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Case lawCBDT Circulars & Instructions › Statutory position — s.271AA(2): a flat five hundred thousand rupees for failing to furnish the master file under s.92D(4), imposed by the PRESCRIBED AUTHORITY and not by the Assessing Officer — and how it differs from the two per cent penalty in s.271AA(1)
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.271AAs.271AA(1)s.271AA(2)s.92Ds.92D(1)s.92D(2)s.92D(4)s.286s.286(1)s.270As.271s.271BAs.273BRule 10DARule 10D

Statutory position — s.271AA(2): a flat five hundred thousand rupees for failing to furnish the master file under s.92D(4), imposed by the PRESCRIBED AUTHORITY and not by the Assessing Officer — and how it differs from the two per cent penalty in s.271AA(1)

We did not file Form 3CEAA. Which penalty applies, who imposes it, and is it a percentage of anything?

We did not file Form 3CEAA. Which penalty applies, who imposes it, and is it a percentage of anything?

Section 271AA(2) provides: "If any person fails to furnish the information and the document as required under sub-section (4) of section 92D, the prescribed income-tax authority referred to in the said sub-section may direct that such person shall pay, by way of penalty, a sum of five hundred thousand rupees." It is a flat figure — five lakh rupees — not a percentage, and the power is in the PRESCRIBED AUTHORITY under s.286(1), not in the Assessing Officer or the Commissioner (Appeals). That is what distinguishes it from s.271AA(1), which is the older penalty: without prejudice to s.270A, s.271 or s.271BA, where a person in respect of an international transaction or specified domestic transaction fails to keep and maintain the information and document required by s.92D(1) or (2), or fails to report such transaction which he is required to do, or maintains or furnishes an incorrect information or document, the ASSESSING OFFICER OR COMMISSIONER (APPEALS) may direct payment of "a sum equal to two per cent of the value of each international transaction or specified domestic transaction entered into by such person". Both sub-sections are named in s.273B, so no penalty is imposable under either if the person proves there was reasonable cause for the failure.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2017-04-01, reported as Section 271AA of the Income-tax Act, 1961, transcribed from incometaxindia.gov.in/w/section-271aa-16 (heading "Penalty for failure to keep and maintain information and document, etc., in respect of certain transactions", Year: 2017); s.273B read on incometaxindia.gov.in/w/section-273b-30 (Year: 2017). It bears on section 271AA, section 271AA(1), section 271AA(2), section 92D, section 92D(1), section 92D(2), section 92D(4), section 286, section 286(1), section 270A, section 271, section 271BA, section 273B, section Rule 10DA, section Rule 10D of the Income Tax Act 1961, in Penalty, Appeals and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed. The text is taken from a single departmental page stamped Year 2017; I probed suffixes -2, -5 and -10, all of which returned the pre-2012 text with a different heading and no sub-section (2), and I did NOT locate a page for this section with a later Year stamp. A later amendment therefore cannot be excluded. The footnote dating sub-section (2) to Act No. 28 of 2016 with effect from 1 April 2017 is consistent with the identically dated footnote inserting s.92D(4) on the s.92D page, which is the obligation this penalty enforces. I did not check judicial treatment of s.271AA(2).

Why it matters

Three practical consequences. First, because s.271AA(2) is flat, quantum arguments do not run: there is nothing to reduce by pointing to the size of the transaction, and the only defences are that the obligation did not arise, that it was complied with, or reasonable cause under s.273B. Second, because it is imposed by the prescribed authority under s.286(1) and not by the Assessing Officer, a s.271AA(2) penalty appearing in an assessment order or in a notice issued by the Assessing Officer is open to a jurisdictional objection, and the identity of the authority should be checked on the face of the order. Third, the two sub-sections punish different failures and can both be in play: s.271AA(1) reaches failure to keep the transaction-level documentation under Rule 10D and failure to REPORT a transaction, at two per cent of the value of each transaction, while s.271AA(2) reaches only the master file failure under s.92D(4). A constituent entity that has not filed Part A of Form No. 3CEAA — which Rule 10DA(3) requires of every constituent entity regardless of any threshold — is exposed to the five lakh rupee penalty even though it is far below every master file threshold.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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Related

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