Comparison of section 298 "Levy of interest and penalty in certain cases." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....sessees subject to notices u/s 294(1)(a) and income-tax authorities. Effective date or decision date: Not stated in the document. Background & Scope Statutory hooks: references throughout to section 294(1)(a) and to penalty-imposing provisions including sections 244(2), 357, 362, 377 and various sections in Chapter/Part cited as 444, 450, 451 and either 452 or 453. Context: special procedure for assessment of search cases and consequences where the return called for is not furnished within prescribed time. Coverage: interest on tax determined in search assessments, imposition of penalty equal to 50% of tax leviable on undisclosed income, and limitation/ procedural safeguards for imposing penalty. Statutory Provision Mode Text & Scope T....

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....ve debates are Not stated in the document. Exceptions/Provisos Key carve-outs and conditions in the text: * Sub-section (3) bars imposition of penalty under this section and certain other specified sections for the block period if four cumulative conditions are met: the person furnished the return u/s 294(1)(a); tax payable on that return has been paid (or money seized is offered to be adjusted against tax); evidence of tax paid accompanies the return; and no appeal is filed against the assessment of the portion of income shown in the return. * Sub-section (4) states the bar in sub-section (3) does not apply where undisclosed income determined exceeds the income shown in the return; in such cases penalty attaches only to the excess po....

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....pecific interactions with Rules, Notifications, Circulars, or the substantive content of the cited sections are Not stated in the document. Therefore precise interplay and potential conflicts or supplementing procedural rules cannot be determined from the provided text alone. Differences Between the Two Texts and Practical Impact * Terminology of the return called for: The Bill (old version) uses the phrase "return of total income as required under a notice u/s 294(1)(a)" while the Act version uses "return of undisclosed income as required under a notice u/s 294(1)(a)". * Practical impact: The change narrows or clarifies the subject of the return called for - from a general "total income" return to a return specifically of "undisclosed....

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....tions * Compliance and risk areas: Failure to file the specified return u/s 294(1)(a) exposes the assessee to immediate interest at 1.5% per month on the tax determined on undisclosed income plus potential penalty equal to 50% of that tax. Even where a return is filed, if the Assessing Officer finds undisclosed income exceeding declared income, penalty applies to the excess. * Threshold and approvals: Where penalty exceeds Rs. 200,000, prior approval from senior officers is required before lower-ranked officers impose such penalty; this creates an internal control and possible administrative delay. * Limitation/procedural safeguards: Requirement of reasonable opportunity to be heard, and specific limitation computations (exclusions fo....