Comparison of section 470 "Penalty not to be imposed in certain cases." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....se; it affects taxpayers and the revenue department. Effective date or decision date: Not stated in the document. Background & Scope Statutory hooks: the clause references multiple sections of the Bill - sections 441, 442, 446, 447, 448, 449, 450, 451, 454, 455, 456, 457, 458, 459, 460, 461, 462, 463, 465(1)(c), 465(1)(d), 465(2)(c), 465(2)(d), 466, 467, 468(1) and 468(2). Context: Clause 470 is contained in the Part labelled "PENALTIES" of the Income Tax Bill, 2025 - Old Version. Coverage: the clause purports to negate imposition of penalties under the listed provisions where the person proves reasonable cause for the failure. Definitions or explanations: Not stated in the document. Statutory Provision Mode Text & Scope The operative ....

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....ove" reasonable cause. There are no thresholds, time-limits, or procedural prerequisites set out in Clause 470. Any carve-outs are not stated in the document. Illustrations * Example 1: A taxpayer fails to file a return triggering penalty under one of the listed sections but subsequently adduces evidence that the failure was due to a natural calamity preventing compliance. Whether penalty can be imposed depends on whether the taxpayer "proves" reasonable cause as required by Clause 470. The clause does not provide a standard for assessment of such proof. (Consistent with the text: illustrative only.) * Example 2: An assessee incurs a late-deposit penalty under a listed provision; the assessee claims postal delay as reasonable cause and....

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....n limited the protection to specified sub-clauses (c) and (d) of 465(2), whereas the Act-version appears to expand the protection to all sub-clauses of 465(2). This widens the class of failures for which a reasonable-cause defence is available in the enacted provision. * Particularity of section 468: Document 1 refers to "468" generally; Document 2 specifies "468(1) or 468(2)". * Practical impact: The Bill-version explicitly confines protection to sub-clauses (1) and (2) of section 468; Document 1's broader reference to section 468 may capture any future sub-clauses or the entire section more clearly, though practically the difference is narrow if section 468 contains only sub-sections (1) and (2). * Overall breadth: On balance, D....