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of <h1>Income Tax Bill 2025 Clause 457 maintains 2% penalty for transfer pricing documentation failures under Section 171(2)</h1> The Income Tax Bill 2025's Clause 457 imposes a penalty of 2% of transaction value for each failure to furnish required transfer pricing documentation under Section 171(2) for international or specified domestic transactions. This provision directly mirrors Section 271G of the Income-tax Act 1961, maintaining identical penalty quantum, scope, and authorized officers (Assessing Officer, Transfer Pricing Officer, Commissioner Appeals). Both provisions aim to enforce transfer pricing compliance and transparency. Key differences include updated cross-references and potential changes in procedural safeguards, particularly regarding reasonable cause defenses. The clause represents policy continuity in strengthening transfer pricing enforcement mechanisms.
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