Corporate liability for tax offences extends to responsible officers, subject to a due diligence defence.

Liability attaches to companies and to persons in charge of their business when an offence under the Act is committed; officers are separately liable if the offence occurred with their consent, connivance or attributable negligence. The provision similarly treats partners, karta or managing trustees as guilty for offences by partnership firms, LLPs, HUFs or trusts. A defence exists where the person proves lack of knowledge or that all due diligence was exercised to prevent the offence. "Company" includes a firm or association of individuals and a firm's partner is treated as a "director".

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