Comparison of section 427 "Fee for default in furnishing statements." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)
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....ly in minor drafting aspects: a cross-reference to another section (393(3)(b) v. 397(3)(b)) and presentation of the amount (spelled out v. numeric). Effective date or enactment/notification timing: Not stated in the document. Background & Scope Statutory hooks: both texts are labelled under the Income-tax enactment for 2025 and are described as dealing with the "Levy of fee in certain cases" for "Fee for default in furnishing statements." The provision applies "without prejudice to the provisions of this Act" and operates where "a person fails to deliver or cause to be delivered a statement within the time prescribed" in a cross-referenced subsection. The obligation gives rise to liability to pay, by way of a fee, a daily amount for each ....
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.... The two limits in sub-section (2) indicate a legislative intent to cap the fee at the quantum of tax deductible/collectible and to make payment of the fee a precondition to subsequent compliance (delivery of the statement). The text implies a daily accrual mechanism ("for every day during which the failure continues"), signalling continuing liability until compliance. No legislative intent beyond these textual indicia is set out in the documents. Exceptions/Provisos No express exceptions or provisos beyond the two limitations in sub-section (2) are provided in the text. Specific carve-outs (for example, reasonable cause, force majeure, devolved liability) are Not stated in the document. Illustrations * Example 1: A withholding agent r....
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....nbsp;(Document 2) Clause 427 of the Income-tax Bill, 2025 Identified differences: * Cross-reference: Old Bill (Document 2) cross-refers to section 393(3)(b); later text (Document 1) cross-refers to section 397(3)(b). Practical impact * Cross-reference change (393(3)(b) -> 397(3)(b)): The practical significance depends entirely on the substantive content of the cited subsections. Since the documents do not state what section 393(3)(b) or 397(3)(b) contain, the precise impact (for example, who is captured, the time period for filing, or the triggering event) is Not stated in the document. However, at a drafting level, changing the cross-reference alters the statutory trigger and therefore can expand, narrow or other....
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