Comparison of section 487 "Abetment of false return, etc." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)
17 September, 2025
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Corporate vicarious liability tightened: personal liability now operates notwithstanding due diligence where consent, connivance or neglect is shown. Section 487 creates both a deeming rule treating companies and those in charge as guilty for corporate tax offences and a separate personal-liability ... Summary
Corporate vicarious liability tightened: personal liability now operates notwithstanding due diligence where consent, connivance or neglect is shown.
Section 487 creates both a deeming rule treating companies and those in charge as guilty for corporate tax offences and a separate personal-liability route making directors, managers, secretaries, officers, partners and controlling members individually culpable where an offence is committed with their consent, connivance or attributable to their neglect; a statutory defence allows persons deemed guilty to avoid liability by proving lack of knowledge or that they exercised all due diligence, but the enacted text makes the personal-liability route operate irrespective of the deeming rule and the due diligence defence.
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