Section 273B

Section 273B — the law in short

What the courts have decided on section 273B, in one screen. Read this first; open an entry when you need the facts, the reasoning and the source.

• Singapore Airlines Ltd v CIT Supreme CourtCuts both ways
  My agents keep the difference between the price they charge customers and the net price they pay me — do I have to deduct TDS on money that never passed through my hands?
  Yes. The Supreme Court held on 14 November 2022 that the supplementary commission retained by IATA travel agents — the excess of the actual fare charged to the passenger over the net fare payable to the airline — is "commission" under section 194H, and the airlines were bound to deduct tax at source on it. Section 194H is read with section 182 of the Contract Act: where the contract shows a principal-agent relationship, the definition is attracted. But because the agents had paid tax on those amounts, no recovery of the shortfall could be made from the airlines; only interest under section 201(1A) survives, and the section 271C penalties were quashed.
• ADIT (Investigation) v Kum. A.B. Shanthi Supreme CourtHelps department
  You took a cash loan and now face penalty equal to the whole amount. Is there any relief?
  Yes, through s.273B. The Court upheld s.269SS as valid precisely because s.273B mitigates the hardship: no penalty is imposable if you prove reasonable cause for the failure.
• Hindustan Steel Ltd v State of Orissa Supreme CourtCuts both waysPartly overruled — read this first
  Must penalty be imposed just because the law permits it?
  No. Penalty is discretionary and is not to be imposed merely because it is lawful to do so — and not at all for a technical or venial breach, or where the default flowed from a bona fide belief.
• Sandeep Kaur Gill v Union of India High CourtHelps taxpayerNo later treatment found
  The financier insisted on cash. Can they penalise me under 271E for repaying the loan in cash?
  Not where reasonable cause is shown. Section 269T is mandatory, but bona fide belief coupled with the genuineness of the transaction is reasonable cause under s.273B, and once that is shown no penalty under s.271E is attracted.
• Chavakkad Service Co-operative Bank v ITO High CourtHelps taxpayerNo later treatment found
  Our audit report was late because the statutory auditor was late. Can the officer still levy the s.271B penalty?
  No, where the delay is genuinely the auditor's and the report reaches the officer before the assessment is completed. The Kerala High Court set aside penalties of Rs 1.5 lakh, holding that s.273B is peremptory: no penalty can be imposed under s.271B if the assessee proves reasonable cause, and a co-operative society has no control over the timetable of the statutory auditor appointed under the State co-operative law.
• Pr. Commissioner of Income Tax v Shree Madhi Surali Vibhag Nagarik Sahakari Dhiran Mandli Ltd High CourtHelps taxpayer
  Our credit society takes and repays members' money in cash across the counter like a bank. The officer has levied penalty under sections 271D and 271E on the whole turnover. Can it stand?
  No, on these facts. The Gujarat High Court upheld the deletion of penalties of Rs 28,66,93,898 under section 271D and Rs 27,12,01,825 under section 271E. Section 273B says no penalty is imposable if the person proves reasonable cause, and that gives the authority a discretion to be exercised justly on the record. The Commissioner (Appeals) and the Tribunal found on the facts that the society, whose members' accounts work like savings accounts repayable on demand, acted on a bona fide belief that sections 269SS and 269T did not apply, that the deposits were accepted as genuine with no addition made, and that its auditor had never reported a contravention. The Court found no legal infirmity and dismissed the Revenue's appeal, holding that no substantial question of law arose.
• Grihalakshmi Vision v Addl CIT High CourtHelps departmentHigh Courts differ
  My assessment order says penalty under sections 271D and 271E is initiated. The Joint Commissioner issued his notice months later and passed the penalty order after that. Does time run from the assessment order or from his notice?
  From his notice, on this judgment. The Kerala High Court held that because a penalty under s.271D or s.271E may be imposed only by the Joint Commissioner, only the Joint Commissioner can initiate the proceedings; the assessing officer cannot. It follows that the sentence in the assessment order saying that proceedings under those sections are initiated is inconsequential, and that limitation under s.275(1)(c) is measured from the Joint Commissioner's notice. On the dates before the Court - assessment order 6 November 2007, notice by the Joint Commissioner 28 March 2008, penalty orders 29 July 2008 - the penalty orders were in time. The appeals were rejected and the questions answered in favour of the Revenue.
