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<h1>Income Tax Bill 2025 Clause 442 imposes 2% penalty on transaction value for transfer pricing documentation failures</h1> The Income Tax Bill 2025's Clause 442 establishes penalties for documentation failures in international and specified domestic transactions, mirroring Section 271AA of the Income-tax Act 1961. The provision imposes a 2% penalty on transaction value for failing to maintain required documentation, failing to report transactions, or furnishing incorrect information. Additionally, a flat penalty of five lakh rupees applies for non-furnishing of information. The clause maintains identical penalty structure and quantum as existing law, ensuring continuity in transfer pricing compliance enforcement while updating section references to align with the restructured legislation.