Comparison of section 511 "Furnishing of report in respect of international group." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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...., parent entities, alternate reporting entities) and the tax administration. Effective date or commencement is Not stated in the document. Background & Scope Statutory hooks: Clause 511 sits within miscellaneous provisions of the Income Tax Bill, 2025 and proposes a standalone reporting obligation for "international groups". The clause creates duties to notify the prescribed income-tax authority and to furnish reports containing consolidated and constituent-level financial and operational information. Definitions and scope are provided within the clause itself. Any subordinate rules, forms, timelines and thresholds are to be set out "as prescribed" (delegated rule-making). Statutory Provision Mode Text & Scope Clause 511 imposes three ....

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....o implement a country-by-country reporting regime targeted at large international groups with constituent entities resident in India. The use of express definitions (e.g., "consolidated financial statement", "parent entity", "constituent entity", "reporting accounting year") demonstrates an intent to align reporting obligations with financial reporting and with international standards for transfer pricing transparency. Several interpretive principles are signalled by the text: alignment with parent-jurisdiction financial periods, deference to prescribed forms and procedures, and reliance on intergovernmental agreements for automatic exchange. Exceptions/Provisos Key carve-outs and conditions: * Threshold exemption (sub-section (8)): The....

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....inancial statements as a PE falls within "constituent entity" and, if the foreign parent's jurisdiction neither files nor exchanges reports with India, that Indian PE may be required to furnish the report within the prescribed period. (Precise prescribed period is Not stated in the document.) Interplay The clause expressly contemplates interaction with: * Section 159(1) or (2) (via the definition of "agreement") - signalling reliance on specified intergovernmental agreements for exchange. * Section 173(c) (for the meaning of "permanent establishment"). * Prescribed rules/guidelines/conditions that remain to be issued for form, manner, dates and thresholds. The document does not reproduce any subordinate rules or forms. Specific ....

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....ns, thresholds or exceptions between the two texts provided. The principal practical impact arises from the change in status from a Bill clause (Document 2) to an enacted statutory section (Document 1) and minor drafting refinements that preserve the same legal obligations and delegated-rulemaking expectation. Practical Implications * Compliance and risk areas: Indian resident constituent entities of international groups must track whether their group's parent is resident outside India, determine whether they are designated as alternate reporting entity, and ensure timely notification to the prescribed income-tax authority. Parent or alternate reporting entities resident in India must prepare and file the prescribed report within 12 ....