• CIT (TDS) v Superintendent of Police High CourtHelps taxpayer
  CPC has raised a s.272B penalty of ten thousand rupees for each of 196 deductees whose PANs were invalid in my TDS statement. The deductees gave me those numbers. Is that reasonable cause?
  Yes, on these facts. The Punjab and Haryana High Court dismissed the Revenue's appeal against the deletion of a Rs 19,60,000 penalty levied at Rs 10,000 per default for 196 invalid PANs in a quarterly TDS statement. The Court held that whether sufficient cause had been shown within s.273B was a question of fact, on which the CIT(A) and the Tribunal had concurrently found in the assessee's favour after examining the explanation, and that no substance remained in the Revenue's argument.
• CIT v Triumph International Finance (I) Ltd High CourtCuts both ways
  We settled a loan against an amount the same party owed us, by journal entry, and paid only the small balance by cheque — can penalty under section 271E be levied?
  It depends, and on this record no. The Bombay High Court held on 12 June 2012 that repaying a loan or deposit by journal entry does contravene section 269T: the section draws no line between bona fide and other transactions, and does not speak of an outflow of funds, it simply bars every mode except an account payee cheque or draft. But section 273B saves the assessee where reasonable cause is shown, and that expression is wider than sufficient cause and is construed liberally. Here the same party owed the assessee almost the identical sum for shares, the genuineness of both legs was never doubted, and the penalty of Rs.4,28,99,325 was rightly deleted.
• CIT v Sunil Kumar Goel High CourtHelps taxpayer
  I took and repaid small cash loans from my family's sister concern, all recorded in the books. Must penalty follow automatically under sections 271D and 271E?
  No. The Punjab and Haryana High Court held that section 273B opens with a non obstante clause and overrides sections 271D and 271E, so an assessee who proves reasonable cause escapes penalty even though section 269SS or 269T has been contravened. On these facts the Tribunal had found the cash loans were between family members and a sister concern, taken for business exigency, entered in cash books produced to the Revenue, with no tax avoidance or evasion and no prejudice to the Revenue. That is reasonable cause, and whether it exists is a finding of fact giving rise to no substantial question of law.
• CIT v Rugmini Ram Ragav Spinners P Ltd High CourtHelps taxpayer
  We refunded share application money in cash. Is that a repayment of a deposit under s.269T?
  No. The Madras High Court held that money received as advance towards allotment of shares, with no time frame for return and no interest, is neither a deposit nor a loan but share capital advance, and that ss.269SS and 269T apply only to deposits or loans — when it is neither, those sections have no application at all. Penalty under s.271E is not automatic and a bona fide belief that advances against allotment of shares are not loans or deposits is itself a reasonable cause under s.273B.
• TSC Fashions Pvt Ltd v ITO ITATHelps departmentNo later treatment found
  My client missed the tax audit because the old auditor stopped cooperating. Is that a reasonable cause that kills the s.271B penalty?
  Not on assertion alone. The Tribunal confirmed the penalty because the assessee produced no correspondence, email, letter, complaint or affidavit against the earlier auditor, and showed no proactive steps of its own; a bald plea of auditor non-cooperation is a mere allegation and does not discharge the burden under s.273B.
• DCIT v Umiya Co-operative Credit Society Ltd ITATHelps taxpayerNo later treatment found
  Our credit society takes deposits and repays loans in cash to members. Can the department levy 271D and 271E on the whole amount?
  Not where the transactions are genuine dealings with members in the ordinary course. The Tribunal upheld the deletion of penalties under s.271D and s.271E on cash deposits and repayments of roughly Rs 28 crore and Rs 27 crore, treating a co-operative credit society's dealings with its own limited membership as attracting the reasonable cause protection in s.273B, particularly where no addition was made in the assessment and the genuineness of the transactions was not in dispute.
• Jaya Rinkubhai Bandukwala v ITO, Ward 3(3)(1), Surat ITATCuts both waysNo later treatment found
  The Assessing Officer has levied Rs 30,000 under section 272A(1)(d) — Rs 10,000 for each of three notices I did not answer. Can he multiply the penalty like that, and what can I actually get reduced?
  Yes, the section provides a penalty of Rs 10,000 per default and the Assessing Officer may levy one for each unanswered notice; the Surat Bench said so in terms. But section 273B is not all-or-nothing on the facts: finding that reasonable cause existed for some of the defaults and not for others, the Tribunal restricted the total from Rs 30,000 to Rs 10,000.
