
The statutory precondition for a search under section 132 and, historically, for reassessment. It must exist before the action is authorised and rest on material; its existence is examinable even where its sufficiency is not.
Rectification
Amendment of an order to correct a mistake apparent from the record, under section 154. The four-year period runs from the end of the financial year in which the order sought to be amended was passed, and cannot be extended.
Retraction
Withdrawal of an admission made in a statement recorded during search or survey. Examined on its promptness, the reasons given, and whether the original statement finds corroboration in the seized material.
S
Satisfaction note
The recorded satisfaction that material seized in one person's search pertains to or relates to another person, required before an assessment can be made on that other person. It must be recorded by the Assessing Officer of the searched person and separately by the Assessing Officer of the other person; its existence and timing are jurisdictional questions.
Statement on oath
A statement recorded during a search under section 132(4), usable in evidence in any proceeding under the Act. It has evidentiary value but is not conclusive, and an addition resting on it alone without corroboration stands on weaker ground.
Stay of demand
An order holding recovery in abeyance while an appeal is pending. The standard figure fixed by CBDT is 20 per cent of the disputed demand, raised from 15 per cent by the office memorandum of 31 July 2017 — a standard rate rather than a rigid rule, and one that courts have held cannot be applied mechanically.
Survey
Action under section 133A at business premises. A survey is not a search, and a statement recorded during one does not carry the same statutory footing as a statement on oath under section 132(4).
U
Undisclosed income
A defined expression, not a general description. Under the block assessment scheme it is the income determined for the block period; under section 271AAB it carried its own definition. Whether an estimated addition answers the definition at all is frequently a threshold objection.
Unexplained cash credit
A credit in the books for which no explanation is offered, or one the Assessing Officer does not accept, charged under section 68 and taxed at the special rate. Where the credit is share capital or premium, the source of the source must also be explained in specified cases.
Definitions are given for orientation and are not advice. Where a term carries a statutory definition, that definition governs. Positions stated are as at August 2026.