Clause 439 Income Tax Bill 2025 sets formula-based penalties for under-reporting and misreporting income under Section 270A rules

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....Clause 439 of the Income Tax Bill, 2025, largely replicates Section 270A of the Income-tax Act, 1961, establishing a formula-based penalty regime for under-reporting and misreporting of income to enhance tax compliance and reduce litigation. Both provisions empower designated tax authorities to impose penalties of 50% of tax on under-reported income and 200% for misreporting, distinguishing between inadvertent errors and deliberate falsification. They enumerate specific scenarios constituting under-reporting, provide detailed computation methods, and include exceptions for bona fide explanations and voluntary disclosures. The key difference is Clause 439's omission of an explicit exclusion for undisclosed income in search cases, present in .........