Comparison of section 469 'Power to reduce or waive penalty, etc., in certain cases.' between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

New clause tightens prior-approval thresholds for penalty relief under Section 439 for voluntary full pre-detection disclosures

Two versions of a provision empower the Principal Commissioner/Commissioner to reduce or waive penalties under section 439 where a taxpayer made voluntary, pre-detection full and true disclosure, cooperated, and paid or secured tax/interest; applications for hardship relief require recorded reasons and disposal within 12 months with a hearing right. Both set deeming rules, bar repeat relief across years, and impose prior-approval thresholds (income/disclosure aggregate > Rs.500,000; aggregate relief > Rs.100,000). The enacted text adds an 'irrespective of' prefatory clause in the prior-approval rule, tightening discretion in threshold cases and clarifying the income-based trigger.