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ITA 1961 → DTC 2025Penalties

Section 271AA Section 347

Penalty for failure to keep and maintain information and document, etc., in respect of certain transactions

RetainedHigh - Major risk for MNCs.

Quick Answer

Section 271AA of the Income Tax Act, 1961 (Penalty for failure to keep and maintain information and document, etc., in respect of certain transactions) corresponds to Section 347 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: XXI

Sec 271AA

Provision Summary

Penalty of 2% of the value of each international transaction for failing to maintain Transfer Pricing documents under Section 92D.

New Law (DTC 2025)Ch: XXIV

Sec 347

Provision Summary

Retained. A highly punitive penalty designed to enforce strict TP documentation.

Key Changes & Highlights

  • No change.

Related Sections

Frequently Asked Questions

What does Section 271AA of the Income Tax Act 1961 deal with?

Section 271AA (Penalty for failure to keep and maintain information and document, etc., in respect of certain transactions) Penalty of 2% of the value of each international transaction for failing to maintain Transfer Pricing documents under Section 92D.

What is the new section number for Section 271AA under the Direct Tax Code 2025?

Section 271AA of the ITA 1961 maps to Section 347 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

What is the status of Section 271AA under the new tax code?

Section 271AA is marked as "Retained" with status "Active". Impact: High - Major risk for MNCs.

What are the key changes to Section 271AA under DTC 2025?

No change.

Disclaimer: This page is for educational and reference purposes only. Section mappings are based on publicly available drafts and circulars. Always consult a qualified Chartered Accountant before filing or making compliance decisions under the Direct Tax Code 2025.

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