Under section 442(1)(a) of the Income-tax Act, 2025, what penalty may be imposed where a person fails to keep the required information and documents for an international transaction?

Section 442(1)(a) of the Income-tax Act, 2025 allows a penalty of 2% of the value of each international or specified domestic transaction for which the information and documents required by section 171(1) are not kept. The fixed ₹5,00,000 penalty in section 442(2) is for a constituent entity of an international group that fails to furnish the information required under section 171(4).