Income-tax penalties for under-reporting will be included within assessment orders for assessments made on or after April 1, 2027. The amendment mandates that the reasonable opportunity of being heard be given by a show cause notice and provides that penalties for under reporting shall, for drafts or assessments made on or after 1 April 2027 for AY 2026-2027 or earlier years, constitute part of the draft or final assessment or reassessment; references to assessment or penalty orders shall follow that treatment, and Joint Commissioner approval for assessment or reassessment taken on or after 1 April 2027 is deemed to include approval for such penalties. The amendment is retrospective to 1 March 2026.