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ITA 1961 → ITA 2025Penalties

Section 271G Section 354

Penalty for failure to furnish information or document under section 92D

RetainedHigh - Prevents stalling tactics by MNCs during TP audits.

Quick Answer

Section 271G of the Income Tax Act, 1961 (Penalty for failure to furnish information or document under section 92D) corresponds to Section 354 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.

What changed for Section 271G

In the 1961 statute, Section 271G deals with penalty for failure to furnish information or document under section 92d. Penalty of 2% of the value of the international transaction if the assessee fails to submit the requested TP documents to the AO/TPO during an audit.

From 1st April 2026, the same subject sits at Section 354 of the Income-tax Act, 2025 — retained and renumbered as Section 354 of the Income-tax Act, 2025. Retained. Supplements Section 271AA.

For Section 271G, the practical impact is rated High. Prevents stalling tactics by MNCs during TP audits.

Old Law (ITA 1961)Ch: XXI

Sec 271G

Provision Summary

Penalty of 2% of the value of the international transaction if the assessee fails to submit the requested TP documents to the AO/TPO during an audit.

New Law (ITA 2025)Ch: XXIV

Sec 354

Provision Summary

Retained. Supplements Section 271AA.

Key Changes & Highlights

  • None.

Related Sections

Frequently Asked Questions

What is Section 271G of the Income Tax Act, 1961 about?

Section 271G of the Income Tax Act, 1961 covers penalty for failure to furnish information or document under section 92d. Penalty of 2% of the value of the international transaction if the assessee fails to submit the requested TP documents to the AO/TPO during an audit.

Which section replaces Section 271G in the Income-tax Act, 2025?

Section 271G of the Income Tax Act, 1961 maps to Section 354 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. Supplements Section 271AA.

What is the impact of the change to Section 271G under the new tax code?

The transition impact for Section 271G is rated High. Prevents stalling tactics by MNCs during TP audits.

What should I watch out for when Section 271G moves to the 2025 code?

None. These points are specific to Section 271G (Penalty for failure to furnish information or document under section 92D).

Disclaimer: This mapping of Section 271G (Penalty for failure to furnish information or document under section 92D) to Section 354 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 271G is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.

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