<s>[INST] When penalty under Section 271GB(1) may be imposed? [/INST] ​​Section 286 of the Income-tax Act requires a parent entity resident in India or an alternate reporting entity resident in India to furnish a 'Country by Country Report' (CbCR) in respect of the international group of which it is a constituent in Form 3CEAD. The penalty under section 271GB(1) may be imposed if a reporting entity fails to furnish a report in Form No. 3CEAD.​ </s>