For tax year 2026–27, a company furnishes its section 172 transfer-pricing report 20 days late. What fee is payable under section 428 of the Income-tax Act, 2025, as amended by the Finance Act, 2026?

The Finance Act, 2026 omitted the section 447 penalty for not furnishing the section 172 report and replaced it with a fee under section 428: ₹50,000 where the delay is up to one month and ₹1,00,000 for a longer delay. A 20-day delay therefore attracts ₹50,000; 2% of the transaction value is the section 442 penalty for documentation or reporting failures.