Failure to furnish accountant's report under section 172 may attract fixed statutory penalty; procedural safeguards need clarification.
Clause 447 authorises the Assessing Officer to impose a fixed penalty of one lakh rupees for failure to furnish an accountant's report as required by section 172; the provision mirrors Section 271BA in structure and intent, emphasising a uniform fixed penalty to enforce documentary compliance, while raising issues about the scope of section 172, the absence of an explicit reasonable cause exception, and procedural safeguards such as show cause notice and opportunity to be heard.