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Case lawIncome-tax Act 2025Chapter XXI › Section 451
Chapter XXIwas s.271DA

Section 451 of the Income-tax Act, 2025

Section 451 — Penalty for failure to comply with provisions of section 186. Successor to s.271DA of the 1961 Act.

Where this section sits

Section 451 is in Chapter XXI — Penalties, which runs from section 439 to section 472.

← Section 450  ·  Section 452 →

What this section does

The section empowers the Assessing Officer to impose on a person a penalty equal to the sum received by him in contravention of the provisions of section 186.

Why it is there

Section 186 prescribes the mode in which certain sums may be received, and such a rule is effective only if receiving in the wrong mode costs the recipient the sum itself. Fixing the penalty at the amount received rather than at a percentage removes any calculation of advantage from breaching it.

Who it applies to

The figures, and what each one turns on

Read the condition in the same row. A figure quoted without it is a wrong answer with a citation attached.
WhatFigureThe condition on itWhere
Amount of penaltyA sum equal to the sum received in contravention of section 186Imposed on the person who received it; the section says the Assessing Officer "may" imposeSection 451

What this means in practice

The measure is the sum received, so the penalty is the whole of that amount and not a proportion of any tax on it. The section is addressed to the recipient. The power is "may impose", not "shall", and the procedure in section 471 — hearing by way of a show-cause notice, and prior approval above the stated limits — applies to any penalty order under this Chapter.

An example

Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.

A person receives Rs. 3 lakh in a mode that contravenes section 186. The Assessing Officer may impose a penalty of Rs. 3 lakh, being a sum equal to the amount received, and not a percentage of it or of the tax on it.

Where you meet this section

You meet this section as a penalty order, preceded by the show-cause notice and opportunity of hearing that section 471 requires for any penalty under this Chapter.

The words themselves

The Assessing Officer may impose on a person, a penalty equal to the sum received by him in contravention of the provisions of section 186.
Section 451, Income-tax Act, 2025.

What people get wrong

What this replaced

The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.

See the full 1961 to 2025 concordance.

Circulars of the Board on this section

A circular binds the department, not you and not a court. Every one below was written under the 1961 Act; it reaches this section because the department’s own concordance carries the provision it names to this one.

See the circulars index.

Case law carried across

Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 451. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.

Explainers

Read with

What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.