The 2018 Indian Finance Act amended the litigation procedure (Section 276CC of the Income Tax Act) for a willful failure to file an income tax return by the due date, effective for tax returns for taxable years beginning on or after 1 April 2017.

 According to Finance Act 2018, the principal officer of a company, including a foreign company, may become subject to legal proceedings including prosecutions for failure to file an income tax return, even if final tax due is less than the INR3,000 minimum tax liability.