Read the information order before modelling exposure
Section 124 of the CGST Act addresses information or returns required under section 151. One limb concerns failure without reasonable cause to furnish the required material; the other concerns wilfully furnishing, or causing to be furnished, material known to be false. The section provides a fine up to ₹10,000 and, for a continuing offence, a further fine up to ₹100 for each day after the first, subject to the stated ₹25,000 maximum for that continuing component. These are ceilings, not an automatic portal late fee. ICAI 2026 bare law: CGST sections 124, 134 and 151.
Use the current section 151 wording
Section 151 now permits the Commissioner or an authorised officer, by order, to direct any person to furnish information concerning a matter connected with the Act, within the time, form and manner specified in that order. Do not apply the pre-2022 notification-based statistics wording as though it were the current procedure. Keep the actual order, authority, scope, specified period and submission channel in the response file. ICAI 2026 bare law: CGST sections 124, 134 and 151.
Separate the two alleged forms of conduct
A missing submission and a knowingly false submission require different evidence. Preserve the factual explanation for non-furnishing and any reasonable-cause case. For an allegation of wilful known falsity, identify the particular answer, the underlying source records and who knew what. An accounting revision or an innocent data discrepancy should not silently be labelled wilful falsity. Conversely, a response date alone does not establish the truth of what was submitted. ICAI 2026 bare law: CGST sections 124, 134 and 151.
Define continuing days carefully
Build the chronology from the actual requirement and legally established offence period. The statutory further-fine wording excludes the first day. Do not count every day since receipt of the information order automatically, or continue counting after the legally relevant failure has ended. The examples stipulate the established duration and use the maximum ₹100 rate only to show the ceiling arithmetic. They do not decide liability or a court's assessment. ICAI 2026 bare law: CGST sections 124, 134 and 151.
Keep this fine separate from neighbouring provisions
Section 123 concerns a different information-return route under section 150 and has its own conditions. Section 125 is residual and should not replace a separately provided fine simply to obtain a different amount. Section 134 governs court cognizance, including prior Commissioner sanction and the minimum court level. Do not treat section 124 as an automatically generated administrative late-fee invoice or claim that paying a calculated figure alone concludes proceedings. ICAI 2026 bare law: CGST sections 124, 134 and 151.
Prepare a reproducible response and amount bridge
Maintain the order, service evidence, deadlines, original data, checks, response acknowledgement and any correction chronology together. Record any imposed basic and continuing fines separately, along with payments validly credited to them. The models concern the central Act only and do not automatically double amounts for State law. Any defence, procedural route or further liability must be assessed on the actual applicable facts rather than inferred from a spreadsheet total. ICAI 2026 bare law: CGST sections 124, 134 and 151.
Applicable primary references
ICAI 2026 bare law: CGST sections 124, 134 and 151
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: First day only
Assume an established continuing-offence period of one day. Days after the first are zero; the maximum continuing component is ₹0. This does not determine whether a basic fine is imposed or its amount.
Illustrative example 2: Eleven-day duration
For an assumed established duration of eleven days, ten days fall after the first. At the maximum ₹100 per day, the continuing-component arithmetic is ₹1,000, within its stated ₹25,000 ceiling.
Illustrative example 3: Ceiling reached
For an assumed 251-day duration, 250 days after the first multiplied by ₹100 equals ₹25,000. This is the ceiling model for the continuing component, not a mandatory assessment.
Illustrative example 4: Longer duration
For an assumed 301-day duration, 300 multiplied by ₹100 gives ₹30,000. Applying the stated continuing-component ceiling limits that component to ₹25,000; the unbounded calculation exceeds it by ₹5,000.
Illustrative example 5: Stipulated imposed amounts
Assume a competent determination imposes a basic fine of ₹4,000 and a continuing fine of ₹600. The combined imposed amount is ₹4,600. Do not substitute both maximum figures for the amounts actually imposed.
Illustrative example 6: Avoid counting the first day twice
Assume an established eight-day continuing period. Seven days after the first multiplied by ₹100 equals ₹700 at the maximum daily rate. Using all eight days would produce ₹800, overstating this model by ₹100.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Locate the information order | Preserve the actual section 151 direction. |
| 2 | Check authority and scope | Record the Commissioner or authorised officer and requested matter. |
| 3 | Extract submission requirements | Identify the order's time, form and manner. |
| 4 | Preserve service evidence | Keep the date and actual communication record. |
| 5 | Classify the allegation | Separate non-furnishing from wilful known-false information. |
| 6 | Build the factual explanation | Retain reasonable-cause or accuracy evidence as relevant. |
| 7 | Determine the continuing period | Support start, end and exclusion of the first day. |
| 8 | Check ceiling arithmetic | Separate basic and continuing components. |
| 9 | Review the proper procedure | Address section 134 and other applicable procedural requirements. |
| 10 | Reconcile the outcome | Track determination, valid payment credits and remaining amounts. |
Sixteen practitioner FAQs
1. Does section 151 still use only its old statistics-notification procedure?
No. Read the current order-based wording.
2. Who may issue the current direction?
The Commissioner or an officer authorised by him.
3. Is every section 151 response due within a universal number of days?
The order specifies its time, form and manner.
4. What non-furnishing limb does section 124 use?
Failure without reasonable cause to furnish the required information or return.
5. What false-information limb does it use?
Wilful furnishing or causing furnishing of information or a return known to be false.
6. Does a later correction automatically prove wilful falsity?
No. Examine the facts and mental-element requirements.
7. Is ₹10,000 a mandatory basic fine?
No. The wording provides a fine that may extend to that amount.
8. Is ₹100 automatically due for every calendar day?
No. Establish the continuing offence and relevant days first.
9. Is the first day included in the further daily component?
The wording applies to days after the first.
10. What ceiling do the continuing-component models use?
The section's stated ₹25,000 maximum for that component.
11. Do the examples determine a court's fine?
No. They illustrate upper-bound arithmetic on stipulated durations.
12. Is this the same route as section 123?
No. That provision concerns the section 150 information-return route.
13. Can section 125 simply replace a separately provided fine?
Do not use the residual provision that way.
14. Is section 124 merely an automatic portal late fee?
No. Read its fine wording and the relevant procedure, including section 134.
15. Can central amounts simply be doubled for State law?
Check the separate enactment and proceeding first.
16. What is the strongest operational control?
A dated order-to-response file with source data, factual explanations and separately reconciled outcomes.
Conclusion
Section 124 distinguishes failure without reasonable cause from wilful known-false information. Establish its conditions before modelling the basic fine and the separate continuing-offence component.