Section 484 — Abetment of false return, etc. Successor to s.278 of the 1961 Act.
Section 484 is in Chapter XXII — Offences and Prosecutions, which runs from section 473 to section 498.
The section punishes a person who abets or induces another, in any manner, to do one of two things: under clause (a), to make and deliver an account, statement or declaration relating to income chargeable to tax which is false and which he either knows to be false or does not believe to be true; or under clause (b), to commit an offence under section 478(1).
The punishment provision was substituted by Act No. 4 of 2026 with effect from 1 April 2026, and now grades the offence in three tiers by the amount of tax, penalty or interest that would have been evaded had the declaration, account or statement been accepted as true, or that is wilfully attempted to be evaded. Above fifty lakh rupees, the punishment is simple imprisonment for a term up to two years, or fine, or both. Above ten lakh rupees but not exceeding fifty lakh rupees, it is simple imprisonment for a term up to six months, or fine, or both. In any other case, it is fine.
The provision before substitution had two tiers only: rigorous imprisonment of not less than six months extending to seven years, and fine, where the amount exceeded twenty-five lakh rupees, and in any other case rigorous imprisonment of not less than three months extending to two years, and fine.
The person who prepares or procures a false return is often not the person who signs it, and without this section only the signatory would be exposed. The section reaches the abettor or inducer directly, on the same false statement, and grades the punishment by the tax at stake so that a small misstatement and a large evasion are not treated alike.
| What | Figure | The condition on it | Where |
|---|---|---|---|
| Punishment where the amount involved exceeds fifty lakh rupees | Simple imprisonment for a term up to two years, or fine, or both | Amount of tax, penalty or interest that would have been evaded had the declaration, account or statement been accepted as true, or that is wilfully attempted to be evaded; as substituted by Act No. 4 of 2026 w.e.f. 1-4-2026 | Clause (i) |
| Punishment where the amount involved exceeds ten lakh rupees but does not exceed fifty lakh rupees | Simple imprisonment for a term up to six months, or fine, or both | Measured on the same amount of tax, penalty or interest; as substituted by Act No. 4 of 2026 w.e.f. 1-4-2026 | Clause (ii) |
| Punishment in any other case | Fine | Where the amount does not exceed ten lakh rupees; no imprisonment is provided | Clause (iii) |
| Threshold and punishment before the 2026 substitution | Twenty-five lakh rupees; rigorous imprisonment of not less than six months extending to seven years, and fine, above it, and not less than three months extending to two years, and fine, otherwise | The provision as it read before substitution by Act No. 4 of 2026 with effect from 1 April 2026; no longer the live text | Footnote 29 to the section |
The 2026 substitution changed the character of the punishment as much as its length. Imprisonment is now simple rather than rigorous, the terms are maxima with no minimum, and the court may award fine alone even in the highest tier, where the earlier provision required both imprisonment of at least six months and fine. A third tier was added at the bottom: where the amount does not exceed ten lakh rupees the punishment is fine only, so no imprisonment is available. The thresholds moved from a single line at twenty-five lakh rupees to two lines at ten lakh and fifty lakh rupees. What has not changed is the reach of the offence — abetting or inducing "in any manner" — and that liability does not depend on the false account having been accepted, since the amount is measured on what would have been evaded had it been accepted as true, or on what is wilfully attempted to be evaded.
An adviser prepares and persuades a firm to file a statement understating its income, on which the tax that would have been evaded, had the statement been accepted as true, is Rs. 80 lakh. The statement is detected before any assessment is made, but that does not matter, because the amount is measured on what would have been evaded had it been accepted. Since Rs. 80 lakh exceeds fifty lakh rupees, clause (i) applies and the adviser is punishable with simple imprisonment for a term up to two years, or with fine, or with both. Had the amount been Rs. 8 lakh, clause (iii) would leave only a fine.
In a criminal complaint filed before a court against a person who prepared or procured a false return, rather than in any assessment or penalty proceeding — the person prosecuted here need not be the assessee at all.
If a person abets or induces in any manner another person––
with simple imprisonment for a term up to two years, or with fine, or with both, where the amount of tax, penalty or interest which would have been evaded ... exceeds fifty lakh rupees
with fine, in any other case.
See the full 1961 to 2025 concordance.