Minor breach protections bar penalties for trivial, rectifiable tax-document errors and require proportional penalties with a hearing.

Section 126 limits penalties for trivial regulatory lapses and easily rectifiable documentation errors made without fraud or gross negligence, requires penalties to be commensurate with the breach, mandates an opportunity to be heard and specification of the breach and applicable law in any penalty order, treats voluntary pre-discovery disclosure as a mitigating factor in penalty quantification, and excludes cases where the penalty is prescribed as a fixed sum or fixed percentage.

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