VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — section 285BA, rule 114E and Form 61A: who must file the statement of financial transactions, and the section 271FA and 271FAA penalties
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Statutory position — section 285BA, rule 114E and Form 61A: who must file the statement of financial transactions, and the section 271FA and 271FAA penalties

A notice says my client should have filed Form 61A and proposes a penalty of five hundred rupees a day. Who actually has to file, for what transactions, and how is the penalty computed?

A notice says my client should have filed Form 61A and proposes a penalty of five hundred rupees a day. Who actually has to file, for what transactions, and how is the penalty computed?

The statement of financial transactions is furnished under section 285BA(1) in Form No. 61A, and rule 114E(2) fixes both the reporting persons and the transactions in a table: for most reporters the threshold is ten lakh rupees in a financial year, for immovable property registered by a Registrar or Sub-Registrar it is thirty lakh rupees, and for a person liable to audit under section 44AB it is receipt of cash exceeding two lakh rupees for a sale of goods or services. The due date under rule 114E(5) is 31 May following the financial year. The penalty under section 271FA is five hundred rupees for every day of default, rising to one thousand rupees a day from the day after the time given in a notice under section 285BA(5) expires; section 271FAA adds fifty thousand rupees for an inaccurate statement, and, for a reporting financial institution, a further five thousand rupees for every inaccurate reportable account.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2023-04-01, reported as Income-tax Act 1961, ss.285BA, 271FA and 271FAA; Income-tax Rules 1962, rule 114E and Form No. 61A; s.271FAA(2) inserted by the Finance Act 2023 w.e.f. 1 April 2023; the words 'clause (k) of' omitted from s.271FAA by Act No. 23 of 2019 w.e.f. 1 September 2019. It bears on section 285BA, section 285BA(4), section 285BA(5), section 285BA(6), section 285BA(7), section 271FA, section 271FAA, section 273B, section 44AB, section 50C of the Income Tax Act 1961, in Penalty, Cash Transaction Limits, Evidence & Burden of Proof and How Tax Law Is Read matters.

Still good law. This is the statute and the rule, not a decision about them. Section 285BA was read from a departmental page carrying a current 'Year: 2026' stamp. Section 271FA in its current five hundred / one thousand rupee form was read from three departmental pages stamped Year 2020, Year 2022 and Year 2024 (No. 2), all identical; none of them printed a footnote list, so the amending Act and the date of the increase from one hundred / five hundred rupees could not be established on this pass and are not stated. Section 271FAA in its current two-sub-section form was read from a page stamped Year 2024 (No. 1) carrying footnotes attributing sub-section (2) to the Finance Act 2023 with effect from 1 April 2023. Rule 114E carries no year stamp, as no departmental rule page does, so its currency rests on it being the page the department serves for that rule and not on any date printed on it.

Why it matters

The commonest mistake in this area is to assume the obligation attaches to a class of institution. It does not: rule 114E(2) attaches it to a TRANSACTION recorded by a named class of person, and Sl. No. 11 of that table catches 'any person who is liable for audit under section 44AB' who receives cash exceeding two lakh rupees for a sale of goods or services of any nature. An ordinary trading company with a tax audit is therefore a reporting person, and its Form 61A obligation is easy to miss until the notice arrives. Two more traps. First, the penalty structure is two-tier and the second tier is the expensive one: section 271FA charges five hundred rupees a day for the original default and one thousand rupees a day only 'beginning from the day immediately following the day on which the time specified in such notice for furnishing the statement expires', so a reporting person served with a section 285BA(5) notice who continues to do nothing doubles his exposure from that point. Answering the notice within the period it allows is worth more than any argument. Second, section 285BA(4) has a sting: if the prescribed authority intimates that a statement is defective and the defect is not rectified within thirty days or such further period as is allowed, then 'notwithstanding anything contained in any other provision of this Act, the provisions of this Act shall apply as if such person had furnished inaccurate information in the statement' — which is the gateway to section 271FAA. A defective statement left unrectified is deemed to be an inaccurate one. Note also that section 285BA(6) requires a reporting person who discovers an inaccuracy to inform the authority within ten days, and that failing to do so is itself a limb of section 271FAA(1)(c). Section 273B is not part of section 285BA but it does cover section 271FA and section 271FAA, so reasonable cause remains available; that is where these appeals are usually won.

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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