VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.271GB: the country-by-country penalties are DAILY and they escalate — Rs 5,000, then Rs 15,000, then Rs 50,000 a day after the penalty order is served — plus Rs 5 lakh for an inaccurate report, and the s.273B reasonable-cause defence that applies to all of them
CBDT Circulars & InstructionsCuts both wayss.271GBs.271GB(1)s.271GB(2)s.271GB(3)s.271GB(4)s.286s.286(2)s.286(6)s.273B

Statutory position — s.271GB: the country-by-country penalties are DAILY and they escalate — Rs 5,000, then Rs 15,000, then Rs 50,000 a day after the penalty order is served — plus Rs 5 lakh for an inaccurate report, and the s.273B reasonable-cause defence that applies to all of them

We missed the country-by-country report deadline. What is the exposure, and does it stop accruing once the department passes an order?

We missed the country-by-country report deadline. What is the exposure, and does it stop accruing once the department passes an order?

It does not stop; it gets worse. Section 271GB(1) penalises a reporting entity that fails to furnish the s.286(2) report at "five thousand rupees for every day for which the failure continues, if the period of failure does not exceed one month" and "fifteen thousand rupees for every day for which the failure continues beyond the period of one month". Section 271GB(2) penalises failure to produce information and documents within the period allowed under s.286(6) at five thousand rupees a day, running from the day immediately following the day the period expires. Section 271GB(3) is the escalation: if the failure under sub-section (1) or (2) continues AFTER an order directing payment of the penalty has been served, then notwithstanding sub-sections (1) and (2) the prescribed authority may direct payment of "fifty thousand rupees for every day for which such failure continues beginning from the date of service of such order". Section 271GB(4) imposes a flat penalty of five lakh rupees for inaccurate information in the report in three situations — knowledge of the inaccuracy at the time of furnishing coupled with failure to inform the prescribed authority; discovery after furnishing coupled with failure to inform and to furnish a correct report within fifteen days of discovery; and furnishing inaccurate information or documents in response to a s.286(6) notice. Section 273B names s.271GB, so no penalty is imposable under it if the entity proves there was reasonable cause for the failure.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text), reported as Section 271GB of the Income-tax Act, 1961, transcribed from incometaxindia.gov.in/w/section-271gb (heading "Penalty for failure to furnish report or for furnishing inaccurate report under section 286", Year: 2016) and sub-sections (1) to (3) read again on incometaxindia.gov.in/w/section-271gb-2 (Year: 2020); s.273B read on incometaxindia.gov.in/w/section-273b-30 (Year: 2017). It bears on section 271GB, section 271GB(1), section 271GB(2), section 271GB(3), section 271GB(4), section 286, section 286(2), section 286(6), section 273B of the Income Tax Act 1961, in Penalty, Appeals and How Tax Law Is Read matters.

Still good law. The text is current so far as I could establish: two departmental pages with different "Year:" stamps (2016 and 2020) print sub-sections (1) to (3) identically, and neither carries an amendment footnote. I probed no suffix above /w/section-271gb-2, so a later version cannot be excluded. Judicial treatment: an exact-phrase search on indiankanoon for "section 271GB" returned no decision imposing, reducing or setting aside a penalty under the section and none construing it; that is what my search found, not a certification that no such decision exists.

Why it matters

The arithmetic is the point. Three months of default under sub-section (1) is roughly Rs 1,50,000 for the first month and Rs 15,000 a day thereafter — about Rs 10 lakh — and once a penalty order is served and the report is still not filed, the meter runs at Rs 50,000 a day with no cap written into the section. There is no maximum anywhere in s.271GB. The practical lesson is that the single most valuable thing to do after a default is discovered is to FILE, because every provision here is framed around a failure that "continues". Sub-section (4) rewards self-correction in the same way: an entity that discovers an inaccuracy after filing escapes the five lakh rupee penalty if it informs the prescribed authority AND furnishes a correct report within fifteen days of the discovery, so the fifteen-day window is worth diarising the moment an error is found. And because s.273B covers s.271GB, reasonable cause is a complete answer — but it has to be proved by the entity, so the contemporaneous record of why the report could not be filed (a parent that would not release group data, an exchange relationship that was not in place, a systemic failure intimation) is what wins the penalty appeal.

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

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

Read aloud by your device. Press again to stop.

Related

Other authorities on the same sections.