Penalties for Reporting Non-Compliance by Resident constituent entity of an international group under Indian Tax Law : Clause 459 of the Income Tax Bill, 2025 Vs. Section 271GB of the Income-tax Act, 1961

Reporting penalties: new clause preserves escalating daily fines and a large fixed penalty for inaccurate international tax reports.

Clause 459 establishes a tiered penalty regime under section 511 for reporting entities: daily penalties for failure to furnish reports, daily penalties for failure to produce information after the allowed period, an escalated daily penalty if default continues after service of a penalty order, and a substantial fixed penalty for furnishing inaccurate information or failing to correct known or discovered inaccuracies. The prescribed authority under section 511 is empowered to impose these penalties, and the clause mirrors Section 271GB in quantum and triggers while raising issues about reasonable cause relief and procedural safeguards.