• Amit Jain v DCIT, Circle (International Taxation), Jaipur ITATHelps taxpayerNo later treatment found
  I asked the Assessing Officer for more time on a section 142(1) notice and then filed the reply within the time I had asked for. He has still levied Rs 10,000 under section 272A(1)(d). Is that sustainable?
  No, on these facts. Where the assessee answered the notice by filing an adjournment request, and the Assessing Officer never rejected that request by a speaking order, the notice was attended to and there is no 'failure to comply' at all — the Tribunal deleted the Rs 10,000 penalty without needing to reach section 273B.
• Palanirajan Rajarajan v Addl. CIT ITATHelps taxpayerNo later treatment found
  Your return for the year was late and treated as invalid, though it did disclose the foreign assets in Schedule FA. Can the Rs 10 lakh penalty under s.42 still stand?
  On this order it was deleted - but not because s.42 was held to confer any discretion. The Tribunal deleted Rs 10 lakh penalties for both years, under s.43 for AY 2016-17 and under s.42 for AY 2017-18. The discretion reasoning, drawn from the word 'may' in s.43 and from Hindustan Steel, belongs to the s.43 year. For the s.42 year the route is factual and technical: the belated return did disclose the foreign assets in Schedule FA, the officer adopted the income admitted in that return, the return filed under s.153C substituted the regular return, and the late filing was 'mere technical breach'.
• Meet Forex Private Limited v Addl./JDIT (I&CI), New Delhi ITATHelps taxpayerNo later treatment found
  My client is a small money changer who never knew he had to file Form 61A. A penalty of eighty-one thousand rupees has been levied under s.271FA. Is ignorance of the requirement any answer?
  On these facts, yes. The Delhi Bench deleted the whole penalty, holding that the explanation of not filing the statement of financial transactions for lack of knowledge was bona fide, given that the assessee had only one transaction to report, and following two Kolkata decisions treating such a default as a technical or venial breach flowing from bona fide ignorance. The relief was outright deletion, not a remand.
• Star Quenchers Spirit Pvt Ltd v JCIT (TDS), Nashik ITATHelps departmentNo later treatment found
  My quarterly TDS and TCS statements for 2010-11 were filed late and the JCIT has levied penalty at Rs 100 a day under section 272A(2)(k). No tax was lost. Is that a defence?
  No. The Pune Bench upheld a penalty of Rs 1,09,304 under section 272A(2)(k) read with section 200(3), holding that the absence of loss to the Revenue does not mean the deductor may skip the obligation to file quarterly statements within the statutory time. It followed the Allahabad High Court in Raja Harpal Singh Inter College v PCIT, noting that no decision of the jurisdictional High Court had been brought to its notice.
• Yuvraj Singh v ITO ITATHelps taxpayerNo later treatment found
  The officer treated my cash deposits as turnover, said I crossed the s.44AB limit and levied s.271B. The quantum was settled under Vivad se Vishwas. Does the penalty still stand?
  No. Where the assessee's declared turnover was below the s.44AB threshold and the officer crossed the threshold only by adding cash deposits to it, and the quantum dispute ended under the Vivad se Vishwas Scheme 2020 without any final judicial finding on the correctness of the turnover, the benefit of the doubt goes to the assessee and the s.271B penalty is reversed.
• DCIT, CC-7(3), Mumbai v Macrotech Developers Ltd ITATHelps taxpayer
  The group squares off inter-company balances by journal entry. The Department says every entry is a s.269SS or s.269T violation. What survives?
  The Tribunal dismissed the Revenue's appeals and confirmed the deletion of penalties under ss.271D and 271E. Its route was not that journal entries fall outside the sections — on the jurisdictional High Court's decision they are hit — but that the reasons for using them were commercial and therefore reasonable cause under s.273B. The reasons accepted were raising funds, assignment of receivables, squaring up transactions, operational efficiency and MIS, consolidation of family member debts, correction of errors, and loans taken in cash, and there was no finding that the transactions involved unaccounted money or were not genuine.
• Faith Intertrade v ITO ITATHelps taxpayer
  I obtained Form 3CEB from my accountant but never uploaded it, and the officer has levied the flat Rs 1 lakh penalty under s.271BA. Is that penalty automatic?
  It is not automatic. Section 271BA says the officer 'may' direct payment of the penalty, not 'shall', and s.273B forbids the penalty where the assessee proves reasonable cause. The Tribunal quashed a Rs 1,00,000 penalty on an assessee who had obtained the accountant's report dated 7 September 2013 but failed to upload it electronically, in the first year in which specified domestic transactions were brought within s.92E, where the TPO had made no adjustment at all.
