Provisional attachment powers protect revenue by allowing property restraint pending tax proceedings, subject to guarantees and time limits.
Clause 500 empowers the Assessing Officer to provisionally attach assessee property during assessment, reassessment or specified penalty proceedings subject to prior written approval of a defined Competent Authority, execution in the prescribed manner, and a default six month duration extendable for recorded reasons within statutory limits; it permits substitution of a bank guarantee equal to fair market value (or a lower amount if objectively sufficient), mandates valuation by a Valuation Officer, sets timelines for revocation upon guarantee receipt, and prescribes invocation, application and release mechanics for guarantees.

Voidable asset transfers: transfers during tax proceedings can be voided against tax claims, with exceptions for bona fide transferees.
Clause 499 renders charges or transfers of assets void against tax claims when effected during proceedings or after completion but before service of recovery notice, covering transfers by sale, mortgage, gift, exchange or any other mode and an expansive list of assets including virtual digital assets. Exceptions protect transfers made for adequate consideration without notice and those with prior permission of the Assessing Officer, while stock in trade is excluded; the clause updates procedural references and preserves core safeguards from the predecessor provision.

Application of new criminal procedure code aligns tax prosecutions under updated procedures, altering prosecutor status and qualification requirements.
Clause 498 applies the Bharatiya Nagarik Suraksha Sanhita, 2023 to Special Court proceedings under the Income Tax Bill, deeming the person conducting the prosecution to be a Public Prosecutor and enabling the Central Government to appoint Special Public Prosecutors. Appointments require an experienced advocate with "special knowledge of law", and appointees are treated as Public Prosecutors within the BNSS definition, thereby importing BNSS powers, duties and procedural rules to tax prosecutions.

Summons case classification: minor tax offences must be tried by Special Courts under the new criminal procedure framework.
Clause 497 requires that offences under the Income Tax Bill punishable with imprisonment not exceeding two years, or with fine, or with both, be tried as summons cases by a Special Court, overriding contrary BNSS provisions and applying the BNSS summons-case procedure accordingly.

Exclusive jurisdiction of Special Courts centralises tax prosecutions, with cognizance only on authorised complaints.
Clause 496 mandates exclusive trial of income tax offences by designated Special Courts, subject to actual designation for relevant areas or classes of cases, and contains a non obstante provision giving it overriding effect over the general criminal procedure code. Cognizance by a Special Court is restricted to complaints filed by authorities authorised under the Act. Transitional rules preserve continuity by allowing designated courts to continue existing and future trials and permitting non designated courts to finish pending matters; the clause cross references the Bill's procedural provision to align competence within the reorganised statute.

Special Courts designation enables focused, consolidated trials for tax offences and aligns procedure with the new criminal code.
Clause 495 empowers the Central Government, after consultation with the Chief Justice of the High Court, to notify one or more courts of Judicial Magistrate of the first class as Special Courts for specified areas, cases or classes of cases to try offences under the Income Tax Bill, 2025; it permits these Special Courts to try related offences joined at the same trial under the applicable criminal procedure and updates procedural references to the Bharatiya Nagarik Suraksha Sanhita, 2023, while preserving the core scheme of Section 280A.

Unauthorized disclosure by public servants criminalised; prosecution requires Central Government sanction and carries imprisonment and fine.
Clause 494 criminalises unauthorized furnishing of taxpayer information or production of documents by a public servant in contravention of the Bill's secrecy provision, prescribes imprisonment and fine, and requires prior sanction of the Central Government before prosecution.

Admissibility of official tax records: certified copies allowed as evidence, easing prosecution while preserving challenge rights.
Clause 493 mandates that entries in records or documents in the custody of an income-tax authority "shall be admitted in evidence" in prosecution proceedings under the chapter and permits proof either by production of the original records or by production of a certified copy signed by the custodian stating it is a true copy and that the originals are in its custody. The clause covers varied formats of records, limits application to criminal proceedings under the chapter, and preserves courts' power to test genuineness and require originals where fairness demands.

Non-cognizable classification of specified tax offences requires magistrate sanction before arrest or investigation, limiting summary enforcement.
Clause 492 of the Income Tax Bill, 2025 designates specified income tax offences as non-cognizable for purposes of the Bharatiya Nagarik Suraksha Sanhita, 2023 by means of a non-obstante provision. As a result, arrest cannot be effected without a magistrate-issued warrant and investigations into those offences require prior magistrate authorization, imposing judicial gatekeeping at the threshold of criminal proceedings and constraining unilateral police action in tax enforcement.

Prior sanction for tax prosecution centralises oversight, enables compounding, and restricts arbitrary criminal initiation against taxpayers.
Clause 491 makes prior sanction by designated senior officers a precondition to prosecution for specified tax offences, authorises senior regional heads and the Board to issue directions, permits compounding of offences at any stage by senior officials, bars prosecution where specified penalties have been reduced or waived, and affirms that statements or documents given to tax authorities remain admissible notwithstanding an expectation of penalty reduction or compounding.

