Documentation penalties: new clause preserves ad valorem and flat penalties, reinforcing strict transfer pricing compliance for cross border transactions.
Clause 442 establishes penalties for failures to maintain, report, or furnish accurate documentation for international transactions and specified domestic transactions, comprising an ad valorem penalty imposed by the Assessing Officer or Commissioner (Appeals) for non maintenance, non reporting or incorrect information, and a prescribed authority's power to levy a flat monetary penalty for failure to furnish required information; the provision largely mirrors Section 271AA but omits an explicit "without prejudice" clause and does not address reasonable cause or proportionality concerns.