• Smt. Meera Devi Kumawat v JCIT, Range-4, Jaipur ITATHelps taxpayer
  My client's husband gave her the money to buy a plot registered in her name, partly in cash. Is that a s.269SS violation?
  The Jaipur Bench deleted the s.271D penalty. It held that registering property in a wife's name is guided by family and societal factors and by the Government's own incentive of reduced stamp duty for female purchasers, that pooling family funds in that situation calls for a flexible approach to the reasonableness of the explanation, and that where the whole transaction is documented in the registered sale deed and the cash portion came from the husband's known sources, the assessee had shown reasonable cause and did not deserve to be penalised.
• Dr. Sanjiv Keshav Karande v ITO, Ward-11(1), Pune ITATHelps departmentNo later treatment found
  The penalty under s.271D came more than six months after it was initiated. Is it automatically time-barred?
  No. Section 275(1)(c) gives the Department the later of two periods, and where the proceedings in the course of which the penalty was initiated were completed in a financial year that ends after the six-month period, the financial-year limb governs. Here the penalty was initiated in April 2016, six months would have run out at the end of October 2016, but the relevant financial year was 2016-17, so a penalty order passed on 29 November 2016 was in time. The Tribunal also dismissed the reasonable-cause plea on the facts.
• Mekkadampu Service Co-op Bank Ltd v Jt DIT (I & CI) ITATHelps departmentNo later treatment found
  The s.133(6) notices went unanswered and the s.272A(2)(c) penalties have been confirmed by the Commissioner (Appeals). Is there anything left to run before the Tribunal?
  On these facts, no. The Cochin Bench reproduced its own earlier order in Kakoor Service Co-operative Bank Ltd, which had held a penalty under s.272A(2)(c) valid where no reasonable cause within s.273B had been furnished for not answering the Income-tax Officer (Intelligence), and, finding the facts identical, held that the Commissioner (Appeals) was justified in upholding the penalty orders. All nine appeals and the three stay applications were dismissed. The order adds no reasoning of its own, on s.273B, on jurisdiction or on how the daily figure is computed.
• Guntur District Co-operative Central Bank Ltd v DIT ITATCuts both ways
  We had no reportable transactions and filed no SFT. Can they still levy penalty under 271FA?
  No, not for a year in which there was nothing to report. Section 285BA casts the filing obligation on a person who has registered or recorded a specified financial transaction during the financial year, so where no such transaction exists the duty to furnish the statement never arises and s.271FA has nothing to bite on. The burden is on the department to show that reportable transactions were in fact recorded before it can allege a failure.
• Sanmathi Ambanna v Jt CIT ITATHelps taxpayerNo later treatment found
  I took a cash loan from my father-in-law. Can they levy 271D on a genuine family transaction?
  No, on these facts - but on one ground only. The Tribunal deleted the penalty by following a coordinate bench decision, holding that cash loans from close relatives do not fall within the mischief of s.269SS because near or close relatives cannot be said to be 'other persons' within that section. It made no finding of reasonable cause under s.273B: that section appears in the grounds of appeal and inside the decisions the order extracts, but not in the Tribunal's own reasoning.
• ACIT v Dilipkumar V. Lakhi ITATHelps taxpayerNo later treatment found
  The TPO wants segment-wise profit and loss accounts for my AE and non-AE business and I cannot produce them. He has levied 2 per cent of the transaction value under s.271G. Can I resist it?
  Yes, where the failure is backed by a reasonable cause, because s.273B applies to s.271G. The Tribunal upheld the deletion of a Rs 56,72,162 penalty on a diamond trader who had furnished entity-level margins but could not split AE from non-AE segments, holding that in a trade where rough and polished diamonds move in mixed lots it is practically impossible to trace which rough stone became which polished stone, and that the assessee had substantially complied to the extent the trade allowed.
• P. Murali Mohana Rao v Addl. CIT, Range-1, Hyderabad ITATHelps taxpayerNo later treatment found
  The Additional Commissioner has levied Rs 30,000 on me personally, as the chartered accountant representing my client, for not attending on three dates in answer to section 131 summons. Does he even have the power to pass that order?
  On this reasoning, no. Because section 272A(1) imposes Rs 10,000 for each default, the penalty in law was Rs 10,000 per default and not Rs 30,000 in aggregate; and on the thresholds in section 274(2) a penalty of that amount is for the Income-tax Officer to impose, so the Tribunal held the Addl. CIT had no jurisdiction to pass the order. It also held there was reasonable cause under section 273B, that one show-cause notice cannot support penalties for three separate defaults, and that the completion of the client's assessment under section 143(3) rather than section 144 showed the subsequent compliance was good compliance.
