Minor breach protection prevents penalties for easily rectifiable, non-fraudulent documentation errors and requires proportionality.

The provision prohibits penalising minor breaches-omissions or documentation errors that are easily rectifiable and made without fraudulent intent or gross negligence-defining such breaches by reference to a low tax amount and errors apparent on the face of record. Penalties must be commensurate with the facts and severity, imposed only after an opportunity to be heard, and must state the nature of the breach and the statutory basis. Voluntary pre-discovery disclosure is a mitigating factor; the section excludes penalties that are fixed sums or fixed percentages.

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