Presumption of culpable mental state shifts evidentiary burden to accused to disprove intent beyond reasonable doubt.
Clause 490 mandates that once the prosecution establishes the actus reus, the court shall presume the existence of a culpable mental state-broadly defined to include intention, motive, knowledge, belief and reason to believe-and permits the accused to rebut that presumption only by proving absence of such mental state beyond reasonable doubt.

Presumption regarding assets and documents found in searches shifts evidentiary burden, now including virtual digital assets.
Clause 489 creates a rebuttable presumption that assets (including virtual digital assets) and books or documents found in a person's possession during an authorised search, or received via requisition, are presumed to belong to that person and that documents' contents are true when tendered in prosecution, applied "so far as may be" by reference to the Bill's presumption provision and extending to other persons identified by the Bill's connected-person provision.

Presumption of karta guilt shifts evidential burden, requiring demonstration of due diligence to avoid prosecution.
Clause 488 places primary criminal responsibility on the karta of a Hindu Undivided Family by deeming the karta guilty of an offence by the HUF, subject to statutory defences of lack of knowledge or proof of having exercised all due diligence. It further deems any member guilty where the offence is proved to have been committed with that member's consent or connivance or is attributable to their neglect, creating independent member liability while preserving the karta's available exculpatory defences.

Corporate officer liability: deeming provision shifts initial burden to accused, with due diligence defence for tax offences.
Where a company commits an income-tax offence, the company and every person who was in charge of, and responsible to, the company for the conduct of the business at the time are statutorily deemed guilty and liable to prosecution, subject to a defence that the individual lacked knowledge or exercised all due diligence to prevent the offence; separate liability arises where the offence occurred with the consent, connivance, or neglect of officers, companies are punishable by fine while individuals may face full penal consequences, and definitions explicitly include firms and associations of persons.

Reasonable cause defence limits criminal liability for certain tax compliance failures, protecting bona fide taxpayers from prosecution.
Clause 486 creates a non obstante statutory reasonable cause defence prohibiting punishment for failures under the specified sections of the Income Tax Bill, 2025 when the accused proves reasonable cause. The provision places the burden of proof on the accused, preserves judicial fact specific assessment of reasonable cause, and operates to limit prosecutions for bona fide or uncontrollable lapses while directing enforcement attention to willful or egregious defaults.

Enhanced penalties for repeat tax offences impose mandatory imprisonment and fine upon subsequent convictions under specified tax provisions.
A prior judicial conviction under any specified income tax offence triggers enhanced punishment: a person again convicted under any of those listed offences is subject to mandatory rigorous imprisonment and a mandatory fine, regardless of whether the subsequent conviction is for the same or a different listed offence; judicial discretion governs the precise sentence within the prescribed range, and the provision applies only after a prior conviction, not mere charge or prosecution.

Abetment of false returns: broadened criminal exposure for facilitators with mandatory imprisonment and fines for culpable conduct.
Clause 484 criminalises abetment or inducement in making or delivering false tax-related statements, requiring that the abettor know the falsity or not believe the statement to be true. Punishment is tiered by the quantum sought to be evaded, with mandatory minimum imprisonment terms and fines, while procedural details and definitions such as "induce" are not specified, raising interpretive and evidentiary challenges. The clause mirrors prior law's structure but broad wording could implicate advisors and intermediaries absent judicial or legislative clarification.

Falsification of accounting records: criminal liability for wilful false entries intended to enable another person to evade tax.
Clause 483 makes it an offence to wilfully make or cause false entries in books of account or other documents with intent to enable another person to evade tax, interest, or penalty; it requires proof of wilful conduct and intent but not proof that the beneficiary actually evaded liability, covers physical and electronic records relevant to tax proceedings, and prescribes rigorous imprisonment and a fine.

False verification offences: criminal liability requires proved knowledge or recklessness, with graded imprisonment and mandatory fines.
The provision criminalises making false statements in any statutory verification or delivering false accounts where the person knows or believes the statement to be false or does not believe it to be true. Prosecution must prove this mental element beyond reasonable doubt. A graded penalty applies according to the financial impact of the falsity: substantial evasion attracts a higher term of rigorous imprisonment while other cases attract a lower term, and a fine is mandatorily imposed in addition to imprisonment.

Willful failure to produce accounts triggers criminal liability including imprisonment and mandatory fine under the new tax provision.
Clause 481 establishes a penal offence for willful failure to produce accounts and documents called for by a notice under section 268(1), or willful non compliance with a direction under section 268(5), punishable by rigorous imprisonment for up to one year and liability to fine, with criminal prosecution requiring proof of willfulness beyond reasonable doubt and adherence to procedural safeguards; the clause mirrors prior law while leaving the fine quantum unspecified and raising interpretative issues regarding the threshold for willfulness and potential overlap with other provisions.