• Kalpakancherry Service Co-op Bank Ltd v Addl. DIT (Intelligence) ITATHelps departmentNo later treatment found
  We ignored the s.133(6) notices because we thought the officer had no business asking. What does that cost?
  A penalty under s.272A(2)(c) that the Tribunal will not disturb. Twenty-one appeals were dismissed. The Tribunal held the Income-tax Officer (Intelligence) had jurisdiction to issue the notices, that the penalty orders were within the limitation in s.275(1)(c), and that no valid reason having been offered for not furnishing the information, there was no reasonable cause under s.273B.
• ITO (TDS) v Rakesh Kumar ITATHelps taxpayerNo later treatment found
  I did not collect TCS because I did not think what I sold was 'scrap'. The officer has levied penalty at a hundred per cent. Is a wrong but honest view a defence?
  Yes, where the belief is honest and founded on reasonable grounds. The Tribunal upheld the deletion of a penalty of Rs.12,80,988 under s.271CA, holding that a dealer who honestly believed the goods he sold were not 'scrap' within Explanation (b) to s.206C had reasonable cause, even though the Commissioner (Appeals) had rejected that belief on merits. It also weighed that the buyers had returned the income and paid the tax, so no demand for the tax itself had been raised and no loss was caused to the Revenue.
• Statutory position — section 285BA, rule 114E and Form 61A: who must file the statement of financial transactions, and the section 271FA and 271FAA penalties CBDT Circulars & InstructionsCuts both ways
  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.
• Statutory position — section 139A(5), rule 114B and Form 60: where PAN must be quoted, and the section 272B penalty of ten thousand rupees for each default CBDT Circulars & InstructionsCuts both ways
  A penalty notice under s.272B says ten thousand rupees for each of dozens of defaults. Where is PAN actually required to be quoted, what does a person without one do, and is the penalty really per default?
  Rule 114B lists eighteen transactions in which every person must quote his permanent account number, from opening a bank account and buying a car to a sale or purchase of immovable property exceeding ten lakh rupees and any sale or purchase of goods or services exceeding two lakh rupees per transaction. A person other than a company or firm who has no permanent account number makes a declaration in Form No. 60 instead. Section 272B(1) charges ten thousand rupees for failure to comply with section 139A; sub-sections (2), (2A) and (2B) each charge ten thousand rupees 'for each such default', and no order under any of them may be passed without an opportunity of being heard.
• 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 waysNo later treatment found
  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.
• Statutory position — s.271J: the Rs 10,000 penalty on the accountant, merchant banker or registered valuer personally CBDT Circulars & InstructionsCuts both ways
  A notice under section 271J has come to me, the chartered accountant who signed the report, not to my client. On what can it be levied, and how much?
  Section 271J allows the Assessing Officer or the Commissioner (Appeals), in the course of any proceedings under the Act, to direct an accountant, a merchant banker or a registered valuer who has furnished incorrect information in any report or certificate under the Act or the Rules to pay a penalty of Rs 10,000 for each such report or certificate. It reaches only those three classes of person, each defined in the Explanation; it cannot be levied on the assessee who filed the report.
• Statutory position — s.271H replaced s.272A(2)(k) for TDS and TCS statements from 1 July 2012 CBDT Circulars & InstructionsCuts both ways
  The TDS officer has levied a penalty for a late quarterly statement. Which section applies — the daily penalty in section 272A(2)(k) or section 271H — and what gets me out of it?
  It depends on when the tax was deducted or collected. For tax deducted or collected before 1 July 2012 the penalty is under section 272A(2)(k) at Rs 100 for every day of default, capped by the proviso at the amount of tax deductible or collectible. For tax deducted or collected on or after 1 July 2012 the second proviso to section 272A(2) bars that penalty altogether and section 271H applies instead — a sum of not less than Rs 10,000 and up to Rs 1,00,000, directed by the Assessing Officer, with an escape in section 271H(3) which since 1 April 2025 requires the statement to have been filed within ONE MONTH of the prescribed time, not one year.
• 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 ways
  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.

Listed strongest first: Supreme Court, then High Court, then Tribunal, then CBDT. Nothing here has yet been read in full by a chartered accountant — open an entry to see where it came from.