Registered valuer representation enables technical valuation expertise in tax proceedings, subject to personal-examination exception and updated registration framework. Clause 513 grants an assessee the discretionary right to attend valuation-related proceedings before income-tax authorities or the Appellate Tribunal through a "registered valuer," excludes cases where personal attendance is required for examination on oath or affirmation, and defines "registered valuer" by reference to section 514 of the Bill, thereby creating a self-contained regime that modernizes registration, oversight, and professional standards for valuers.
Public disclosure of tax offenders can deter non-compliance while imposing reputational consequences under discretionary publication powers. Clause 512 empowers the Central Government to publish names and particulars of assessees when it considers such publication necessary or expedient in the public interest, subject to a safeguard that penalty-related publication await exhaustion or non-pursuit of appellate remedies, and permits publication of partners, directors and other associated persons if circumstances justify it. The clause modernises language and cross-references from Section 287 of the 1961 Act while preserving substantive continuity, raising interpretive concerns about the breadth of "particulars" and the subjectivity of "public interest."
Country-by-Country reporting requires multinational groups to submit consolidated jurisdictional tax and economic data for risk assessment. Clause 511 mandates Country-by-Country (CbC) reporting by parent entities or alternate reporting entities resident in India and requires Indian constituent entities to notify the tax authority of the parent or ARE. It prescribes report contents-aggregate jurisdictional financial and economic indicators, constituent identification, and business activities-provides a secondary filing route where the parent's jurisdiction lacks filing or exchange, allows designation of a single Indian filer, sets a revenue threshold for applicability, and grants verification powers to the authority, with procedural details to be prescribed.
Annual Information Statement: statutory digital disclosure enabling taxpayers to verify and reconcile reported financial data. The provision requires upload of an Annual Information Statement into the assessee's registered electronic filing account by the prescribed income tax authority or an authorised person, in the prescribed form, manner and time, containing such information as is in the possession of the authority; specifics of content, format and timelines are left to subordinate rules, and the clause confines AIS data to information already held by the authority.
Crypto-asset reporting obligations require prescribed entities to file periodic transaction statements and correct inaccuracies promptly. Clause 509 creates a statutory obligation for prescribed reporting entities to furnish periodic statements on crypto-asset transactions to the income-tax authority in a prescribed form and manner; it provides time-bound notice-and-cure procedures for defective or non-filed statements, mandates prompt self-correction of inaccuracies, and empowers rule-making for registration, record-keeping and due diligence including KYC.
Obligation to furnish financial transaction statements expands reporting duties and mandates due diligence, thresholds, and correction procedures. Clause 508 requires prescribed persons to furnish statements of specified financial transactions and reportable accounts, with rules determining scope, thresholds, form and timing. It mandates registration, record maintenance and due diligence for identifying reportable accounts, sets timelines for rectification of defective statements and correction of inaccuracies, and permits the Board and Central Government to prescribe differential thresholds and procedural details; unrectified defects or failures are treated as inaccurate information, invoking consequences under the Act.
Reporting obligations for media producers require disclosure of substantial payments to enhance transparency and tax oversight. Clause 507 requires persons producing cinematograph films or engaging in specified entertainment activities during any part of a tax year to furnish prescribed statements to income-tax authorities identifying payments made or due to each engaged person that exceed the aggregate reporting threshold; it defines inclusive categories of specified activities, delegates timing, form and manner to subordinate rules (including electronic filing and standardized formats), and emphasizes reporting both actual payments and accrued liabilities to enhance transparency and tax oversight.
Disclosure obligations for indirect transfers require Indian concerns to furnish prescribed information to tax authorities. Clause 506 requires an Indian concern, where a foreign company's shares or interests derive substantial value from Indian assets held through that concern, to furnish prescribed information and documents within prescribed periods and manners to the prescribed income-tax authority to enable determination of income arising in India under the indirect transfer regime. The clause mirrors Section 285A's substantive obligations, defers detailed compliance requirements to rules, and aligns with operational specifics exemplified by Rule 114DB regarding form, timelines, documentary breadth, retention, and group-filing.
Statutory reporting by liaison offices requires a fixed sixty day post tax year filing to strengthen compliance and oversight. Clause 505 requires every non-resident having a liaison office established under RBI/FEMA to deliver a prescribed statement of the office's activities to the Assessing Officer within sixty days from the end of the tax year, with the form and particulars to be specified by delegated legislation and non-compliance subject to general penalty provisions.
Service of notice for discontinued businesses allows authorities to serve former members or principal officers to proceed with assessment. Clause 504 permits the Assessing Officer, where an assessment is to be made under section 320, to serve a notice on the person whose income is to be assessed, any person who was a member of a firm or association of persons at the time of its discontinuance, or the principal officer of a company; such notice may contain all or any of the requirements included in a notice under section 268(1), and the Act's provisions shall apply as if the notice were issued under that sub section.
Service of notice after partition preserves tax proceedings by enabling notice on designated former managers or adult members. Clause 503 secures continuation of tax proceedings after a HUF's total partition or a firm's dissolution by allowing service of notices for pre disruption income on the last manager of the HUF (or, if deceased, all adults who were members immediately before partition) and on any adult partner or member of a dissolved firm or association; a formal finding of partition or dissolution by the Assessing Officer triggers application and minors are excluded from service.
