Balancing Deterrence and Fairness : Clause 486 of Income Tax Bill, 2025 Vs. Section 278AA of Income-tax Act, 1961

Reasonable cause defence limits criminal liability for certain tax compliance failures, protecting bona fide taxpayers from prosecution.

Clause 486 creates a non obstante statutory reasonable cause defence prohibiting punishment for failures under the specified sections of the Income Tax Bill, 2025 when the accused proves reasonable cause. The provision places the burden of proof on the accused, preserves judicial fact specific assessment of reasonable cause, and operates to limit prosecutions for bona fide or uncontrollable lapses while directing enforcement attention to willful or egregious defaults.