Comparison of section 478 'Wilful attempt to evade tax, etc.' between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

Act tightens willful tax evasion and under-reporting rules with Rs25 lakh threshold, drafting refinements widen liability

The Act and the Bill both criminalise wilful attempts to evade tax, penalty or interest and wilful under-reporting, with tiered imprisonment linked to a Rs.25 lakh threshold and fines; key differences are drafting refinements rather than substantive changes. The Act relocates and rephrases the preservation of other statutory penalties as a standalone clause ('without prejudice to any penalty'), clarifying non-exclusivity, whereas the Bill expressly stated additional liability. The Act also changes 'may have the effect' to 'will have the effect' for conduct enabling evasion, tightening causal language and potentially broadening prosecutorial reach, subject to judicial interpretation of wilfulness and causation.