Authentication of notices: statutory deeming of validity where designated authority details appear, enabling electronic and paper issuance. Clause 502 requires notices and documents to be signed and issued in paper form or communicated electronically as per prescribed procedures, deems documents authenticated where the name and office of a designated income-tax authority are printed, stamped or written thereon, and defines designated authorities as those authorized by the Board to issue such authenticated documents, thereby centralizing authorization while delegating procedural detail to subordinate rules.
Service of notices: modernised electronic and prescribed modes expand tax communication obligations and board rule making. Clause 501 prescribes authorised modes for serving statutory tax communications-post or Board approved courier, CPC methods for summons, electronic records under the IT Act, and other prescribed means-while empowering the CBDT to designate addresses (including electronic mail addresses) for service and to prescribe additional modes. It supplies a comprehensive, technology neutral definition of electronic mail covering messages and attachments, thereby modernising and clarifying the law of service and reducing ambiguities present in the earlier statutory cross references.
Provisional attachment powers protect revenue by allowing property restraint pending tax proceedings, subject to guarantees and time limits. Clause 500 empowers the Assessing Officer to provisionally attach assessee property during assessment, reassessment or specified penalty proceedings subject to prior written approval of a defined Competent Authority, execution in the prescribed manner, and a default six month duration extendable for recorded reasons within statutory limits; it permits substitution of a bank guarantee equal to fair market value (or a lower amount if objectively sufficient), mandates valuation by a Valuation Officer, sets timelines for revocation upon guarantee receipt, and prescribes invocation, application and release mechanics for guarantees.
Voidable asset transfers: transfers during tax proceedings can be voided against tax claims, with exceptions for bona fide transferees. Clause 499 renders charges or transfers of assets void against tax claims when effected during proceedings or after completion but before service of recovery notice, covering transfers by sale, mortgage, gift, exchange or any other mode and an expansive list of assets including virtual digital assets. Exceptions protect transfers made for adequate consideration without notice and those with prior permission of the Assessing Officer, while stock in trade is excluded; the clause updates procedural references and preserves core safeguards from the predecessor provision.
Application of new criminal procedure code aligns tax prosecutions under updated procedures, altering prosecutor status and qualification requirements. Clause 498 applies the Bharatiya Nagarik Suraksha Sanhita, 2023 to Special Court proceedings under the Income Tax Bill, deeming the person conducting the prosecution to be a Public Prosecutor and enabling the Central Government to appoint Special Public Prosecutors. Appointments require an experienced advocate with "special knowledge of law", and appointees are treated as Public Prosecutors within the BNSS definition, thereby importing BNSS powers, duties and procedural rules to tax prosecutions.
Summons case classification: minor tax offences must be tried by Special Courts under the new criminal procedure framework. Clause 497 requires that offences under the Income Tax Bill punishable with imprisonment not exceeding two years, or with fine, or with both, be tried as summons cases by a Special Court, overriding contrary BNSS provisions and applying the BNSS summons-case procedure accordingly.
Exclusive jurisdiction of Special Courts centralises tax prosecutions, with cognizance only on authorised complaints. Clause 496 mandates exclusive trial of income tax offences by designated Special Courts, subject to actual designation for relevant areas or classes of cases, and contains a non obstante provision giving it overriding effect over the general criminal procedure code. Cognizance by a Special Court is restricted to complaints filed by authorities authorised under the Act. Transitional rules preserve continuity by allowing designated courts to continue existing and future trials and permitting non designated courts to finish pending matters; the clause cross references the Bill's procedural provision to align competence within the reorganised statute.
Special Courts designation enables focused, consolidated trials for tax offences and aligns procedure with the new criminal code. Clause 495 empowers the Central Government, after consultation with the Chief Justice of the High Court, to notify one or more courts of Judicial Magistrate of the first class as Special Courts for specified areas, cases or classes of cases to try offences under the Income Tax Bill, 2025; it permits these Special Courts to try related offences joined at the same trial under the applicable criminal procedure and updates procedural references to the Bharatiya Nagarik Suraksha Sanhita, 2023, while preserving the core scheme of Section 280A.
Unauthorized disclosure by public servants criminalised; prosecution requires Central Government sanction and carries imprisonment and fine. Clause 494 criminalises unauthorized furnishing of taxpayer information or production of documents by a public servant in contravention of the Bill's secrecy provision, prescribes imprisonment and fine, and requires prior sanction of the Central Government before prosecution.
Import restrictions on specified IT hardware require valid import authorisation, while parts and certain exemptions remain available. The DGFT classified laptops, tablets, all in one PCs, ultra small form factor computers and servers under HSN 8471 as restricted, permitting import only ... Summary
Import restrictions on specified IT hardware require valid import authorisation, while parts and certain exemptions remain available.
The DGFT classified laptops, tablets, all in one PCs, ultra small form factor computers and servers under HSN 8471 as restricted, permitting import only against a valid Import Authorization; exclusions include desktop computers under the same chapter, spare parts and components, SEZ captive use imports, and IT hardware strictly incidental to capital goods, while importers may obtain multiple authorisations and amend quantities within value constraints.
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